Document 85vxGBxVRevgGbxZ2pXzk8nJK

ATTACHMENT C Targeted Detailed Comments -- IAGC/API/NOIA/OOC No. Page DPEIS Language Comment/Question 1 1-9 This Programmatic EIS is being This indicates that site-specific EA's will be prepared to serve as the required for G&G activities. The industry would programmatic NEPA analysis appreciate greater clarity on what the future permit from which BOEM will tier its application and supporting NEPA process will look site-specific NEPA analysis for like for individual applicants. BOEM to permit and authorize G&G activities under the OCSLA. 2 1-15 Exposure Versus Take Saying habitat avoidance is an extreme case and BOEM and NMFS do not including it alongside "death" is not appropriate and believe that every exposure to misleading. Neither long-term nor permanent sound results in a "take". .. habitat avoidance has been observed in conjunction And/or, in extreme cases, habitat with seismic surveys. No mortalities have ever been avoidance or even death. confirmed, despite extensive effort to detect such effects. It is unreasonable and not consistent with best available information to infer these effects are possible just because they are imaginable. Contrast with sonar sound, in which association with strandings and mortalities are well-documented. Just because one sound source might have an effect does not mean that other very different sources, used in very different contexts, might have the same effect, especially when the sources in question have been in widespread use for over 50 years. 3 1-16 Significant strides have been Using the Atlantic G&G PEIS as a reference for made in quantifying the effects showing that significant strides have been made in of noise on marine mammals quantifying the effects of noise on marine mammals (cites Atlantic final PEIS) is not useful or appropriate. That document used a similar approach to estimated exposures as used in this DPEIS for the GOM, but there are no data to indicate how accurate these methods are in representing actual exposures or impacts from the modeled activities. 4 1-16 The efficacy of the proposed Text in the Adaptive Monitoring Plan section of mitigation finally selected for Chapter 1.2.3 does not include any materials that implementation as part of the address the efficacy of proposed mitigation Record of Decision will be measures. examined under the Adaptive Monitoring Plan discussed in Chapter 1.2.3 above. 5 2-33 Therefore, depending on whether The potential for a single mortality from a vessel or not a collision did occur, strike causing a jump from nominal to moderate nominal to moderate impacts are impact is inconsistent with arguments made on the expected for Alternatives A-F previous pages that changes in impacts to a single species/stock are insufficient to warrant a change in 1 ATTACHMENT C