Document L34gegg5vLVNOk8NmOyzw2pz

"worst-case" and "median" SSPs in the Shelf Zone result in +0-15 dB at/near the 160 dB range. +15 dB SPL would be a very large distance and therefore difference between median and worst case results. 19 D-99 Sea State. propagation in sound No actual analysis was performed to assess the speed profiles that cause surface variability in model results caused by increasing sea sound channels can be quite state. All modeling assumes perfect reflectance; strongly affected, as sound can however, this statement makes it clear that the long be scattered out of the duct. distance estimates resulting from the presence of sound channels in unrealistic in high sea states, and perhaps moderate, however, no effort is made to quantify this. This should have been quantified and/or a moderate (median) sea state used in all modeling scenarios. D-174 Neither mitigation nor aversion The DPEIS builds a strong case that some sort of are used to adjust take estimates mitigation reduction or aversion effect should be incorporated and would make a considerable difference in the take estimates, but neither well- established phenomenon is taken into account. D-162 Stand-off distances The JASCO Phase I model clearly shows that separation schemes and `corridors' are most likely not meaningful or used by the animals, and that the effect of such schemes is more likely to increase exposure, especially Level B SEL. We are hopeful that this proposed added mitigation will therefore be removed from consideration. K-32 Hypothetical treatment of "lost This is a novel and poorly supported idea within the communication space" research community and is not well enough developed or supported by data to be treated as a meaningful regulatory concept. K-7 Introduction of Leq metric in No formula or rationale for use of Leq is provided. addition to SEL and SPL Leq is not used in the rest of the PEIS. Introduction of a new, unjustified metric is not warranted. K-18 Introduction of the concept of This is a novel and scientifically controversial idea; "listening space" and a simplistic it is not mature enough for regulatory application. approximation of biological de A DPEIS is not the place to introduce a radically masking is unwarranted. different concept for UW sound regulation: this should be further developed and vetted as a policy or regulatory rule-making on its own before it is considered solid enough for regulatory application. K-22 Introduction of a novel metric, This is not an accepted ISO or ANSI standard, and cumulative SEL and Leq for an for good reason. Concepts of hearing recovery, entire year. effective quiet and other basic hearing phenomenon would need to be considered and are not, leading to absurd expressions of acoustic energy "accumulation" that are biologically impossible and biologically meaningless even if possible. 4 ATTACHMENT C ATTACHMENT D