The death of numerous whales off New Jersey, mostly humpbacks, deserves a lot of attention. The federal NOAA Fisheries agency is responsible for whales. An outrageous statement by their spokesperson got me to do some research on humpback whale deaths. The evidence appears to suggest that offshore wind development is killing whales by the hundreds.
“NOAA said it has been studying what it calls 'unusual mortality events' involving 174 humpback whales along the East Coast since January 2016," reports The Morning Call. "Agency spokesperson Lauren Gaches said that period pre-dates offshore wind preparation activities in the region."
The humpback death rate roughly tripled starting in 2016. But the claim that this huge jump in mortality predates offshore wind preparation activities is wildly false. In fact, it coincides with the large scale onset of these activities.
To begin with, offshore lease sales really geared up 2015-16, with nine sales off New Jersey, New York, Delaware and Massachusetts. These sales generated a lot of activity, including damaging sonar. In fact, 2016 saw the beginning of what are called site characterization surveys. These surveys are licensed by NOAA Fisheries under "Incidental Harassment Authorizations" or IHAs.
There is misleading jargon here. These IHAs are "incidental" to offshore wind development. They are not incidental to the whales. The term “harassment” includes injuring the whales. That is called level A harassment, while level B harassment just causes behavior changes or temporary deafness, which can also be deadly.
NOAA has issued 46 one-year IHAs for offshore wind sites, each authorizing the harassment of numerous whales. Site characterization typically includes use of what I call “machine gun sonar.” This device emits an incredibly loud noise every few seconds, often for hours or days at a time, as it maps the sea floor.
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There are lots of ways this sonar blasting can cause whales to die. Simply fleeing the noise could cause ship strikes or fish gear entanglements, the two leading causes of whale deaths. Or the whales could be deafened, to be struck later. Note that defenders of offshore wind often point to ship strikes as somehow showing that sonar is not the culprit. In fact, it is evidence sonar is guilty.
The point is that the huge 2016 jump in annual humpback mortality coincides with the jump in NOAA IHAs. Nor is this just about humpbacks. There are the severely endangered North Atlantic Right Whales, on the verge of extinction. Their precipitous decline also began in 2016.
Clearly we need a moratorium on new IHAs until the safety of the whales can be assured. But "Damn the whales, full speed ahead" is the policy of Biden's NOAA. They now propose to approve yet another New Jersey site survey, just 10 miles off Atlantic City.
The survey area is an incredible 2,300 square miles. Ironically, the project is called Atlantic Shores, which is where all the dead whales are washing up. In fact, this is a renewal of a prior permit. NOAA acts as though nothing has changed, ignoring the horrible New Jersey whale deaths.
NOAA's National Marine Fisheries Service (NMFS) is taking public comments on this preposterous proposal (details below).
NMFS predicts that a great many marine mammals will be subjected to unsafe levels of survey noise. Here are the staggering numbers by category:
42 Whales
2,534 Dolphins
142 Porpoises
1,472 Seals
"....[O]nly Level B harassment is proposed for authorization, which NMFS expects would be of a lower severity, predominately in the form of avoidance of the sound sources that may cause a temporary abandonment of the location during active source use that may result in a temporary interruption of foraging activities for some species," NOAA's bureaucratic argument reads. "NMFS does not expect that the proposed activity will have long-term or permanent impacts as the acoustic source would be mobile and would leave the area within a specific amount of time for which the animals could return to the area."
In short, these thousands of critters will get the hell out of the way and come home when the survey is over, in a year or so. Apparently NMFS thinks this massive forced relocation is harmless. Here are two harmful possibilities, among many.
First, the site is deliberately in a relatively low ship traffic area, surrounded by high traffic zones. This is one of the busiest ship traffic areas in the world. Being forced to relocate into higher traffic areas is virtually certain to increase the incidence of fatal ship strikes.
Second, moving this many animals into territory already occupied by similar animals should greatly increase the population densities for each species. But the food supply remains the same, which could lead to food scarcity.
The treatment of the severely endangered North Atlantic Right Whale is especially egregious. NOAA says this: "...the size of the survey area (5,868 km2) in comparison with the entire migratory habitat for the North Atlantic right whale (269,448 km2) is small, representing 2.11 percent of the entire migratory corridor."
Right Whales migrate through the area twice a year, going between offshore Georgia and New England so the "corridor" is indeed large, but this is irrelevant. What is crucial is that the survey area is about 35 miles wide east to west and the migrating whales presently pass through it. Thus the survey has the effect of blocking the migration, or seriously disrupting it.
NOAA maintains this proposed harassment is exempt from the National Environmental Policy Act (NEPA). They claim there is "no anticipated serious injury or mortality." They should anticipate a little harder. NEPA requires assessment if injury is reasonably likely. Injury and death certainly are reasonably likely here, to thousands of supposedly protected marine mammals, including the severely endangered Right Whales. More deeply, the Atlantic Shores Wind Project has yet to be approved and may never be. Site surveys should not be authorized until the Project is approved.
Comments should be addressed to Jolie Harrison, Office of Protected Resources, National Marine Fisheries Service. Written comments should be submitted via email to ITP.Potlock@noaa.gov. In the offshore wind stampede Biden's National Marine Fisheries Service has lost sight of its mission to protect marine mammals. Just say no to NOAA.
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