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Meghan Lapp's Congressional Testimony on Marine Mammal Deaths
The more I think about this issue linking offshore wind farms to more than 60 whale deaths in the Northeast, the more enraged I become about it. If you haven’t already done it, you need to watch the most recent episode of The Energy Question I posted earlier today. In that interview, Meghan Lapp goes through the litany of major negative impacts these offshore wind behemoths will have on not only whales and other sea mammals, but also on the marine fisheries industry in the Northeast.
If you live in Louisiana and Texas, you need to also be aware that the federal government recently held a lease sale in the Gulf of Mexico for offshore wind developers. While only one company submitted a bid for a lease in the Gulf, the one successful bid means it is likely that we are about to start seeing similar negative issues impacting marine mammals and the huge Louisiana fishing industry as well in the years to come.
Also note that, where the Northeast wind farms are being sited smack in the middle of whale breeding grounds and what Meghan calls a “migratory superhighway” for whales, the proposed Gulf wind farms will be sited smack in the middle of what the federal government knows is a migratory superhighway for well over 300 species of migratory birds. I recently posted slides from a presentation made by the Department of Interior that admits that more than 3 billion birds traverse this migratory corridor every year.
The carnage the Gulf wind farms create will be enormous, yet no one in the Biden administration or at the big “animal rights” lobby groups seems to give a damn.
Back to Meghan: She testified at a congressional field hearing held in New Jersey on the whale issue in May, and shared that testimony with me via email. I wanted to share it with you all as well.
Here it is:
Testimony for NJ Virtual Select Committee Hearing on Marine Animal Deaths 5/3/23
Thank you, Senators, for having me today. My name is Meghan Lapp, and I am the fisheries liaison for Seafreeze, a commercial fishing company based in Rhode Island. We own several federally permitted commercial fishing vessels and two shoreside facilities. In my role, I am intimately involved in the NOAA regulatory environment. I read NOAA documents and notices on a regular basis, provide comments on NOAA Federal Register notices, etc. Today I want to read to you from NOAA’s own documents, because rather than take my word for it, I want the Senators and public to hear from NOAA itself. I think that’s important because I am sure many of you have seen NOAA’s press statements on the whale deaths off NJ, denying that the ongoing offshore wind farm surveys could be or are connected to the whale deaths. But that isn’t what their own documentation states.
What I’m about to read are not my words, not my allegations or conjectures. These statements are taken directly from a Proposed Rule published by NOAA in the Federal Register on Feb 10, 2023, entitled “Takes of Marine Mammals Incidental to Specified Activities; Taking Marine Mammals Incidental to the Sunrise Wind Offshore Wind Farm Project Offshore New York”.1
But before I read from this document, I want to set the stage for what an Incidental Take Authorization is and what kinds there are. Under the Marine Mammal Protection Act, NOAA is authorized to issue Incidental Take Authorizations which allow certain levels of harm to marine mammals as incidental to other ocean activities. The two types of Authorizations are an Incidental Harassment Authorization, or IHA, and a Letter of Authorization, or LOA. An IHA is typically what is issued for offshore wind site characterization surveys and is good for one year, while an LOA is typically what is issued for construction activities and post construction surveys, and is good for five years. Both IHAs and LOAs can authorize both Level A and Level B Harassment of marine mammals, but only an LOA can authorize serious injury or death. If a wind developer or anyone possessing an IHA or LOA exceeds the allowable levels of Harassment or injury that have been authorized to them, the authorization may be revoked. NOAA currently has 14 active Incidental Take Authorizations permitted for offshore wind activities on the East Coast, 15 in process of being reviewed for issuance, and 34 expired authorizations dating back to 2014/2015 through 2022/2023.2 The numbers of these have increased in recent years as offshore wind leasing and development activities have also increased.
Two other terms that you need to be familiar with are TTS and PTS. TTS stands for “temporary threshold shift” and is temporary deafness for marine mammals. PTS stands for “permanent threshold shift” is permanent deafness for marine mammals. TTS, or temporary deafness, is considered Level B Harassment, and is not considered “injury” by NOAA; PTS, or permanent deafness, is considered “auditory injury” and is Level A Harassment.
Most IHAs for site characterization surveys, such as the IHA issued to Atlantic Shores off NJ for example, request authorization for Level B Harassment.3 Here is a statement from a previously issued Atlantic
Shores IHA: “Underwater sound resulting from Atlantic Shores' planned site characterization surveys has the potential to result in incidental take of marine mammals in the form of behavioral harassment (i.e., Level B harassment only). The estimated duration of the surveys is expected to be up to 350 total days (including 210 survey days within the Lease Area and 140 survey days within the Export Cable Routes areas; see Table 1) between April 2020 and April 2021. This schedule is based on 24-hour operations and includes potential down time due to inclement weather.”4
With all that said, here is where it gets interesting. I will begin reading verbatim off of NOAA’s Federal Register notice for the Sunrise Wind project, which gets at the real issues surrounding the temporary and permanent threshold shifts and Level B/Level A Harassment.
I quote: “Generally speaking, Level B harassment take estimates based on these behavioral harassment thresholds are expected to include any likely takes by TTS…. TTS of a sufficient degree can manifest as behavioral harassment, as reduced hearing sensitivity and the potential reduced opportunities to detect important signals (conspecific communication, predators, prey) may result in changes in behavior patterns that would not otherwise occur.”… “TTS can have effects on marine mammals ranging from discountable to serious depending on the degree of interference of marine mammals hearing. For example, a marine mammal may be able to readily compensate for a brief, relatively small amount of TTS in a non-critical frequency range that occurs during a time where ambient noise is lower and there are not as many competing sounds present. Alternatively, a larger amount and longer duration of TTS sustained during time when communication is critical ( e.g. for successful mother/calf interactions, consistent detection of prey) could have more serious impacts.
Currently, TTS data only exist for four species of cetaceans (bottlenose dolphin, beluga whale ( Delphinapterus leucas), harbor porpoise, and Yangtze finless porpoise….. There is currently no data available on noise-induced hearing loss for mysticetes.”5 End quote. Mysticetes are low frequency baleen whales such as humpback whales, fin whales, minke whales, sei whales and NARW. It is been primarily humpbacks and other mysticetes washing up on NJ and other East Coast beaches.
Now listen to this, also from NOAA’s Federal Register notice, and I quote: “Marine mammals exposed to high-intensity sound or to lower-intensity sound for prolonged periods can experience hearing threshold shift (TS)….. Threshold shifts can be permanent, in which case there is an irreversible increase in the threshold of audibility at a specified frequency or portion of an individual's hearing range or temporary, in which there is reversible increase in the threshold of audibility at a specified frequency or portion of an individual's hearing range and the animal's hearing threshold would fully recover over time (Southall et al., 2019). Repeated sound exposure that leads to TTS could cause PTS.
When PTS occurs, there can be physical damage to the sound receptors in the ear ( i.e., tissue damage) whereas TTS represents primarily tissue fatigue and is reversible (Henderson et al., 2008). In addition, other investigators have suggested that TTS is within the normal bounds of physiological variability and tolerance and does not represent physical injury ( e.g., Ward, 1997; Southall et al., 2019). Therefore, NMFS does not consider TTS to constitute auditory injury.
Relationships between TTS and PTS thresholds have not been studied in marine mammals, and there is no PTS data for cetaceans.” End quote. Cetaceans include whales, dolphins and porpoises.
So, what NOAA says officially is this: They are authorizing offshore wind companies to conduct site characterization surveys which operate 24 hours a day for many days on end that could lead to temporary deafness in whales, which can lead to changes in behavior and other impairment. Repeated sound exposure can cause temporary deafness to turn into permanent deafness. But while they are authorizing this, they do not have any information on how much noise causes hearing loss in low frequency baleen whales, and they have no information whatsoever on what levels cause permanent deafness for any kind of whale. So, the fact is that NOAA is authorizing activities that it cannot enforce, measure, or monitor. Because it does not have the science to do so.
I’ll let the Senators and the public decide for themselves whether they think a moratorium is necessary to determine these thresholds and impacts prior to continuing with development. Thank you, Senators, for the opportunity to testify.
Communicate with your member of congress on this. Share this testimony with them. What the government is doing in the name of climate alarmism is truly disgusting and inhumane.
That is all.