Seismic Blasting of Irish Sea (in order to faciliate a deep nuclear dump) Review by Tim Deere-Jones

The West of Copeland Acoustic Airgun Survey Proposal: <<>> A critical analysis Review Briefing:

Black Combe from Walney Island

by Tim Deere-Jones Marine Radioactivity Research & Consultancy 10/06/2022 On Behalf of Radiation Free Lakeland

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Contents: INTRODUCTION

page 5

1:

Summary of Conclusions

page 6

2:

Summary of airgun surveying

page 10

3:

Constraints on effectiveness of surveys

page 11

4:

Justification for claimed “Scientific and Educational” status

page 13

5:

EIA assessment regimes for surveys

page 14

6:

The SCAN cetacean survey

page 15

7:

ID of Marine Conservation Zones

page 16

8:

Factors related to “sensitivity” of habitats & species

page 18

9:

Acoustic survey impacts on marine fauna

page 21

10:

Academic peer reviewed studies of acoustic impacts

page 23

11:

Impact on Cetaceans

page 23

12:

Impact on Harbour porpoise

page 25

13:

Impact on Fish

page 25

14:

Impact on Seabirds

page 27

15:

Impact on Cephalopods

page 27

16:

Impact on Shark/elasmobranch species

page 28

17:

Impact on Crustaceans

page 30

18:

Impact on Shellfish larvae

page 31

19:

Impact on Copepod/ and other zooplankton

page 32

20:

Marine Invertebrate sound reception

page 35

21:

JNCC Guidance on acoustic surveys

page 36

22:

Alternative Seismic Survey Techniques

page 39

23:

Postscript

page 42

Thank You To All who have contributed to the Crowdfunder to make this Review possible

3 “These surveys will support our assessment of the deep geology and its potential suitability to dispose of radioactive waste for the long term. We are committed to environmental protection and will work to minimise the impact of these surveys on marine life by following relevant UK guidance”. Chris Eldred, Senior Project Manager for Geosphere Characterisation at Nuclear Waste Services “There is a lot of scientific evidence about the problems underwater noise can lead to – seismic surveys roughly 3000 km away were loud enough to drown out the mating calls of whales on the middle of the Atlantic. Conducting seismic surveys in an area known to be inhabited by many highly sensitive species is really concerning.” Dr Chris Parsons, Marine Mammal Scientist “Through the course of our investigations over the last 30 years, we know that noise exposure can be a problem for a wide variety of cetaceans – dolphins, porpoise and whales. Noise related impacts have also been causally linked to many cetacean stranding and mass stranding events globally.Various potentially vulnerable cetacean and other marine species are normally resident across this region, and we’re concerned that the proposed use of seismic surveys over the summer could lead to a number of impacts, ranging from temporary displacement to more direct physical effects, including mortality.” Rob Deaville Zoological Society of London’s Cetacean Strandings Investigation Programme ‘The proximity of proposed coal mining along the extended trend of the coastal faults is a serious geological issue – stress change in those rocks subsea and possibly even subsidence could jump 20km along a fault to affect the proposed GDF site close to the coastline.“ Stuart Haszeldine OBE FRSE C.Geol, Professor of Carbon Capture and Storage, University of Edinburgh “The Irish Sea and the coasts of West Cumbria are already abnormally irradiated from the operations of the Sellafield complex; it would be unlikely that the leakage of radiation from a facility beneath the seabed would be detected for some time given the pre-existing background radiation. Consequently, rather than solving a problem for future generations, it could be leaving them a legacy of a nuclear waste dump gradually releasing radioactivity into the environment and cutting off their options for deciding how to deal with this waste.” Cllr David Blackburn, Chair of the Nuclear Free Local Authorities Steering Committee

Quotes Above, from The Environment Journal: Seismic testing for nuclear disposal risks harming marine life https://environmentjournal.online/articles/feature-seismic-testing-for-nuclear-disposal-risks-killingmarine-life/

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1: INTRODUCTION 1:1 The UK Nuclear Waste Services (under the Department of Business, Energy and Industrial Strategy) and other Government funded nuclear agencies have been actively investigating the viability of the deep disposal of the UK’s high level nuclear wastes under the Irish Sea. As part of this work Nuclear Waste Services are now engaged in investigations in preparation for the delivery of a Nuclear Geological Disposal Facility (NGDF). It is proposed that the NGDF may consist of possibly two vaults extending over an area of 25km square beneath the seabed of the north east basin of the Irish Sea, adjacent to the coast of Cumbria 1:2 In order to further their work on the NGDF, UK Nuclear Waste Services, Radioactive Waste Management, Nuclear Decommissioning Authority and the Mid-Copeland Community Partnership have initiated a seismic survey using “acoustic air-guns” in order to investigate and map the sub sea-bed geology. This work is required as part of the site identification process for the underground elements of a Geological Disposal Facility.

Shearwater Geo Services have been contracted to carry out the seismic survey.

1:3 An FoI request submitted to the Agencies listed above extracted the following information from the NDA: Surveys are due to take place off the coast of Mid and South Copeland for around 3-4 weeks this summer between July and August as part of a continuous 24-hour operation taking place in an area 5-20kms off the coast. It is stated that the relevant sea area to be surveyed is over 20 metres deep.

1:4 According to the NDA, the survey will take place in an area approximately 250 km square which lies within the inshore region adjacent to Copeland Borough Council district and is bounded to the south by the Walney wind farm. Such surveys can generate two dimensional (2D) and three dimensional (3D) images of the deep geology, either below the land or below the seabed, providing information about the thickness, layering, and depths of the different rock types in particular geographical areas. Within this area the survey vessel will fire the sound source and collect the reflected data through its hydrophone streamers for the 3D and 2D elements of the survey. It is claimed that, because this will be in water which is over 20m deep, there is no physical interaction with the seabed. REF: email from gdfenquiries@nda.gov.uk. Received 11/5/2022 1:5 However, a response to an earlier FoI request has contained contradictory information about the area covered by the proposed survey, as follows: “Survey area: para 3.5. The survey area is a circa 1000 km2 area in the inshore region adjacent to Copeland Borough Council district boundary.” REF: “Notification of marine geophysical survey.” Copeland. February 2022. Nuclear Waste Services. page 20

1:6 The contradiction between the area to be surveyed quoted by the NDA GDF enquiries email of 11/5 (250km sq) and that quoted in the NWS Feb 22 “Notification” (1,000 km sq) requires clarification from both bodies.

It is reported that acoustic pulses will be produced once every 10 seconds throughout the survey period. If this is correct, it will require the production/generation of 60,480 airgun acoustic impulsive pulses per week, totalling 181,440 pulses over 3 weeks or 241,920 pulses over 4 weeks.

1:7 The proposal to undertake the seismic survey has been submitted to the MMO (an Agency of the UK Government Department of Environment, Food and Rural Affairs). It has not been made the subject of a public consultation process and documents detailing

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aspects of the proposed survey have not been put on the public register. In order to access that information, it has been necessary for members of the public and citizens groups to submit FoI requests to the NWS, the NDA and the local authority.

1:8 An assessment of the potential environmental impact of the proposed seismic survey has been published by NWS/NDA but, as there is no evidence that the assessment has been produced by an independent source, it is concluded that it has been drawn up “in-house” by NWS/NDA. The NWS/NDA environmental assessment has concluded that there are no contra-indications to the proposal and that “there is predicted to be, with a high level of confidence, no likely significant effects” to MCZs or regional marine species.

1:9 In the context of the lack of both public access to relevant information and an independent assessment of potential impacts, this Briefing offers an alternative and independent review of the NWS/NDA assessment.

In the following document reporting of the official NWS/NDA positions re policy and assessment etc are set out in normal print.

This Briefing’s analytical comment, critique, contentions and recommendations are set out in bold italics.

Summary of Conclusions Chapter 1: An assessment of the potential environmental impact of the proposed seismic survey has been published by NWS/NDA but, as there is no evidence that the assessment has been produced by an independent source, it is concluded that it has been drawn up “in-house” by NWS/NDA. The NWS/NDA environmental assessment has concluded that there are no contra-indications to the proposal and that “there is predicted to be, with a high level of confidence, no likely significant effects” to MCZs or regional marine species.

In the context of the lack of both public access to relevant information and an independent assessment of potential impacts, this Briefing offers an alternative and independent review of the NWS/NDA assessment.

A contradiction between the area to be surveyed quoted by the NDA GDF enquiries email of 11/5 (250km sq) and that quoted in the NWS Feb 22 “Notification” (1,000 km sq) requires clarification from both bodies.

Chapter 2: It is reported that acoustic pulses will be produced once every 10 seconds throughout the survey period. If this is correct, it will require the production/generation of 60,480 airgun acoustic impulsive pulses per week, totalling 181,440 pulses over 3 weeks or 241,920 pulses over 4 weeks.

Chapter 3: It is widely recognised that a number of factors can reduce the effectiveness of seismic surveys. The West of Copeland proposal will be carried out in waters characterised by a number of these factors including elevated suspended sediment concentrations, reverberation from airgun shots, wave generated bubbles and seasonal algal and zooplankton blooming. Given the methane rich nature of the adjacent Cumbrian coal field there is also a possibility that seeping methane gas bubbles will also be present in the survey area.

More distant natural and anthropogenic sounds should also be taken into consideration. The NW of England is subject to relatively frequent low magnitude natural seismic activity with at least three earthquakes recorded by the British Geological Survey from January 2022 to the end of May 2022.

Earthquakes of more significance (4.7 mag, 4.1 mag and 3.1 mag) have occurred since 1970.

The issues raised above have not been referenced in the discussion of the proposed seismic survey.

Consequently, the effectiveness of survey work carried out in the shallow sea area under consideration remains uncertain.

7 Chapter 4: NWS/NDA have applied for a Wildlife or EPS Disturbance licence for “scientific and educational purpose.” This Briefing contends that the claimed “Scientific or Educational purpose” is a mis-representation of the true purpose of the proposal which should clearly be judged as an industrial activity because it is specifically and solely associated with an industrial or commercial proposal to construct a sub-seabed infrastructure (NGDF).

Chapter 5: West of Copeland survey proposed for the sea area west of the Copeland coast would require an EIA and HRA if it was shown to be a “sensitive sea area” containing a protected habitat or species. The requirement for EIA or HRA is dependent on the findings of any preliminary environmental assessment. The NWS/NDA have confirmed that the environmental assessment was undertaken/carried out, and presumably scoped, “in house”, and not by an independent consultant as is normally the case with such assessments.

That assessment was based on, and reliant on the NWS/NDA interpretation of third party research and investigations which they have compiled by data search/desk review using their own search terms. Other than their desk review of the available scientific literature and field research it is not evident that NWS/NDA have undertaken any original site and region specific empirical field research.

Chapter 6: A major sector of the NWS/ND assessment was based on the outcomes of the international SCAN cetacean survey. The SCAN survey was an international initiative with survey work in each Sovereign state jurisdiction involving national “partner agencies”. The partner agencies in the UK were the DEFRA ministry and the JNCC. The SCANS report provided a map of the total search area achieved under all conditions. From this map it is evident that significant areas of Block F (north east Irish Sea) specifically including the area of the proposed survey, were NOT subjected to aerial survey. Whether this was due to bad weather, the lack of resources or low national priority was not explained by the SCANS report. As a result, Table 33, page 27 reporting of cetacean presence in Block F is reported as “estimate” in the context of “partial coverage only” for Irish Sea Block F. Additional weakness in the survey methodology was noted by the SCAN report on page 15 which noted that the effective visual strip width from aerial detection was, at its maximum, no more than 400 metres. Further SCAN comment on this issue (page 33) reported that “detection probability and therefore effective strip width is smaller from an aircraft than from a ship, but aerial survey is considerably cheaper than ship survey.”

This Briefing contends that the NWS/NDA documentation is seriously remiss and lacking in scientific rigour because, despite the fact that the authors of the SCAN report clearly and transparently referenced these weaknesses, the NWS/NDA documentation has failed to reference these matters and has thus presented (intentionally or otherwise) an inadequate and incomplete report of the SCAN survey of cetaceans in Block F and particularly in the area where the proposed seismic survey is to take place.

Chapters 7 & 8: These chapters discuss the NWS/NDA assessment of the potential impact of the proposed acoustic survey on regional MCZs. This Briefing’s review of the assessment concludes that regional MCZs referenced by the UK Wildlife Trusts are close enough, in terms of miles/kms, to the proposed West of Copeland airgun survey area for the sounds to be audible or detectable throughout the MCZs. Even in shallow water, such as that of the survey area, airgun pulses are reckoned to propagate over approximately 100kms.

This Briefing concludes that the NWS/NDA assessment conclusions on the MCZs discussed above lack rigour in the following respects: because they omit and “scope out” relevant adjacent MCZs, they fail to discuss a high number of designated habitat species (including important bivalve, sea urchin, anemone, starfish and bryozoan species and Basking Sharks). Despite an extensive literature search no report of any research into acoustic airgun survey impacts on these species has been identified.

8 The NWS/NDA assessment states that designated features are “not sensitive to underwater sound”.

Despite an extensive literature search, no record of any studies of the impact of seismic airgun survey noise on brittle stars, sea urchins, sea pens, spoon worms, Dublin Bay prawns, sea squirt, Saballeria, bryozoans and baking Sharks has been found. This briefing therefore contends that the claim has been made without any scientific justification and must therefore be discounted.

Clearly the assessment of “sensitivity” of both sites and marine species is a vitally important factor in the decision making process preceding the initiation of any seismic acoustic survey.

The flaws and failures of omission catalogued above have severely diminished the scientific rigour and transparency of the NWS/NDA assessment of potential impacts of airgun seismic surveying on regional MCZs. There is a body of empirical evidence demonstrating that acoustic seismic surveying can have a negative impact on fish schooling and subsequently on commercial fishing harvests during both the survey period and for some time afterwards (see next section below). This Briefing note reports that the NWS/NDA have failed to assess and report on this issue.

The omissions and flaws discussed above clearly indicate the imperative need for a thorough and fully independent EIA and HRA. Such an EIA should be transparently and independently scoped with the benefit of major input from regional non statutory organisations/groupings with no interest or involvement in the proposed NGDF and associated activities. The proposed seismic survey should be cancelled/postponed until these omissions and flaws have been remedied by a full, and independently scoped and performed EIA/HRA. Chapters 9 to 19: The NWS/NDA assessment of the proposed acoustic survey impact thresholds on West of Copeland marine species is based on methodologies derived from only two sources. This is not representative of the available papers addressing such methodologies.

It is noted that the NWS/NDA assessment has not drawn attention to the important and precautionary warning from a leading fish scientist, that there has been inadequate research into the response of marine creatures to acoustic sources. This failure conveys the impression that the NWS/NDA interpretation of the available data is based on a broad consensus derived from unequivocal and sound data, which is not the case.

This Briefing has reviewed a wide selection of independent, peer-reviewed academic data on acoustic airgun survey impacts to a wide variety of marine species, including many NOT referenced by the NWS/NDA assessment. That review confirms that the NWS/NDA have failed to report scientifically verified impacts to a high number of species known to be present in, and close to the West of Copeland proposed survey area.

These species include schooling fish species such as cod, haddock and mackerel; octopus, cuttlefish and squid; lobsters and crabs; bivalve shellfish such as scallop; shellfish larvae and zoo-plankton. This Briefing also notes that the regional MCZs have been designated because of the species they support, but that many of those species including, bryozoans, marine worms, starfish, sea pens, urchins and juveniles of many species have NOT been studied to quantify any impact they may suffer from acoustic surveying.

This Briefing also notes that there are no empirical analyses of the abundance of basking sharks within or near the proposed acoustic survey and no reporting of investigation of either the primary or secondary impacts of air gun acoustic surveying on basking sharks and other elasmobranch species.

This Briefing concludes that the NW/NDA assessment of impacts from acoustic airgun surveying are deeply inadequate and lacking in appropriate scientific/academic rigour. It is concluded that the NWS/NDA assessment does not provide a sufficient level of empirical data on the potential impacts of air gun surveys to the full range of regional and MCZ marine species likely to be impacted.

9 In that context it is evident that local communities, environmental and conservation organisations and statutory decision makers such as the Marine Management Organisation, do not have sufficient information on potential impacts to the full assemblage of marine species to successfully carry through the decision making process. It is therefore advised and recommended that the decision making process should be postponed until a fully independent EIA is enabled and completed.

In the context of the poorly managed and scoped NWS/NDA assessment it is recommended that the scoping process should also be undertaken by an independent body benefitting from significant representation from regional communities, regional environmental/conservation organisations and commercial marine users and stakeholders.

Chapter 21: The JNCC 2017 Guidelines offer a suite of mitigation measures which the JNCC propose are based on “reasonably conservative assumptions” and states that compliance with these Guidelines “constitutes best practice” which will, in most cases, reduce the risk of injury to marine mammals to “negligible levels.” However, the JNCC “negligible level” has not been defined. In that context it should be assumed that it is a subjective, rather than an objective and empirical, judgement to be taken by the decision maker. In the case under consideration, it remains unclear which individual or organisation will make the eventual subjective decision and on what basis the decision will be made.

The JNCC 2017 Guidelines focus on marine mammals, and notes that “they could be adapted to help reduce the risk of deliberate injury to other marine species if deemed appropriate by the relevant Regulator. For example, other potentially sensitive species include marine turtles, also listed as EPS (European Protected Species), and several shark species including basking shark which are UK priority marine species.”.

The above statement, taken from the introduction to the 2017 JNCC document, is (in the context of more recent scientific peer reviewed evidence discussing impact effects on schooling fish and other invertebrates) now clearly outdated and inadequate. The major differences between the sound awareness faculties of species as diverse as marine mammals, crustaceans, marine worms and zoo-plankton render the claim that JNCC Guidelines “could be adapted to help reduce the risk” of injury to other species unrealistic, inadequate and lacking scientific rigour.

It is strongly recommended that UK seismic acoustic surveys are suspended and/or postponed until the scientific evidence related to acoustic impacts on schooling fish and invertebrates such as worms, bryozoans, zooplankton, urchins etc has been incorporated into updated JNCC Guidelines.

Chapter 22: The NWS/NDA assessment has stated that “There is no suitable alternative

non-intrusive survey method available to collect data on deep geology”.

The NWS/NDA statement is not true. This Briefing provides summary information showing that both Marine Vibroseis and Passive Seismic Transmission Tomography pose a lesser threat of damage and impacts to marine species than airgun seismic surveys. Additionally, both technologies offer advantages for geological imaging in the environment of the Cumbrian marine seabed due for surveying by the seismic airgun method.

Despite the likely objection of both survey companies and survey users, it is recommended that the NWS/NDA withdraw their claim that “There is no suitable alternative non-intrusive survey method available to collect data on deep geology”, cancel the proposed and environmentally damaging West of Copeland seismic airgun survey and make use of one of the above “alternative” technologies discussed above. ……………………………………………………………………………………………………………

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2: Summary of Airgun surveying 2:1 Seismic Airguns have been widely deployed in the search for hydrocarbon resources which began in aquatic environments to investigate the geological layers beneath water bodies (rivers, lakes and oceans). Usually, the intention is to study the geology in order to locate subsea gas or oil reserves.

However, in the case under consideration in this Briefing, the investigations are intended to clarify the suitability of the sub-sea geology for a UK NGDF and, presumably, to ensure that the proximity of the methane rich and seismically unstable west Cumbria coal beds are not a contra-indicating factor.

2:3 Airguns produce a sonic pulse by rapidly releasing a bubble of compressed air. The airgun bubble production generates a loud sound (up to 240 decibel level) that travels through the water to the ocean floor as a “seismic wave”. Airgun seismic waves are generally louder than naval sonar and maritime construction activities such as pile driving.

2:4 While some of the sound energy is reflected off features of the seafloor, it will also travel into the seafloor and reflect off sea-bed sediments and the underlying rock layers below the seabed. These deeper, reflected sounds also travel back up to the surface and can be detected by hydrophone arrays. The acoustic characteristics, particularly the strength and timing, of the reflected signals can be analysed by computer software to provide image based information used by academic geologists for the study of plate tectonics and sedimentation patterns and geological features including oil and gas deposits.

2:5 One of the major differences between sonar, construction activity and seismic air gunning is that airgun surveying generates loud sounds on a much more frequent and sustained basis, continuing on an every 10 to 15 second basis for days or weeks at a time. In the case under consideration, it is proposed that the duration of such testing will last for about one month.

2:6 Frequency range of airgun seismic surveying: An acoustic survey industry magazine reports that most of the sound energy from seismic sources is at low frequencies below 200 Hz. Single air-guns generate signals in the frequency range of 5-200 Hz, while the combined signal from air-gun arrays is in the order of 5-150 Hz. Depending upon their method of operation, airguns may emit acoustic amplitude well above the frequencies of interest for seismic exploration. Broad-band noise, up to 15 kHz or more, although small in amplitude, is detectable at relatively close range. REF: “Marine Seismic Sources Part IV.” Lasse Amundsen and Martin Landrø. Vol.7, No 5. GeoExPro. 2010.

2:7 In summary it is evident that the industry supports the concept that the significant majority frequency range of airgun seismic surveys lies between 5 and 200 Hertz. Sounds with a frequency less than 250 Hz are widely defined as low frequency. Anthropogenic low frequency sound is a major, global source of ocean noise that is consensually agreed to have a significant disruptive impact on acoustic communications for a variety of marine animals.

2:8 Hearing sensitivity range for cetaceans has been defined as follows: low frequency cetaceans: Baleen whales including minke: from 7Hz to 35kHz mid frequency cetaceans: toothed whales and dolphin: from 150Hz to 160kHz high frequency cetaceans: harbour porpoise: from 75 Hz to 75 kHz REF: Table A9: Appendix A: MLA_2022_00085: Notification of Geophysical Survey.

Clearly cetaceans are in the low frequency sensitivity range

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2:9 Marine seismic airgun surveys release pulses of sounds up to 250 decibels at least several times per minute. This is a very loud sound and many sources report that seismic airguns are 100,000 times more intense than a jet engine.

2:10 Multiple airguns are typically arranged in a rectangular pattern to form tuned airgun arrays. The direct sound generated from individual airguns within such arrays combine to produce a much louder sound than that from a single gun. Tuned airgun arrays generate an acoustic beam directed toward the seafloor. In addition, acoustic energy across a wide range of frequencies also propagates laterally into the water column. Some airgun towed arrays may be at least 250 metres wide.

2:11 Marine airgun seismic surveys produce intense, broadband “impulsive” sounds that can propagate, and be heard, up to at least 1000s of kilometres from the source.

REF: https://dosits.org/animals/effects-of-sound/anthropogenic-sources/seismic-airguns/

2:12 Impulsive sound is characterised by brief bursts of sound pressure, with the duration of each impulse usually less than 1 second, including without limitation specific sound containing “bangs”, “clicks”, “clatters” or “thumps” from hammering, banging of doors and metal impacts; 2:13 Safety Radii/ Mitigation Zones: The radius of a circle is the length of the line from the centre to any point on its edge. “Academic” surveys use anywhere from 1 to 20 airguns in their arrays; on average it is quite common for these surveys to use 3-12 guns. The standard "safety radius/mitigation zone" for such surveys is 500-1000m, though it can be less on small-array projects, or more (up to 3000m) in certain shallow-water situations. It is noted that the application for permission to conduct the proposed survey defines it as a “Scientific” survey.

2:14 Despite the evidence that the proposed survey area encompasses wide areas of shallow water (less than 50 metres deep) the proposal has made no allowance for this fact and has insisted on retaining the 500 metre safety/mitigation zone and does not reference the concept of expanding the “zone” or investigating the potential “certain shallow water situations”.

2:15 Industrial surveys are more likely to use full-power 20 to 60 gun arrays, however, the standard safety radius is still just 500m measured from the centre of the airgun array. Thus, the safety/mitigation zone actually encompasses a 1000 metre wide zone.

2:16 Industrial seismic surveys have been taking place worldwide since the 1970s and activity peaked in the late 1980s through to the mid-1990s. However, a more recent generation of higher resolution air gun, hydrophone and computing technologies and the recent trend toward ongoing seismic monitoring of active hydrocarbon reservoirs has recently been driving increased seismic survey activity.

3: CONSTRAINTS ON THE EFFECTIVENESS OF SHALLOW WATER AIRGUN SURVEYS 3:1 As referenced above there are “safety radius” constraints on the operation of airgun technology with a much increased “safety radius” identified for “certain shallow-water situations”. This is related to the sonic output of noise sources.

3:2 In shallow water, such as that within the designated Cumbrian waters survey site, there are three primary sources of ambient noise:

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a: anthropogenic shipping including merchant and naval vessels. The nearby Beaufort Trench is designated as a nuclear submarine warfare “exercise area”. It should be assumed, in the absence of data to the contrary, that such exercises may include the generation of sonar acoustics. None of the documents discussing the proposed survey have referenced this issue nor mentioned agreement with the MOD/Royal Navy to ensure that such activity will not reduce the effectiveness of the proposed survey. b: other anthropogenic noise; it is relevant to note that there is evidence of seismic activity in and around the survey area and that the nearby Beaufort Trench is well known as a source of unintended explosions from dumped military munitions. REF: NFLA Radioactive Waste Policy Briefing Number 84. T. Deere-Jones. Nuclear Free Local Authorities.

c: natural wind and wave noise; and biological noise. (Animal vocalisations are reported to significantly lower the quality of recorded airgun signals.)

3:3 It is widely agreed that background sonic levels are hard to predict in shallow waters because there is a wider range of ambient noise levels for different shallow water acoustic environments. It is closely linked to the sensitivity of the natural variables likely to affect sound propagation. Ambient noise in shallow water is affected by both wind speed and wave height. The seabed type – reflective or absorptive – is also a substantial factor and levels are likely to be significantly higher over a reflective seabed.

3:4 A 2009 study reports that in shallow water (less than 50 metres deep) sound propagation loss from seismic survey air gunning is lower than in deeper water thus permitting louder noise in shallow environments. Hence shallow water environments should require larger “safety radii” than deep water because of the energy reflection between the sea surface and the seafloor 3:5 However, it has also been shown that sound propagation is also highly dependent on the local seafloor geology and that sound transmission loss is also caused by the absorption and scattering of sound from objects and material between the sound source and the receiving hydrophones. Such objects and material include flotsam and jetsam, particulate material suspended in the water column, bubbles generated by breaking waves and biological material such as fish, algal blooms and floating macroalgae.

REF: “Broadband calibration of the R/V Marcus G. Langseth four-string seismic sources.” M.Tolstoy et al’.

Geochemistry, Geophysics, Geosystems. 15 August 2009.

3:6 The seismic survey proposal under discussion (Cumbrian Waters) will be carried out in waters with elevated suspended sediment concentrations, wave generated bubbles, reverberation from airgun shots and seasonal algal and zooplankton blooming.

Given the methane rich nature of the adjacent Cumbrian coal field there is also a possibility that seeping methane gas bubbles will also be present in the survey area.

More distant natural and anthropogenic sounds should also be taken into consideration.

The NW of England is subject to relatively frequent low magnitude natural seismic activity with at least three earthquakes recorded by the British Geological Survey from January 2022 to the end of May (09/04/22 Irish Sea; 20 km NW of Whitehaven: 20/04/22 25 km east of Isle of Man: 11/05/22 Waterbeck NE Ecclefechan). Earthquakes of significant magnitude have also occurred at Carlisle 1979, 4.7 mag: Kirkby Stephen 1970,4.1 mag and Dumfries 2006, 3.1 mag. Both low mag and significant mag seismic events have the potential to reduce the effectiveness of the proposed survey.

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The issues raised above have not been referenced in the discussion of the proposed seismic survey. Consequently, the effectiveness of survey work carried out in the shallow sea area under consideration remains un-analysed and therefore uncertain.

3:7 In 2016 it was reported that reverberation from repetitive airgun shots increased the background noise levels in shallow waters and that this could both decrease the detection range of nearby passive acoustic monitoring (PAM) systems and potentially mask communication signals between animals. (PAM systems include towed hydrophone arrays) It was reported that there was no quantitative information about such reverberation.

3:8 Two metrics were suggested for quantifying reverberation: a “minimum level” metric that measures reverberation levels between airgun pulse arrivals, and a “reverberation metric” that estimates the relative magnitude of reverberation vs. expected ambient levels in the hypothetical absence of airgun activity, using satellite-measured wind data.

3:9 These metrics were applied to acoustic data measured by autonomous recorders in the Alaskan Beaufort Sea in 2008. It was shown that seismic surveying in shallow water (less than 50 m deep) can increase the background noise over natural ambient levels by 30-45 dB within 1 km of the activity, by 10-25 dB within 15 km of the activity, and by a few dB at 128 km range. Shallow-water reverberation can thus substantially reduce the performance of PAM systems within several kms of shallow-water seismic surveys. REF: “Quantitative measurements of seismic airgun reverberation in the shallow-water Beaufort Sea”. Aaron Thode et al’. The Journal of the Acoustical Society of America 140, 3020 (2016).

3:10 The Cumbrian waters which are the subject of the proposed survey are generally less than 50 metres deep. From the data and information currently made available by the proposers of the Cumbrian seismic survey re NGDF, it is not possible to confirm or deny if quantitative information on the background noise levels from air gun “reverberation” in the shallow waters of the proposed survey area has been acquired. Thus, it is unclear what impact the planned airgun array reverberation will have on the effectiveness of the survey. …………………………………………………………………………………………………

4: JUSTIFICATION FOR THE CLAIM THAT THE SURVEY IS SCIENTIFIC & EDUCATIONAL 4:1 Under UK legislation there is no mandated requirement for a permit or licence to carry out acoustic airgun seismic surveys within UK territorial waters. However, “If there is a risk which cannot be removed or sufficiently reduced by the taking of mitigation measures then a Wildlife Licence (or EPS Disturbance Licence) may be required to be granted by the regulatory authorities for a number of purposes”. (Purposes include “overriding public interest” and “scientific and educational” purposes).

“Licences can however only be issued where there is no satisfactory alternative. It is expected that the majority of activities will not require a wildlife licence since their potential for disturbance will fall below the threshold of the office in the Regulations.” REF: https://oilandgasukenvironmentallegislation.co.uk/Contents/Topic_Files/Offshore/Geological_Ha bitats.htm

4:2 NWS/NDA have applied for a Wildlife or EPS Disturbance licence for “scientific and educational purposes”. On that basis it is deduced that NWS/NDA agree that there is a risk which cannot be removed or sufficiently reduced by mitigation and that there is no satisfactory alternative to a seismic airgun survey.

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In the context of the longer term search for an NGDF site, it is important to note that a licence application has NOT been applied for on the basis of an “overriding public interest”.

It may therefore be assumed that the NWS/NDA do not regard the need for an NGDF as an “overriding public interest”.

4:3 The NWS and NDA have put forward the proposed West of Copeland seismic survey and submitted an “Application for a wildlife licence under the nature conservation legislation.”

MLA/2022/00085. Page 9 of the application states that the proposed survey is for “Scientific or Educational Purposes” but then explains that the survey is in pursuit of a “necessary site characterisation to understand the deep geology in the proposed area”, which is admitted by the applicant (NWS/NDA) to be in support of plans for the construction of a Geological Disposal Facility.

4:4 This Briefing therefore contends that such a site characterisation survey clearly has a long term, and predominantly industrial and commercial purpose and contends that describing the proposal as “scientific or educational” implies that the proposed survey is to be carried out as a disinterested search for knowledge, rather than an integral part of an industrial/commercial development.

4:5 This Briefing notes the Wikipedia report that “The British Geological Survey (BGS) is a partly publicly funded body which aims to advance geo-scientific knowledge of the United Kingdom landmass and its continental shelf by means of systematic surveying, monitoring and research.” Scientific and educational research is here clearly defined as the advancement of geo-scientific knowledge, not necessarily attached to any specific industrial or commercial construction project.

4:6 In that context it is proposed that the claimed “Scientific of Educational purpose” is a mis-representation of the true purpose of the proposal which should clearly be judged as an industrial activity because it is specifically and solely associated with an industrial or commercial proposal to construct a sub-seabed infrastructure (NGDF).

5: ENVIRONMENTAL IMPACT ASSESSMENT REGIME FOR SEISMIC AIRGUN SURVEYS 5:1 “An EIA may be required for seismic and high resolution surveys in sensitive sea areas such as Cardigan Bay, English Channel, Moray Firth, St George’s Channel and deep waters areas to the west and north of the UK. EIA (and Habitats Regulatory Assessment) may also be required for any survey that could affect a protected habitat or species. A licence under FEPA will also be required where any deposit on the seabed is planned, for example installation of seabed equipment for 4D seismic. Where there is a risk to European Protected Species that cannot be removed or sufficiently reduced by the taking of mitigation measures, then a Wildlife Licence may be required for a number of categories of activities”.

REF: https://oilandgasukenvironmentallegislation.co.uk/Contents/Topic_Files/Offshore/Seismic.htm

5:2 Clearly the survey proposed for the sea area west of the Copeland coast would require an EIA and HRA if it was shown to be a “sensitive sea area” containing a protected habitat or species.

5:3 In the context of the above it is relevant to review the NWS/NDA methodology used to assess the potential “sensitivity” of the marine environment within, and adjacent to the proposed seismic survey area.

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5:4 Page 9 of MLA/2002/00085 states “We have undertaken appropriate environmental assessments in order to ensure any potential impacts are investigated, clearly evidenced and mitigated.” This “appropriate assessment” has been published by the NWS/NDA as APPENDIX A to the following document … REF: EXE_2022_00048-Copeland - Notification of Geophysical Survey Appendices A to F-3.pdf https://drive.google.com/file/d/1r4G-getKX26x-6DOs9isci1rgDd1udpB/view?usp=sharing

The NWS/NDA assessment consists of a review of the acoustic impacts of airgun surveying on marine species and designated Marine Conservation Zones.

5:5 The NWS/NDA assessment has confirmed that the environmental assessment was undertaken/carried out, and presumably scoped, “in house”, and not by an independent consultant.

This work is based on, and reliant on the NWS/NDA interpretation of third party research and investigations which they have compiled by data search/desk review using their own search terms. Other than desk review of the available scientific literature and field research it is not evident that NWS/NDA have undertaken any original site and region specific empirical field research.

5:6 In the context of the above paragraphs, it is relevant to review the major data sources referenced by the NWS/NDA APPENDIX A: 6: THE SCAN Cetacean Survey: 6:1 A major data source interrogated by the NWS/NDA assessment process is the SCAN survey of cetacean abundance in European Atlantic Waters which was carried out in 2016, but not published in full until 2021. The SCAN survey was an international initiative with survey work in each Sovereign state jurisdiction involving national “partner agencies”. The partner agencies in the UK were the DEFRA ministry and the JNCC. 6:2 Explaining the methodology of the survey work in the Irish Sea, the SCAN report notes that the north east sector of the Irish sea, from the Solway coast of Scotland to the north coast of Wales (which includes the area of the proposed NWS survey) was designated as Irish Sea Block F and that it was surveyed from the air. SCAN reported that “within each aerial block three sets of random transect lines were generated with the minimal aim that at least one set would be covered in each block. If weather permitted, additional sites would be covered, which Blocks would receive additional coverage depending on resources remaining, weather and national priorities.”

6:3 If a group of animals was detected at any stage in the flyover, the aircraft circled back in order to re-survey the relevant sector of the transect line and carry out a confirmatory count of the numbers. Sighting conditions were defined as “good”, “moderate” or “poor”, based primarily on sea conditions, water turbidity and glare. Only outcomes for “good” and “moderate” conditions were used.

6:4 Figure 3, page 10, of the SCANS report provided a map of the total search area achieved under all conditions. From this map it is evident that significant areas of Block F (north east Irish Sea) specifically including the area of the proposed survey, were NOT subjected to aerial survey. Whether this was due to bad weather, the lack of resources or low national priority was not explained by the SCANS report. As a result, Table 33, page 27 reporting of cetacean presence in Block F can only be reported as “estimate” in the context of “partial coverage only” for Irish Sea Block F.

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6:5 Additional weakness in the survey methodology was noted by the SCAN report on page 15 which noted that the effective visual strip width from aerial detection was, at its maximum, no more than 400 metres. Further comment on this issue (page 33) reported that “detection probability and therefore effective strip width is smaller from an aircraft than from a ship, but aerial survey is considerably cheaper than ship survey”.

REF: “Estimates of Cetacean Abundance in European Atlantic Waters in summer 2016 from the SCANS111 aerial and shipboard surveys.” June 2021.

6:6 Whatever the reason for the admitted weakness of the Block F aerial survey for cetaceans (bad weather, lack of resources, low national priority in respect of the proposed seismic survey area or the desire of UK Government to cut costs) it is clear that the aerial cetacean survey of Block F of the N.E. Irish Sea was sub-standard because: a: it did not cover the area of the proposed airgun seismic survey b: it made use of a lower standard (aerial as opposed to ship) visual strip width leading to a reduced detection probability c: a & b above therefore contributed to “partial coverage only” of Block F and nil coverage of the area of the proposed acoustic survey area d: and generated only “estimate” of cetacean numbers for the entire Block F and nil data for a large area lying between the Sellafield coast and Isle of Man, including the area of the proposed survey.

6:7 This Briefing contends that the NWS/NDA documentation is seriously remiss and lacking in scientific rigour because despite the fact that the authors of the SCAN report, clearly and transparently referenced these weaknesses in its survey work, the NWS/NDA documentation has failed to reference these matters and has thus presented (intentionally or otherwise) an inadequate and biassed reporting of the SCAN survey of cetaceans in Block F and particularly in the area where the proposed seismic survey is to take place.

7: Identification of Marine Conservation Sites potentially impacted by acoustic seismic survey: 7:1 The UK Wildlife Trusts have identified and designated a number of sensitive and protected seabed areas adjacent to the proposed survey area, and identified key species of special interest relevant to the designation of these sites, as the following extracts from their listings explain: 7:2 West of Copeland: This 158 km2 offshore MCZ is located in the eastern Irish Sea between the Copeland coast and the Isle of Man. The seabed here ranges from fine sand to mixed and coarse sediment, providing a home for a variety of animals such as anemones, sea urchins, bivalves (animals with paired, hinged shells), starfish, and bryozoans (“moss animals”). The site is especially important for the protection of subtidal coarse sediment habitats and the communities supported by them, particularly in deep water.

7:3 The West of Copeland is an offshore Marine Conservation Zone (MCZ) located in the Irish Sea, and is composed of a mixture of subtidal sediments from fine sand to coarse sediment.

The range of habitats support a variety of species including many bivalves, sea urchins, anemones, starfish and bryozoans. Designation of this area protects the important coarse sediment seabed habitats and the species they support, particularly in deeper waters. REF: https://www.wildlifetrusts.org/marine-protected-areas/england/irish-sea

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7:4 This site was designated on 31st May 2019. The most recent JNCC formal conservation advice for this site was published on 27th May 2022.

7:5 Cumbria Coast: The Cumbria Coast was designated as a Marine Conservation Zone in 2013 to protect a wide range of habitats found within the site, including honeycomb worm reefs and rock habitats. The rocky scar that is St Bees Head provides a unique habitat in the north-west, hosting a variety of fascinating species. This MCZ will help to protect the headland’s biodiversity and retain the character that makes it so special.

7:6 The sandy seafloor off the Cumbria Coast has rich communities of burrowing animals and provides a feeding ground to the 10,000 pairs of breeding seabirds nesting at St Bees Head, including England’s only breeding colony of black guillemots at Fleswick Bay.

REF: https://www.wildlifetrusts.org/marine-protected-areas/england/irish-sea

7:7 West of Walney: The West of Walney MCZ is located just off the coast of Walney Island, Cumbria, and covers two different habitat types: mud to the north and sand to the south.

Mud and sand are both brilliant habitats for wildlife and full of life. High densities of burrowing brittle stars colonise the surface of the sandy areas, while urchins, worms and molluscs enjoy the mud alongside the commercially important Dublin Bay prawn (also known as the pub grub favourite, scampi).

7:8 Strange-looking spoon worms can also be found here. These bizarre creatures extend their long, green, spoon-shaped tongues out of their burrows in the mud to feed. Delicate sea pens also live on the West of Walney mud; their numbers are in decline and protection will help them to thrive once more.

REF: https://www.wildlifetrusts.org/marine-protected-areas/england/irish-sea

7:9 Allonby Bay: The Allonby Bay MCZ hugs the coast into the Solway Firth and includes two extremely important areas for marine life, Dubmill Scar and Maryport Roads. The area is highly diverse containing many different species of sponge, soft coral, seaweed, sea squirt, anemone and the reef-building honeycomb worms which is at its most northern extent. The region is home to creatures such as the breadcrumb sponge and baked bean sea squirt.

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7:10 Honeycomb worm (Sabellaria alveolata) reefs are a key feature of the northwest coastline. Millions of these worms form tubes from tiny grains of sand and shell, growing side-by-side to form a living reef. These reefs play a vital role as a home to other species, allowing settlement in areas which would otherwise be shifting sediments. Allonby Bay contains some of the best examples of reefs in the North West.

REF: https://www.wildlifetrusts.org/marine-protected-areas/england/irish-sea

7:11 Solway Firth MCZ: The Solway Firth is a shallow, wide estuary that provides a corridor between England and Scotland. The sand banks provide resting places for seals and the fast flowing waters are home to many species of fish that are not only of importance to us, but also create a rich feeding ground for seabirds. This site is being recommended to protect smelt, a species of conservation importance. It is also an important nursery ground for bass, pollack and some flatfish species.

The Solway Firth is an important area for conservation and is already designated as a Special Area of Conservation and Area of Outstanding Natural Beauty. Each type of designation protects different features of the area and, with the Marine Conservation Zone, will complement each other for maximum protection for the habitat and the species that live there.

REF: https://www.wildlifetrusts.org/marine-protected-areas/england/irish-sea

8: Factors related to perceived “sensitivity” of marine habitats and species: 8:1 Academic work confirms the consensus that the sound of seismic airgun surveying can propagate over large distances in marine environments. Various distances are quoted as follows: “Seismic airgun pulses propagate beyond 500 km in deep water and approximately 100 km in shallow water” Ref: https://www.sciencedirect.com/science/article/pii/S0967063718300591

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Seismic airguns produce loud, repetitive sounds that can travel underwater for up to 2,500 miles. REF: https://oceana.org/seismic-airgun-blasting-overview 8:2 It is evident from the above that each of the above MCZs referenced by the UK Wildlife Trusts are close enough, in terms of miles/kms, to the proposed West of Copeland airgun survey area for the sounds to be audible or detectable. Even in shallow water, such as that of the survey area, airgun pulses are reckoned to propagate over approximately 100kms.

8:3 Relevant sensitive sites (MCZs) identified by the NWS/NDA assessment: Appendix A: Marine Environmental Assessments (page 106) of the West of Copeland proposal identified four MCZs it considered relevant to the assessment of possible impacts as follows: 8:4 West of Walney (0 km from the survey area) “Site designated based on seabed habitats: subtidal sand and subtidal mud and sea-pen and burrowing megafauna communities” 8:5 The West of Copeland proposal has omitted mention of the fact that the MCZ designation refers to “High densities of burrowing brittle stars colonise the surface of the sandy areas, while urchins, worms and molluscs enjoy the mud alongside the commercially important Dublin Bay prawn (scampi)”, spoon worms and the fact that the sea pen communities “are in decline”.

8:6 Wyre-Lune (19 km from the survey site) “Site designated due to its community of migratory smelt (Osmerus eperlanus)” 8:7 Cumbria coast (2 km) “Site designated based on habitats and birds, such as razorbills and guillemots” 8:8 The West of Copeland proposal has failed to reference that the MCZ designation also refers to “The sandy seafloor off the Cumbria Coast has rich communities of burrowing animals .”

8:9 Solway Firth (9 km) “Site designated with its community of migratory smelt (Osmerus eperlanus).

8:10 The West of Copeland proposal fails to mention that the MCZ designation also refers to “an important nursery ground for bass, pollack and some flatfish species.”

REF: EXE_2022_00048-Copeland - Notification of Geophysical Survey Appendices A to F-3.pdf https://drive.google.com/file/d/1r4G-getKX26x-6DOs9isci1rgDd1udpB/view?usp=sharing

8:11 The NWS/NDA Appendix A Environmental Assessments concludes that “The designated features for the West of Walney MCZ are not sensitive to underwater sound and, as there would be no interaction between the survey apparatus and the seabed, there is predicted to be, with a high level of confidence, no likely significant effects to the site or its designating features.”

Re’ the Wyre Lune MCZ, “the distance from the inshore area to the geophysical survey area is beyond the point at which significant behavioural response would occur. Thus, it is predicted that no significant impact at the individual or population level within the MCZ is likely. Based on the distance and timing, the confidence in this assessment is high.”

“The Cumbria coast MCZ and Solway Firth MCZs were identified as part of the baseline, however both were scoped out due to distance and no clear impact pathways. “ 8:12 The APPENDIX A conclusions on the MCZs discussed above lack rigour in the following respects:

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Appendix A does not include the Allonby Bay MCZ in its discussion, despite the fact that it is closer to the proposed survey area than the Solway Firth MCZ. 8:13 Appendix A has “scoped out” the West of Copeland MCZ from its discussion. This site is described by the JNCC as situated “in the eastern Irish Sea”. Mapping imagery of the site relative to the Cumbrian and Manx coasts is unclear. However, the site lies midway in the channel between the Cumbrian coast and the Isle of Man which is 65kms wide. The proposed West of Copeland seismic survey area extends out to 20km from the Cumbrian coast and NWS/NDA documentation confirms that sectors of the 158 sq km West of Copeland MCZ are 1.1km from sectors of the survey area.

8:14 No justification was given for the “scoping out” of the West of Copeland MCZ despite the fact that the range of habitats within the MCZ supports a variety of species including important bivalve, sea urchin, anemone, starfish and bryozoan species. Despite an extensive literature search no report of any research into acoustic airgun survey impacts on these species has been identified. Clearly there is an absence of data on such issues and the NWS/NDA “scoping out” of the West of Copeland MCZ is not justified without the initiation of further research into air-gunning impacts on the species in question 8:15 Appendix A states that “The designated features for the West of Walney MCZ are not sensitive to underwater sound”. Despite an extensive literature search, no record of any studies of the impact of seismic airgun survey noise on brittle stars, sea urchins, sea pens, spoon worms, Dublin Bay prawns, sea squirt, Saballeria and bryozoans has been found.

The NWS/NDA assessment makes no reference to any such study in support of the claim that the species “are not sensitive to underwater sound”.

This briefing therefore contends that the claim has been made without any scientific justification and must therefore be discounted.

8:16 Appendix A states that “The Cumbria coast MCZ and Solway Firth MCZs …… were scoped out due to distance and no clear impact pathways.” The sites are described as being 2 kms and 9 kms respectively from the survey area. An extensive literature search indicates that there has been very limited investigation of the long term far field (in excess of 2kms from source) effects of airgun implosion and that what has been investigated has been focussed on cetaceans and not the “rich communities of burrowing animals” characteristic of the Cumbria coast MCZ or the “important nursery ground for bass, pollack and some flatfish species” of the Solway Firth MCZ. This Briefing therefore contends that the NWS/NDA statement is based on scant and inadequate data and lacks credibility 8:17 Appendix A has “scoped out” any reference to 2 important adjacent and extensive MCZs both of which contain significant assemblages of marine species and lie close to the survey area. West of Copeland and Allonby Bay. The Appendix A summary of MCZ species of designation interest have omitted the Wildlife Trusts references to hugely important marine species assemblages which have NOT been investigated for their sensitivity to acoustic airgun seismic surveys Clearly the assessment of “sensitivity” of both sites and marine species is a vitally important factor in the decision making process preceding the initiation of any seismic acoustic survey. The flaws and failures of omission catalogued above have severely diminished the scientific rigour and transparency of the NWS/NDA assessment of potential impacts of airgun seismic surveying on regional MCZs.

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8:18 There is a body of empirical evidence demonstrating that acoustic seismic surveying can have a negative impact on fish schooling and subsequently on commercial fishing harvests during both the survey period and for some time afterwards (see next section below). This Briefing note reports that the NWS/NDA Appendix A has also failed to assess and report on this issue.

9: Marine fauna and acoustic impact thresholds 9:1 NWS/NDA have attempted to identify effect thresholds for a range of marine animals, deemed relevant to the West of Copeland area, which were then used to estimate impact zones around the survey area based on the results from underwater sound propagation modelling. Appendix A reports that “The derivation of appropriate threshold levels of noise on marine life exposed to impulsive type noise draws on the methodologies developed by the US National Marine Fisheries Service for cetaceans and pinnipeds and Popper et al’ (2014) for fish and sea turtles.” Ref: EXE_2022_00048-Copeland - Notification of Geophysical Survey Appendices A to F-3.pdf https://drive.google.com/file/d/1r4G-getKX26x-6DOs9isci1rgDd1udpB/view?usp=sharing

9:2 It is clear from the above that the NWS/NDA assessment of the proposed acoustic survey impact thresholds on West of Copeland marine species is based on methodologies derived from only two sources. This is not representative of the available papers addressing such methodologies.

9:3 In a more recent 2019 review of such work, ignored/not referenced by the NWS/NDA assessment, Professor Popper states that the more recent report provides the most complete summary of the effects of anthropogenic noise on fishes to date. The 2019 paper also warns that it is “clear that there are currently so many information gaps that it is almost impossible to reach clear conclusions on the nature and levels of anthropogenic sounds that have potential to cause changes in animal behaviour, or even result in physical harm. Further research is required on the responses of a range of fish species to different sound sources, under different conditions. There is a need both to examine the immediate effects of sound exposure and the longer-term effects, in terms of fitness and likely impacts upon populations.” REF: “An overview of fish bioacoustics and the impacts of anthropogenic sounds on fishes”: Popper AN et al’. Fish Biology: Vol 94: issue 5. May 20 9:4 Professor Popper’s empirically based precautionary warning from the 2019 Review, by an accepted world leader in the field, is NOT reflected or referenced by the NWS/NDA documentation, which conveys the impression that it’s interpretation of the available data is based on a broad consensus derived from unequivocal and sound data.

9:5 It is equally clear from the NWS/NDA statement that, other than marine mammals, sea turtles and fish, a very wide range of marine species have been excluded from detailed assessment. Excluded species include those NOT referenced in the NWA/NDA discussion of “designated feature” species in the MCZs adjacent to the proposed survey area (e.g.: brittle stars, urchins, marine worms, molluscs, sea pens and juveniles of many species).

Other species not discussed include Basking Shark and zoo-plankton (including the larvae of most of the species present in the NE sector of the Irish Sea).

9:6 It is also evident that the NWS/NDA assessment of potential impacts on fish species is focussed on sea/river lamprey, Atlantic salmon and smelt and that generalised

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extrapolation of data concerning these species has been applied to other regional fish species, despite their widely differing feeding, schooling, breeding and habitat occupation behaviours. This is not justified by the empirical evidence of these factors.

9:7 This Briefing also notes that there are no empirical analyses of the abundance of basking sharks within or near the proposed acoustic survey and no reporting of investigation of either the primary or secondary impacts of air gun acoustic surveying on basking sharks.

10: Review of academic peer reviewed literature of acoustic seismic surveying impact on marine biota: 10:1 This Briefing offers a summary review of academic studies of the impacts of acoustic seismic surveying on a wide range of marine species, representative of many of those found in the sea area under discussion.

10:2 Because the studies cited by the NWS/NDA assessment have been incomplete in terms of species assessed and have failed to highlight Professor Popper’s warning of multiple “information gaps”, the fact that it is “almost impossible to reach clear conclusions” and “the need for further research”; this Briefing presents a selection of academic research which counters the NWS/NDA assertion that it is expected that there would be “no likely significant effects to the site or its designating features” and “no significant impact at the individual or population level” etc.

10:3 There is a very broad consensus that most marine species communicate by sound.

Hydrophone recordings captured in both deep and shallow waters demonstrate that crustaceans, fin fish, elasmobranch species and cetaceans all create and respond to sound which is an important sensory stimulus underwater, as it can spread in all directions quickly and propagate further than any of the other sensory cues. A large number of studies have demonstrated that anthropogenic noise causes auditory masking, leading to cochlear damage, changes in individual and social behaviour and altered metabolisms, reduces population recruitment, can subsequently affect the health and service functions of marine ecosystems and may, in extreme cases, contribute to mortality of individuals.

10:4 A 2015 peer reviewed Review study noted that, “since a wide variety of sampling methodologies and un-standardized measurements have been used and the effects of noise on marine organisms are dependent on the characteristics of the species and noise investigated, it is difficult to compare the reported results. Moreover, the scarcity of studies carried out with other species and with larval or juvenile individuals severely constrains the present understanding of noise pollution. In addition, further studies are needed to reveal in detail the causes for the detected impacts.”

10:5 The 2015 Review also reported the consensus that “marine noise may cause stress in animals, increase the risk of mortality by unbalancing predator-prey interaction, and interfere with sound-based orientation and communication, especially in reproductive contexts. There is growing international concern regarding the impact of anthropogenic noise on marine organisms. A number of studies have shown that the effects of anthropogenic sound on marine organisms can range from no influence to immediate death depending on the differences in the intensity and frequency of the noise and the distance from the noise source. However, the mechanisms underlying these effects are still poorly

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understood.” REF: “Noise in the Sea and Its Impacts on Marine Organisms”: Chao Peng et al’. Int J Environ Res Public Health. 2015 Oct; 12(10): 12304-1232.

10:6 International opinion: In Australia, after immense public outrage about seismic testing in 2020 the Senate held an Inquiry into the impact of seismic testing on fisheries and the marine environment. One clear recommendation from the Senate Inquiry is that “seismic blasting doesn’t belong in marine parks, and it doesn’t belong in critical marine habitats.”

In America in 2018, Environmental groups opposed to offshore drilling sued the federal government to prevent future seismic tests for oil and gas deposits in Atlantic waters off the U.S. East Coast. Seismic testing, which uses air gun blasts, violates federal laws that protect marine mammals, endangered species, and national environmental policy, according to a lawsuit filed in U.S. District Court in Charleston, South Carolina, against U.S. Secretary of Commerce Wilbur Ross and the National Marine Fisheries Service.

The Irish Times reported in 2018: "The Government has been called on to review seismic testing for oil and gas in Irish waters, following a newly-published Australian study showing such exploration techniques can destroy plankton populations. The research by the University of Tasmania and Curtin University found that air gun signals which are commonly used in marine petroleum exploration can cause a two to three-fold increase in mortality of adult and larval zooplankton".

11: Impacts on Cetaceans: 11:1 The impact of anthropogenic ocean noise on whale populations has been very widely documented and publicised. This has occurred because of the large number of peer reviewed studies of those impacts which have been published in academic journals, the press and audio/visual media.

A 2015 study of the impacts of seismic surveying on Bowhead whales found that when in proximity to seismic airgun operations, bowhead whales (Balaena mysticetus) decreased their calling rates. Data were collected in August–October 2007–2010, during the westward autumn migration in the Alaskan Beaufort Sea. In addition to identifying whale call production rates, airgun pulses were identified, analysed, and a cumulative sound exposure level was computed. The data which was gathered was used to examine the relationship between the received sounds from airguns and the number of detected bowhead calls.

11:2 It was observed that calling rates increased as soon as airgun pulses were detectable, compared to calling rates in the absence of airgun pulses. However, after the initial increase, Bowhead calling rates levelled off at a received sound volume of ~94 dB (the lower threshold). In contrast, once the received volume exceeded ~127 dB (the upper threshold), whale calling rates began decreasing, and when the sound volume values were above ~160 dB, the whales were virtually silent. REF: “Effects of airgun sounds on bowhead whale calling rates: Evidence for two behavioural thresholds”. Blackwell SB, et al. 2015. PLoS ONE, 10(6), e0125720.

11:3 Investigation of the impact of shipping and air-gun acoustics on fin whales was published in 2012. The study researched the acoustic and behavioural changes of fin whales in response to two different types of anthropogenic noise: shipping and air gun noise.

Acoustic features of recorded fin whale 20-Hz song notes were compared for areas with different shipping noise levels, different traffic intensities and during a seismic air gun array

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survey. In high noise conditions find whale 20-Hz song note duration shortened, bandwidth decreased, centre frequency decreased and peak frequency decreased. Similar results were obtained in 20-Hz song notes recorded during a 10-day seismic survey.

11:4 During the first 72 h of the seismic survey, a steady decrease in song received levels and bearings to singers indicated that whales moved away from the air-gun array source and out of our detection area, and this displacement persisted for a time period well beyond the 10-day duration of seismic air gun activity. This study provides evidence that male fin whales from two different subpopulations modify song characteristics under increased background noise conditions, and that under seismic air gun activity conditions they leave an area for an extended period.

11:5 The researchers concluded that “Fin whale songs and behaviour are modified in response to shipping and air gun noise. Temporal and spectral song features decreased in high noise conditions. Under seismic air gun activity conditions, they leave the area for an extended period. Fin whale communication is modified to compensate for increased background noise. These responses are documented in two subpopulations and multiple areas. REF: “Acoustic and behavioural changes by fin whales (Balaenoptera physalus) in response to shipping and airgun noise.” Castellote M., et al. 2012. Biological Conservation, 147, 115-122.

11:6 Research published in 2014 investigated the effect of seismic air-gun surveying on Humpback whales. Passive acoustic monitoring (PAM) was used to document the presence of singing Humpback whales off the coast of Northern Angola, and opportunistically test for the effect of seismic survey activity in the vicinity on the number of singing whales.

11:7 The researchers concluded that the results of the study indicated that the breeding display and behaviour of humpback whales is disrupted by seismic survey activity, and thus merits further attention and study, and potentially conservation action in the case of sensitive breeding populations. REF: “Seismic surveys negatively affect humpback whale singing activity off Northern Angola.” Cerchio S., et al. 2014. PLoS ONE, 9(3), e86464.

11:8 Each of the three whale studies referenced above concerned baleen whale species which have baleen instead of teeth which they use to collect shrimp-like krill, plankton and smaller fish from the sea. A number of baleen species visit UK waters at various times of the year.

Fin whales are seen in deeper waters stretching from Scotland down to the western part of the English Channel, records of fin whale observations are relatively sparse but they have been recorded in the Irish Sea, with several strandings reported in the northern sector.

Minke whales are more common in UK waters and mapped distributions of Minke sitings demonstrate a regular presence of these whales throughout the Irish Sea including the northern sector, though in smaller numbers than some other UK sea areas. Most sightings are between July and September but can be seen any time from May through to October, and some remain in coastal waters year-round. The poor recording methodology for cetaceans discussed above have militated against a clear understanding of Minke numbers in the proposed West of Copeland survey area 11:9 Minkes consume more schooling fish (such as sand eels, herring, sprat, cod, capelin, haddock, saithe, whiting) than other northern hemisphere rorquals; zoo-plankton are also an important food, especially in more northern waters such as the Irish Sea. Minke whales are also more frequently seen in shallower coastal and inshore waters.

There is every reason to believe that the acoustic impacts discussed above are relevant to

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the proposed Cumbrian air gun survey. It is noted that studies of the impact of airgun surveys on schooling fish and zoo-plankton swarms (the major food stuff of Minke whales) indicate that acoustic seismic surveys generate significant and long term disruption of the prey species upon which minke rely (see below).

12: Harbour porpoise: 12:1 A 2020 study from Denmark investigated the impact of air gun seismic surveying on harbour porpoise in the Danish sector of the North Sea. Decreases in echolocation signals were detected up to 8–12 km from active airguns, which the researchers concluded may indicate temporary displacement of porpoises or a change in porpoise echolocation behaviour.

12:2 However, no general displacement of harbour porpoises away from the seismic survey area could be detected when comparing to reference stations 15 km away from any seismic activity. It was concluded that the results added to the understanding that underwater noise has the potential to affect temporarily foraging efficiency in porpoises.

12:3 While the effect of seismic surveys on harbour porpoise behaviour was smaller than that reported for pile-driving, the researchers warned that cumulative effect of anthropogenic impacts could be assessed by evaluation of potential population level consequences. REF: “Harbor Porpoise (Phocoena phocoena) Reaction to a 3D Seismic Airgun Survey in the North Sea.” Sarnocinska, J.; et al’ . Frontiers in Marine Science, 6, 824. 2020.

12:4 It is clear that some aspects of the harbour porpoise study reported impacts (decrease in echo-location activity) at 8 to 12 km from airgun activity. Many animals exploit sound for navigational and communication purposes, but only some produce signals dedicated to probe their environment actively through echolocation. There is a broad consensus that toothed cetaceans, including harbour porpoises, have also evolved echolocation to serve as a primary sense informing not only navigation, but also foraging for highly agile prey under conditions of poor lighting.

Decrease in echo location activity, from airgun activity 8 to 12 kms distant, has major implications for intra pod communication, individual navigation and feeding behaviour.

12:5 This Briefing reports that despite confirmation of harbour porpoise presence in the proposed survey area, due to relatively sparse cetacean spotting activity in the north east basin of the Irish Sea and flawed survey work described in earlier sections of this report the numbers and distribution of harbour porpoises in the area of the proposed survey remains ill defined.

13: Impact on Fish: 13:1 Sea Bass: A 1999 paper reported the results of an experimental air gun seismic survey in the open sea, carried out to evaluate the effects of air gun acoustic waves on marine animals.

Although no mortality occurred, air gun acoustic output was shown to have a marked influence on confined Dicentrarchus labrax. The data demonstrated a biochemical response to acoustic stress induced by air gun blasts. Variations of cortisol, glucose, lactate, AMP, ADP, ATP and cAMP in different tissues of D. labrax, indicated that fish have a typical negative primary and secondary stress response after air gun detonations.

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Radiography indicated that the air gun blasts did not induce any macroscopic effect on skeletal apparatus. The variations of biochemical parameters returned to normal values within 72 h of exposure indicating a recovery of homeostasis after acoustic stress. REF: Biochemical responses of European sea bass (Dicentrarchus labrax L.) to the stress induced by off shore experimental seismic prospecting. Santulli, A., et al. 1999. Mar. Pollut. Bull. 38: 1105–1114.

13:2 It is clear that adult Sea Bass exposed to airgun survey noise generate negative

primary and secondary stress responses.

This Briefing has not found any study of the potential impacts of acoustic surveying on Sea Bass breeding agglomerations or juveniles. There is a consensus that UK Sea Bass spawn in “open waters” during May and June and that juveniles spend the autumn and winter in coastal estuarine and near shore waters. Spawning areas are not well identified. It is likely that eggs and small fry may be represented in in the zoo- plankton assemblages found in the West of Copeland proposed survey area.

13:3 Schooling species: Cod and Haddock: Field research in Arctic waters, published in 1996, reported major reductions in both trawl and long line catches for cod and haddock. To determine whether seismic exploration affected abundance or catch rates of cod and haddock, acoustic mapping and fishing trials with trawls and longlines were conducted in the central Barents Sea 7 days before, 5 days during, and 5 days after seismic shooting with air guns.

13:4 It was found that seismic shooting severely affected fish distribution, local abundance, and catch rates in the entire investigation area of 40 × 40 nautical miles. Trawl catches of cod and haddock and longline catches of haddock declined on average by about 50% (by mass) after shooting started, which agreed with the acoustic abundance estimates; longline catches of cod were reduced by 21%.

13:5 Reductions in catch rates were observed 18 nautical miles from the seismic shooting area (3 × 10 nautical miles), but the most pronounced reduction occurred within the shooting area, where trawl catches of both species and longline catches of haddock were reduced by about 70% and longline catches of cod by 45%; a relatively greater reduction was found (in both catches and acoustic estimates) for large, rather than for small, fish.

Significantly, abundance and catch rates did not return to pre-shooting levels during the 5-day period after seismic shooting ended. REF: “Effects of seismic shooting on local abundance and catch rates of cod ((Gadus morhua) and haddock )(Melanogrammus aeglefinus)” A Engas et al’. Canadian Journal of Fisheries and Aquatic Sciences. October 1996

13:6 The implication of these research outcomes is that, during airgun seismic surveys and for at least a 5 day period following the survey, commercial catches of these shoaling species may experience major declines. In the case of the survey proposed by NWS/NDA such a catch decline may have a duration of at least 5 weeks. These findings are of major significance for shoaling species fisheries in the north eastern sector of the Irish Sea. It is relevant to note that this study reported severe reductions fish distribution, local abundance and catch rate up to 18 miles distant from airgun activity and for at least 5 days following cessation of airgun activity. This issue was not raised or assessed by the NWS/NDA. 13:7 Sand eels: A 2004 field experiment on the effect of seismic shooting on the lesser sand

eel (Ammodytes marinus) was conducted on fishing grounds in the south eastern part of the North Sea in May 2002.

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Sand eel buried in the sand at night were trapped in steel frame cages (2.0×1.8×2.0m) deployed in positions with high abundance of fish located by a van Veen grab. In an experimental area, three sand eel cages were exposed to full-scale seismic shooting for about 2.5 days. Cameras in the cage and on a remotely operated vehicle (ROV) were used to monitor the activity of the enclosed fish. A control area about 35km southeast of the seismic shooting area was established with two sand eel cages. The distribution and abundance of the lesser sand eel during daytime in the experimental region were regularly monitored by acoustic surveying, but the methodology could not demonstrate that seismic shooting caused any change in sand eel abundance.

13:8 Repeated grab surveys were conducted using a van Veen grab for a predetermined set of localities almost every night during the experimental period, both prior to and after seismic shooting. The results indicate that the seismic shooting had a moderate effect on the behaviour of the lesser sand eel.

13:9 The total mortality in the cages of about 35% on average, both in the experimental group and the control group. Researchers concluded that this was probably a result of injuries during deployment, due to handling and confinement. Analyses of landing data from the Norwegian sand eel trawlers show a temporary drop in the sand eel landings for a short period after the seismic experiment. Unfortunately, the researchers did not report the duration of this catch decline. REF: “Influence of seismic shooting on the lesser sand eel (Ammodytes marinus)” : Arne Hassel et al’: ICES Journal of Marine Sciences: 2004: vol 61: no 7

13:10 Evidently acoustic survey activity had a detectable effect on sand eel behaviour and an observed negative “knock on” impact on sand eel catch and landing, though the experiment was unable to clearly quantify this effect.

14: Sea birds: although seabirds are unlikely to experience direct primary impacts from acoustic air-gunning, it cannot be denied that any deleterious impacts on fish species will clearly have a knock on effect on many of the seabird species permanently or temporarily resident in and around the Cumbrian coastal and inshore waters. The NWS/NDA assessment did not reference, or discuss this issue.

15: Impact on Cephalopods: 15:1 In 2001, five giant squid mass stranded in one localised area off northern Spain. Two years later, four more giant squid stranded or were found floating in the same area. All of these nine strandings, some of them live, occurred contemporaneously with hydrocarbon geophysical seismic surveys using air guns. These unusually high numbers of dead giant squid, washed up on Spanish shores, have led scientists to believe that loud, low-frequency sounds made by acoustic air guns are killing marine creatures.

15:2 Even though externally, they showed no obvious cause of death, the squid all had massive internal injuries. Post mortem of two of the squid demonstrated that they had suffered “...extensive damage to internal muscle fibres, their stomachs were ripped open and their digestive tracts were mangled” according to Angel Guerra of the Institute for Marine Investigations in Vigo, Spain. Some also showed substantial damage to their hearing organs, leaving them effectively disoriented. As a result, these normally deep-water animals

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might have floated to warmer surface waters, where, because of their blood chemistry, they lost oxygen, potentially causing their death 15:3 Guerra told the New Scientist that on both occasions geologists were conducting offshore seismic surveys nearby for oil and gas that same week, firing 200 decibel pulses of sound below 100 Hertz from an array of 10 air guns. Local fishermen also reported seeing large numbers of dead fish floating at sea during the surveys. REF: “Seismic surveys may kill giant squid:” Deborah MacKenzie. NEW SCIENTIST 22 September 2004

15:4 Cephalopods species (cuttlefish, squid and octopus) are poorly surveyed in UK waters but are found along UK west coasts from the south west of England to the north west of Scotland. There is growing evidence that warming sea temperatures are driving the northward movement of cephalopod species.

Clearly the recorded post acoustic survey impacts on giant squids may well impact cuttlefish, squid species and octopus. The NWS/NDA assessments have made no reference to investigation of cephalopod numbers and distribution in the north east sector of the Irish Sea and have failed to review the potential impacts of air gun surveying on cuttlefish, squid and octopus.

16: Sharks: 16:1 Many studies have noted the negative impacts of artificial anthropogenic on a wide range of marine species, however, the effect of sound on the behaviour of sharks has received very little investigation and sound-induced behavioural changes in sharks remain poorly understood.

While mammal hearing is based on detection of sound pressure, fish and invertebrates primarily sense sound using particle motion. Particle motion can be calculated indirectly from sound pressure measurements under certain conditions, but these conditions are rarely met in the shelf-sea and shallow-water habitats that most aquatic organisms inhabit.

Direct measurements of particle motion have been hampered by the availability of instrumentation and a lack of guidance on data analysis methods. REF: “Particle motion: the missing link in underwater acoustic ecology.” Sophie L Nedelec et al’: Methods in Ecology and Evolution. July 2016. Volume 7, Issue 7.

16:2 A 2019 study by researchers at the University of Western Australia noted that the auditory apparatus of sharks comprises the paired inner ears that, as in all fishes, detect the particle motion component of a sound and that cartilaginous fishes, such as sharks and rays, have two sensory organs shown to be responsive to particle motion detection. These organs in the inner ear of sharks are known to be sensitive to low frequency sounds up to 1.5 kilo Hertz, peaking between 200 and 600 Hz, depending on the species. This is of particular relevance to the sounds produced by air gunning.

16:3 The Australian researchers used a baited underwater camera rig to record the behavioural responses of eight species of sharks (seven reef and coastal shark species and the oceanic white shark) to the playback of two distinct sound stimuli in the wild: an orca shark hunting call sequence and an anthropogenically generated sound.

16:4 When both sounds were played, reef and coastal sharks were less numerous in the area, were responsible for fewer interactions with the baited test rigs, and displayed less ‘inquisitive’ behaviour, compared to during silent control trials. Oceanic white sharks also

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spent less time around the baited camera rig when the artificial sound was presented, but showed no significant difference in behaviour in response to orca calls.

16:5 The researchers concluded that the behavioural response of the 8 shark species to anthropogenic sound raised “concern about the effects of anthropogenic noise on these taxa”. REF: “The effect of underwater sounds on shark behaviour.” Lucille Chapuis et al’. Scientific Reports. NATURE. Volume 9. 2019

16:6 In the context of the 2019 study, it is highly relevant to note that there is no evidence of any investigation of the potential impact of seismic air gunning surveys on any of the Irish Sea elasmobranch (shark and ray) species.

Despite the fact that Cumbrian waters are reported to hold a variety of both ray and shark species, their status in, and adjacent to, the proposed survey area is poorly documented.

The NWS/NDA assessment has not referenced shark and ray species in any sensible way and has not discussed or referenced any investigation of acoustic survey impacts on these species.

16:7 A number of “iconic” shark species are known to be either resident or seasonal visitors to the area to the east of the Isle of Man. Basking Shark are perhaps the most vulnerable of the seasonal visitors with a range covering Irish, Northern Irish, Manx and Cumbrian waters, in all of which, they have protected status.

16:8 Basking Sharks are one of the most heavily protected sharks in UK and EU waters. In the UK Basking Sharks are protected under: Schedule 5 of the Wildlife and Countryside Act 1981 which protects them from capture, killing, injury or harassment in British territorial waters (up to 12 miles offshore). They are similarly protected within the territorial waters of the Isle of Man, which also extend out to 12 miles offshore.

16:9 In 2007 Basking Sharks became a Prohibited Species in the EU. EU commercial fishing vessels are prohibited from targeting, retaining, trans-shipping or landing them. This applies to third country vessels in EU waters. Under the UK Biodiversity Action Plan (BAP), In 1997 Basking Shark was listed in the UK BAP, an inventory of the nation’s biodiversity. This identified the Basking Shark as being in urgent need of conservation management and laid out detailed plans for their protection.

16:10 Basking shark also protected under the International Union for Conservation of Nature (IUCN) where Basking Sharks are listed as Endangered on the IUCN Red List of Threatened Species (on the Global, European, and Mediterranean assessments) and the Convention on International Trade in Endangered Species of Wild Fauna and Flora (CITES) .

The Basking Shark is listed under Appendix II of the CITES. International trade is controlled to ensure it doesn't threaten the survival of the species and under the Convention on Migratory Species (CMS) where Basking Sharks are listed in Appendices I and II of the CMS. Basking Shark are also protected under the United Nations Convention on the Law of the Sea (UNCLOS) where the Basking Shark is listed under Annex I – Highly Migratory Species – of the UNCLOS. Article 64 of UNCLOS directs signatory States to cooperate to ensure the conservation of this species.

16:11 Despite all of these protections the NWS/NDA assessment has studiously avoided any in-depth discussion of these aspects of Basking Shark protection and relied solely on

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the EPS designation which is one of the very few such protective legislations which does not apply to the Basking Shark.

16:12 Despite the conservation designations listed in the above paragraphs there are no records of any studies of the potential acoustic impacts on any UK endemic species of elasmobranch species, including Basking Shark.

The SCAN and other surveys referenced by the NWS/NDA have not investigated the presence or distribution of Basking Sharks in the proposed seismic survey area.

The NWS/NDA assessments have not addressed the potential impact of seismic surveying on Basking Shark.

In the context of both of the UK and the international protective legislation and the IUCN Red List classification for Basking Shark, there is a high priority for the suspension of seismic airgun surveys until such species specific work has been carried out and subjected to independent peer review.

The absence of such data, the failure of the NWS/NDA to gather such data and the utter failure of the NWS/NDA assessment to consider the impact of the proposed survey on Basking Shark represent a clear failure to respect a range of national and international legislation and major failure to adhere to standards of scientific rigour.

17: Impact on Crustaceans: 17:1 There is a consensus that there has been a critical knowledge gap regarding the impacts of seismic air gun signals on the physiology of adult crustaceans. However, research published in 2017 conducted a number of controlled field experiments to investigate the impact of seismic acoustic signals on one representative species, the southern spiny lobster, Jasus edwardsii.

17:2 The investigations revealed that seismic air gun exposure suppressed total haemocyte count (THC) for up to 120 days post-exposure. This finding strongly implied a chronic negative impact on crustacean immune competency and nutritional condition. THC levels after 365 days post-exposure, remained elevated two-fold, potentially indicating an immune response to infection. There was no effect of air gun exposure on 24 haemolymph (blood) biochemical parameters, hepatopancreas index or survival.

17:3 Collectively these results indicated that despite the fact that the biochemical haematological homeostasis of J. edwardsii appeared reasonably resilient to seismic acoustic signals, it was evident that air gun exposure can negatively influence the lobster's nutritional condition and immunological capacity. Ref: “The impact of seismic air gun exposure on the haemolymph physiology and nutritional condition of spiny lobster, Jasus edwardsii.” Quinn P Fitzgibbon et al’|: Mar Pollut Bull 2017 Dec 15; 125 (1-2): 146-156

17:4 A follow-on study of the seismic airgun impacts on the southern spiny lobster, published in 2019 undertook additional research. The 2019 study investigated the impact of seismic surveys on the righting reflex and statocyst (hearing organs) morphology of the southern rock lobster, using field-based exposure to air gun signals.

17;5 Following exposure equivalent to a full-scale commercial assay passing within 100-500 m, lobsters showed impaired righting and significant damage to the sensory hairs of the statocyst. Reflex impairment and statocyst damage persisted over the course of the

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experiments-up to 365 days post-exposure and had not improved following moulting. These results indicate that exposure to air gun signals caused morphological damage to the statocyst of rock lobsters, which can in turn impair complex reflexes. REF: “Seismic air guns damage rock lobster mechanosensory organs and Impair righting reflex.” Ryan D Day et al’: Procs Biol Sci. 2019 Jul 24; 286 (1907)

17:6 The reported damage and impairment confirms that anthropogenic aquatic noise generated by seismic airgun surveying has the potential to harm decapod crustaceans (lobsters, crabs, shrimps and prawns) , and further confirms the imperative need for a better understanding of possible ecological and economic impacts and considerable caution around the ongoing use of airgun surveying technology.

An extensive literature search has found no evidence of any research on the acoustic impacts of airgun activity on any UK decapod crustacean species. It is therefore concluded that UK authorities have no data or understanding on the potential acoustic impacts on crabs and lobsters in and adjacent to the proposed survey area.

18: Shellfish larvae: 18:1 A 2013 study investigated the impact of airgun seismic survey work on the larvae of scallops. The researchers analysed 4881 scallop larvae from a larger sample of fertilised eggs divided into four noise and four control sub-samples. “Noise samples” were exposed to a playback of pre-recorded seismic airgun sounds at 3 s intervals. Larvae were sampled from both groups at seven fixed intervals between 24 and 90 hours after fertilisation.).

18:2 In the first sample, 24 hours after the start of noise exposure, all larvae were in relatively early developmental stages, however, the average proportion of larvae in the most advanced stage was significantly higher (42%) in the control group than in the noise group.

Malformations were observed in all four of the noise-exposed groups starting in the sample corresponding to 66 hours post-fertilization. By this time, 100% of the larvae in the control group had continued to develop normally. At experiment completion, after 90 hours, all 329 larvae sampled in the control group were normal, while an average of 46% of the noise-exposed larvae (27 to 91% in the four noise samples) showed malformations (63 out of 141 sampled larvae). These malformations were evident as abnormal growth, with localised bulges in the soft body of the larvae, but not in the shell.

18:3 The research results demonstrated unequivocally that longer exposures to lower levels of airgun survey noise caused delayed development and abnormal growth of scallop larvae. It was stated that both effects reduce the probability of larval survival in the wild by increasing exposure to pelagic predators and by reducing larval competence. It was also stated that there are no reasons to expect that scallop larvae are more vulnerable to sound than other shellfish with similar larval development and the effects of noise on larvae of other species therefore requires examination.

This Briefing notes that scallop fisheries represent an important commercial activity in and around the northern basin of the Irish Sea. It is also noted that scallop larvae are pelagic and mobile and that adult scallop harvested from the coastal water of the Isle of Man may well have been free swimming larvae in and around the shallower waters of the proposed seismic survey area and adjacent waters.

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18:4 The researchers proposed that noise exposure during critical growth intervals may also contribute to stock vulnerability, underlining the urgency to investigate potential long-term effects of acoustic pollution on marine fauna. Moreover, these results call for applying the precautionary principle when planning activities involving high-intensity sound sources, such as seismic exploration, in spawning areas of marine invertebrates with high natural and economic value. REF: “Anthropogenic noise causes body malformations and delays development in marine larvae.” Natacha Aguilar de Soto et al’: Scientific reports: Volume 3: Article number: 2831 (2013)

18:5 Despite an agreed inadequate database, there is a loose consensus that scallop breed from late April through to September and that larvae can remain suspended in the water column, prior to settling on the seabed, for between 3 to 6 weeks. Larval stages of scallop in the NE sector of the Irish Sea, both settled and suspended, are likely to be exposed to impacts from the proposed seismic survey during the proposed chronology of the intended survey.

The implications of the above research for bivalve shellfish stocks within and adjacent to the proposed survey area are clear and the researcher’s recommendation for applying the precautionary principle should be noted.

However, the NWS/NDA assessment makes no reference to, or discussion of the serious impact of seismic air gun surveys on bivalve shellfish larvae.

19: Impact on Copepod and other Zooplankton: 19:1 The NWS/NDA assessment states that Irish Sea plankton blooms peak from March through to May with expected “secondary” production peaking “some weeks later”.

However, this is an incomplete and scientifically inaccurate description of plankton production in the northern basin of the Irish Sea. In fact, an extensive study from the Port Erin Marine Lab published in 2005, reported that the highest phyto (plant) plankton concentrations were recorded from waters across the Irish Sea from May to September. This study reported that areas close to inshore waters tended to have higher chlorophyll concentrations throughout the production season in response to nutrient elevation of coastal waters from river inputs. REF: “The Plankton Ecology of SEA6 (Irish Sea): Technical Report”: Kevin Kennington: 2005: Port Erin Marine Lab: Isle of Man

19:2 Phyto plankton are primary producers and their blooms generate the so-called “secondary” production of zoo (animal) plankton which feed upon the phyto plankton. It is the case that the phytoplankton blooms permit the development of the “secondary” production which peaks “some weeks later”. This zooplankton production provides an immensely important food source for the majority of regional schooling fish, Basking Shark, Baleen whales, filter feeders and some seabirds. In that respect it is not at all secondary.

19:3 The Port Erin Marine Lab study reports that there are well over 20 species of zooplankton in the Irish Sea including the larvae of a number of commercial species and also that zooplankton data for the north east Irish Sea is not common. The Port Erin study reports that there is both empirical and “extrapolated” information that the concentrations of a number of zooplankton species can be relatively high in the region over the period between May and September. But, in that context, the Port Erin report advises that caution should be

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taken when studying data for the eastern sector of the Irish Sea as many of the patterns observed in the north-eastern Irish Sea are not actual values.

19:4 Port Erin also reports that the many species of zooplankton in the Irish Sea include the larvae of a number of commercial species and that many of them are the larvae of valuable commercial decapod species lobster, crab, shrimp and Dublin Bay prawn (scampi).

From distribution plots in the Port Erin study, it can be seen that decapod larvae are abundant throughout the Irish Sea, however, it is noted that maximum abundances are found in the Morecambe Bay and Cumbrian waters area. This is in agreement with other studies which have noted that all species were more common in shallower waters especially in the eastern Irish Sea. Seasonal abundances of decapod larvae are reported to appear very strong, with reduced numbers over the winter months and a large peak from June to August.

It is reported that longer term studies implied a reduction of abundance over the last 30 years where a steady decline in decapod larval numbers has been seen since the 1970’s. REF: “The Plankton Ecology of SEA6 (Irish Sea): Technical Report”: Kevin Kennington: 2005: Port Erin Marine Lab: Isle of Man

19:5 This Briefing notes that decapod crustacean larvae clearly represent the base of an important commercial activity in and around the northern basin of the Irish Sea. It is also noted that decapod crustacean larvae are pelagic and mobile and that adult decapod crustaceans harvested from coastal waters throughout the northern basin of the Irish Sea may well have been free swimming larvae in and around the shallower waters of the proposed seismic survey area and adjacent waters.

19:6 Alluding to potential impacts on plankton in the relevant sea area the NWS/NDA assessment reports that “Most plankton have no, or very limited, mobility and therefore unable to move away from a potentially harmful sound source. Thus, some mortality or injury of plankton could occur within tens to hundreds of metres from the sound source.

However, phytoplankton and zooplankton are widely distributed through the water column, and so only a fraction of any population may be involved. Any effect will also be short-term, as many of these organisms are quickly replaced due to rapid generational turnover times, and so any observable effect at the population level is unlikely”.

19:7 The NWS/NDA assumption quoted above takes no account of the nature of seismic surveys in which an airgun array, which may be several hundred metres wide, is towed backwards and forwards through the survey area on parallel track transect lines. This Briefing has been unable to find information from NW/NDA, or their survey company, on the methodology of the proposed survey. As a result, it is unclear how wide the acoustically surveyed swathe of each transect will be, how closely spaced the tow transects will be, or the timing of each pass over any given point on the seabed and consecutive adjacent areas.

19:8 However, it is assumed that the methodology employed will indeed be similar to that described in the preceding paragraph ands that during periods of peak production of zooplankton, which the available data indicates will coincide with the timing of the proposed survey, there is a strong likelihood that individuals within the bloom will be subjected to one exposure only as the airgun arrays pass.

19:9 If that should be the case then zooplankton swarms/blooms are at risk of multiple exposures to acoustic implosions, and short term effects only are contra-indicated.

19:9 Copepods and other zooplankton are of particular importance as a food source for many juvenile and small fish species and also for larger plankton feeders (baleen whales, Basking Shark) in the northeast region of the Irish Sea. A 2019 paper reported that the effect

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of seismic airgun blasts on adults of one zooplankton Calanus spp.) a key food source for commercially important fish, was assessed in field experiments. The study found empirical evidence that the immediate mortality of copepods was significantly different from controls at distances of 5 m or less from the airguns. Mortality one week after the airgun blast was still significantly higher—by 9% relative to controls—in the copepods placed 10 m from the airgun blast but was not significantly different from the controls at a distance of 20 m from the airgun blast. The increase in mortality—relative to controls—did not exceed 30% at any distance from the airgun blast. REF: “Airgun blasts used in marine seismic surveys have limited effects on mortality, and no sublethal effects on behaviour or gene expression, in the copepod Calanus finmarchicus”: David M Fields et al’. ICES Journal of Marine Science. Vo; 76, Issue 7. Dec’ 2019.pps 2033-2044

19:10 This Briefing notes that the 2019 study summarised above, explains that the subjects of its study were “adults of one zooplankton” species. However, there is a body of evidence to prove that other developmental stages of zooplankton are more sensitive to acoustic damage.

19:11 A 2017 study has reported mortality of ALL larval zooplankton at distances far in excess of 10 metres from seismic air gun activity.

This empirical study confirmed that experimental “air gun signal exposure decreased zooplankton abundance when compared with controls, as measured by sonar (~3-4 dB drop within 15-30 min) and net tows (median 64% decrease within 1 h), and caused a two- to threefold increase in dead adult and larval zooplankton. Impacts were observed out to the maximum 1.2 km range sampled, which was more than two orders of magnitude greater than the previously assumed impact range of 10 m.”

Although no adult krill were present, “all larval krill were killed after air gun passage” There is a significant and unacknowledged potential for ocean ecosystem function and productivity to be negatively impacted by present seismic technology.” REF: “Widely used marine seismic survey airgun operations negatively impact zooplankton” McCauley RD et al’ Nat Ecol Evol. 2017 Jun 22; 197);195

19:4. From the text of the 2017 paper it is clear that larval zooplankton are impacted to at least 1.2 kms from the sound source and that impacts may extend beyond that range, which was the limit of the study.

19:5 It is clear that impacts are detectable to at least 1.2 kms from the airgun impulses and thus exceed the JNCC advised and industry and government backed 500 metre safety/mitigation zone radius (1 km wide in total). It is clear that the results from these experiments demonstrate that seismic airgun blasts have detectable effects on the mortality and escape response of adult Calanus sp. within at least 10 m of the blast, and possibly at greater distance, but NOT at 20 metres. However, given that towed airgun arrays may be up to at least 250 metres wide and that it is presumed that they will follow relatively closely spaced transect lines backwards and forwards across the proposed survey area, the potential for a significant impact on zooplankton swarms is high.

19:6 In the context of the area to be surveyed off the Cumbrian coast (250sq km in extent), the duration timescales and intensity of the proposed survey (continuous 24 hour operation for a 4 week duration), the potential 250 metre wide airgun arrays and the proximity survey “lines” traversed during such work, it is clear that significant numbers of adult zooplankton will be within the 10 metre impact range of airgun blasts during the survey.

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19:8 It is also clear that the proposed airgun survey will be carried out at a time when blooming zooplankton populations (including schooling fish and crustacean eggs and larvae) in the survey area may be expected to be high and acting as a significant food source at the base of marine food webs. Many species including adult schooling fish, summering whales and basking shark utilise zoo plankton as a major food stock.

Zoo-plankton stock and the schooling fish which feed on them provide a food source for many other regional marine species and seabirds and also nurture valuable commercial species harvested by regional commercial fishers.

20: Marine Invertebrate sound reception: 20:1 A review of marine animal acoustic sensing reports that there is empirical evidence to suggest that marine invertebrates can detect both water-borne and substrate -borne particle motion (vibration). Water-borne particle motion is detected as movement in the surrounding aquatic environment, whereas substrate-borne vibration is detected as particle motion below the seafloor. Semi- terrestrial and marine crabs and seafloor-dwelling marine invertebrates, such as mussels have been shown to respond to substrate-borne vibration.

20:2 Marine invertebrates may detect particle motion using external sensory hairs, internal “statocysts”, and external organs on body appendages. Although some marine invertebrates that produce sound in air have specialised sensory organs that can detect pressure changes in air, most groups do not have organs for detecting water pressure and also lack the air-filled spaces and compressible tissues required for pressure sensing.

20:3 Marine decapod crustaceans (e.g., lobster, crabs, and shrimp) have an extensive array of sensory hairs covering their bodies, which have been shown to function in a similar way to the lateral lines on fish. Water- or substrate-borne vibrations associated with changes in acceleration, hydrodynamic flow, and/or sound may stimulate these sensory hairs. Detecting these vibrations may help animals sense the movements of other nearby organisms and their surroundings. Researchers found sensory hairs located on the claws of freshwater crayfish to be most sensitive to water-borne particle motion at frequencies between 150 and 300Hz. Sensory hairs found on different body parts of the American lobster can also detect low frequency underwater sound. Other invertebrate groups are known to respond to water movement or vibrations using sensory hair cells or other epidermal structures for detection.

20:4 The statocyst is a complex sensory organ found in most marine invertebrates, consisting of a dense mass (the statolith) inside a fluid filled chamber. It primarily provides orientation cues that allow an animal to maintain its position in the water column. In some animals, the statocyst may also function to detect the low frequency, particle motion component of sound.

20:5 Many marine crustaceans also possess statocysts, usually located on their first antennae or in the abdomen. found to be responsive to stimuli ranging from 40 to 1500 Hz. Not all marine crustaceans that have statocysts use them for sound detection. Researchers found that removing the statocyst of the American lobster did not eliminate their neural response to acoustic stimuli. However, immobilising body surface sensory hairs did eliminate the response.

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20:6 There are indications that molluscs such as the oyster, cockles, scallops and various clam species are sensitive to sound or vibrational exposures. Scientists hypothesised that bivalves can detect sounds and vibrations either with the statocyst or external body hairs; but there are few studies investigating sound and substrate vibration detection in molluscs.

Pacific oysters suspended in a mesh bag in an experimental flume exhibited valve-closing behaviour in response to playback sounds in the frequency range of 10 – 1000 H. Laboratory experiments showed blue mussels responded to substrate-borne vibrations between 5 and 400 Hz, with sensitivity being relatively constant across all frequencies before reaching a decrease in sensitivity at 200 Hz. REF: https://dosits.org/animals/sound-reception/how-do-marine-invertebrates-detect-sounds

21: JNCC OFFICIAL UK GUIDANCE on MARINE SEISMIC SURVEY OPERATIONS 21:1 UK “guidance” on these issues has been drawn up by the Joint Nature Conservation Committee. The JNCC is an executive non-departmental public body, sponsored by DEFRA (Department for Environment, Food and Rural Affairs). Although in theory the JNCC is nominally independent, Defra ministers are responsible for the appointment of senior JNCC staff including CEOs, Directors and Board Members.

21:2 In 2017 the JNCC issued “JNCC guidelines for minimising the risk of injury to marine mammals from geophysical surveys”, this was an update of a similar document published in 2010. The2017 JNCC Guidelines document accepts that sound generated by marine seismic acoustic surveys “has the potential to cause injury (e.g. hearing damage) to marine mammals (cetaceans and seals).

21:3 The JNCC 2017 Guidelines offers a suite of mitigation measures intended to reduce the risk of injury to marine mammals and proposes that the measures are based on “reasonably conservative assumptions” and proposes that compliance with these Guidelines “constitutes best practice” which will, in most cases, reduce the risk of injury to marine mammals to ”negligible levels.”

21:4 The JNCC “negligible level” has not been defined. In that context it should be assumed that it is a subjective, rather than an objective and empirical, judgement to be taken by the decision maker. In the case under consideration, it remains unclear which individual or organisation will make the eventual subjective decision and on what basis the decision will be made.

21:5 Although the JNCC 2017 Guidelines clearly focus on marine mammals, the JNCC notes that “they could be adapted to help reduce the risk of deliberate injury to other marine species if deemed appropriate by the relevant Regulator. For example, other potentially sensitive species include marine turtles, also listed as EPS (European Protected Species), and several shark species including basking shark which are UK priority marine species.”.

21:6 The above statement, taken from the introduction to the 2017 JNCC document, is (in the context of more recent scientific peer reviewed evidence discussing impact effects on schooling fish and other invertebrates) now clearly outdated and inadequate.

The major differences between the sound awareness faculties of species as diverse as marine mammals, crustaceans, marine worms and zoo-plankton render the claim that

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JNCC Guidelines “could be adapted to help reduce the risk” of injury to other species unrealistic and lacking scientific rigour.

It is strongly recommended that UK seismic acoustic surveys are suspended and/or postponed until the scientific evidence related to acoustic impacts on schooling fish and other invertebrates has been incorporated into updated JNCC Guidelines.

21:7 JNCC (2017) mitigation measures: The mitigation measures outlined in the JNCC Guidelines include the operation of a 500 metre “mitigation zone” measured from the centre of the airgun arrays. The JNCC Guidelines state that the 500 metres mitigation zones are “standard” for the UK. 21:8 A paper published back in 1998 reported that mitigation, or safety, zones are defined by the radii of received sound levels “believed to have the potential for at least temporary hearing impairment for marine mammals induced by sound levels in excess of 180 Decibels” The authors of the 1998 paper report that maximum safety zone radii used in the US for both toothed and baleen whales extended out to beyond 1,000 metres, while the UK safety zones radii for those species was restricted to 500 metres. REF: “Protection from, and mitigation of, the potential effects of seismic exploration on marine mammals”: M.O. Pierson et al’.

Proceedings of the Seismic and Marine Mammal Workshop: LONDON: June 1998. (Eds: Tasker M & Weir C.)

21:9 The justification for the JNCC recommendation of a 500 metre safety/mitigation zone is not presented and directly contradicts the action of US authorities. JNCC must explain why they believe that UK marine mammals have less sensitive hearing than those in US waters.

21:10 The 2017 JNCC Guidelines mandate the use of marine mammal observers (MMOs) and passive acoustic monitoring (PAM) to conduct pre-survey searches, within the mitigation zone, for marine mammals. The primary role of marine mammal observers (MMOs) is to ensure that no marine mammals are observed within the mitigation zone before a noisy activity begins, thus reducing the potential for injury to negligible levels. The wording of the JNCC Guidelines implies that the size of the standard mitigation zone “may be determined at the application stage, following review of an impact assessment undertaken by the applicant.”

21:11 However, as there is no evidence that any form of independent impact assessment has been carried out it must be assumed that the “standard” 500 metre mitigation zone advised by the JNCC will be, or has been, adopted. It is certainly indicated by the NWS/NDA assessment.

21:12 The use of MMO and PAM strategies was incorporated into the JNCC guidelines as a form of mitigation in 2002 and has been increasingly used as a tool for monitoring marine mammals during night time and poor visibility conditions. Again, the aim is to ensure no marine mammals are within the specified area prior to the activity commencing.

The JNCC document advises that specialist trained PAM operatives are needed to set up and deploy the equipment and to interpret detected sounds. It is acknowledged that current PAM systems are not suitable for detecting seals and some cetaceans (e.g., baleen whales)

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and have limited range for others (e.g., harbour porpoise). However, despite this weakness PAM is considered by the JNCC to be a viable monitoring method during periods when effective visual monitoring is not possible.

21:13 The JNCC Guidelines advice that when a PAM system is used, it should achieve as much as possible of the following: a: Detect the range of frequencies of marine mammal vocalisations expected to be present in the survey area; b: Detect and identify vocalising marine mammals and establish bearing and range in a reasonable period of time; c: Immediately communicate relevant information to the PAM operator (real time) so appropriate and timely mitigation measures can be undertaken (e.g. delay operation start); d: Able to be repaired on board or replaced in case of breakdown (e.g. appropriate repair tools and back-up equipment).

21:14 The MMO and PAM strategies proposed by JNCC must now be regarded as outdated and inadequate in the context of the more recent scientific and peer reviewed evidence for sonic impacts on schooling fish and other marine invertebrates. Similarly, it is clear that they are not suitable for detecting seals and baleen whales, such as the Minke whales often sighted in the waters of the northern Irish Sea, this is especially the case with Minke whales which are understood to be one of the least easily detected of the cetaceans.

21:15 Both MMO and PAM strategies will experience reduced effectiveness in declining sea states and weather conditions and their effectiveness will also be dependent on the extent of the “safety radii” or “mitigation zone” declared for the specific project in the specific site. No public evidence has been presented as to the size or extent of any “mitigation zone” to be deployed during the proposed Cumbrian survey.

21:16 A paper published in 1998 reported that mitigation safety zones are defined by the radii of received sound levels “believed to have the potential for at least temporary hearing impairment for marine mammals induced by sound levels in excess of 180 Decibels”.

21:17 The authors of this paper report that maximum safety zone radii used in the US for both toothed and baleen whales extended out to beyond 1,000 metres, while the UK safety zones radii for those species had been restricted to 500 metres since 1995. The paper also reported that “mitigation measures”, including all of those listed in the 2017 JNCC Guidelines, had been in place in the UK since 1995. REF: “Protection from, and mitigation of, the potential effects of seismic exploration on marine mammals”: M.O. Pierson et al’. Proceedings of the Seismic and Marine Mammal Workshop: LONDON: June 1998. (Eds: Tasker M & Weir C.)

21:18 Other mitigation measures mandated by the 2017 JNCC Guidelines are as follows: “soft start”: slow achievement of maximum power of the airgun array sonic output, based on the expectation that the soft start muted acoustic will drive marine mammals away before damaging volumes are achieved Cessation of firing when vessels (and arrays) are turning during survey runs and exercise of “soft start” during resumption of firing Use of “soft start” in the event of any break in firing lasting longer than 10 minutes

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If airgun arrays are to be “tested” before use a soft-start is required, this should be carried out over a time period proportional to the number and/or volume of guns being tested and should not exceed 20 minutes in duration. Airguns should be tested in order of volume, smallest first.

A pre-shooting search (MMO/PAM) must be undertaken before any instances of airgun testing. Where feasible, it is recommended that airgun testing is incorporated into the soft start procedure and conducted before the start of a survey line to reduce the total amount of noise being introduced into the marine environment.

21:19 It is noted that while “soft start” etc mitigation may reduce primary impact by forcing cetaceans to move out of the survey mitigation zone of, it will clearly induce secondary impacts by inducing disruption of feeding and socialisation behaviour and may still disrupt vocalisation and communication. This Briefing warns that this represents only a limited degree of mitigation.

The various mitigation measures advised by the 2017 JNCC Guidelines are clearly based on assessments of pre 1995 research and have not changed since 1995 despite the publication of more recent and detailed data relating to acoustic impacts on marine mammals and schooling fish and other marine invertebrates (which are not referenced in the 2017 JNCC Guidelines). It is clear that the JNCC Guidelines are significantly out of date and do not reflect more recent information. This is particularly relevant to the wide range of non-cetacean species not addressed by the JNCC Guidance.

This Briefing concludes that the JNCC appears to be unaware of the serious seismic airgun survey impacts on a wide range of species other than cetaceans. ………………………………………………………………………………………………… ……………

22: Alternatives to acoustic airgun seismic survey techniques 22:1 NWS/NDA assessment has stated that “There is no suitable alternative non-intrusive survey method available to collect data on deep geology” REF: MLA/2022/00085 page 9.

22:2 However, in 2009 a conference received a presentation on Low Frequency passive seismic imaging, a new technology that had been applied mostly in land surveys but warranted further investigation and development for application to a marine environment.

Initial testing had been carried out in the North Sea for oil and gas applications and it was concluded that the information gained could be used for planning follow-on surveys to further advance this technology.

22:3 That presentation explained that although the use of controlled sources (dynamite, airguns or vibrators) for such geological imaging is the industry standard, it has been known for many decades that industry and academics can also use natural seismic sources to illuminate the earth’s structure. Much of our knowledge of the interior geology of the earth has been derived from imaging involving the transmission and reflection of seismic waves whose source was an earthquake on the other side of the earth.

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22:4 Explaining the method of operation of passive seismic transmission tomography (PSTT), the presentation noted that work using surface waves excited by the pounding of waves on the beach had begun to unravel the crustal structure of continents. In the previous decade there had been work directed at using these natural energy sources to create images useful for hydrocarbon exploration and production. These efforts are driven by both environmental concerns and by the expense of conventional seismic imaging. Collectively we refer to these imaging techniques using naturally occurring or ambient noise sources as passive seismic tomography.

22:5 PSTT creates 3-D images using the observed travel time of seismic signals originating from micro-earthquakes occurring below the target and the survey proceeds by simply listening. Assuming an initial velocity model, the observed micro-earthquakes are located in time and space using long-standing location algorithms based upon the timing of seismic waves arrival at each observation station. The speed of travel of these waves is controlled by the velocity of the material that the wave “sees”. Longer wavelengths penetrate more deeply into the earth and therefore sample the earth to a greater depth. This allows the creation of a structural image of the subsurface geology. REF: “Passive Seismic Tomography: structural imaging using natural sources”. Peter M. Duncan, MicroSeismic. Page 25. From REPORT OF THE WORKSHOP ON ALTERNATIVE TECHNOLOGIES TO SEISMIC AIRGUN SURVEYS FOR OIL AND GAS EXPLORATION AND THEIR POTENTIAL FOR REDUCING IMPACTS ON MARINE MAMMALS. Held

by Okeanos - Foundation for the Sea. Monterey, California, USA 31st August – 1st September, 2009

22:6 More recently academic papers reflect a growing consensus that “Seismic tomography is a powerful tool for mapping the three-dimensional structure of the Earth's interior.

Tomographic images obtained in the past four decades have greatly improved our understanding of the Earth's heterogeneous structure and dynamics, which signify a revolution in Earth sciences.” REF: “Importance of later phases in seismic tomography.” Dapeng Zhao. Physics of the Earth and Planetary Interiors. Volume 296. Nov’ 2019

22:7 Marine Vibroseis: The 2019 review of alternative technologies puts forward an alternative method to seismic surveying, known as marine vibroseis, that has shown less of an impact on whales while still being able to penetrate and acoustically explore sub-sea bed geology in order to locate fossil fuels.

Marine vibroseis is designed to release the same amount of energy as airgun surveys, but rather than blasting all the energy at once, it is released continuously or intermittently for a longer period of time. REF: “Importance of later phases in seismic tomography.” Dapeng Zhao.

Physics of the Earth and Planetary Interiors. Volume 296. Nov’ 2019

22:8 “A company called Geokinetics, founded in 1997, developed AquaVib, a marine vibrator, to provide an alternative to the high decibel sound traditionally created by seismic airgun activity. Another company called Petroleum Geo-Services (PGS) also carries a similar product for marine vibroseis with very low frequency sound level. Their plan was not to address the environmental concerns from seismic activity but instead to help mitigate the harm that marine mammals suffer due to this process. It is the high noise decibel of seismic airguns that disrupts the communication; with marine vibroseis the sound now resembles background noise instead of high energy blasts, therefore marine mammal communication would not be disrupted. They relate this sound to more of a hum instead of bang”. REF: https://blogs.umass.edu/natsci397a-eross/marine-vibroseis-a-safer-alternative-to-seismic-airguns -for-the-north-atlantic-right-whale/ (recovered 23/05/2022

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22:9 The 2019 review reported that a problem with products like AquaVib “was funding for final testing of the product. Because the oil industry has already put so much money and time behind seismic airgun surveying, they are reluctant to provide support for this new product. It is not economical for them to fund the research for the final testing of AquaVib when they already have a system that works for them.” REF: “Importance of later phases in seismic tomography.” Dapeng Zhao. Physics of the Earth and Planetary Interiors. Volume 296. Nov’ 2019

22:10 However, other work points out that “These companies that are unwilling to switch over to marine vibroseis may not realize the full benefit of having marine vibroseis over seismic airguns. Not only does marine vibroseis produce significantly less noise pollution, it also is much smaller and more customizable than seismic airguns. Seismic airguns do not have a lot of variation between product size and they are generally much larger than marine vibroseis products. This means that they cannot survey shallow waters as the actual airgun is too large to navigate without wrecking the seafloor in its wake. Alternatively, marine vibroseis can be used in more shallow waters between 8-30 meters deep much more easily.

REF: https://blogs.umass.edu/natsci397a-eross/marine-vibroseis-a-safer-alternative-to-seismic-airguns -for-the-north-atlantic-right-whale/ (recovered 23/05/2022)

22:11 The BBC has, in layman's terms, reported favourably on these alternatives, noting that academics have concluded that shockwaves fired from an air gun - like a very powerful speaker - are blasted down towards the seabed. The waves bounce off features below and are detected again at the surface. The signal that returns reveals whether there is, for instance, oil locked in the rock beneath. The process creates a tremendous racket. "It's like an explosion," says Lindy Weilgart at Dalhousie University in Nova Scotia. She says that there is now plenty of evidence to show that many marine animals are negatively affected by the clamour. Quieter tech is not being introduced quickly enough, says researcher Lindy Weilgart The effects aren't just felt by mammals like whales and dolphins, she adds. Fish and invertebrates such as crabs have also been seen to change their behaviour when noise levels rise. They can be put off feeding or become less able to detect predators, for example.

And yet a technology exists that could be far less harmful. It is called marine vibroseis and is a low-energy alternative to air guns. Instead of explosive blasts, vibroseis uses smaller vibrations to transmit waves down to the seabed. It actually emits a similar amount of energy overall but spreads it over a longer period, meaning the survey has a less "shocking" impact. REF: Protecting whales from the noise people make in the ocean. Chris Baraniuk Technology of Business reporter. 28 February 2020

22:12 Overall, the 2019 Review referenced above concluded that “marine vibroseis is the best solution to the negative impacts of seismic surveying on North Atlantic Right whale fitness without completely getting rid of ocean surveying for oil deposits. With seismic airgun surveying being so loud, it interferes with North Atlantic Right whale communication calls and prevents them from finding each other as well as to find food sources. Since the North Atlantic Right whale population is so small (only about 350 individuals), it really cannot take any individual losses. Marine vibroseis is a safer alternative and therefore can prevent any more harm being done to the endangered North Atlantic Right whale via its softer approach to sound surveying. Legislation needs to be enacted on this new technology

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of marine vibroseis to force oil companies to fund the final testing and then adopt the new technology. Current laws also need to be enforced so we can conserve the remaining individuals of this endangered species in the meantime.”

22:13 This Briefing contends that the above summaries show that both Marine Vibroseis and Passive Seismic Transmission Tomography pose a lesser threat of damage and impacts to marine species than airgun seismic surveys. Additionally, both technologies appear to offer advantages for geological imaging in the environment of the Cumbrian marine seabed due for surveying by the seismic airgun method.

However, it is clear that Governments and users of airgun technology have not been demonstrably keen to take these technologies forward and adopt them wholesale.

Academic commentators note that both oil companies and other users are reluctant to engage in the final development and need to be forced by legislation to support final testing and application of these alternative technologies.

Despite their objections it is recommended that NWS/NDA withdraw their claim that “There is no suitable alternative non-intrusive survey method available to collect data on deep geology”, cancel the proposed and environmentally damaging seismic airgun survey and investigate the use of one of the above “alternative” technologies discussed above. ………………………………………………………………………………………………… ……………

23: Postscript: There is a precedent for seismic surveys to be called off in protected areas such as the Irish Sea West of Copeland. From the Western Telegraph in 2019 - “A PLANNED oil and gas exploration survey in Cardigan Bay has been called off after anger from residents and local politicians. Energy company Eni UK Ltd had submitted an application to undertake a 3D seismic survey off the coast at Cardigan Bay, an area of outstanding natural beauty and home to a wide range of wildlife. This survey was due to last 40 days, starting on Saturday, June 1, and would have covered 955 square kilometres, taking in three Special Areas of Conservation: West Wales, Cardigan Bay and Pembrokeshire Marine.” https://www.westerntelegraph.co.uk/news/17676887.oil-gas-survey-cardigan-bay-called-off “On 7th June 1991 the Irish Government declared Ireland a whale and dolphin sanctuary….proper conservation requires not only the relevant scientific study but the creation of the political will if conservation measures are to be effective.” The management of Irish waters as a whale and dolphin sanctuary EmerRogan Simon D.Berrow https://www.sciencedirect.com/science/article/abs/pii/S0163699506800661

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