MARINE MAMMAL COMMISSION — Annual Report for 1991 



National Marine Fisheries Service on four requests for 

 letters of authorization to take bowhead, gray, and 

 beluga whales and bearded, ringed, and spotted seals 

 incidental to oil and gas exploratory drilling opera- 

 tions offshore Alaska. These requests were from 

 Shell Western E&P Inc. (SWEPI), Amoco Production 

 Company, ARCO Alaska, Inc., and Chevron, U.S.A. 

 Inc. The Commission, in consultation with its Com- 

 mittee of Scientific Advisors, also reviewed and 

 provided comments and recommendations on requests 

 for letters of authorization from BP Exploration 

 (Alaska) Inc. and Amerada Hess Corporation to take 

 bowhead, gray, and beluga whales and ringed, beard- 

 ed, and spotted seals incidental to geophysical seismic 

 exploration activities in the Beaufort Sea during the 

 1991 open-water season. 



In its comments, the Commission noted that the 

 site-specific monitoring plans provided with the 

 requests generally did not provide sufficient informa- 

 tion to determine whether the planned monitoring 

 programs would be adequate to verify the number of 

 marine mammals taken incidental to the authorized 

 activities and that the effects of the take are inconse- 

 quential. Likewise, in most cases, it was not clear 

 whether the planned monitoring program would be 

 sufficient to determine whether the authorized activi- 

 ties had any unmitigable adverse effects on the avail- 

 ability of the six species for Native subsistence 

 purposes. 



On a related point, the Commission noted that, 

 even if properly designed and implemented, the site- 

 specific monitoring programs were not likely, by 

 themselves, to provide an adequate basis for determin- 

 ing whether the authorized activities caused or con- 

 tributed to changes in the distribution, size, or produc- 

 tivity of the affected populations. The Conmiission 

 pointed out that, while the effects of any one activity 

 might be negligible, the combined effects of multiple 

 activities may not be negligible and that site-specific 

 monitoring must be accompanied by long-term popula- 

 tion and habitat monitoring to ensure that there are no 

 significant adverse cumulative effects. 



With respect to exploratory drilling, the Commis- 

 sion noted that such activities could result in drilling 

 muds, petroleum products, etc., being discharged into 

 the environment and that such discharges could 



contaminate invertebrate and fish species eaten by 

 whales, walruses, and seals. The Commission further 

 noted that these marine mammals could accumulate 

 toxic substances and pose a health threat to Alaska 

 Natives and polar bears who eat them. The Commis- 

 sion therefore recommended that the relevant site- 

 specific monitoring plans be revised to include assess- 

 ment of the levels and trends of potentially hazardous 

 contaminants in the benthic fauna and in the marine 

 mammals taken by Alaska Natives for subsistence 

 purposes from areas in and near the planned explor- 

 atory drilling sites. 



The Conmiission also noted that there were com- 

 mon deficiencies in many of the requests for letters of 

 authorization, suggesting that the National Marine 

 Fisheries Service's regulations or its instructions to 

 applicants did not clearly state what is required to 

 meet the intents and provisions of section 101(a)(5) of 

 the Marine Mammal Protection Act. The Commission 

 recommended that, if it had not already done so, the 

 Service advise all of the applicants that renewal of 

 letters of authorization would be problematic if the 

 site-specific monitoring programs carried out during 

 the 1991 season did not provide sufficient information 

 to verify that only small numbers of marine mammals 

 were taken in the course of the exploratory activities 

 and that the effects of the take were negligible. 



Following receipt and review of the comments 

 fi:om the Commission and others, the National Marine 

 Fisheries Service issued letters of authorization to all 

 of the previously mentioned applicants. These autho- 

 rizations were valid for the 1991 open-water season 

 and allowed the unintentional, non-lethal taking of 

 unspecified numbers of bowhead, gray, and beluga 

 whales and bearded, ringed, and spotted seals inciden- 

 tal to oil and gas exploration activities in the Chukchi 

 and Beaufort Seas. 



In addition, the Fish and Wildlife Service issued 

 letters of autiiorization to Chevron U.S.A. Inc. and 

 Shell Western E&P Inc. allowing the unintentional, 

 non-lethal take of unspecified numbers of walruses 

 and polar bears incidental to offshore oil and gas 

 exploration activities in the Chukchi Sea during the 

 1991-1992 open-water season. The letter of authori- 

 zation issued to Shell Western E&P Inc. was based on 

 a petition submitted to the Fish and Wildlife Service 





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