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Transcript
Seismic Seas:
Understanding the impact of offshore seismic petroleum
exploration surveys on marine species
Wild Migration Technical and Policy Review: #3
Geoff Prideaux & Margi Prideaux
December 2013
Page |Review:
35
Wild Migration Technical and Policy
#3
Support for this review has been generously
provided by the Purves Environmental Fund.
The Fund’s vision is an environmentally sustainable
world in which biodiversity is preserved.
Wild Migration works to benefit wildlife and the habitats on which they
depend: providing accessible information to wildlife scientists, wildlife policy
experts and non-governmental organisations (NGOs) to secure international
wildlife conservation.
Photo credits
Galapagos sea lion (front cover) Wafue/iStockphoto; Weddell Sea seals (page 2) Changehali; sea turtle (page 4)
Mikael Eriksson/iStockphoto; southern rock lobster (page 6) Zureks/WikiMedia Commons; polar bear (page 14)
John Pitcher/iStockphoto; dugong (page 22) Mikael Eriksson/iStockphoto; sperm whale (page 24) Shane
Gross/iStockphoto; noble scallop (page 28) OpenCage Systems/WikiMedia Commons; tuna school (back cover)
Rostislavv/iStockphoto
Suggested citation
Prideaux G & Prideaux M (2013) Seismic Seas: Understanding the impact of offshore seismic petroleum exploration
surveys on marine species, Wild Migration Technical and Policy Review: #3, Wild Migration, Australia
Further information about this review
www.wildmigration.org
Contact Geoff Prideaux, Wild Migration: [email protected]
Seismic Seas:
Understanding the impact
of offshore seismic
petroleum exploration
surveys on marine species
Geoff Prideaux & Margi Prideaux
December 2013
Wild Migration Technical and Policy Review: #3
Wild Migration Technical and Policy Review: #3
Page | 1
2 | Page
Wild Migration Technical and Policy Review: #3
Table of contents
Introduction
5
Sound in water: It's complicated!
7
Decibels (dB)
7
RMS and peak to peak
8
Measuring sound in air and in water
8
Spherical and cylindrical spreading and transmission loss
8
SOFAR
9
Super positioning, phase and phase cancellation
9
Elasticity
Conventional seismic surveys and alternative technologies
10
11
Air guns
11
How seismic surveys work
11
Controlled source alternatives
12
Air gun design can be optimized to reduce unwanted energy
13
Noise impact potential
15
Fish, Crustaceans and Cephalopods
15
Pinnipeds
17
Sirenians
17
Cetaceans
17
Sea turtles
18
Polar bears and seabirds
19
The importance of considering stress
19
Unexpected consequences for deep diving mammals
20
International commitments flow to proponents
21
Natural Justice: Consultation, transparency and commercial sensitivity
23
Natural Justice
23
Transparency and commercial sensitivity
23
Consultation
23
Environmental Impact Assessments: Offshore Petroleum Exploration
A Model Environmental Impact Assessment and consultation process
Bibliography
Wild Migration Technical and Policy Review: #3
25
25
29
Page | 3
Sound travels almost five
times faster through sea
water than through air
4 | Page
Wild Migration Technical and Policy Review: #3
1
Introduction
The sea is the interconnected system of all
the Earth's oceanic waters, including the five
named ‘oceans’ - the Atlantic, Pacific, Indian,
Southern and Arctic Oceans - a connected
body of salty water that covers over 70
percent of the Earth's surface.
The sea is home to a broader spectrum of
higher animal taxa than exists on land. Many
marine species have yet to be discovered
and the number known to science is
expanding annually. The sea also provides
people with substantial supplies of food,
mainly fish, shellfish and seaweed. It is a
shared resource for us all.
Acoustic energy (sound) is a new threat to
this shared realm and sound is not easily
contained - travelling fast and potentially
over great distances. One generator of this
sound is the offshore petroleum exploration
industry.
The sea region and type of sound
propagation can significantly affect the
characteristics of arriving sound energy,
making petroleum industry generalizations
about the level of impact difficult to assert.
Section two of this review provides a primer
for regulators, policy makers and marine
stakeholders to understand the complexities
of sound in water, in order that informed
and empowered consideration can be given
Wild Migration Technical and Policy Review: #3
to offshore petroleum exploration
proposals. Section three describes basic
information about conventional offshore
petroleum exploration (seismic) surveys and
alternative technologies. Section four
highlights the type of impact that different
species groups might experience including
fish, marine mammals, seabirds and sea
turtles, as well as the importance of
considering stress and a brief explanation of
some unexpected consequences for deep
diving mammals. Section five provides
information about the recent commitments
Governments have made through
international legal process and how these
should flow to proponents. Section six
clearly articulates the concept of natural
justice and discusses consultation,
transparency and commercial sensitivity. In
many jurisdictions around the world
consultation is poor and industry actively
shifts the ‘burden of proof’ to stakeholders.
The final section proposes a model for
Environmental Impact Assessments that can
be used by regulators and industry alike to
provide enough transparent information
and ensure natural justice. Such
transparency and accuracy of information
should have a two-fold advantage. Industry
proponents will ‘front-end’ their
consultation process and are able to move
forward with certainty. Other marine
stakeholders will feel more confident about
plans and impacts because their
engagement has been sought early in the
planning process.
We urge regulators and policy makers to
consider requiring this level of transparency
and technical detail in order to shift the
industry from one of secrecy and disrespect
for public concerns to an industry that has
nothing to hide and can confidently engage
in real consultation with others who share
the sea.
Page | 5
The difficult part is
assumptive
perception
6 | Page
Wild Migration Technical and Policy Review: #3
2
Sound in water:
It's complicated!
In the ocean, acoustic energy (sound)
propagates efficiently, travelling fast and
potentially over great distances. Sea water is
a denser medium than air, which means that
sound travels almost five times faster
through sea water than it does through air,
potentially extending hundreds of
kilometers with little loss in energy.
The extent and way that sound travels
(propagation) can be affected by many
factors, including the frequency of the
sound, water depth and also density
differences within the water column that
vary with temperature, salinity and
pressure.
It is important to recognize that sound
arriving at an animal is subject to
propagation conditions that can be quite
complex.
The region and type of propagation can
significantly affect the characteristics of
arriving sound energy, making petroleum
industry generalizations about the level of
impact difficult to assert.
Modelling of these complex characteristics
requires a level of technical knowledge.
Consequently, plans and proposals involving
sound in water are often difficult to
understand.
We recognise that there will be some who
will accuse this chapter of simplistic
generalisations. However, this chapter’s
intention is simply to create a primmer of
the tools, terminologies, relationships and
processes to make industry proposals easier
to understand.
Wild Migration Technical and Policy Review: #3
We seek to empower the reader to form
their own conclusions.

The following section provides an
explanation of some important basic
concepts about how sound in water is
described.
Decibels (dB)
While the intention is to provide simple
explanations, some aspects of sound are
complicated.
The decibel (dB) is used to measure sound
levels. The dB is a logarithmic unit used to
describe a ratio. The ratio may be power,
sound pressure or intensity.
The logarithm of a number is the exponent
to which another fixed value, the base, must
be raised to produce that number.
For example:
The logarithm of 1000 to base 10 is
3, because 1000 is 10 to the power
3: 1000 = 10 × 10 × 10 = 103.
More generally, if x = by, then y is
the logarithm of x to base b, and is
written y = logb(x), so log10 (1000) =
3.
The difficult part is assumptive perception. It
is convenient to assume that 10dB is half as
loud as 20dB and a third of 30dB.
For instance, suppose there were two
loudspeakers, the first playing a sound with
power P1, and another playing a louder
version of the same sound with power P2,
but everything else (distance and frequency)
is the same.
The difference in decibels between the two
loudspeakers is defined to be:
10 log (P2/P1) dB where the log is to
base 10.
If the second loudspeaker produces twice as
much power than the first, the difference in
dB is 10 log (P2/P1) = 10 log 2 = 3 dB.
Page | 7
To continue the example, if the second
loudspeaker has 10 times the power of the
first, the difference in dB would be:
10 log (P2/P1) = 10 log 10 = 10 dB
If the second loudspeaker had a million
times the power of the first, the difference
in dB would be:
10 log (P2/P1) = 10 log 1,000,000 =
60 dB
This example shows one feature of decibel
scales that is useful in discussing sound: they
can describe very big ratios using numbers
of modest size.
RMS and peak to peak
The second concept to understand is the
difference between Root Mean Squared
(RMS) and ‘peak to peak’.
Peak to peak is the difference between the
highest point of a sound wave and the
lowest.
The greatest environmental impact from an
air gun is most likely to occur within the first
peak of the cycle. The second peak within
the cycle may have attenuated down to a
point where reference to peak to peak
would be inappropriate for this purpose.
Root Mean Squared (RMS) is a formula used
to calculate an approximate average for the
power of a continuous sine wave.
Therefore, calculating an RMS value is not
appropriately achievable.
RMS, for our purpose, is more appropriate
for continuous sound over time, for instance
an engine or propeller noise.
Measuring sound in air and in
water
Water is a much denser medium than air.
The speed of sound in water is
approximately five times faster than it is in
air.
As we have already established, sound is
measured in dB.
In air, dB is measured dB re 20 µPa2 (re air)
In water, dB is measured dB re 1 µPa2 (re
water).
8 | Page
In water dB is generally referred to as sound
intensity level (SIL) or sound exposure level
(SEL).
In air, dB is generally referred to as sound
pressure level (SPL), because air is less
dense than water and has greater
compressibility properties.
Because of the difference in density
between water and air, the comparison
between 'sound intensity level' and 'sound
pressure level' is not simple.
However, for the technical level of this
explanation the difference between air and
water is 61.5 dB less in air.
For example:
161.5 dB in relation to water is
roughly equal 100 dB in relation to
air.

Spherical and cylindrical
spreading and transmission loss
Spherical spreading is quite simply sound
leaving a point source in an expanding
spherical shape.
This shape changes as sound waves reach
the sea surface and sea floor, they can no
longer maintain their spherical shape and
they begin to resemble the shape of an
expanding cheese wheel. This is called
cylindrical spreading.
This is important to understand because the
transmission loss, or the decrease in the
sound intensity levels, happens uniformly in
all directions when there is spherical
transmission.
However, when sound is in a state of
cylindrical transmission it cannot propagate
uniformly in all directions because of the sea
surface and sea floor. The sound is
effectively contained between the sea
surface and the sea floor, while the radius is
still expanding uniformly (the sides of the
cheese wheel) but the height is now fixed
and so the sound intensity level decreases
more slowly.
Wild Migration Technical and Policy Review: #3
This can be represented by the following
two tables.
Spherical transmission
Range in
meters
Relative
intensity
Transmission
loss in dB
1
10
100
1000
1
1/100
1/10,000
1/1,000,000
0
20
40
60
Cylindrical transmission
Range in
meters
Relative
intensity
Transmission
loss in dB
1
1
0
10
100
1000
1/10
1/100
1/1000
10
20
30
Super positioning, phase and
phase cancellation
If two sound sources of equal frequency and
sound pressure or sound intensity level,
converge upon each other and they are in
perfect alignment the sound pressure or
sound intensity amplitude will be the sum of
these two sound sources. This is referred to
as 'super positioning'.
For example:
There are two sound sources ‘A’ and
‘B’
A is 100dB at 100 Hz +
B is 100dB at 100 Hz
The resulting sound is then 103dB at
100 Hz.
If two sound sources of equal frequency and
sound pressure or sound intensity level,
converge upon each other, and they are
perfectly out of alignment, the sound
pressure/intensity amplitude will be the
difference between these two sound
sources. This is referred to as 'phase
cancellation'.
Phase is the measurement of alignment of
two sound sources from 0° to 359°.
Wild Migration Technical and Policy Review: #3
If two sound sources of equal frequency and
sound pressure/intensity level converge
upon each other, and they are in perfect
alignment, this is referred to as 'in phase'.
If two sound sources of equal frequency and
sound pressure/intensity level, converge
upon each other, and they are perfectly out
of alignment, this is referred to '180° out of
phase'.
If two sound points are at any other angle
(for instance 90°) it is said that the ‘phase
angle’ of that angle (for instance 90°) is
between them.
The examples given in this explanation are
extremely simplistic. In reality, every day
sounds (natural and anthropogenic) consist
of many sound sources, all of different
frequencies, amplitudes and phases.
Sound can have its own characteristics as
well. Some have a sharp attack and release
(like a cannon or a firecracker) whereas
others have slow attack and release (like
wind) and many sounds fall somewhere in
between (like human speech). The
combination of these qualities make up the
'timbre' of particular sounds.
Elasticity
The speed of sound is also not a fixed
numerical value. In fact, sound wave speed
varies quite widely. The sound wave's speed
depends upon the medium, or material, it is
transmitted through, such as gas, solids, or
liquids. Each medium has its own elasticity
(or resistance to molecular deformity). This
elasticity factor affects the sound wave's
movement significantly.
Sound waves move through a medium by
transferring kinetic energy from one
molecule to the next molecule.
Gas Medium
Gas naturally has large spaces between each
molecule. As a result, sound waves take
longer to move through a gas. Each air
molecule vibrates at a slow speed after a
sound wave passes through it since there is
more space surrounding the molecule. The
gas molecule effectively deforms in shape
from the passing sound wave, making gas
Page | 9
reflect a low elasticity. In fact, sound waves
moving through an air temperature of 20° C
will only travel approximately 342ms-1.
Liquid Medium
Liquid molecules bond together in a tighter
formation, compared to gas molecules. The
liquid molecules are more limited in their
overall spacing, allowing only small vibration
movements. As a result, sound waves do not
deform the liquid molecules as severely as
gas molecules, creating a higher elasticity
level. Sound waves moving through water at
22° C travel at approximately 1484ms-1.
Solid Medium
Solid mediums, such as metal, transmit
sound waves extremely fast. The solid
molecules are tightly packed together,
providing only tiny spaces for vibration. As a
result, sound waves move rapidly through
the high elasticity medium, since the solid
molecules act like small springs, aiding the
wave's movement across the medium. In
fact, the speed of sound through aluminum
is approximately 6319ms-1.
The SOFAR channel is created because of
cumulative effect of temperature and water
pressure (and, to a smaller extent, salinity)
that combines to create a region of
minimum sound speed.
This occurs because pressure in the ocean
increases linearly with depth, but
temperature is more variable generally
falling rapidly in the main thermocline from
the surface to around a thousand metres
deep, then remaining almost unchanged
from there to the ocean floor. Near the
surface, the rapidly falling temperature
causes a decrease in sound speed (or a
negative sound speed gradient). With
increasing depth, the increasing pressure
causes an increase in sound speed (or a
positive sound speed gradient). The depth
where the sound speed is at a minimum is
called the sound channel axis. This
phenomenon can be represented with the
graph (below).
Graph: The Sound Fixing and Ranging (SOFAR)
Channel, in this instance with the sound
channel axis at -0.75km
Temperature and Elasticity
Finally, warmer temperatures across a
medium excite molecules. As a result,
molecules move faster under high
temperatures, transmitting sound waves
more rapidly across the medium. However,
decreasing temperatures cause the
molecules to vibrate at a slower pace,
hindering the sound wave's movement.
SOFAR
In addition to cylindrical spreading, there is
an additional variable which can impact how
sound will be transmitted. This is usually
called a Sound Fixing and Ranging Channel
(SOFAR), or deep sound channel (DSC), and
is a horizontal layer of water in the ocean at
which depth, the speed of sound is at its
minimum.
SOFAR channels can act as a waveguide for
sound and low frequency sound waves
within the channel may travel thousands of
kilometres before dissipating.
10 | Page
Scientists believe that some whale species
dive to these channels to 'sing' to
(communicate with) other whales many
kilometres away.
Wild Migration Technical and Policy Review: #3
3
Conventional
seismic surveys
and alternative
technologies
Air guns
Air guns are the common term for
equipment used to discharge a high
intensity plosive sound using compressed
air.
Air gun size is measured in cubic inches and
has a charge pressure measured in poundforce per square inch (psi)
For example:
3250in3 at 2000 psi could be a way
of describing a particular air gun’s
capacity.
The sound intensity level produced by a
single gun can vary considerably, but for the
purposes of offshore petroleum exploration
tend to sit in a range between 225 - 250 dB
in relation to water (re 1 µPa2).
How seismic surveys work
The commonly used method in surveying
employed by offshore petroleum
exploration is called ‘seismic reflection’.
The energy from an air gun array penetrates
sub surface layers and is reflected back to
the surface where is can be detected by
acoustic receivers (hydrophones). The
analysis of these reflections provides a
profile of the underlying rock strata and
helps industry to identify any configurations
that are favorable to hydrocarbon
accumulations. In some cases, it is possible
to record anomalies that may correspond to
actual hydrocarbon deposits.
The two main types of seismic surveying are
what are called 2D and 3D exploration. 2D
surveys can be described as a fairly basic
survey method using a single streamer and a
single energy source. This method is
generally used for quick surveying.
3D surveys use multiple streamers deployed
in parallel and often multiple energy sources
(commonly two), to record data suitable for
the three-dimensional interpretation of the
structures beneath the sea bed.
Air gun arrays are towed behind a seismic
survey vessel, and set to about 6 metres
below the surface.
The discharge is usually a low frequency
high intensity sound pulse, emitted at 10-15
second intervals.
The reflected sound is collected by generally
twelve hydrophone collectors (streamers)
Wild Migration Technical and Policy Review: #3
Page | 11
which can be around 8100m, each
separated by approximately 100-120m and
are towed behind the seismic survey vessel.
The seismic survey vessel generally traverses
along predefined transects (or seismic lines)
which are about 500-750m apart on
average.
For the seismic survey process to work,
there needs to be enough energy discharged
from the air gun array to travel, sometimes
several kilometres, to the sea floor and then
to be refracted as it passes from water into
rock to a prescribed depth and then
refracted from rock to water to do the
return journey to the hydrophone
streamers.

McCauley et al (2000) has made a very
important point which is often missing from
assessment literature - there is as yet no
standardised way to describe an impulsive
air gun signal. This makes it easily possible
to develop erroneous conclusions if the
specifications of each air-gun are not
predetermined.

Alterative technology options to seismic
surveys have been in development for some
years, but their take up is hampered by a
12 | Page
low investment and interest from the
offshore petroleum exploration sector.
Controlled source alternatives
Controlled source alternative to
conventional seismic arrays generally put
the same level of useable energy into the
water as impulsive sources like air guns, but
over a longer period of time or at depth.
This results in lower peak sound levels that
can be hundreds of times quieter.
Electro-mechanical marine vibrators
Electro-mechanical marine vibrators can
operate close to the sea-bed and accomplish
increased penetration and offer the
opportunity to reduce the peak sound levels
introduced into the water column, while
tuning the frequencies transmitted to
exactly the band-width required for
operations. By using a sweep instead of an
impulse source, the peak levels of sound
generated can be reduced by 30 dB. This is
done by spreading out the energy over time.
A sweep that is 10 seconds has the same
amplitude, after correlation, which a short
40 millisecond pulse generated by the air
gun has. However, more research is needed
to fully understand how to implement these
sequences in an effective and optimized
way. Marine vibrators have the additional
Wild Migration Technical and Policy Review: #3
advantage of being more vertically
directional in deeper water.
Controlled-Source Electromagnetics
The use of Controlled-Source
Electromagnetics (CSEM) methods for
exploration has also emerged in the last ten
years as a practical tool for oil and gas
applications. More than 220 marine CSEM
surveys have been acquired worldwide by
industry since 2000 and pre-drill prediction
success rates have been favourably reported
throughout the industry.
of source and receiver characteristics, and
better system gain(s), or new receiver
technologies including fibre optic receivers
that allow the use of quieter sources.
The most useful CSEM survey technique
uses a neutrally-buoyant towed horizontal
electric dipole source and multi-component
electric and magnetic receivers on the
seabed. The continuously towed source
transmits a high-current low-voltage
waveform at a lower frequency, typically
from 0.1 to 0.5 Hz that provides adequate
signal penetration to deep sub-seafloor
targets.
Deep Tow Array Geophysical Systems
The Deep Tow Array Geophysical System
(DTAGS) are also designed to be towed, but
at an altitude of 100 metres at full ocean
depth (6,000 metres). They have sea-bed
penetration of 500 metres.
The DTAGS system operates over an
acoustic band of 260 to 650 Hz with a peak
source level of 201 dB (1 μPa2 @ 1 m)
Air gun design can be
optimized to reduce unwanted
energy
Conventional seismic survey air guns
produce broad-band acoustic energy in
directions (both horizontal and vertical). The
acoustic output has highest energy at
relatively low frequencies of 10–200 Hz, but
air gun arrays can also produce significant
high frequency sound energy, at times
dominating frequencies up to 22 kHz within
a few kilometres of the source.
It is possible to reduce this unnecessary
acoustic energy through array, source, and
receiver design optimization – such as better
system optimization including better pairing
Wild Migration Technical and Policy Review: #3
The complexities of sound in water and air
gun design mean that simple
generalizations about sound transmission
are not appropriate.
Air gun signal descriptors, measurements
and conversions need to be precisely stated.
With this precise information known,
mitigation techniques and risk assessments
should then be developed prior to
commencing surveys.
These risk assessments should include
characteristics of the specific survey to be
used and detailed modelling of probable
noise propagation in the area to be
surveyed.
Page | 13
Wildlife are not
adapted to
anthropogenic
noise
14 | Page
Wild Migration Technical and Policy Review: #3
4
Noise impact
potential
While the ocean is certainly a sound-filled
environment and many natural (or
biological) sounds are very loud, wildlife are
not adapted to anthropogenic noise.
Industry comparisons of anthropogenic
noise to natural sounds is neither defensible
nor relevant.
Wildlife responses to noise fall into three
main categories: behavioral, acoustic and
physiological.
1. Behavioral responses that include
changes in surfacing, diving and heading
patterns. Migrating whales have been
shown to execute significant course and
speed changes to avoid close
encounters with operating seismic
arrays. There are also observations of
whales at the surface approaching an
operating seismic array to within 100
metres, then swimming quickly away by
changing direction.
2. Acoustic responses that include changes
in type or timing of vocalizations relative
to the noise source.
3. Physiological responses or impacts that
include physical damage, hearing
threshold shifts and ‘stress’ in some
mammals, or simply the masking of
natural sounds that the animal would
normal rely on.
Animals exposed to elevated or
prolonged noise levels can suffer
permanent hearing threshold shifts,
temporary hearing threshold shifts
changing their ability to hear, usually at
a particular frequency.
Anthropogenic noise is unexpected and
can also mask important natural sounds,
such as the call of a mate, the sound
Wild Migration Technical and Policy Review: #3
made by prey or the noise made by a
predator.
Other animals may be physically
damaged by the shock wave component
of the sound wave.
As most marine animals rely on sound for
their vital life functions, such as
communication, prey and predator
detection, orientation and for sensing their
surroundings, it is not surprising that
impacts from seismic surveys on marine
species from mammals and fish are also now
well-documented and of growing concern.
Energy from air gun impulses are mostly
concentrated in the lower frequencies,
however there is still substantial energy in
the tens of kiloHertz (kHz), and even energy
up to 150 kHz, which explains why marine
mammals with higher frequency sensitivities
do react to these noises.
Fish, Crustaceans and
Cephalopods
Behavioural responses of fish to seismic
noise is varied and include leaving the area
of the noise, to changes in depth
distribution, spatial changes in schooling
behaviour, as well as startle responses to
short range start up or high level sounds.
Page | 15
In some cases behavioural responses were
observed up to 5 km distance from the
seismic air gun array.
Recent research by Fewtrell and McCauley
(2012) indicate a clear behaviour response
to air gun noise levels. As these increase,
fish respond by moving to the bottom of the
water column and swimming faster in more
tightly cohesive groups. Significant increases
in alarm responses were observed in fish
and squid to air gun noise above 147–151
dB (re 1µPa2 SEL). An increase in the
occurrence of alarm responses was also
observed as noise level increased. Squid in
view of the camera ejected ink at the first air
gun signal (162 dB re 1µPa2.s) and then
moved backwards, away from the air gun.
The behavioural observations in this study
indicate that air gun noise does result in
alterations in fish and squid behaviour. The
types of behaviour observed in response to
noise are similar to those reported in fish by
other researchers including: alarm
responses and changes in schooling
patterns, position in the water column and
swimming speeds. A relationship between
behavioural responses and noise level was
also demonstrated.
Disruption of behaviour during critical
periods such as mating, spawning and
migration could be particularly important.
Anecdotally, fishermen around the world
have recognised a corresponding drop in
fish recruitment in the seasons following a
seismic survey, which could indicate that
damage might have been caused to larval
development or another part of the
breeding lifecycle. However, the significant
absence of studies before, during and after
surveys means that empirical evidence is
hard to demonstrate. The absence of studies
is mostly because industry has been
reluctant to fund or facilitate the studies.
However, the absence of evidence is not
evidence of absence. Seismic survey
proponents cannot empirically demonstrate
that their activities cause no harm.
Studies that have been completed have
found that seismic surveys severely affect
fish distribution, local abundance, and catch
16 | Page
– in one study by about 50 percent (by
mass) for a trawl fishery and by 21 percent
for a longline fishery. These reductions in
catch rates were observed 18 nautical miles
from the seismic shooting area (3 x10
nautical miles), but the most pronounced
reduction occurred within the shooting area,
where trawl catches were reduced by about
70 percent and the longline catches by 45
percent. Abundance and catch rates did not
return to pre survey levels during the 5-day
period after the seismic survey ended while
researchers were still investigating. A
number of other studies have shown a
decrease in larger fish species for a period
after the seismic survey.
A later study has shown a strong likelihood
of damage to the ears of some fish. The
study indicated that regeneration did not
counteract the loss of cells resulting from
intense exposure to sound and that damage
continued to accrue well after exposure.
Such impacts could have significant
implications for the behaviour and fitness of
populations of fish species. Although the
effects of air gun noise on spawning
behaviour of fish have not been quantified
to date, researchers believe that if fish are
exposed to powerful external forces on their
migration paths or spawning grounds, they
may be disturbed or even cease spawning
altogether.
Crustaceans (crabs, lobsters, crayfish,
shrimp, krill and barnacles) are the only
invertebrates besides insects and spiders
that communicate with acoustic signals. An
important study carried out on rock lobster
has brought forward information that sublethal effects have been observed with
respect to feeding and serum biochemistry
weeks to months after exposure. A cellular
change was also noted in the digestive gland
of animals that had been exposed 4 months
earlier, which may be linked to organ
'stress'. While these studies are not
conclusive, they do indicate a need for
caution. The effects on snow crab from close
exposure (in a controlled experiment)
included effects on developing fertilized
eggs, bruising of the heptopancreas and
Wild Migration Technical and Policy Review: #3
ovaries, delayed embryo development,
smaller larvae.
de Soto et al (2013) has also researched
mollusc larvae (in this case scallop) exposed
to playbacks of seismic pulses. They showed
significant developmental delays in the
animals and 46 percent developed body
abnormalities. Similar effects were observed
in all independent samples exposed to noise
while no malformations were found in the
control groups. 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 shellfish.
Similar studies have produced similar results
for cephalopods (octopuses, squid, cuttlefish
and Nautiloidea) in a number of parts of the
world.
Pinnipeds
Pinnipeds (seals, sea lions, walrus) are a
group of species that live part of their lives
in both air and in water. As such, their
hearing is adapted to both and they are
likely to be susceptible to the harmful
effects of loud noise in both media.
The range of greatest hearing sensitivity in
California sea lions has been demonstrated
to be between 1 and 28kHz, with their best
sensitivity at 16 kHz. Similar audiograms
have been demonstrated for harbour seals
and harp seals.
Behavioural responses to anthropogenic
sound have been recorded in a number of
different pinnipeds populations and the long
distance at which behaviour changes have
been observed indicate the need for
precautionary mitigation.
Behavioral responses have included seals
‘hauling-out’ (possibly to avoid the noise)
and removing themselves from feeding
activities. Animals that remained in the
water seemed to have returned to pre-trial
behaviour within two hours of the noise
ceasing.
The physiological impacts of loud low
frequency sounds can include cochlear
lesions and temporary threshold shift. In
Wild Migration Technical and Policy Review: #3
most respects, noise-induced threshold
shifts in pinnipeds follow trends similar to
those observed in other mammals. Unique
to pinnipeds are their vibrissae, which are
well supplied with nerves, blood vessels and
muscles. They have been shown (for
example, in harbour seals, Phoca vitulina) to
be sufficiently sensitive to low frequency
waterborne vibrations that they may
function to detect even the subtle
movements of fish and other aquatic
organisms.
Impact from anthropogenic sound may also
extend to prey. If prey species are affected,
for example fish schools driven away or
diverted by a seismic survey, then there may
be consequences for species which rely
upon them as prey. If there are
disturbances in pinniped feeding
environments that result in reduced food
availability, animals may show signs of
reduced condition and may have difficulty
feeding their pups, which could result in
reduced reproductive success through
higher levels of neonatal mortality.
It is also known that disturbances in marine
and terrestrial environments can cause
pinnipeds to abandon colonies entirely,
which could have serious implications,
especially for species that are already
endangered.
Sirenians
Similarly, sirenians (dugong and manatee)
may be displaced from key feeding habitats
by exposure to noise. While the bulk of
research has focused on boating traffic, their
behavioural response to the noise of passing
vessels substantiates that these animals are
sensitive to noise and should be considered
carefully in any environmental impact
assessments that are conducted.
Cetaceans
Cetaceans (whales, dolphins and porpoises)
are perhaps the most studied group of
marine species when considering the impact
of anthropogenic noise.
Page | 17
Baleen whales use low frequency signals for
communication, hearing, predator
avoidance and localising mates. Whales
have demonstrated very clear acoustic
responses when they change their calling
behaviour around noise from seismic
activity. Most cetacean species studies have
demonstrated avoidance behavioural
responses, with some documented as
responding to sound at 140dB (re 1µPa2s).
Di Iorio & Clark (2010) have concluded that
reducing an individual’s ability to detect
socially relevant signals could affect
biologically important processes.
There are cases of animals hovering at the
surface, perhaps to move into the zone of
least impact (10 metres at the sea surface),
increasing their respiration rates and in a
few instances males showing aggressive
behaviour to the vessels.
There are other cases of animals fleeing
from seismic vessels with at least one
documented case a dolphin travelling
approximately 600 metres ahead of a
seismic survey vessel, presumably in
distress. The animal’s balance became
unstable and as exhaustion progressed the
dolphin rolled over onto one side before
sinking virtually motionless close to the air
gun array, presumably dead.
Researchers have found animals experience
other physiological impacts, including
temporary threshold shifts to their hearing.
Gedamke et al (2011) has suggested that
there is a reasonable likelihood that baleen
whales could potentially be susceptible to
temporary threshold shift at a kilometre or
more from seismic surveys.
In some research studies, dolphins and
porpoises have shown the most significant
avoidance behavior (rather than baleen
whales), suggesting that different taxonomic
groups of cetaceans may adopt different
strategies for responding to acoustic
disturbance from seismic surveys. However,
researchers also caution that short-term
proxies such as avoidance behavior should
not be considered sufficiently robust to
assess the extent and biological significance
of long-term individual and population-level
18 | Page
impacts and that there are serious concerns
about populations threats from reduced
prey availability, physical trauma,
communication distress and stress. They
further caution that there may have been
serious underestimations of noise-induced
strandings or mortalities in the past, as
many impacts will take place below the seasurface.
Recent studies on the energetic demands of
blue whale lunging and foraging have found
that the energetic cost of a single lunge
ranges from 3226 to 8071kj. Large baleen
whales need to feed in areas with high
concentration of krill, and the proximity of
whales to seismic vessels must be
interpreted in the context of their pressing
need to consume tonnes of food per day. It
might be that whales continue to feed in an
area where they experience acoustic
discomfort similarly to meet their dietary
demands.
Habitat displacement is also likely to be a
significant factor for all cetacean species.
Researchers have extrapolated a strong
likelihood that whales at a kilometre or
more from seismic surveys could be
susceptible to acoustic trauma and
temporary threshold shift to the extent that
it could compromise the individual and
possibly the population. Given the emergent
information about elevated stress hormones
a precautionary position is warranted.
Sea turtles
Studies of the hearing capabilities of sea
turtles show that they hear low frequency
sounds within the range of 100 to 1000 Hz
with greatest sensitivity at 200 to 400 Hz for
adult sea turtles, and 600 and 700 Hz for
juveniles.
In 1990 O’Hara & Wilcox assessed the
feasibility of using seismic air guns
discharged underwater to prevent
loggerhead turtles from entering a water
intake canal and found that the turtles
would not breach a 30 metre perimeter
around the source of the noise. However the
method was abandoned due to the sound
output (200dB) and its impact to other
Wild Migration Technical and Policy Review: #3
species. What was not established is what
depth the turtles approaching the sound
were travelling because it might be that
their behavioural impact zone would be
different in deeper water. When these
experiments were extended, researchers
found that although loggerhead turtles
initially avoided the region where the noise
source was located, with repeated exposure
the avoidance response waned. They were
unsure if the decrease in the behavioural
avoidance response was because of
habituation or hearing impairment caused
by repeated exposure to high intensity
sounds.
Elsewhere, trials were also conducted with
caged sea turtles and an approachingdeparting single air gun to gauge
behavioural responses. They showed that
above an air gun level of 166dB (re 1 μPa2
rms) the turtles noticeably increased their
swimming activity compared to non air gun
operation periods and above 175dB (re 1
μPa2 rms) their behaviour became more
erratic possibly indicating the turtles were in
in distress. The researchers hypothesised
that the point at which the turtles showed
the more erratic behaviour would be
expected to approximately equal the point
at which avoidance would occur for
unrestrained turtles.
Polar bears and seabirds
Polar bears and the many seabirds around
the world have yet to be specifically
considered in terms of their reactions to
noise pollution in their environment.
However, this does not reduce their risk nor
the potential for impact as, at a minimum,
their prey may be seriously impacted.
Most marine species have finely tuned
energy budgets. They may not have the
resilience in energy stores to arrive at a
location where food has been previously
abundant and to find their prey gone.
Therefore, the ‘downstream impact’ to
these species should also be considered in
Environmental Impact Assessments.
Wild Migration Technical and Policy Review: #3
The importance of considering
stress
In 2012 Rolland et al released an important
report highlighting the need to consider the
impact prolonged noise exposure may have
on marine species and in particular for their
study on whales. This is especially pertinent
for resident species dependant on certain
habitats, such as beluga, seals or sea lions.
Acoustic studies have long shown that right
whales alter their vocalization behaviour in
noisy habitats by increasing both the
amplitude and frequency of their
stereotyped ‘upcalls’ (the main contact
sounds used by these whales). It is not
material to the point of the research if the
noise is as a result of seismic surveys or
heavy shipping traffic. The point of this
finding is that the habitat was ‘noisy’.
A comparison of three right whale habitats
along the east coast of the USA and Canada
found that the Bay of Fundy had the highest
levels of background low frequency noise
associated with heavy shipping traffic, and
that the frequencies of right whale ‘upcalls’
were significantly higher in this habitat.
Right whales congregate during late summer
in the Bay of Fundy, Canada, to feed and
nurse their calves and since 1980 the New
England Aquarium (Boston, MA, USA) had
been conducting annual population surveys
in this critical right whale habitat.
All shipping traffic around North America
was suddenly halted in the immediate
aftermath of the 9/11 attacks. The
researchers noted the marked decrease
noise produced by ship traffic in the Bay of
Fundy – specifically a noticeable decrease in
low-frequency background noise. A study of
stress-related faecal hormone metabolites
was also underway throughout the 2001
field season and over the four subsequent
years.
When the acoustic recordings and ship
traffic data was analyzed alongside the
faecal glucocorticoid (fGC) they revealed
measures of physiological stress in the
whales before and after 9/11. Researchers
saw a significant decrease in stress-related
Page | 19
fGC hormone levels in right whales
corresponding with the post-9/11 decrease
in background underwater noise.
The production of stress hormones is a key
physiological step in balancing the
expenditure of energy of all vertebrates. It
involves an endocrine system response that
releases corticosteroids. These hormones
facilitate the ability of an individual to
survive exposure to a threat. While this
response is effective in the presence of
short-term stressors, chronic levels of stress
can result in various pathological
dysfunctions, including an increase in blood
glucose, or the inhibition of reproduction,
immune function, or growth. If this
continues for a long time (chronic stress), it
can cause damage to an individual's physical
and mental health.
If this is so, then an animal’s ‘flight’ response
to an unanticipated acute threat (such as
anthropogenic noise) could mean they act to
flee the threats instead of managing their
N2, resulting in decompression injury.
The release of corticosteroids in humans is
known to lead to structural changes in
brains, ultimately producing impairments in
working memory and spatial memory, as
well as increased aggression.
Unexpected consequences for
deep diving mammals
New science is now revealing that the
effects of water pressure may cause a range
of challenges related to the management of
nitrogen gas (N2) for deep diving mammals.
Under pressure, lung gases in diving
mammals move to the blood and other
tissues of the body.
As water pressure increases with depth, the
amount of N2 that is absorbed by the blood
and tissues also increases.
Researchers have recently determined that
under most natural conditions, deep diving
mammals appear to dive without bubbleinduced decompression injury (and the
precursors to this injury from
supersaturation and bubble presence). It
may be that they have developed
physiological adaptations to mitigate N2
loading during dives and that these are
being consciously managed by the animals
themselves, on a dive-by-dive basis.
20 | Page
This section has sought to provide a very
brief summary of the now substantive
weight of impact literature available.
Environmental Impact Assessments should
consider all species that might be present
during an offshore seismic survey as well as
the exposure level and exposure duration
they might experience.
A solid case should be developed for how
impact to these species will be mitigated
when seeking regulatory approval.
Wild Migration Technical and Policy Review: #3
5
International
commitments
flow to
proponents
Detailed international political discussion is
now taking place about the world-wide
regulation of anthropogenic noise in the
marine environment.
Concerns over impacts of seismic surveys in
particular have been expressed by
Governments through 12 separate
international instruments including: the
United Nations General Assembly, the
Convention of Migratory Species (CMS) and
at least 12 CMS species agreements; the
Convention on Biological Diversity (CBD);
the International Maritime Organization; the
International Union for Conservation of
Nature; and a number of region or issue
specific instruments.
CBD Decision XI/18 (2012) has encouraged
Governments to:
“minimize the significant adverse
impacts of anthropogenic underwater
noise on marine biodiversity, including
the full range of best available
technologies and best environmental
practices where appropriate and
needed” and to “develop indicators and
explore frameworks for monitoring
underwater noise for the conservation
and sustainable use of marine
biodiversity, and report on progress to a
meeting of the Subsidiary Body prior to
the twelfth meeting of the Conference of
the Parties” likely to be held in 2015.
Similarly, through CMS Resolution 10.24
(2011) Governments:
“Reaffirmed that there is a need for
ongoing and further internationally
coordinated research on the impact of
underwater noise ... on cetaceans and
Wild Migration Technical and Policy Review: #3
other migratory species and their
migratory routes and ecological
coherence in order to give adequate
protection to cetaceans and other
marine migratory species;
Strongly urge Parties to prevent adverse
effects on cetaceans and on other
migratory marine species by restricting
the emission of underwater noise ... and
where noise cannot be avoided, urges
Parties to develop an appropriate
regulatory framework or implement
relevant measures to ensure a reduction
or mitigation of man-made underwater
noise;
Urge Parties to ensure that
Environmental Impact Assessments take
full account of the effects of activities on
cetaceans and to consider potential
impacts on marine biota and their
migration routes and consider a more
holistic ecological approach already at a
strategic planning stage;
Recommend that Parties apply Best
Available Techniques (BAT) and Best
Environmental Practice (BEP) including,
where appropriate, clean technology, in
their efforts to reduce or mitigate
marine noise pollution;
Encourage Parties to integrate the issue
of anthropogenic noise into the
management plans of marine protected
areas (MPAs) where appropriate, in
accordance with international law,
including [United National Convention
on the Law of the Sea].”
The commitments have been adopted by
193 Governments (as CBD Parties) and 119
Governments (as CMS Parties) respectively.
These international commitments have
been made by Governments and should be
adopted into national policies and law.
Therefore implementing these
commitments becomes the responsibility of
offshore petroleum exploration proponents
to reflect in their Environment Impact
Assessments and project proposals.
Page | 21
semper necessitas
probandi incumbit ei
qui agit: the necessity
for proof lies with the
claim
22 | Page
Wild Migration Technical and Policy Review: #3
6
Natural Justice:
Consultation,
transparency and
commercial
sensitivity
Natural Justice
Natural justice is both a legal and common
concept with two parts: it removes bias to
maintain public confidence in a legal or
policy system and enshrines a right to a fair
hearing so that individuals are not unfairly
impacted (penalized) by decisions that affect
their rights or legitimate expectations.
In the case of decisions for activities in the
marine environment, confidence that there
is no hidden bias can be developed by
ensuring there is full transparency and that
all stakeholders are given reasonable notice
of the plans, a fair opportunity to present
their own concerns and that these concerns
will factor in the final decision that is made.
Stakeholders with a rightful interest in the
marine environment include marine users
such as traditional communities with
cultural or spiritual connections, fishermen
(commercial and recreational), shipping and
boating, tourism operators and scientists, as
well as conservation organisations who are
advocating for the conservation of marine
wildlife or marine ecosystems.
Transparency and commercial
sensitivity
Of course the extent of transparency should
complement the goals of natural justice and
consultation, but does not need to provide
information that is truthfully commercially
or personally sensitive. However, far too
often commercial sensitivity is a veil that
industry proponents hide behind.
Wild Migration Technical and Policy Review: #3
The technical details of offshore petroleum
exploration proposals should all be fully and
transparently available for comment before
plans are submitted for approval to
regulators. This includes:
descriptions of the direct and
surrounding area of the survey;
equipment to be used; modelling of the
survey sound intensity levels and sound
dispersal; timeframes; track-lines; speed
of vessels; cumulative impacts of other
activities; species in the region; baseline
data that has been gathered; and
scientific monitoring programmes
conducted during and after the seismic
survey.
This information is not commercially
sensitive and proponents should not seek to
hide it from view.
Consultation
True consultation has two key components the burden of proof and participation in the
outcome of a decision.
Burden of proof is often associated with the
Latin maxim semper necessitas probandi
incumbit ei qui agit, which when translated
means "the necessity for proof always lies
with the person who makes the claim." In
the case of offshore petroleum exploration
proponents, it is their claim that the
activities they propose to undertake – in a
shared marine environment – will cause no
harm. Stakeholders do not carry the burden
of proof but instead carry the benefit of
assumption, meaning they need no
evidence to support their position. It is up to
the proponent to provide the assurance.
The current situation in far too many
jurisdictions around the world is that
industry has shifted the burden of proof to
stakeholders. It should be the other way
around.
Transparency is necessary for well-informed
consultation. Participation should facilitate
individuals and groups to influence
decisions, increasing trust about the
outcome of environmental decision making.
Page | 23
24 | Page
Environmental Impact
Assessments should be
mandatory in all
jurisdictions
Wild Migration Technical and Policy Review: #3
7
Environmental
Impact
Assessments:
Offshore
Petroleum
Exploration
A Model Environmental Impact
Assessment and consultation
process
Stage one: Developing a thorough
Environmental Impact Assessment
In addition to jurisdictional specific
requirements for impact mitigation, such as
observers or passive acoustic monitoring,
Environmental Impact Assessments for
offshore petroleum exploration proposals
should be developed early in the proposal’s
development process and should
transparently include:
1) Description of area
a) Detailed description of the direct
area of the survey – including
seabed composition, description of
know stratification characteristics
and broad ecosystem descriptions –
as well as neighbouring areas which
will experience sound transmission
above 100dB (re 1 µPa2 ) generated
by the proposed survey
b) Identification of previous surveys,
their seasons and duration in the
same or adjoining areas
c) Identification of previous test wells
in the same or adjoining areas,
including comment about any which
are, or may, breach
The weight of evidence is now sufficiently
strong that full, detailed and transparent
Environmental Impact Assessment should
be mandatory for all offshore petroleum
exploration proposals in all jurisdictions.
Wild Migration Technical and Policy Review: #3
2) Description of the equipment to be
used
a) Explanation of all survey
technologies available and why the
proposed technology is chosen
b) Detailed description of the survey
technology to be used
c) Name and description of the survey
vessel
d) If an air gun array is proposed:
i) Number of arrays
ii) Number of air guns within each
array
iii) Air gun charge pressure to be
used (PSI)
Page | 25
iv) Volume of each air gun in cubic
inches
v) Official calibration figures
supplied by the survey vessel to
be charted
vi) Modelled sound intensity level
one metre from source derived
from the official calibration
figures
vii) Depth the air guns to be set
viii) Number of streamers
ix) Length of streamers
x) Distant set apart
xi) Depth the hydrophones are set
3) Description of activity
a) Full description of the total area of
the acreage to be explored and the
entire exploration plan (2D, 3D and
test wells) and for each activity:
i) Specifics of the activity including
anticipated nautical miles to be
covered, track-lines, speed of
vessels, duration of track-lines,
start up and shut down
procedures, swinging distance
and procedures including any
planned air gun power setting
changes.
ii) Computer modelling of sound
dispersal in the same
season/weather conditions as
the proposed survey. Local
propagation features (spherical
and cylindrical spreading, depth
and type of sea bottom, local
propagation paths related to
thermal stratification), and out
to a radius of a thousand
nautical miles
iii) Identification of any SOFAR or
natural channels characteristics
iv) Identification of proposed
species exclusion zones and
description of how noise
propagation into these zones
will be minimised, taking into
consideration the local
propagation features (spherical
and cylindrical spreading, depth
and type of sea bottom, local
26 | Page
propagation paths related to
thermal stratification).
v) Sound intensity level and
frequencies (Hz) from a point
source, as well as the duration
of each pulse (milliseconds),
interval between pulses
(seconds) and expected
duration of pulses (12/24 hour
days) for the survey
b) Identification of other impacting
activities in the region during the
planned survey, and what the
cumulative impact might be
4) Species likely to be encountered or
impacted
a) Description of all listed/protected
species likely to be present and that
will experience sound transmission
above 100dB (re 1 µPa2) generated
by the proposed survey, the total
time they will experience sound
above 100dB (re 1 µPa2) and
proposed measures being taken for
each to minimise impact.
b) Details of likely impact for each
species, including:
i) Identification of safe / harmful
exposure levels for various
species, age classes and
contexts that is precautionary
enough to handle large levels of
uncertainty. (Extrapolations
from other species, measures of
uncertainty should quantify the
chances of coming up with a
wrong, and dangerous
conclusion)
ii) Type of impact predicted (direct,
behavioural and the duration) as
well as impacts to prey species
iii) Soft start and shut-down
protocols
iv) Plans for 24 hour visual
detection, especially under
conditions of poor visibility
(including high winds, night
conditions, sea spray or fog)
v) Plans for establishing exclusion
zones (EZ). These should be
established on a scientific and
Wild Migration Technical and Policy Review: #3
c)
d)
e)
f)
g)
precautionary basis rather than
as arbitrary and/or static
designations. These EZ should
be verified in the field
Description of all fisheries likely to
be present or to rely on prey that
might be present and that will
experience sound transmission
above 100dB (re 1 µPa2) generated
by the proposed survey and
proposed measures being taken for
each to minimise impact
Details of independent and
transparent monitoring of all at-sea
activities and observer coverage
Details of transparent processes for
regular real-time public reporting of
activity progress and all impacts
encountered
Details of baseline data that has
been gathered before developing
the Environmental Impact
Assessment
Details of scientific monitoring
programmes, conducted during and
after the seismic survey, to assess
impact
5) Reporting plans
a) Details of plans for post operation
reporting including verification of
the effectiveness of mitigation
Stage two: Stakeholder consultation
The stakeholder consultation process
should embrace the principles of natural
justice, burden of proof, participation and
transparency.
6) Details of consultation and
independent review
a) Identification of stakeholders who
have been consulted
b) Identification of independent
experts – especially species experts
– that have been consulted
including their affiliation and their
qualifications
c) Explanation of information provided
to stakeholders and experts, any
opportunities given for appropriate
Wild Migration Technical and Policy Review: #3
engagement and the timeframe
given for them to provide feedback
d) Description of the comments,
queries, requests and concerns
received from each of the
stakeholders and experts
e) Explanation of what amendments
and changes have been made to the
proposed survey to the comments,
queries, requests and concerns
f) Explanation of which comments,
queries, requests and concerns have
not been accommodated and why
g) Details of plans for regular real-time
public reporting of during and after
the activity including all impacts
encountered.
7) Proposal amendment and submission
a) Amendment of the proposal plans
and corresponding Environmental
Impact Assessment/s, including the
inputs of the stakeholder
consultation process and how
concerns have been accommodated
Stage three: Ongoing stakeholder
engagement
The ongoing stakeholder engagement
process should seek to build on the
stakeholder consultation process building
ongoing trust and ensuring stakeholder
confidence.
8) Post operation reporting
b) Engagement with post operation
reporting including verification of
the effectiveness of mitigation
We urge regulators and policy makers to
consider requiring this level of transparency
and technical detail in Environmental
Impact Assessments and consultation
processes.
We urge the offshore petroleum exploration
industry to shift from a stance of secrecy
and disrespect for public concern to an
industry that has nothing to hide and can
confidently engage in real consultation with
others who share the sea.
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28 | Page
Wild Migration Technical and Policy Review: #3
B
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Wild Migration Technical and Policy Review: #3
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