Page 14 - IAGC_November 2017_Newsletter_FINAL

IAGC Continues to Fight for the other alternatives presented geophysical surveys in the GOM are
the Most Practical Approach in the PEIS—including BOEM’s likely to jeopardize the continued
in BOEM’s GOM Final EIS Preferred Alternative C—and request existence of ESA-listed species or
BOEM to adopt Alternative A in its result in the adverse modification
On 4 August, the BOEM released Record of Decision. As a much less or destruction of designated critical
the Gulf of Mexico Geological preferable but potentially acceptable habitat. Consultation is often where
and Geophysical (G&G) Activities alternative, we may support NMFS applies mitigation measures
final Programmatic Environmental Alternative C so long as the Record and restrictions on future activity.
Impact Statement (PEIS). The of Decision (ROD) makes all of the
PEIS is developed to evaluate the modifications stated in our letter. Had the IAGC and API been
potential environmental impacts granted applicant status, it would
of G&G activities within federal On 25 August 2017, the IAGC and have provided the associations the
waters of the Gulf of Mexico’s API sent a letter to Secretary Zinke opportunity to review consultation
(GOM) Outer Continental Shelf to express our disappointment with documents, including the biological
(OCS) and adjacent state waters. certain key aspects of the PEIS. opinion. Applicant status would
have enabled the IAGC to represent
BOEM selected Alternative C as The IAGC previously submitted members who will be affected
the preferred alternative. Under detailed comments on BOEM’s by the action and to provide
Alternative C, G&G activities draft PEIS. The final PEIS can be operational and technical input
would continue to be authorized found on BOEM’s website HERE, during the consultation process.
and would include the mitigation and the press release from 8
measures, monitoring, reporting, August can be found HERE. The IAGC, along with API, sent a
survey protocols, and guidance The 4 August IAGC Press letter on 2 October to the National
in place prior to the settlement Release can be found HERE. Marine Fisheries Service (NMFS)
agreement from 2013, as well as reiterating a previous request to
additional mitigation and temporal be granted applicant status to
measures for seismic and HRG IAGC Denied Applicant participate in NMFS’ Endangered
surveys.In addition, mitigation Status for GOM Endangered Species Act (ESA) Consultation
measures for non-seismic HRG Species Act Consultation with the Bureau of Ocean Energy
surveys and a four-month closure for On 10 October, the National Management (BOEM) over future
seismic surveys in state and federal Marine Fisheries Service (NMFS) authorization of geophysical surveys
coastal waters would be included. in the U.S. Gulf of Mexico (GOM).
notified the IAGC and API of its
Many of the measures and controls decision to deny the associations’ 2 October 2017 Letter
of concern to our members were request for applicant status in its Requesting Applicant Status
kept out of the preferred alternative, consultation with the Bureau of NMFS Letter of Denial
including shutdowns for dolphins, Ocean Energy Management (BOEM)
broader closure areas, buffer zones regarding the Endangered Species
between concurrent surveys, lowest Action (ESA) consultation for the Australia
practicable source standard, limits Marine Mammal Protection Act IAGC Responds to Australia
on “duplicative” surveys, and across- (MMPA) incidental take regulations Tax Office Multiclient
the-board reductions to activity. for G&G surveys in the Gulf of Data Tax Regulation
Notwithstanding, we maintain that Mexico Outer Continental Shelf. Reinterpretation
Alternative A is the only alternative The end-product of a formal ESA
that may be consistent with the consultation is NMFS’ completion The IAGC has engaged Ernst &
best available science, operational of a “biological opinion,” which Young and will be retaining outside
feasibility, and applicable law. We will determine whether future counsel to assist with government
continue to strongly object to all involvement and to determine the

14 IACG Newsletter | In Depth