Page 6 - IAGC July Newsletter

IAGC Newsletter
IAGC to Submit Comments, Express
Concerns with NOAA’s Proposed IHAs
n 6 June 2017, the National Oceanic and Summary of issues:
Atmospheric Administration (NOAA) requested • Small dolphin exemption should apply to all dolphin
Ocomments on its proposal to issue Incidental species regardless of dolphin behavior.
Harassment Authorizations (IHAs) to incidentally take • NMFS proposes to require shutdowns for certain
marine mammals during G&G activities, pursuant to the types of marine mammal observations “at any
Marine Mammal Protection Act (MMPA) in the Atlantic distance”. This requirement is arbitrary and unrea-
Outer Continental Shelf (OCS). Nearly 700 days after the sonable because it is unlimited (“at any distance”)
first applications for IHAs were submitted to NOAA’s and therefore contemplates shutdowns for circum-
National Marine Fisheries Service (NMFS), our members stances in which no Level A or Level B harassment
finally have the opportunity to comment on the proposed will occur.
authorizations. • Maintaining 2 PSOs on-duty at all times requires
The IAGC’s comments will express concerns with each source vessel to accommodate 4-5 PSOs at all
the impracticability of some of the proposed mitigation times.
measures and with NMFS’s substantial overestimation of • IAGC believes using Passive Acoustic Monitoring
the number of incidental takes that may occur as result (PAM) should be optional.
of the surveys. The best available scientific data and
information demonstrate that mitigation programs can For over 40 years, the federal government and aca-
and do effectively minimize and avoid the incidental take demic scientists have studied the potential impacts of
of marine mammals associated with offshore geophysical G&G activities on marine mammal populations and have
survey operations. NMFS has proposed some mitigation concluded that any such potential impacts are insignifi-
measures that are not practicable. These measures will cant. This conclusion has been publicly reaffirmed on
likely result in increased survey duration, which, in turn, multiple occasions by the Bureau of Ocean and Land
can increase the potential exposure of marine mammals to Management (BOEM).
potential seismic-related effects because shutdowns and The extensive record of information regarding the
delays necessarily result in overall increased surveying time insignificant effects of OCS seismic surveying demon-
to preserve data quality and integrity. strates that the Proposed IHAs will have no more than a
The comment period ends 21 July. temporary, localized, and negligible impact on marine
mammals and marine mammal species or stocks. The
proposed seismic surveys are critical to the safe and
orderly development of the oil and gas resources of the
Atlantic OCS, and can be accomplished with insignificant
environmental impacts. The IAGC therefore strongly
supports NMFS’s authorization of IHAs to address any in-
cidental harassment of marine mammals that may result
from the proposed Atlantic OCS surveys.
The IAGC will continue to work to ensure members
have the oppor tunity to survey in new markets around
66 the world including the Atlantic OCS.
IAGC Newsletter
IAGC Comments on Metal
Export Regulations
Effecting Industry
The IAGC, along with other trade
associations, submitted the Oil & Natural
Gas Industry comments on Section 232
National Security Investigation of Imports
of Aluminum (23 June 2017) and Steel
(31 May 2017) to the U.S. Department of
Commerce.
he Secretary of Commerce initiated an the proper findings of this Section 232 investigation and
investigation into the large volumes of excess avoid broad applications which sweep in all imported
Tcapacity worldwide in an effort to potentially steel and aluminum products from all countries.
limit or tax the imports of steel and aluminum. Limiting steel and aluminum imports into the U.S. will
In summary, the Associations urge the Department have a dramatic effect on the Oil & Gas industry as we use
of Commerce to use the following criteria to determine and consume large amounts of both products throughout
the appropriate policy recommendations to address the the lifecycle of exploration through the final product.
findings of this Section 232 investigation of steel and Prices of both commodities will increase with these
aluminum imports: potential regulations causing each phase of the oil lifecycle
1. When determining harm to national security, to become more expensive and reducing the ability of the
employ a narrow definition of “national security” U.S. Oil & Gas industry to compete on a global scale.
that conforms with 15 CFR § 705.4 and that does not We will continue to monitor the policy developments
include steel and aluminum supply to the U.S. oil and of Section 232 for steel and aluminum imports. Read full
natural gas industry. comments for Aluminum and Steel.
2. Consider the extent of existing trade remedies already
in place to address the unfair steel and aluminum trade
practices of U.S. trade partners and only put forward IAGC Committees to Consult
new actions that are targeted precisely and narrowly
to any previously unaddressed underlying causes of on OGA Regulations
distortions in the global market for steel and aluminum.
3. Consider the ways in which new U.S. tariffs, quotas or Over the past 4 years, the IAGC EAME Committee has led
other measures could have a potential negative effect IAGC’s efforts in negotiations with OGA (the United King-
on U.S. energy security beyond their initial and direct dom’s Oil and Gas Authority) on how geophysical data will
effects on steel and aluminum, such as how they may be regulated in the UK’s jurisdiction going forward. As part
increase costs for oil and natural gas industry by being of that process, the OGA is seeking ‘consultation’ on recently
passed through the chain of distribution, and how proposed ‘regulations for the retention and disclosure of
they could potentially affect affordable energy for information and samples’. The IAGC EAME and Global Data
consumers, including the US government. Licensing Committees will be responding to the comment
The Associations believe that any policy deadline on 25 August 2017.
recommendations to address the findings of this Read the UK Oil & Gas UK Regulation Consultation for
Section 232 investigation should be narrowly tailored to Comments, as well as some background materials. 7