WDCS believes that all stages of the development of these projects could directly, or indirectly, harm marine mammals including the entrainment [extracted during water intake] of plankton (the sole prey resource of critically endangered North Atlantic right whales), the risk of ship strikes from the tankers and support vessels, and acoustic disturbances during construction and the subsequent operation of each plant. According to WDCS Senior Biologist, Regina Asmutis-Silvia, "WDCS does not believe that the plans will adequately mitigate against long, medium or short term impacts on right whales as a result of habitat degradation, food resource compromise, entanglement, vessel strikes or displacement from the area in, and around, the proposed sites. Industrializing the ocean could be the proverbial last straw for right whales."
With specific regard to ship strikes, already the greatest existing threat to right whales, WDCS believes the mitigation measures to be introduced are totally inadequate. "While the proposed real-time acoustic buoy array that would listen for right whales and alert the LNG vessels has the potential to be helpful" said Asmutis-Silvia "it is important to remember that marine mammals do not vocalize at all times. Absence of vocalizations should not be mistaken for absence of animals in the development area."
WDCS also questions the proposed mitigation package put forward by the each company to support their respective developments. According to a December 2, 2006 Boston Globe article, a $23.5 million dollar mitigation package was agreed upon by Excellerate, one of the two approved projects. While the package included funding for sea floor mapping, biological research and acoustic monitoring devices to listen for whales, it also included funding to improve transportation to the Boston Harbor islands and money to maintain and construct boat ramps. Not only are some of the funding allocations questionable but there is a significant discrepancy between the amounts specified for each project. For example, $5.3 million was earmarked for improving transportation to the Boston Harbor islands yet only $3.25 million was allotted for an acoustic buoy system to track marine mammals and alert tankers. Furthermore $650,000 will go to the Massachusetts Fish and Game office for public access boat ramp maintenance or construction but only $600,000 is designated to New England Aquarium for biological research within the exclusion zone.
"WDCS does not question the validity of some of these allocations" said Michael Waterson, WDCS Treasurer "but upon closer inspection, some seem suspect. It is unclear why only $3.5 million is earmarked for marine mammal ship-strike risk mitigation, yet more than $5million will go to improving transportation to parks in Boston Harbor? How that can be considered a mitigation measure for this industrial development is questionable. Furthermore, only $600,000 is dedicated to study impacts from the project in the exclusion zone, and that's over the entire 25 years life span of the development, which is inexcusable " a mere $24,000 per annum at current prices. Contrast that to the economic benefits that will accrue elsewhere and the fact that funding for federal regulatory bodies is being slashed meaning their ability to police these developments is being compromised" .
The other issue that WDCS believes has not been adequately addressed is the increased pressure development of these sites will cause for all other users of the sea in these areas. Homeland Security restrictions will create closed exclusion zones, which have to be policed at some cost, and therefore the fishing, whale watch and recreational boating activities that have previously taken place will be displaced to elsewhere on the water. This means further pressure will become concentrated as a 4 sq. mile exclusion zone will be enforced around each ship. In the mitigation measures there is no allowance for monitoring the impact this will have on the summer resident whale population. As we know from research elsewhere, if pressure on whale populations grow to such a point, that population will change its behavior and become less accessible. Each year over 1 million people visit this part of New England and go whale watch " a small drop in this figure will have a major impact on the leisure industry and all the associated support services. Further issues with the proposals include the lack of sufficient measures detailing how the respective applicants intend to ensure any of the proposed mitigation measures are adhered to, and more importantly, the penalties that will be applied if they are not. It is a documented fact that voluntary compliance is typically low where the proposed mitigation measures are already utilized. And then what happens at the end of the 25 year period to the equipment that will be redundant?
"We don't disagree that the energy crisis is real" said Sue Fisher, WDCS-NA Policy Director "but we do think that States and Federal Agencies should be supporting programs to reduce energy consumption and not continue to industrialize the oceans and pollute the environment."
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