By David Wojick
The Ocean Energy Administration and NOAA Fisheries Agency have both issued a number of “arguments from ignorance” claiming that offshore wind developments have nothing to do with recent whale deaths. . “We don’t know anything about it so it can’t happen” is a ludicrous defense against the allegation that offshore wind development has caused the deaths of so many whales. But this is exactly what the Fed is saying right now.
NOAA Fisheries is a scientific body and their version of the more scientific family, which is important because this is really a matter of science. Let’s see their argument. They have a pretty long FAQ page about wind and whales here: https://www.fisheries.noaa.gov/new-england-mid-atlantic/marine-life-distress/frequent-questions-offshore-wind-and-whales
Here is their core argument: “At this time, there is no evidence to support the assumption that noise generated by site characterization surveys associated with wind development is likely to cause whale death. There is no specific link between recent great whale mortality and ongoing investigations into offshore wind development.”
These two sentences present different aspects of the argument. Let’s take the second sentence first.
The concept of “specific link” is quite vague. It has a narrow meaning that BOEM has asserted, namely detonating sonar that kills whales on the spot. There’s really no evidence that this ever happened. This is not like the wind on land, where you can count the dead eagles on the ground around the tower.
Instead, the causes of death may be indirect, and death may occur relatively far away in space and time. These causes range from trauma, such as bleeding and deafness, to running or avoiding or other behavioral changes.
But ask this question about possible injury: “How many whales have been examined for injuries after being detonated by sonar?” The answer is no, because there is no way to check if wild whales are bleeding or deaf. Therefore, the fact that we are not aware of any injuries does not mean that there are no such injuries. Injuries can actually be common.
However, there are some very specific associations between mortality and sonar survey explosions in the broader sense. First of all, the mortality rate of humpback whales on the East Coast has nearly tripled since the beginning of 2016, which is when offshore wind surveys really started. I discuss this in my post here: https://www.cfact.org/2023/01/23/evidence-says-offshore-wind-development-is-killing-lots-of-whales/.
The recent humpback deaths appear to be part of this long-term trend. The NOAA FAQ suggests that this 2016 spike in mortality may be due to a sharp increase in the number of hunchbacks. This conjecture is falsified by the fact that the critically endangered North Atlantic Whale (NARW) extinction also began in 2016.
With no other obvious cause, ongoing sonar blast surveys could be a link between the development of offshore winds and rising whale mortality. So sentence two is wrong. There is a likely link.
Sentence one states that there is no evidence that survey noise is potentially fatal. It is interesting that this statement is falsified by the work of NOAA itself. Since 2016, they have issued more than 40 noise survey permits to harass large numbers of whales. One authorization I reviewed authorized the harassment of more than 100 right whales, whose total population is estimated to be around 340.
Harassment is defined as having the potential to cause changes in behavior that are potentially fatal. Therefore, NOAA Fisheries Agency has clearly certified the possibility that survey noise can be fatal.
I first pointed out a simple case last year in an article titled “How to Kill Whales with Offshore Wind”. See https://www.cfact.org/2022/09/27/how-to-kill-whales-with-offshore-wind/ (which I sent to a lot of people at NOAH Fishing).
The article is about operational noise but site survey noise is just as bad, probably much worse. The described wind site is in a low-traffic area, most likely with heavy coastal traffic passing nearby. To avoid the terrible noise, the migrating whales are forced to circle the site, which exposes them to heavy traffic.
The possibility of an increase in the number of deaths is obvious, making sentence one seriously wrong.
In fact, there seems to be a big hole in the science being made at NOAH Fishery. On the one hand, they do a lot of underwater sound, which is noise, to make these Harassment Licenses.
As I understand it, they first estimate the size and location of the area where the noise level will be above the safe level. They then used a density model to estimate the number of organisms that would be adversely affected and the number of validations to be derived from. In effect, this is a forecast of potential, forced behavioral changes.
On the other hand, they also do a lot of so-called “population dynamics”. This means looking at what is needed to maintain or grow a given population, be it whales, other marine mammals, different monitored fish species or even even sea turtles.
For example, they recently lowered the allowable homicide rate for NARW from 0.9 homicides per year to 0.7, reflecting a declining population. This means we can safely cause the deaths of no more than 7 whales every 10 years. Killing 2 whales every 3 years also meets this standard as the average is 0.67 whales a year. NOAA estimates we are currently killing more than 2 NARW per year.
What the NOAA Fisheries Agency is unlikely to do is consider the potential adverse impact of authorized wind site harassment on monitored populations, particularly whales. Instead, they now seem to claim that there is no such potential effect, which is clearly false.
It is precisely this type of adverse population impact that needs to be assessed before any further Harassment Permits are issued by NOAH Fishery.
What behavioral changes due to harassment are expected? How can they lead to death, such as from injury, infection, ship collision or fishing gear entanglement, etc.? In some cases, especially the declining population in NARW, adverse effects on fertility may also be important.
The basic science question is simple: “What is the suggested potential mortality rate from authorized harassment?” Permission to harass whales and other protected animals should be suspended until this question is answered.
Author
David Wojick
David Wojick, Ph.D. is an independent analyst working at the intersection of science, technology and policy. For the origin see http://www.stemed.info/engineer_tackles_confusion.html For more than 100 previous articles for CFACT see http://www.cfact.org/author/david-wojick-ph-d/ Available for confidential research and consultation.
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