The sur­vey will have a max­i­mum sound pres­sure of 260 deci­bels (dBA). The thresh­old for hu­man pain (au­di­to­ry) is 130 dBA. A jet air­craft 50m away is 140 dBA. Why does the EMA con­sid­er "ramp­ing up" (seis­mic ex­plo­sive sound) with over 20,000 in­di­vid­ual ex­plo­sives, each of 260 dBA at­tached to the four ca­bles un­der the ocean and ig­nit­ed si­mul­ta­ne­ous­ly, to not have a ma­jor im­pact on all life forms? (http://www.sen­g­pielau­dio.com/Table­Of­Sound­Pres­sureLevels.htm)

Petrotrin is mak­ing un­found­ed and de­lib­er­ate­ly mis­lead­ing state­ments, and suc­ces­sive gov­ern­ments ap­pear to have mis­di­rect­ed the En­vi­ron­ment Man­age­ment Au­thor­i­ty (EMA) to side-step an Act of Par­lia­ment. The EMA does not re­quire oil/gas com­pa­nies to as­sess the en­vi­ron­men­tal im­pacts of off­shore seis­mic sur­vey­ing, and this is sim­ply wrong, and must be changed for the pub­lic good.

The En­vi­ron­men­tal Man­age­ment Act is very spe­cif­ic about ac­tiv­i­ties known to be dam­ag­ing to the en­vi­ron­ment, as in the case of ex­plorato­ry seis­mic sur­veys car­ried out by oil/gas com­pa­nies–es­pe­cial­ly where there is mount­ing sci­en­tif­ic da­ta, and in­nu­mer­able sup­port­ing da­ta on the prob­a­ble neg­a­tive im­pact of such ex­plo­sive ac­tiv­i­ty: hence the need for scruti­ny, safe­guards and mit­i­ga­tion that an En­vi­ron­ment Im­pact As­sess­ment (EIA) pro­vides.

The CEO of the EMA is side-step­ping the Cer­tifi­cate of En­vi­ron­ment Clear­ance Rules (CEC Rules), and now, at this late stage, and af­ter 56 seis­mic bomb­ing ap­provals were award­ed with­out en­vi­ron­men­tal scruti­ny–which ar­guably is re­spon­si­ble for the pro­gres­sive de­cline of lo­cal fish­eries–he is now di­rect­ing the EMA to write "guide­lines" for the ap­proval?

These "guide­lines" are out­side of the CEC Rules, and do not in any way con­sid­er the im­pact on the low­er or­gan­isms of the food chain. What about the im­pact and ef­fect on snails and worms, which can­not es­cape the burst­ing ex­plo­sions of the air-guns? And how does this af­fect the larg­er species in the food chain if their food/en­er­gy source is de­stroyed?

Why is the EMA and the Gov­ern­ment not ad­dress­ing this is­sue of high deci­bel seis­mic ex­plo­sions with hard sci­ence?

FFOS has since Ju­ly 2004 sub­mit­ted to the EMA, and to every Gov­ern­ment min­is­ter and Per­ma­nent Sec­re­tary, and to the Board of Di­rec­tors of the In­sti­tute of Ma­rine Af­fairs, IMA and EMA, two tech­ni­cal stud­ies which we ac­quired from the Unit­ed Na­tions Food and Agri­cul­tur­al Or­gan­i­sa­tion, UN­FAO, and in Au­gust 2011 we en­gaged a pro­fes­sion­al to pro­duce a tech­ni­cal work­ing pa­per which con­sists of sum­maries of sev­er­al stud­ies done world­wide on the im­pact of the ma­rine gun ex­plo­sions, which are high deci­bel sounds, but the Min­is­ter of the En­vi­ron­ment is de­lib­er­ate­ly avoid­ing the hard facts, and he is sum­mon­ing a thun­der­cloud of dis­con­tent.

The is­sue of the seis­mic bomb­ing will not go away un­til this avoid­ance strat­e­gy is stopped.Good pub­lic ad­min­is­tra­tion re­quires the EMA to re­quire that Petrotrin and the oth­er oil com­pa­nies pro­vide the fol­low­ing base­line in­for­ma­tion when ap­ply­ing for en­vi­ron­men­tal clear­ance to con­duct off-shore seis­mic ac­tiv­i­ty:

1. What are the com­mer­cial fish­eries in the Gulf? What are their troph­ic de­pen­den­cies (food sources) and life cy­cle de­tails? Are spe­cif­ic pe­ri­ods of the life cy­cle less re­silient to noise im­pact?

2. Where are they lo­cat­ed rel­a­tive to the sur­vey lines and at what time in their life cy­cle?

3. When are the pri­ma­ry/peak pe­ri­ods of mi­gra­tion and spawn­ing for these species?

4. Where are the mi­gra­to­ry paths and how are mi­gra­tion pat­terns af­fect­ed when air gun seis­mic ex­plo­sions are det­o­nat­ed along the mi­gra­to­ry paths?

5. How are spawn­ing pat­terns af­fect­ed by the seis­mic blasts?

6. Pro­vide a 2-D mod­el of sound pres­sure in the Gulf, show­ing the dis­tance de­cay of the sound rel­a­tive to the sen­si­tive ar­eas.

7. Pro­vide a mon­i­tor­ing pro­gramme to cre­ate some da­ta on the im­pact of the sur­veys on the fish­eries while it is on­go­ing.

With this base­line in­for­ma­tion the EMA could pro­tect, as much as pos­si­ble, the in­tegri­ty of our fish stock. They would cur­tail seis­mic sur­veys dur­ing pe­ri­ods of great­est sen­si­tiv­i­ty and en­sure there are cor­ri­dors and sanc­tu­ar­ies that species can use to flee from the sur­veys, so they would not be im­pact­ed.

The for­eign oil and gas com­pa­nies (who claim green cre­den­tials lo­cal­ly) know ful­ly well that they can­not do seis­mic bomb­ing in Nor­way, Cana­da, Ire­land, Aus­tralia, New Zealand and Venezuela with­out an EIA, in­side spawn­ing ar­eas, at spawn­ing times or on mi­gra­to­ry paths. They sim­ply are not al­lowed. This is be­cause Nor­way is for Nor­we­gians, and they will not be bul­lied by reck­less oil com­pa­nies, re­gard­less of how many bil­lions they boast on their stock ex­changes, which they earn at our ex­pense. Why is EOG, BHP Bil­li­ton, Cen­tri­ca, BP and BG know­ing­ly do­ing here what they know they can­not do else­where?

We ask that we are treat­ed no bet­ter and no worse than our broth­ers in the de­vel­oped world: with hu­man­i­ty, with the mea­sure of sci­ence, and ac­cord­ing to the law of our beloved Trinidad and To­ba­go. Any­thing less will reap a thun­der­cloud.

Ter­rence Bed­doe,

Pres­i­dent

FFOS

Gary Aboud

Cor­po­rate Sec­re­tary

FFOS