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Dear JNCC
We are a nuclear safety group in Cumbria who oppose the seismic testing being carried out right now by Shearwater Geoservices commissioned by Nuclear Waste Services/Radioactive Waste Ltd and Copeland Borough Council who have entered the GDF Partnerships of South and Mid Copeland.
Unlike seismic blasting for gas, oil and other developments the seismic blasting underway in the Irish Sea now has not been subject to a Marine Management Organisation public consultation or even a vote by Copeland councillors, as the GDF Partnership advised by the Committee on Radioactive Waste Management applied for an “exemption” from the norms of regulatory control by calling the testing “scientific research.” Mark Kirkbride, the West Cumbria Mining (currently focussed on coal) CEO is also advising the Committee on Radioactive Waste Management on "investigation techniques" for the Geological Disposal of high level nuclear wastes. Despite Geological Disposal being ruled out of coal mining areas the seismic testing is overlapping WCM's offshore licence areas.
Screenshot from August 14th 2022 - Marine Traffic - Shearwater Bly Seismic Blasting Route overlain on West Cumbria Minings Licence Area
West Cumbria Mining licence areas.
Screenshot from Marine Traffic - Shearwater Bly - seismic testing vessel route on August 14th 2022.
In the last few days Porpoise have been seen in Whitehaven harbour near paddleboarders- this has enthralled witnesses but may well be a behavioural avoidance response to the seismic blasting approved by JNCC guidelines.
A witness account in Seascale has noted on Sunday 14th August that “On three separate occasions I have heard the dull thud of that Seismic testing vessel. About three nights ago about 3am I had to take my dog out for a wee and the ship was off Seascale. I could hear a dull thud every few seconds. Yesterday the same at about 16.00, every 4-5 seconds and again this morning 07.30. It’s like an aftershock when Eskmeals fires one of its thumpers. If I can hear it what must it be like for the marine life?” Seascale Resident, Linda Parsons
The seismic blasting/testing is underway now as a result of factors including:
1. lack of public consultation and independent scrutiny due to Nuclear Waste Services/RWM Ltd/GDF Partnership cynically (and possibly illegally) using the “scientific research” exemption from Marine Management Organisation Licensing and
2. outdated guidelines in use by JNCC and deferred to by Natural England, the Marine Management Organisation and other regulatory bodies. The JNCC’s outdated guidelines on seismic testing have led to the JNCC’s endorsement of seismic testing to facilitate the commercial development by the GDF Partnership of a deep, heat generating nuclear waste disposal site under the Irish Sea.
We draw your attention to the report into the GDF Seismic blasting plan we commissioned from Marine Pollution Expert, Tim Deere-Jones.The report highlights the much more stringent protections for cetaceans in the US, which also has banned seismic testing in the Atlantic, than here in the UK and also states that : "It is strongly recommended that UK seismic acoustic surveys are suspended and/or postponed until the scientific evidence related to acoustic impacts on schooling fish and other invertebrates has been incorporated into updated JNCC Guidelines.”
We agree and urge the JNCC to call a halt to all seismic blasting in the UK including the one underway now in the Irish Sea which started in National Marine Week on the 1st August and will continue for 20 days or more. There should at least be no seismic blasting in areas in or close to Protected Areas such as the multiple protections found in the Irish Sea region.
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Witness Account 14th August 2022: On three separate occasions I have heard the dull thud of that Seismic testing vessel. About three nights ago I had to take my dog out for a wee and the ship was off Seascale. I could hear a dull thud every few seconds. Yesterday the same at about 16.00, every 4-5 seconds and again this morning 07.30. It’s like an aftershock when Eskmeals fires one of its thumpers. If I can hear it what must it be like for the marine life? Linda Parsons resident of Seascale
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The full report is attached and the key conclusions are below -
Note the blasts are every FIVE seconds not Ten seconds as is more usual in developments classed as commercial.
Yours
Marianne Birkby
On behalf of Radiation Free Lakeland
Summary of Conclusions from Review Briefing by Tim Deere-Jones (attached)
Chapter 1: An assessment of the potential environmental impact of the proposed seismic survey has been published by NWS/NDA but, as there is no evidence that the assessment has been produced by an independent source, it is concluded that it has been drawn up “in-house” by NWS/NDA. The NWS/NDA environmental assessment has concluded that there are no contra-indications to the proposal and that “there is predicted to be, with a high level of confidence, no likely significant effects” to MCZs or regional marine species.
In the context of the lack of both public access to relevant information and an independent assessment of potential impacts, this Briefing offers an alternative and independent review of the NWS/NDA assessment.
A contradiction between the area to be surveyed quoted by the NDA GDF enquiries email of 11/5 (250km sq) and that quoted in the NWS Feb 22 “Notification” (1,000 km sq) requires clarification from both bodies.
Chapter 2: It is reported that acoustic pulses will be produced once every 10 seconds throughout the survey period. If this is correct, it will require the production/generation of 60,480 airgun acoustic impulsive pulses per week, totalling 181,440 pulses over 3 weeks or 241,920 pulses over 4 weeks.
Chapter 3: It is widely recognised that a number of factors can reduce the effectiveness of seismic surveys. The West of Copeland proposal will be carried out in waters characterised by a number of these factors including elevated suspended sediment concentrations, reverberation from airgun shots, wave generated bubbles and seasonal algal and zooplankton blooming. Given the methane rich nature of the adjacent Cumbrian coal field there is also a possibility that seeping methane gas bubbles will also be present in the survey area.
More distant natural and anthropogenic sounds should also be taken into consideration. The NW of England is subject to relatively frequent low magnitude natural seismic activity with at least three earthquakes recorded by the British Geological Survey from January 2022 to the end of May 2022. Earthquakes of more significance (4.7 mag, 4.1 mag and 3.1 mag) have occurred since 1970.
The issues raised above have not been referenced in the discussion of the proposed seismic survey. Consequently, the effectiveness of survey work carried out in the shallow sea area under consideration remains uncertain.
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Chapter 4: NWS/NDA have applied for a Wildlife or EPS Disturbance licence for “scientific and educational purpose.” This Briefing contends that the claimed “Scientific or Educational purpose” is a mis-representation of the true purpose of the proposal which should clearly be judged as an industrial activity because it is specifically and solely associated with an industrial or commercial proposal to construct a sub-seabed infrastructure (NGDF).
Chapter 5: West of Copeland survey proposed for the sea area west of the Copeland coast would require an EIA and HRA if it was shown to be a “sensitive sea area” containing a protected habitat or species. The requirement for EIA or HRA is dependent on the findings of any preliminary environmental assessment. The NWS/NDA have confirmed that the environmental assessment was undertaken/carried out, and presumably scoped, “in house”, and not by an independent consultant as is normally the case with such assessments.
That assessment was based on, and reliant on the NWS/NDA interpretation of third party research and investigations which they have compiled by data search/desk review using their own search terms. Other than their desk review of the available scientific literature and field research it is not evident that NWS/NDA have undertaken any original site and region specific empirical field research.
Chapter 6: A major sector of the NWS/ND assessment was based on the outcomes of the international SCAN cetacean survey. The SCAN survey was an international initiative with survey work in each Sovereign state jurisdiction involving national “partner agencies”. The partner agencies in the UK were the DEFRA ministry and the JNCC.
The SCANS report provided a map of the total search area achieved under all conditions. From this map it is evident that significant areas of Block F (north east Irish Sea) specifically including the area of the proposed survey, were NOT subjected to aerial survey. Whether this was due to bad weather, the lack of resources or low national priority was not explained by the SCANS report. As a result, Table 33, page 27 reporting of cetacean presence in Block F is reported as “estimate” in the context of “partial coverage only” for Irish Sea Block F.
Additional weakness in the survey methodology was noted by the SCAN report on page 15 which noted that the effective visual strip width from aerial detection was, at its maximum, no more than 400 metres. Further SCAN comment on this issue (page 33) reported that “detection probability and therefore effective strip width is smaller from an aircraft than from a ship, but aerial survey is considerably cheaper than ship survey.”
This Briefing contends that the NWS/NDA documentation is seriously remiss and lacking in scientific rigour because, despite the fact that the authors of the SCAN report clearly and transparently referenced these weaknesses, the NWS/NDA documentation has failed to reference these matters and has thus presented (intentionally or otherwise) an inadequate and incomplete report of the SCAN survey of cetaceans in Block F and particularly in the area where the proposed seismic survey is to take place.
Chapters 7 & 8: These chapters discuss the NWS/NDA assessment of the potential impact of the proposed acoustic survey on regional MCZs.
This Briefing’s review of the assessment concludes that regional MCZs referenced by the UK Wildlife Trusts are close enough, in terms of miles/kms, to the proposed West of Copeland airgun survey area for the sounds to be audible or detectable throughout the MCZs. Even in shallow water, such as that of the survey area, airgun pulses are reckoned to propagate over approximately 100kms.
This Briefing concludes that the NWS/NDA assessment conclusions on the MCZs discussed above lack rigour in the following respects: because they omit and “scope out” relevant adjacent MCZs, they fail to discuss a high number of designated habitat species (including important bivalve, sea urchin, anemone, starfish and bryozoan species and Basking Sharks). Despite an extensive literature search no report of any research into acoustic airgun survey impacts on these species has been identified.
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The NWS/NDA assessment states that designated features are “not sensitive to underwater sound”. Despite an extensive literature search, no record of any studies of the impact of seismic airgun survey noise on brittle stars, sea urchins, sea pens, spoon worms, Dublin Bay prawns, sea squirt, Saballeria, bryozoans and baking Sharks has been found. This briefing therefore contends that the claim has been made without any scientific justification and must therefore be discounted.
Clearly the assessment of “sensitivity” of both sites and marine species is a vitally important factor in the decision making process preceding the initiation of any seismic acoustic survey. The flaws and failures of omission catalogued above have severely diminished the scientific rigour and transparency of the NWS/NDA assessment of potential impacts of airgun seismic surveying on regional MCZs.
There is a body of empirical evidence demonstrating that acoustic seismic surveying can have a negative impact on fish schooling and subsequently on commercial fishing harvests during both the survey period and for some time afterwards (see next section below). This Briefing note reports that the NWS/NDA have failed to assess and report on this issue.
The omissions and flaws discussed above clearly indicate the imperative need for a thorough and fully independent EIA and HRA. Such an EIA should be transparently and independently scoped with the benefit of major input from regional non statutory organisations/groupings with no interest or involvement in the proposed NGDF and associated activities. The proposed seismic survey should be cancelled/postponed until these omissions and flaws have been remedied by a full, and independently scoped and performed EIA/HRA.
Chapters 9 to 19: The NWS/NDA assessment of the proposed acoustic survey impact thresholds on West of Copeland marine species is based on methodologies derived from only two sources. This is not representative of the available papers addressing such methodologies.
It is noted that the NWS/NDA assessment has not drawn attention to the important and precautionary warning from a leading fish scientist, that there has been inadequate research into the response of marine creatures to acoustic sources. This failure conveys the impression that the NWS/NDA interpretation of the available data is based on a broad consensus derived from unequivocal and sound data, which is not the case.
This Briefing has reviewed a wide selection of independent, peer-reviewed academic data on acoustic airgun survey impacts to a wide variety of marine species, including many NOT referenced by the NWS/NDA assessment. That review confirms that the NWS/NDA have failed to report scientifically verified impacts to a high number of species known to be present in, and close to the West of Copeland proposed survey area.
These species include schooling fish species such as cod, haddock and mackerel; octopus, cuttlefish and squid; lobsters and crabs; bivalve shellfish such as scallop; shellfish larvae and zoo-plankton. This Briefing also notes that the regional MCZs have been designated because of the species they support, but that many of those species including, bryozoans, marine worms, starfish, sea pens, urchins and juveniles of many species have NOT been studied to quantify any impact they may suffer from acoustic surveying.
This Briefing also notes that there are no empirical analyses of the abundance of basking sharks within or near the proposed acoustic survey and no reporting of investigation of either the primary or secondary impacts of air gun acoustic surveying on basking sharks and other elasmobranch species.
This Briefing concludes that the NW/NDA assessment of impacts from acoustic airgun surveying are deeply inadequate and lacking in appropriate scientific/academic rigour. It is concluded that the NWS/NDA assessment does not provide a sufficient level of empirical data on the potential impacts of air gun surveys to the full range of regional and MCZ marine species likely to be impacted.
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In that context it is evident that local communities, environmental and conservation organisations and statutory decision makers such as the Marine Management Organisation, do not have sufficient information on potential impacts to the full assemblage of marine species to successfully carry through the decision making process. It is therefore advised and recommended that the decision making process should be postponed until a fully independent EIA is enabled and completed.
In the context of the poorly managed and scoped NWS/NDA assessment it is recommended that the scoping process should also be undertaken by an independent body benefitting from significant representation from regional communities, regional environmental/conservation organisations and commercial marine users and stakeholders.
Chapter 21: The JNCC 2017 Guidelines offer a suite of mitigation measures which the JNCC propose are based on “reasonably conservative assumptions” and states that compliance with these Guidelines “constitutes best practice” which will, in most cases, reduce the risk of injury to marine mammals to “negligible levels.” However, the JNCC “negligible level” has not been defined. In that context it should be assumed that it is a subjective, rather than an objective and empirical, judgement to be taken by the decision maker. In the case under consideration, it remains unclear which individual or organisation will make the eventual subjective decision and on what basis the decision will be made.
The JNCC 2017 Guidelines focus on marine mammals, and notes that “they could be adapted to help reduce the risk of deliberate injury to other marine species if deemed appropriate by the relevant Regulator. For example, other potentially sensitive species include marine turtles, also listed as EPS (European Protected Species), and several shark species including basking shark which are UK priority marine species.”.
The above statement, taken from the introduction to the 2017 JNCC document, is (in the context of more recent scientific peer reviewed evidence discussing impact effects on schooling fish and other invertebrates) now clearly outdated and inadequate. The major differences between the sound awareness faculties of species as diverse as marine mammals, crustaceans, marine worms and zoo-plankton render the claim that JNCC Guidelines “could be adapted to help reduce the risk” of injury to other species unrealistic, inadequate and lacking scientific rigour.
It is strongly recommended that UK seismic acoustic surveys are suspended and/or postponed until the scientific evidence related to acoustic impacts on schooling fish and invertebrates such as worms, bryozoans, zooplankton, urchins etc has been incorporated into updated JNCC Guidelines.
Chapter 22: The NWS/NDA assessment has stated that “There is no suitable alternative non-intrusive survey method available to collect data on deep geology”.
The NWS/NDA statement is not true. This Briefing provides summary information showing that both Marine Vibroseis and Passive Seismic Transmission Tomography pose a lesser threat of damage and impacts to marine species than airgun seismic surveys. Additionally, both technologies offer advantages for geological imaging in the environment of the Cumbrian marine seabed due for surveying by the seismic airgun method.
Despite the likely objection of both survey companies and survey users, it is recommended that the NWS/NDA withdraw their claim that “There is no suitable alternative non-intrusive survey method available to collect data on deep geology”, cancel the proposed and environmentally damaging West of Copeland seismic airgun survey and make use of one of the above “alternative” technologies discussed above.