The North Carolina Coastal Federation sent a comment letter Monday to the federal Bureau of Ocean Energy Management (BOEM) and a second comment letter to the National Marine Fisheries Service (NMFS), requesting the two agencies consider and discuss the impact of new information about the environmental effects of geological and geophysical oil and gas surveys — commonly referred to as seismic testing — in the mid-Atlantic.

Specifically, the federation requested that BOEM prepare a supplemental programmatic environmental impact statement (PEIS) that takes into account scientific studies that were not included in the PEIS released in 2014. These studies demonstrate the harmful effects of human-created noise, including noise from seismic airgun discharge, on fish. The federation also asked that BOEM and NMFS enter into a formal consultation to discuss the effects of geological and geophysical activity on essential fish habitat.

The federation sent a third letter to the Mid-Atlantic Fishery Management Council, asking that the council support the federation by sending letters with the same requests to the two agencies. The council also opposes seismic surveys.

In March 2016, BOEM announced its decision to not pursue offshore drilling in the mid-Atlantic, but eight companies have applied for permits to perform seismic surveys to look for oil and natural gas resources in the area. The federation is advocating against these surveys.

Ladd Bayliss, a coastal advocate for the federation, argued in the letters that BOEM cannot rely on its 2014 PEIS, the Atlantic Geological and Geophysical Programmatic Environmental Impact Statement, because of regulations outlined in the National Environmental Policy Act. The 2014 PEIS concluded acoustic effects on fish and the fishing industry would be minor — but there is hefty evidence against that conclusion.

The act states that in the event of “significant new circumstances or information relevant to environmental concerns and bearing on the proposed action or its impacts,” an agency should provide a supplemental PEIS.

This new information comes in the form of several studies, which are outlined in the letters, that demonstrate the effects of seismic surveys on fish.

A study completed in 2000 found that in addition to the deaths of adults, juveniles and eggs of fish that are in close proximity to noise caused by seismic airgun discharges, the exposure might also have long-term physiological and behavioral effects on fish that can contribute to early death. These changes are not well understood and could damage an entire species.

Other studies demonstrated the damage seismic surveys cause to cod and mollusks, as well as the fact that the effects of human-created sound on fish are not well-understood — noise from seismic airguns could cause even worse long-term effects on fisheries than realized.

The 2014 PEIS already states noise from seismic survey related equipment might affect fish important to mid-Atlantic commercial and recreational fishing industries, which bring in millions of dollars to the North Carolina economy each year.

Behavior changes in species of fish would hurt these industries, especially if seismic surveys occur in areas designated as essential fish habitat closed to harvest and fishing during spawning season. Disruptions in these areas could lead to displacement of local fish, and conversely, a decrease in catch when the areas reopen to commercial and recreational fishing.

The outlined studies in the letters indicate that the effects of seismic surveys have the potential to be more damaging than BOEM relayed in its PEIS. The federation argues that legally, BOEM must provide a supplemental PEIS to thoroughly inform the public of the potential effects of seismic surveys on fish and the fishing industry.

For more information, contact coastal advocate Ladd Bayliss at and/or visit