ALASKA WILDERNESS LEAGUE—AUDUBON ALASKA—CENTER FOR BIOLOGICAL DIVERSITY—EARTHJUSTICE—NATURAL RESOURCES DEFENSE COUNCIL—NORTHERN ALASKA ENVIRONMENTAL CENTER—OCEAN CONSERVATION RESEARCH—PACIFIC ENVIRONMENT—SIERRA CLUB— WORLD WILDLIFE FUND

• Main Authors: Via Email, Michael Payne Chief
• Other Authors: The Pennsylvania State University CiteSeerX Archives
• Format: Text
• Language: English
• Published: 2012
• Subjects: Pacific; Payne; Chukchi; Alaska
• Online Access: http://citeseerx.ist.psu.edu/viewdoc/summary?doi=10.1.1.348.3631; http://www.nmfs.noaa.gov/pr/pdfs/permits/ion2012_comments_received.pdf

Dear Mr. Payne: The undersigned groups submit the following comments on the National Marine Fisheries Service’s (“NMFS”) August 17, 2012, issuance of a proposed incidental harassment authorization (“IHA”) pursuant to the Marine Mammal Protection Act (“MMPA”). 1 NMFS proposes to allow the incidental take by Level B harassment of nine marine mammal species and by Level A harassment of three marine mammal species resulting from ION Geophysical’s (“ION’s”) seismic survey activities in the Beaufort and Chukchi seas that are scheduled to begin in October 2012. NMFS should deny ION’s application. ION’s proposal is remarkable for both its scope and timing. ION intends to use a survey vessel equipped with a 26-gun array with a total volume of 4,450 cubic inches. Not only is this an incredibly powerful array, but the surveying will take place across a large portion of the Alaskan Beaufort and Chukchi seas, with transect lines of approximately 7,175 kilometers (4,458 miles). The total area of water exposed to sounds greater than or equal to 160 dB will be 209,752 square kilometers. ION will survey for 76 days, beginning in October and lasting into