Opposing Woodfibre LNG's proposed amendment to Condition 3.8

I would like to express my deep concern and strong opposition toward Woodfibre LNG’s proposed amendment to Condition 3.8, regarding the protection of marine mammals. I am a senior marine mammal research scientist with Raincoast Conservation Foundation, with a background in bioacoustics and two decades of experience studying the impacts of underwater noise on marine mammals.

The proponent’s conclusion that “the use of a 125 meter pinniped-specific exclusion zone during in-water impact pile installation is unlikely to be detrimental or adverse to individual health or the health and viability of harbour seal or Steller sea lion populations in B.C.” is not based on the most current available science. In fact, there is strong scientific evidence supporting the notion that a 125-m exclusion zone is not adequate to prevent temporary or permanent damage (hearing threshold shifts) to pinnipeds (see for example White et al. 2020, Hastie et al, 2015).   In addition, Southall et al (2019) used data on hearing sensitivity across pinniped species to estimate onsets for Temporary and Permanent threshold shifts (TTS and PTS). For phocids underwater (phocids are more sensitive than Otariids) , thresholds for impulsive sounds were estimated to be 170 and 185 dB re: 1μPa s for TTS and PTS, respectively (note that these thresholds are the same as those provided by the US National Marine Fisheries Sesrvice, NMFS, 2016, 2018). According to theoretical scenarios modelled by Faulkner et al. (2019) involving pile driving at offshore windfarms, using Southall’s most current criteria, the estimated range of Permanent Threshold Shift risk for seals is 2 km  - far exceeding the proponent’s 125 m zone. Let me remind you that a PTS means permanent hearing damage that can severely impact an animal’s ability to survive.

The notion that pinnipeds have the ability to avoid acute underwater noise by raising their heads for an extended period of time also borders on ludicrous. This notion does not consider the fact that this means lost foraging time (pinnipeds chase their fish prey underwater), and likely acute stress. Further, WFLNG does not consider the impacts of noise in air on seals and sea lions, which have very sensitive aerial hearing.

Given that Steller Sea Lions have very recently returned to Átl’?a7tsem / Howe Sound, and are listed as a species of special concern under the Federal Species at Risk Act (SARA), it is the Government of Canada’s duty to protect this species and its habitat. It is also evident to me that WFLNG is not applying the precautionary principle, and is not providing robust scientific evidence for the proposed changes to condition 3.8. Given the recognition of the Átl’?a7tsem / Howe Sound UNESCO Biosphere Region as "a cultural and ecological treasure.", this is deeply concerning.

Sincerely, 

Valeria Vergara, PhD

Cetacean Conservation Research Program Co-Director

Raincoast Conservation Foundation

Cited References

Faulkner, R. C., Farcas, A., and Merchant, N. D. (2019). “ Risk assessment of permanent auditory injury in marine mammals: Differences arising from the application of the Southall and NOAA criteria,” Scottish Marine and Freshwater Science Report (Marine Scotland Science, Edinburgh), Vol. 10, No. 1. https://doi.org/10.7489/12205-1

Hastie, G.D., Russell, D.J.F., McConnell, B., Moss, S., Thompson, D., Janik, V.M., 2015. Sound exposure in harbour seals during the installation of an offshore wind farm: predictions of auditory damage. J. Appl. Ecol. 52, 631–640.

Southall, B.L., Finneran, J.J., Reichmuth, C., Nachtigall, P.E., Ketten, D.R., Bowles, A.E., Ellison, W.T., Nowacek, D.P., Tyack, P.L., 2019. Marine Mammal Noise Exposure Criteria: Updated Scientific Recommendations for Residual Hearing Effects. Aquat. Mamm. 45, 125–232. https://doi.org/10.1578/AM.45.2.2019.125

Whyte, K.F., Russell, D.J.F., Sparling, C.E., Binnerts, B., Hastie, G.D., 2020. Estimating the effects of pile driving sounds on seals: Pitfalls and possibilities. J. Acoust. Soc. Am. 147, 3948–3958. https://doi.org/10.1121/10.0001408