Dear All, On behalf of several NGOs, NRDC has submitted extensive comments to the U.S. Bureau of Ocean Energy Management, about its plan to open up the U.S. mid-Atlantic and south Atlantic to seismic surveys. We are deeply concerned about the government's analysis of marine mammal impacts. The fundamental issue, as we see it, is that the agency does not take the problem of cumulative, sublethal effects seriously; and misapprehending their scale and potential significance, it fails to consider alternatives sufficient to address it. BOEM does not attempt to identify biologically important habitat for protection, aside from a portion of North Atlantic right whale habitat; does not attempt to reduce the enormous amount of activity that is contemplated, e.g., by restricting exploration from areas that are unlikely to be leased; and fails even to devise a long-term marine mammal monitoring plan for the region. Together with the greater impacts recently predicted from Navy activity, populations in the U.S. Atlantic will be hard hit. Please write me if you'd a copy of our comments. BOEM plans to make a final decision in November of December. We'll keep the community apprised as this important issue moves forward. Best, Michael Michael Jasny Senior Policy Analyst Natural Resources Defense Council 4479 W. 5th Avenue Vancouver, BC V6R1S4 tel. 604-736-9386 mob. 310-560-5536 fax 310-434-2399 mjasny@nrdc.org<mailto:mjasny@nrdc.org>