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This is a review of the White Paper entitled “Potential Environmental Consequences of

Petroleum Exploration and Development on Georges Bank” issued by the New England
Aquarium in September 1999. This critique was requested by the Massachusetts
Fishermen’s Partnership, an umbrella group of 18 Commercial Fishermen’s
Organizations representing most of the major gear sectors in Massachusetts.

The release of the White Paper was extremely ill-timed coming shortly after the Canadian
Review Panel presented their recommendation to extend the Georges Bank Oil and Gas
Moratorium, but immediately before the Canadian Parliament begin their deliberations.
As such, it could perhaps represent the last word from the scientific community on a
decision which could effect all those dependent on Georges Bank for their survival. It is
ironic that this report was being written at the very time the Georges Bank Review Panel
was reviewing testimony from both sides of the issue.

The Steering Committee, consisting of 3 representatives from the Aquarium and two
from the Woods Hole Oceanographic Institution, is to be commended for an accurate and
detailed description of the day to day petroleum operations. These sections were
obviously well researched and show an understanding which could only come from
practical experience in the petroleum industry.

All the more surprising that the discussion of biological impacts is so apparently vague
and obtuse. In reviewing toxicity the Steering Committee concludes:

A simple quantitative comparison of the toxicities of oil-based and water based muds is
not meaningful because of considerable variability of composition for both kinds of mud
and differences in sensitivities among potentially affected species.

The committee must surely be aware that for a given pressure regime and rock type
nearly identical mud formulations are used throughout the world. These mud
compositions can easily be duplicated by an engineer once the well prognosis is known.
It is quite probable that Texaco would have provided this detailed information just as they
provided other elements of the drilling scenario.

Furthermore, dozens of organisms have already been subjected to varying compositions

of drilling mud and the toxicity results are known and well reported. With the detailed
drilling scenario, mud compositions could have been anticipated for the top of the hole
the middle section and at total depth. Then, the sensitivity to different concentrations of
barite and other mud additives could have been determined with a high degree of

In a later section, the authors quip “Most benthic organisms are highly specialized for the
grain size of sediments to which they are adapted. Organisms adapted to coarse
sediments are unlikely to benefit from the addition of fine-grained material.” This is an
extremely curious way to describe mortality of benthic organisms buried under hundreds
of tons of discharged mud and cuttings from a single well.

This writer was shocked and dismayed at the rather superficial and almost cavalier
attitude which members of the Steering Committee showed regarding their responsibility
to protect the Bank and its users.

Jerry Schubel, President of the New England Aquarium, is quoted as saying "we looked
for the bogeyman but there was none." Further, he states, the report “ does not provide
scientific evidence compelling enough to argue against drilling.” Due to the so-called
“gaps in current knowledge” we are expected, in effect, to give the industry the benefit of
the doubt. Well, they have had over 50 years of benefits and paid very little penalty for
the doubts they have raised among environmentalists and fishermen about the impacts
they inflict on marine ecosystems.

The Steering Committee appears to wash their hands of the consequences of their actions.
In the introduction they remark:

"This White Paper is designed to provide reliable and balanced scientific

information to the decision-making process rather than to suggest what that final
decision should be."

Given the critical timing, it is irresponsible to produce a document which could

significantly influence the decision without taking a firm position either endorsing or
disagreeing with the Canadian recommendation.

Should we congratulate the White Paper steering committee for “summarizing what is
known about the likely effects of petroleum exploration and development on Georges
Bank” knowing they have barely scratched the surface on the mountain of recent
evidence which was presented to the Review Panel or prepared at their request? Should
we take comfort knowing that the 5 member “Steering Committee agrees that this
document is factually defensible, and that, taken as a whole, it is an accurate and
balanced summary of current scientific information”? The White Paper was actually
prepared by this Steering Committee and we can only wonder whether the 7-member
review committee would agree with this assessment and its failure to suggest a course of

Finally, one can only be amazed at the general disclaimer that appears on page 15 of the
White Paper which states:

"Because the particulars of the resource influence the risks posed by its
exploitation, available information is presented here. However, much of this information
is anecdotal and its reliability cannot be determined."

After digesting the contents of the White Paper, the Boston Globe (Friday, Sept.24, 1999)
summed it up with the headline “No Easy Answers On Georges Bank Drilling." In
answer to the question: “Whether fish can survive alongside oil and gas exploration on
the Georges Bank?" Leslie Miller of the Associated Press says “Maybe.”

The media is to be forgiven for concluding that the report opens the door to oil and gas
operations and invites drilling by failing to take a stand in spite of overwhelming
evidence of potential damage to the Georges Bank ecosystem. Such popular perceptions
could sway the opinion of Canadian lawmakers at precisely the moment they need to
stand firm against an oil industry media and lobbying blitz.

The Canadian Review Panel appears to have had no difficulty making a conclusive
determination. Their one sentence recommendation leaves no room for misunderstanding
and states succinctly:

“The panel recommends that action be taken to have the moratorium on petroleum
activities on Georges Bank remain in place.”

Possibly, this was because the Panel had the opportunity to listen carefully to what the
petroleum companies had to say; or more particularly, to what they did not say! Is it
conceivable the Panel recognized that the testimony they were hearing from the oil
industry representatives was not entirely forthcoming? Did they fear that they were
engaged in a meaningless debate built on false premises in some ways similar to the
ongoing dialogue about the existence of global warming or the effects of tobacco smoke.

Could it be that the Panel finally came to the realization that something was being hidden
from them after weeks of being told that their questions could not be answered or that the
studies were currently underway? Did they suspect after hearing the same few sources
repeatedly referenced that thousands of unreported environmental studies have been
conducted by the companies and their consultants in other countries and basins of the

The White Paper reportedly “combines new information with existing knowledge about
the possible environmental impact of drilling for oil and gas.” One might well ask,
Where is this new information? The Georges Bank Review Panel listened to testimony
from over 90 participants including scientists from both sides of the argument. The Panel
commissioned more than a dozen new reports from leading universities and consultant
firms to study specific elements of the problem. None of the testimony or supplemental
studies are included in the White Paper making it obsolete before it was distributed.

Moreover, the time has passed when scientists can simply drag out the same old
reworked oil and gas environmental studies from the North Sea and Gulf of Mexico
showing inconclusive results due to a lack of pristine base-line conditions. What about
the hundreds of thousands of wells drilled offshore in other regions? Why do these brief

compilations of available data rarely even mention scientific investigations conducted in
other regions?

Ever since the Santa Barbara oil spill invaded the global consciousness thirty years ago,
foreign countries have frequently demanded that oil companies prepare environmental
impact studies for nearly every well drilled. Are there no environmental impact reports
available from offshore Australia, Africa, South America or Asia? Are we to believe that
multi-nationals who often duplicate each others efforts (sometimes utilizing the same
consultants) still consider this information proprietary after decades of secrecy? Are we
to assume that contractors who provide and prepare the drilling fluids used throughout
the world do not know the toxicity of their products in the marine environment?

According to Daniel Yergin, best-selling author of "The Prize," offshore drilling began in
1947 with the first well being drilled 10 miles off the Louisiana coast. Since that time,
hundreds of thousands of wells have been drilled in basins offshore. In the past 5 years
alone, offshore drilling has occurred in more than 40 countries throughout the world, yet
still the companies claim that critical environmental impact information is lacking. Each
of the companies that presented to the Panel must surely have several hundred of these
environmental reports in their files, some of which could be relevant to Georges Bank

As a result, what was presented to the Panel as scientific evidence or a lack thereof, was
merely a shell game in which the data needed at any given moment was always hidden
and kept just out of reach. Rather than search for the “bogeyman” as Schubel put it,
maybe they should have been looking for the con and the missing data.

And what of the impacts of seismic noise on marine organisms? Multi-national oil and
gas corporations have shot millions of kilometers of offshore seismic data yet they and
their international seismic contractors claim they have “no data” on the effects on
organisms above their airguns or on the spawning grounds below.

Such assertions test the limits of scientific credulity. Is it that they don’t know, don’t care
or they don’t want the public to know the facts that are intuitively obvious to all
fishermen and informed citizens. Put bluntly, oil and gas exploration and production
operations have a negative impact on fishing over a large area and for an indefinite time
period. If the oil companies could show that the environmental impacts of their
operations were negligible isn’t it reasonable to assume that they would have done so
already? After all, tobacco companies tried in vain to demonstrate that their products
were not directly linked to cancer while keeping the results of their tests secret for years.

The following list of potential adverse impacts extracted from the White Paper should
have been more than enough for the Steering Committee to produce a recommendation to
extend the Moratorium on Georges Bank until at least 2012. This is especially true when
seen in light of the practical, operational considerations detailed below.


"Airgun noise has been shown to be lethal to eggs and larvae of marine organisms within
5 m of the source."
Airguns are typically towed at a depth of 6m below the surface. This leaves very little
room above the airguns which is not potentially lethal. Although the oil companies insist
that the energy from the airguns is directed downward, they continue to use spherical
models to calculate dispersal. This suggests that the energy is propagated upwards as
well as downwards. There are no reported studies of impacts on organisms located above
the airguns.

"Seismic noise can disturb and modify the behavior of fishes over distances of several
kilometers in ways that alter commercial fishing success."

In a study in Norway, "there was a decrease in cod and halibut trawl catches of as much
as 80 % within the exploration area and within 5 miles of it." In the Barents Sea,
“acoustic density of cod and haddock decreased over the entire study area by 45% during
shooting and decreased by 64% during the 5 day period after shooting ceased. Because
3D seismic lines are closely spaced involving repeated runs of a slow-moving vessel (5
knots) with one hour for each turn, an intermittent exposure to seismic shots at 10 second
intervals could last for hours.

In 3D seismic, the survey vessel tows multiple strings of hydrophones, typically 100 m
apart. The resulting data show structure in a series of parallel vertical planes. For this
technique, the survey vessel is likely to traverse an area repeatedly, in many closely
spaced parallel tracks, to build up detailed structural information.

If the seismic program which Mobil set out on the Scotian Shelf in 1998 is used as a
guide, then a key exploration area could extend over a 12-mile by 25-mile patch of ocean
and cover 300 sq. miles. A rough calculation using the parameters above would place a
stationary organism or bottom habitat within a 5 mile radius of the source and exposed to
intermittent explosions for over 15 hrs. Considering weather and turns the airguns might
be active for 40% of this time period. There is apparently no hard data on how these
activities could impact the behavior of marine mammals.

"The principle option for mitigating the effects of seismic noise on Georges Bank
is through scheduling to avoid critical interaction with biological resources of the area.
However it is unlikely that all conflicts can be avoided since weather effectively limits
seismic operations to summer month on Georges bank."

At least 17 species are known to spawn on Georges Bank during the summer months. Of
these, 8 key commercial species are known to have their primary spawning times during
this time. There is supposedly no data to estimate how this noise disruption could impact
spawning behavior.


The composition of drilling mud may be changed often during drilling in response to
conditions encountered. In practice, this usually means that mud weight is gradually
increased by adding barite and other chemicals to control the natural pressure increase
with depth. When this happens suddenly, the mud is dumped in bulk and a new batch is
mixed (often with heavier properties in anticipation of increased pressure). Analysis of
the drilling waste scenario data (volume density and weight) could yield a likely
composition. It is indeed strange that adult scallops are highly sensitive to barite but
show relatively low sensitivity to used water based mud cuttings. This strongly suggests
that the samples analyzed came from the upper part of the whole where the concentration
of barite would be at a minimum.

Using the Joint Group of Experts on the Scientific Aspects of Marine Pollution
(GESAMP) estimates from the White Paper (Table 2), discharge of bulk mud at end of a
likely 3 well program would be 450- 1200 tons. For a development program of 50 wells,
the drilling mud discharge would be 45,000 tons or approx. 90,000,000 lbs.

Based on historical data "If one assumes that 500 t of barite were discharged for each
well drilled," (in the US Georges Bank drilling program). Then 1500 tons of barite would
be discharged from a likely three well exploration program and 25,000 tons from a 50
well development program. Of course this discharge would be on prime fishing grounds
where a near-zero discharge policy is in effect for fishermen.

Using the GESAMP estimates from the White Paper (Table 2), discharge of cuttings from
a likely 3 well exploratory program would be 600 to 3000 tons (dry mass). For a
development program of 50 wells the cuttings discharge would be 50,000 tons or approx.
100,000,000 lbs.


During drilling on the US side of Georges Bank, "The greatest increase in barium
concentration in bulk sediment found by Neff and coworkers was 140 ppm at a station
200 m of a drilling site. If one assumes that 500 tons of barite were discharged for each
well, 2 million tons of sediment could be contaminated to this extent for each well

In the toxicity tests for scallops performed by the Canadian Department of Fisheries and
Oceans (DFO), zero growth was observed at the lowest concentration of barite tested
(0.5mg/L). The researchers were therefore forced to estimate the effects threshold and no
effects concentration on adult scallops. These tests were performed as part of the highly
touted benthic boundary layer tests (bblt) on adult scallops only. They could only
speculate on the effects on immature scallops, spawning, growth and development.

"Gas would be brought to market through a pipeline reaching shore in the United

Just such a gas pipeline has already been proposed in a route directly across some of the
richest fishing grounds in New England. Even if one uses the outdated estimates
contained in Table 5 of the White Paper during the period 1967 - 1990 for an oil pipeline,
it yields an unacceptable pollution leakage estimate.

A hypothetical 400 km crude oil pipeline between the Canadian portion of the Bank and
the US shoreline might be expected to leak 50,000 L (50 tons) over an operating lifetime
of 25 years.

It is difficult to understand why the authors did not use the figures on pipeline accidents
for 1986-1998 posted on the web by the Office of Pipeline Safety. These figures show
some improvement in the number of incidents for liquid pipelines since about 1990 but
an increase in gas incidents. In 1998, liquid leakage was at its lowest point during the
period while the number of gas incidents was at it highest point in ten years.

If the most advanced environmental standards and pollution avoidance technologies were
applied to all operations environmental inputs of petroleum could be further reduced.

Where is the evidence for this simple statement? If most pollution incidents are the result
of human error or corrosion and decades of regulation by dozens of meticulous foreign
bureaucracies have failed to curtail petroleum pollution in the oceans why should we
assume that the latest technologies will solve this problem?

It is unfortunate that the New England Aquarium, the only institution to attempt a
detailed re-creation of the Georges Bank habitat for educational purposes, was unable to
come to a conclusion at this time about what should be done to protect the Bank’s future.
It is time for the oil industry to clean up its act. Admit to the mistakes of the past and
release the internal reports which show the true nature of the industry's environmental
impact on a worldwide basis. The oil companies should come clean and reveal the full
extent of environmental damage they have inflicted on fishermen in countries like
Nigeria, Brunei and Gabon. Only then can a truly impartial panel or committee make a
fully informed and enlightened decision about whether oil and gas exploration and
production activities are appropriate for a highly sensitive area like Georges Bank.

The final question which must be answered is; Why should the New England Aquarium
endorse the recommendation to extend the oil and gas moratorium on Georges Bank as
proposed by the Canadian Review Panel? Is it because the overwhelming body of
evidence in the literature has found negative impacts on numerous organisms at
surprisingly low concentrations? Perhaps, it is because the Aquarium itself has
concluded that in many cases there is insufficient data to make a reliable prediction.

Either of these arguments considered in isolation should justify a pre-cautionary

However, the primary reason why exploration, drilling and production should be
prohibited on Georges Bank is that the oil companies have failed to show that it can be
done safely with negligible impacts on the environment. Even with decades to gather the
evidence and prepare their case, and with hundreds of highly-paid scientists and lawyers
at their disposal to present the industry’s side of the argument, the companies have failed
to convince an impartial panel selected solely to represent the best interests of the
Canadian government and its people. The Provincial Government of Nova Scotia has
endorsed this decision.

This writer is confident that after assimilating all of the related documents which have
been made available in the past year on the Georges Bank Moratorium issue no impartial
panel or steering committee representing American interests could disagree with the
Canadian recommendation.

David Lincoln
Greenlite Consultants 1999

Note: For the sake of simplicity all quotes taken directly from the White Paper are