Atlantic Shores IHA Comment 2024

The Comment Period Ends on February 5th, 2024

Comment suggestions below in opposition to Atlantic Shores Offshore Wind latest request to harm and harass thousands of marine mammals over the next year-plus in NY, NJ, DE, MD.

Be sure to email your version of the following to: 

Jolie Harrison, Chief, Permits and Conservation Division, Office of Protected Resources, National Marine Fisheries Service

Re: Incidental Take Authorization: Atlantic Shores Offshore Wind, LLC’s marine site characterization surveys off of New York, New Jersey, Delaware, and Maryland

Dear NMFS, 

Atlantic Shores request for authorization for incidental take authorization should be denied. 

Reasons for denial include: 

— Offshore wind survey activities in NY/NJ waters have  coincided with an unprecedented surge in marine mammal deaths here during the past year;

— 31 whales and 67 dolphins sacrificed during offshore wind survey activity from Dec. 2022 to Dec 2023;

— Plenty of evidence exists showing correlation between the survey activities and whale deaths and needs to be addressed by the industry and NMFS;

— Allowable harms described as non lethal (Level B), such as Temporary Threshold Shift (TTS) or temporary deafness, can lead to significant behavioral modifications in protected marine mammals. This harm can lead to flight and secondary mortality events such as ship strikes or strandings. This needs to be studied further.

— Scallop, oyster, and clam beds have been altered and decimated coinciding with the recent survey activities. This has severely impaired local commercial fishermen. Continued ongoing activity will put thousands of jobs and livelihoods at risk.

— Horseshoe crab protected areas have and will be further infringed upon, putting this medically and migratory important species at risk. The horseshoe crab is vital to the migration of endangered avian species, which rely on spawning grounds in the lower Delaware Bay;

— To date, no full necropsies have been released for whales stranded in NY/NJ waters dating back to Dec. 2022. As such “cause of death” has yet to be determined. Why not?

— Congressionally authorized GAO study has yet to be released and will in all likelihood result in modifications to approval processes; 

— Offshore wind industry remains in financial turmoil. Why is NMFS approving wide scale harms to marine life for questionably viable projects?