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An Open Letter To Our Members and Marine Mammal Mitigation Stakeholders

The Marine Mammal Observer Association (MMOA) have become aware that rates paid to many contractors engaged by the oil and gas industry have fallen significantly over recent months. While the MMOA recognise that this is a natural consequence of industry contraction, we are concerned that the emphasis on maintaining high environmental standards may start to decline. Regardless of rates paid the MMOA stress that it is important to ensure that:

• Only suitably qualified, experienced and dedicated personnel should be hired as Marine Mammal Observers (MMOs) and Passive Acoustic Monitoring (PAM) Operators.
• MMO/PAM mitigation training certificates should not be the only requirement to qualify a person as a MMO or PAM Operator, in addition, appropriate field experience is required.

High industry standards in other areas of operation should be mirrored in mitigation compliance. Mitigation personnel should have experience in seismic survey methods and protected species mitigation, including Passive Acoustics Monitoring (where applicable). Employing inexperienced and unqualified personnel should only be done in a limited capacity and under supervision of experienced personnel.

In December 2015 the 21^st Biennial Conference on the Biology of Marine Mammals was held in San Francisco, California. The conference was one of the largest in its 40-year history and saw over 2500 attendees from 80 countries and over 1000 presentations including talks, speed talks and over 500 posters.

Prior to the official start of the Conference two days of workshops were held including the MMOAs workshop on 'Incorporating new mitigation technologies into guidelines for seismic surveys and other underwater acoustic activities and producing performance standards', co-hosted once again with Dr. Andrew Wright from New Zealand’s Department of Conservation (with the support of Mel Cosentino from Wild Earth Foundation). This workshop followed on from the very successful workshop the MMOA and New Zealand’s DOC hosted at the 29th European Cetacean Society Conference in Malta in March 2015.

The workshop in San Francisco was attended by over 50 people representing government, industry, environmental consultants, non-profit and academia. Professional MMOs and PAM Operators were also present, including at least 7 members of the MMOA.

In October 2015 the final Proceedings of the ECS Workshop New Mitigation Methods and Evolving Acoustic Explosure Guidelines were published. The proceedings, edited by Andrew Wright of New Zealand's Deparment of Conservation and Frances Robertson, current MMOA Chair, provides a combination of abstracts and short papers by those presenting at the workshop in Malta. The proceedings end with a summary of the workshop's afternoon discussion session -this summary also includes a list of the key points raised by workshop participants.

The workshop participants and organizers concluded that performance standards are key to addressing current and developting mitigation methods. It is surprising that to date there has been little assessment of the effectiveness of commonly applied mitigation methods -namely MMO and PAM methods and there are no specific standards to which these traditional methods are held. This makes it incredibly difficult to assess the effectiveness of new mitigation technologies. The report highlights the resounding need for minimum standards in terms of qualifications and experience of MMOs and PAM Operators, thier equipment and mitigation/data collection protocols. For example better data collection and reporting protocols would allow regulators greater opportunities to assess the effectiveness of different PAM systems and settings, as well as the effectiveness of MMO-based mitigation compared to PAM-based mitigation.