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.
Each company has a responsibility to ensure it conforms with industry best practice and environmental requirements, and there are several legal instruments and international agreements that they must adhere to in order to control marine noise and promote best practice. In Europe legislation to protect cetaceans and other marine mammals has been driven principally by the European Habitats Directive 92/43/EEC, it has equivalents in the US, Australia, New Zealand, Trinidad, Greenland and many other countries. Article 12 of the European Habitats Directive requires that Member States take the requisite measures to establish a system of strict protection for Annex IV listed species, including all cetaceans. As implementation of this policy of protection it is recommended/required to have dedicated and qualified persons to carry out mitigation policies. Thus the onus is on companies to ensure personnel are the best qualified for the required work.
While the industry is in an undeniable downturn that will push rates lower, some rates currently being suggested are now too low to support professional personnel who are well educated, experienced and professionally certified and engaged in Continuing Professional Development (CPD). Companies should seek to encourage the raising of standards, both in the contractors they engage and in their own procedures, and therefore, should not seek to engage personnel that are merely adequate for requirements, but those that can raise standards.
Marine Mammal Observer Association Committee
Communications House, 26 York Street,
London, W1U 6PZ, UK