Expert Analysis of the Impacts on Western Gray Whales of the Construction of Temporary Unloading Facilities by Exxon in Piltun Bay, Russia

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1 Expert Analysis of the Impacts on Western Gray Whales of the Construction of Temporary Unloading Facilities by Exxon in Piltun Bay, Russia Aleksey Knizhnikov 1, Aimée Leslie 2, Doug Norlen 3 1 WWF-Russia, 19 Nikoloyamskaya Street, Building 3, Moscow, Russia 2 WWF International, Av. Mont-Blanc 27, Gland 1196, Switzerland 3 Pacific Environment, 369 Pine Street, Suite 518, San Francisco, CA 94104, USA ABSTRACT The main feeding ground of the Western North Pacific Gray Whale (Eschrichtius robustus) population, which is listed as endangered in the Russian Red Book and as critically endangered by the International Union for the Conservation of Nature (IUCN), is adjacent to Piltun Bay in the Sea of Okhotsk. Exxon Neftegaz Limited seeks to construct a coastal infrastructure project at Piltun Bay that an independent scientific body says threatens these critically endangered whales. These independent experts conclude that Exxon must select a different project alternative in order to protect this critically endangered whale population. KEYWORDS: FEEDING GROUNDS, CONSERVATION MANAGEMENT PROCEDURE, SEA OF OKHOTSK, WESTERN GRAY WHALE INTRODUCTION Gray whales arrive in the waters off of North East Sakhalin Island from June and stay there until November, roughly, depending on factors such as sea ice coverage. This area is a critical feeding habitat for the gray whales. This population is estimated at 150 gray whales according to the latest report from the Western Gray Whale Advisory Panel (WGWAP). In September-November 2013 Sakhalin Environmental Watch, with the support of WWF, IFAW, Pacific Environment, organized a Public Environmental Expert Review of Sakhalin 1 Project, Odoptu Onshore facilities, Reconstruction of Odoptu 2 (Northern) Drill Site, Temporary Unloading Facilities of Exxon Neftegaz Limited (hereafter Expert Council). The Expert Council consisted of 11 experts from Moscow, Vladivostok, and Yuzhno-Sakhalinsk; amongst its members were two Doctors of Science and six PhDs, as well as members of the Western Gray Whale Advisory Panel 1. Evgeniy Ignatov, Doctor of Geography, Professor of M.V. Lomonosov Moscow State University s Geography Faculty at Lomonosov Moscow State University s Department of Geomorphology and Paleogeography chaired the Expert Council. The Expert Council analysed a proposed Exxon Neftegaz Limited project which consists of the construction of temporary unloading facility (TUF) on the Eastern shore of the Piltun Bay, roughly in the center of a sand spit that separates the bay from the Sea of Okhotsk. The TUF is to be used for unloading heavy modules 2 weighing up to 3000 tons each. The planned TUF is a temporary earthen structure measuring 885 m long and 40 m wide (the width of a standard industrial roadbed) made of locally sourced compacted sand. Construction is planned to take place in According to project design materials, the modules are to be transported by barge during the navigation periods from June to November of 2016 and A total of 18 barge loads are planned for delivery of the modules. Due to the modules' size and the local navigation conditions, the plan calls for the use of special MARMAC barges (series 400 and 455, which 1 Since 2004, IUCN has worked with Sakhalin Energy in order to provide advice and recommendations on how 2 Bunkering/storage facility for barge transport 1

2 displace thousand tons, and are up to 122 m in length, up to 32 m wide, and have a design draught of 2.1 m). An open sea capable tow boat will deliver each barge to the transfer point, while shallow draught towboats will be used to tow the barges along Piltun Bay and for mooring to the unloading facilities. Once the delivery and unloading of large size modules is completed, the plan is to dismantle the mooring area. Dismantling will take approximately 6 months, from April to September Approximately 100,000 m 3 of sand will be returned to onshore sand pits and, according to the project design materials, 83,000 m 3 of sand will remain in the Piltun Bay to be cleared away naturally by the current. If settled sediments are detected (for example, after strong storms), which complicates safe passage of barges, local leveling of the seabed will be performed using a long range back shovel excavator mounted on a barge or bridge boats. The project proposal outlines a number of alternative ways to deliver cargo to the Odoptu 2 drill site, including: Option 0 abandoning the plan to build the TUF, and deliver cargo through the port of Moskalvo (Fig. 1). Option 3а construction of a temporary foundation mechanism or boot basin on the Okhotsk Sea side, to the north of the gray whale feeding grounds for further transport of cargo overland. Option 4 construction of a TUF in the form of a 800 m long mound in Piltun Bay (Fig. 2) for barges to unload while afloat via water ballasting using a volume of 4,000 m3 for one operation. Figure 1. Map of Oil and Gas activity in the Western Gray Whale habitat 2

3 Figure 2. Map of the proposed mound in Piltun Bay The Piltun Bay is a large semi-closed coastal lagoon situated on the North Eastern coast of Sakhalin Island, and is separated from the Okhotsk Sea by two low sand spits. Piltun Bay is approximately 56 km long, and Astokh Bay is 71 km long. The bay s widest point is 12 km, and its overall surface area is 435 km2. This is the largest lagoon on northeastern Sakhalin. The only channel connects it with the Sea of Okhotsk. The outflow of the Piltun bay believed to play significant role in forming Western gray whale prey benthic communities. IMPACT ASSESSMENT Western North Pacific Gray Whale The main immediate impact on the western population of the Pacific gray whale will come from underwater noise generated by the passage of barges through the Piltun area of its grounds. The zone with dangerous noise levels exceeding 120 db includes the whales feeding grounds within a distance of over 40km along the Piltun sand spit. This zone will include most of the seaboard feeding grounds of the gray whale, which is the only suitable feeding area for mother and calf pairs. The project will use five towboats simultaneously in moment transfer barge from осеаnic towboat to four shallow-water towboats (and back); while the barge is transported from the transfer location (4km from the shore) to the bay and back by four towboats. Noise level from big oceanic towbout at towing can exceed 200 db3, while according to the Environmental Impact Assessment (EIA) data of this project the noise levels for shallow-water towboats (type Sesok/Nachik) are 194 db re 1 mkpa for each. According to the Expert analysis, the cumulative noise from four shallow-water towboats during a barge passage would be 200 db; the noise level from five towboats during the transfer operation would be 203 db. Thus, the Expert Council s calculations show that the radius of the dangerous noise impact zone (with a continuous noise level of over 120 db) will amount to approximately 20 km to the South as well as the same distance to the North and the East from the entrance to Piltun Bay. Considering that barge passage will occur twice a month during the navigation season over 3 3 Measurements was done by Jasco on Sakhalin, Reference: Hannay, D., MacGillivray, A, Laurinolli, M. and Racca, R., Source level measurements from 2004 Acoustics Program,

4 years (November 2015, 2016, 2017), the main area of the Piltun feeding grounds of the gray whale and the habitat of numerous seals will be within the area of what the Experts determined is inadmissible acoustic impact from continuous industrial noise over a considerable length of time (over a third of the gray whale s entire fall-summer feeding season). The expected cumulative acoustic impact from a series of seismic exploration activities planned by the oil and gas companies close to this area during the operation of the TUF (SEIC plan SS on Piltun area in 2015, Rosneft plan SS on North Chayvo in ) may bring the Western Gray Whale population to the brink of catastrophe, state the Expert Council. Therefore, the Expert Council concluded that Exxon Neftegaz Limited plans to build the temporary unloading facilities at the Piltun sand spit are unacceptable and contrary to the laws of the Russian Federation, due to the long-term negative acoustic impacts on the population of endangered gray whales. Besides immediate impact of the noise effect on whales, the amount of sand (83000 m 3 ) foreseen by the project to be left at TUF site in the water (after completion of operations and TUF disassembly) raises concerns about the effect of such volumes of sediment being introduced into the lagoon system, its hydrodynamic processes and the outflow which is one of the key features supporting benthic communities gray whales feed nearshore. Such effects, with potential for reducing the bay outflow, may have long-term negative and irreversible impacts on Western gray whale habitat, critical for the survival of the population. Aquatic Biota of Piltun Bay The Expert Council also observed that construction activities will have a negative physical impact on the biota due to the large volume of spoil that will be dumped into the waters during filling; this will lead to a sharp increase in the water s turbidity, and suspended solid particles in the water will also have adverse impacts for local biota. This will be a direct impact on the aquatic biota. In addition to the damage listed plainly in the project design materials, construction of the TUF will also kill plankton and benthos because dumped spoil will crush and asphyxiate small infauna, along with attached and slow moving forms of epifauna. At the actual site of the filling activities, death of a large portion of the plankton population is inevitable, as filling will occur non-stop from June to November, and additional sand filling will be performed during piling wall installation. This will have inevitable impacts on the gray whale, because of it s unique feeding on benthic organisms, which means they feed from the sea bottom, churning up the sea bed and filtering the disturbed invertebrates through their baleen plates. The shallow waters close to the island are the only waters that are suitable for mothers to teach their calves how to feed this way. Introduction of large volumes of sand into the lagoon system may also have significant impacts on the fishstock of Piltun lagoon in the long term. DISCUSSION The analysis of the proposed Sakhalin 1 Project, Odoptu Onshore facilities, Reconstruction of Odoptu 2 (Northern) Drill Site, Temporary Unloading Facilities of Exxon Neftegaz Limited led the Expert Council of the Public Environmental Expert Review to conclude that the project does not comply with the requirements of Russian environmental legislation (in particular, with the requirements of Article 24, Federal Law Concerning wildlife ). The Expert Council also concluded that the mentioned project contains considerable deficiencies with regards to its treatment of environmental, technical, and social issues, does not ensure environmental safety of the projected activities, and creates a high risk of accidents. The Expert Council concluded that implementation of any project option involving dredging, navigation, and unloading operations in the Piltun Bay and/or waters adjacent to the Bay is inadmissible due to the high impact on the ecosystem and fish stocks of the Piltun Bay, and the extremely negative effect on the largest multi-species true seal haulout (including the 4

5 world's largest ringed seal haulout) and the only known feeding grounds of the Western Pacific Gray Whale population, used by females and calf pairs. Not withstanding the above, the Russian government announced last March 4 the decision to move forward with Option 4 of the proposed project, a matter we are requesting be reconsidered. RECOMMENDED ALTERNATIVES Option 0 The Expert Council is of the opinion that Option 0 (delivering the cargo through the port of Moskalvo) is acceptable and must be carefully considered. Exxon Neftegaz Limited acquired extensive experience delivering heavy modules to the Odoptu 2 northern drilling site during the first phase of the oilfield s development during which it delivered materials through the port of Moskalvo using and improving the transport infrastructure that is already in place, as is mentioned in the project materials. As the project presentation indicates, if the modules size is reduced, they would number no more than units total. The rest of the cargo includes materials and equipment, none of which are large, and could be delivered either through the Moskalvo port or through the Korsakov and Kholmsk ports using existing railroads and motorways. Option 3b Also the Expert Council offers for consideration an alternative option for delivery of cargo to the Odoptu-2 drilling site through the construction of the TUF from the side of the Okhotsk Sea, to the north of the gray whale feeding grounds, using the Maly Ekhabi Bay for construction of the boot basin (Option 3b). This is a small lagoon bay, typical for northeast Sakhalin, measuring approximately 700 х 1600 m, and is situated 1 km to the north of the Ekhabi Bay with a narrow channel outlet to the Sea of Okhotsk. This option and the Moskalvo option would require extensive overland transportation of the modules, and would also require a decrease of their size and subsequent increase in the number of modules. This would lead to the considerable decrease in the size of barges, which in turn decreases the volume of dredging operations in the Sea of Okhotsk to make the access channel passable. Compared to Option 3a, this option has a number of considerable advantages: much lower volume of dredging operations; no need to do major construction work involving removal of material near the coast, as a natural harbor already exists here; much lower amount of maintenance and recovery activities on the TUF, as the boot basin would be built on the naturally existing silt bed; no threat of erosion and breach of the Piltun sand spit; the TUF would not conflict with the oilfields of JSC RN-Sakhalinmorneftegaz. The Maly Ekhabi Bay and the relevant Sea of Okhotsk coastal area apparently have less environmental sensitivity than the Piltun Bay, due to less diverse biota and absence of spawning grounds of the main economically and socially important fish species (except the Asian smelt and the Pond smelt). This results in a far lower diversity of birds in this bay. The bay has also already experienced considerable human-induced changes its condition is far from natural, but there is not any active oil or gas infrastructure. This Option compares favorably with Option 0 (Moskalvo) due to the fact that the necessary overland transportation route is half the distance: 47 km vs. 108 km, and it lies only in lowlands with no noticeable slopes. This option proposes using the decommissioned Okha Nogliki railroad section, situated 1 km away from the Maly Ekhabi Bay and further to the south, past the Ekhabi and the Odoptu bays before the Odoptu River. This would also require building a 2 km section of road from Maly Ekhabi Bay to the road that Exxon Neftegaz Limited, already widened and enforced for use in delivering large modules from the port of 4 Rosprirodnadzor under the Ministry of the Russian Federation (March 26, 2014) 5

6 Moskalvo to the Odoptu-2 drilling site. The proposed Option 3b compares favorably with Option 4, in particular due to total absence of negative impact on the Piltun Bay, its ecosystem, fish stocks, or seal haul outs at its mouth; minimized negative impact on the gray whale, as construction and operation of the TUF would take place outside of their feeding grounds; considerable decrease in the risk of accidents related barges capsizing, as the size of modules would be reduced; total absence of negative social and economic impacts and lack of impacts to indigenous people s traditional natural resource use, as the Maly Ekhabi Bay is not of value for them, and the transportation will take place mainly along the already disturbed areas (the abandoned railroad and the motorway which is already in use). The Expert Council is therefore of the opinion that selection of Option 4 is unfounded, and this option is highly likely to have extreme adverse consequences. On the basis of the combined environmental benefit approach, the most acceptable options would be Option 0 (Moskalvo), and Option 3b (the Maly Ekhabi Bay), outlined above. From the point of view of the social and economic interests of Russia and in particular of the Sakhalin region, Option 0 has considerable advantages over Option 4. CONCLUSION Having studied the proposed project, the Expert Council is of the opinion that due to the inadmissibly high adverse impact on the Western Pacfic Gray Whale population and on other marine mammals inhabiting the area of the Piltun Bay mouth, as well as the projected longterm negative impacts on the aquatic biota and fish stocks in Piltun Bay, the project operator must select a different option for delivery of large cargo than the one proposed in the project. The most acceptable option would be the delivery of large cargo either through the Moskalvo port or via a harbor in the Maly Ekhabi Bay. Finally, the Expert Council stated that it is necessary to justify site selection for cargo delivery in great detail, and conduct an environmental impact assessment for such option in compliance with the current legislation. REFERENCES WGWAP-13. Report of the Western Gray Whale Advisory Panel at its Thirteenth Meeting. Tokyo, Japan, May, Public Environmental Expert Review of Sakhalin 1 Project. Odoptu Onshore facilities. Reconstruction of Odoptu 2 (Northern) Drill Site. Temporary Unloading Facilities of Exxon Neftegaz Limited ( Jones, Mary Lou., Steven L. Swartz, and Stephen Leatherwood. The Gray Whale: Eschrichtius Robustus. Orlando, FL: Academic, Print. 6