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4.0 CUMULATIVE IMPACTS

Cumulative impacts are defined by the Council on Environmental Quality (CEQ) regulations in 40 Code of 

Federal Regulations (CFR) 1508.7 (1978) as the “impact on the environment which results from the 

incremental impact of the [proposed] action when added to other past, present, and reasonably 

foreseeable future actions regardless of what agency (federal or non-federal) or person undertakes such 

actions. Cumulative impacts can result from individually minor, but collectively significant, actions taking 

place over a period of time.”

Cumulative effects may be additive or interactive. Additive effects are the sum of the effects on a 

resource; for example, groundwater pumping for agricultural irrigation, domestic consumption, and 

industrial cooling and process activities that all contribute incrementally and additively to drawing down 

a groundwater aquifer. Interactive effects may be either countervailing – where the net adverse 

cumulative effect is less than the sum of the individual effects – or synergistic – where the net adverse 

cumulative effect is greater than the sum of the individual effects. An example of a countervailing effect 

is when particulate matter and aerosol air pollutants, which tend to block or reflect insolation (sunlight or 

incoming solar radiation) and thus cool the planet surface, counteract the warming or radiative forcing 

effect of carbon dioxide emitted at the same time. The discharge of nutrients and heated water to a river 

that combine to cause an algal bloom and subsequent loss of dissolved oxygen greater than the additive 

effects of each individual pollutant is an example of a synergistic effect. CEQ recommends that the 

cumulative impact analysis be narrowed as much as possible to focus on important issues at a national, 

regional, or local level (CEQ, 1997b). The first step in the cumulative impacts analysis is to identify 

cumulative actions. The second step is to analyze how, if at all, the effects of the Proposed Action may 

contribute to the effects of the cumulative actions thereby resulting in cumulative impacts (Section 4.2).

4.1 CUMULATIVE ACTIONS

Per 40 CFR 1508.25(a)(2), cumulative actions are those past, present, and reasonably foreseeable future 

actions that must be addressed in a cumulative effects analysis because their environmental effects may 

combine with the effects of the Proposed Action addressed in the National Environmental Policy Act

(NEPA) document (CEQ, 1997b). Based on the scope of the National Ocean Service (NOS) Proposed Action 

and the amount of information available regarding the past, present, and reasonably foreseeable future 

actions taking place in the action area that was defined in Chapter 2, NOS has considered actions taking 

place during a 17-year period spanning from 2010 to 2027. Due to the volume and diversity of these 

cumulative actions, this section identifies specific projects and programs, both public and private sector, 

but also relevant environmental and economic trends.

In addition to the more substantial or widespread cumulative actions described in Sections 4.1.1-4.1.12, 

the resources in the action area, particularly biological resources, are sensitive to other human activities 

that should also be considered in the cumulative impact analysis, when appropriate. These additional 

activities include:

• Accumulation of marine debris from marine or terrestrial sources (e.g., plastics, polystyrene, glass, 

metals, or rubber);

• Accidental or illicit discharges (e.g., oil or fuel spills or other introduction of chemical 

contaminants);

• Habitat encroachment from onshore and nearshore development (e.g., as a function of coastal 

population growth);
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• Illegal, unreported, and unregulated (IUU) fishing;

• Flows of non-point source pollutants, contaminants, sediments, and nutrients from urbanized and 

agricultural areas in watersheds into coastal waters, with the greatest adverse effects 

experienced in waters with limited circulation such as bays, sounds, and estuaries.

As a result of the ongoing global coronavirus disease 2019 (COVID-19) pandemic, there has been a 

measurable decrease in maritime activities, including the delay and cancellation of ocean research 

projects, to ensure the health and safety of maritime workers and the coastal population. The reduction 

in overall maritime activity such as shipping, fishing operations, recreation/tourism, and research efforts 

would be expected to reduce long-term and short-term impacts on coastal environments and the ambient 

ocean sound level; however, impacts are not fully known (NOAA, 2020b). At the same time, the ongoing 

pandemic is expected to reduce the beneficial economic impacts of many maritime activities (NMFS, 

2021b). Despite the potential short- and long- term cumulative effects of the ongoing global COVID-19 

pandemic on the resources evaluated in this Final Programmatic Environmental Impact Statement (PEIS), 

the pandemic is not considered in this analysis because its effects are not fully known. In general, 

decreases in maritime activity would be expected to decrease impacts to the coastal environment; 

therefore, the conservative assumption is to assess cumulative impacts under pre-pandemic cumulative 

actions.

4.1.1 Other Surveying and Mapping Efforts in the Action Area

As of the summer of 2010, only 906,496 square kilometers (km2) (350,000 square miles [mi2]) of seafloor, 

less than 8 percent of the U.S. Exclusive Economic Zone (EEZ), had been mapped in the Atlantic, Pacific, 

Gulf of Mexico, and Arctic (NSTC, 2013). As of 2020, 43 percent of the 8,905,960 km2 (3.4 million square 

nautical miles [nm2

]) of U.S. underwater territory is mapped to modern standards (NOAA, 2020c). Given 

the many applications of the collected data, agencies at all governmental levels, universities, non-profit 

research institutions, and the private sector, conduct surveying and mapping projects in the action area. 

Other agencies or private groups performing hydrographic surveys would use echo sounders and 

equipment similar to those described in Chapter 2. Surveying and mapping projects that use a 

combination of different equipment and techniques can be referred to by what they are mapping rather 

than by the type of surveying equipment used. Benthic (ocean floor or lake bottom) habitat mapping 

entails using a combination of techniques, such as acoustics and lidar, to create a spatially explicit way to 

identify submerged features (NPS, 2018). Geological and geophysical (G&G) surveys are used to map gas 

hydrate deposits, bedrock characteristics, and marine mineral resources (BOEM, 2018b; USGS, 2019a). 

Marine seismic surveys are a type of G&G survey that use a variety of acoustic sources to image sediment 

and rock deep below the seafloor (USGS, 2019a). For example, deep penetration seismic airgun surveys 

are conducted by vessels towing an array of airguns that produce low frequency sound pulses that 

penetrate deep into the subsurface and are then reflected and recorded by receivers to image deep 

geological features (BOEM, 2018b). This mechanism is illustrated in Figure 4.1-1 below. 
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Source: BOEM, 2018a

Figure 4.1-1. Deep Penetration Seismic Airgun Surveying

High resolution geophysical (HRG) surveys are another type of G&G survey which use sound waves that 

are reflected off submerged structures to collect data on conditions both at the seafloor and the shallow 

subsurface. HRG equipment generally includes the sonar survey equipment described in Chapter 2 (e.g., 

multibeam echo sounders, side-scan sonars, sub-bottom profilers). HRG systems usually use higher 

frequencies than those used in seismic airgun surveys and image smaller structures with a higher level of 

detail (BOEM, 2018b). HRG surveys, deep penetration seismic surveys, and other types of G&G surveys 

are used during the preliminary resource assessment phases for Oil and Gas (O&G) exploration, renewable 

energy siting, and marine mineral projects (BOEM, 2018b). 

Surveying and mapping projects can also involve the collection of “core” (samples that preserve surface 

and subsurface sediment layers) and “grab” samples from the seafloor. Additional equipment used in 

these projects can include pressure gauges for measuring waves and currents, Acoustic Doppler Current 

Profilers (ADCPs) for measuring water depth, autonomous and towed instrumentation for characterizing 

ocean chemistry, and optical backscatter remote-sensing instruments for estimating the concentration of 

sediment in the water column (USGS, 2020).

Coordination within the ocean and coastal mapping community is facilitated through the Interagency 

Working Group on Ocean and Coastal Mapping (IWG-OCM) under the National Ocean Council (NSTC, 

2016; IOCM, No Date-a). In addition to NOAA, other federal agencies that undertake or permit surveying 

and mapping projects include Bureau of Ocean Energy Management (BOEM), Federal Emergency 

Management Agency (FEMA), National Park Service (NPS), Naval Oceanographic Office (NAVO), United 

States Army Corps of Engineers (USACE), and United States Geological Survey (USGS).

Universities, Non-Profit Research Institutions, and Other Private Sector Efforts. Many of the federal 

agencies that undertake or permit surveying and mapping projects support research conducted at 

universities, non-profits, and other institutions. Ocean use activities are coordinated through the 

University-National Oceanographic Laboratory System (UNOLS), an organization of academic institutions 
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and National Laboratories (UNOLS, No Date). UNOLS vessels conduct a wide array of research activities 

including marine seismic research and oceanographic aircraft research (UNOLS, 2021).

Given the exceptional variability and vast number of surveying and mapping activities in the action area, 

it is not possible to provide an exhaustive list of all projects in the action area; however, by identifying 

regional surveying and mapping needs and using incidental take authorization data, reasonably 

foreseeable surveying and mapping projects are described for each region.

Due to their potential impact to marine mammals, surveying and mapping projects that use active acoustic 

sources require incidental take authorizations granted by the National Marine Fisheries Service (NMFS) 

under the Marine Mammals Protection Act (MMPA) (NMFS, 2019d). A list of recent surveying and 

mapping projects that require incidental take authorization is presented for each region below as a 

representative, not exhaustive, list of other surveying and mapping projects. These projects are 

categorized as G&G surveys, ecological monitoring, or fisheries management and research because of the 

difference in potential impact. G&G surveys are typically localized and require the use of high intensity 

active acoustic sources that penetrate the surface of the seafloor, while ecological monitoring and 

fisheries management and research generally use lower intensity active acoustic sources. Projects with an 

active take authorization status and projects with a take authorization application in-process are 

considered reasonably foreseeable to occur within the next five years and are categorized as ongoing 

activities. Projects that have been granted take authorizations that have expired within the past 10 years 

are considered activities that have occurred within the past 10 years. Smaller data acquisition projects 

and hydrographic surveys that did not require incidental take authorization are not captured in Tables 

4.1-1-4.1-5. Although projects that require take authorization are not the only projects occurring in the 

action area, they are used as a representative list because projects that require take authorization are 

expected to be the projects with the greatest impact.

4.1.1.1 Greater Atlantic Region

The Chesapeake Bay is the largest of 130 estuaries in the U.S. and much of it has not been charted since 

the 1930s and 1940s, causing great interest in new surveying and mapping of the area (NOAA, No Dateh). Additionally, the National Science Foundation (NSF) has funded marine geophysical surveys off the 

New Jersey coast and Cape Hatteras and has previously partnered with the USGS to conduct seismic 

surveys throughout the Atlantic (NSF, No Date). Additional surveying and mapping projects are expected 

to occur in the region for offshore renewable energy project siting, ecological monitoring, fisheries 

management, and navigational purposes; a representative list of these projects is presented below in 

Table 4.1-1 (NOAA, No Date-h; NMFS, 2019d).

Table 4.1-1. Representative List of Surveying and Research Projects

within the Greater Atlantic Region

Type of 

Surveying 

and Mapping 

Activity

Project 

Category

General 

Location / 

Geographic 

Scope Project Lead Project/Permit Description

Ongoing Activities

Ecological 

Monitoring Research/Other

Eastern MA 

NWRs

USFWS Seabird and shorebird 

monitoring and research
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Type of 

Surveying 

and Mapping 

Activity

Project 

Category

General 

Location / 

Geographic 

Scope Project Lead Project/Permit Description

Fisheries 

Management 

and Research

Research/Other

Atlantic Coast 

Region

NMFS NEFSC Northeast fisheries and 

ecosystem research activities

Atlantic Ocean 

south of Long 

Island

NMFS SEFSC Fisheries and ecosystem 

research activities in the 

Atlantic Ocean

G&G Survey Offshore Wind

NY Equinor Wind 

LLC

Offshore wind surveys

Offshore New 

England

Orsted Ocean 

Wind LLC 

Marine site characterization 

surveys, offshore NJ

Offshore of DE 

and MD

Skipjack Site characterization surveys

Activities within the Past 10 years

Ecological 

Monitoring Research/Other

Cape Cod MA 

NWRs; Eastern 

MA NWRs

USFWS Seabird and shorebird 

monitoring and research

G&G Survey

Offshore Wind

Nantucket 

Sound, MA

Cape Wind 

Associates

High-resolution seismic survey 

in Nantucket Sound, MA

Offshore RI Deepwater 

Wind LLC

Marine site characterization 

surveys, offshore NY

Offshore RI Deepwater 

Wind New 

England LLC

Marine site characterization 

surveys, offshore NY, RI

MA DONG Energy 

MA LLC

Geophysical and Geotechnical 

Surveys Offshore MA

Offshore DE Garden State 

Offshore 

Energy LLC

Marine site characterization 

(geophysical and geotechnical) 

surveys for Skipjack Wind farm

Offshore 

Atlantic City, NJ

Ocean Wind 

LLC

Marine site characterization 

surveys, offshore NJ

NY Statoil Offshore wind surveys

Research/Other

Atlantic Ocean 

off NJ

Lamont 

Doherty Earth 

Observatory / 

NSF 

Marine seismic survey in 

Atlantic Ocean off NJ

Atlantic Ocean 

off the Eastern 

Seaboard

USGS Marine seismic survey in the 

Atlantic Ocean off the Eastern 

Seaboard
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Type of 

Surveying 

and Mapping 

Activity

Project 

Category

General 

Location / 

Geographic 

Scope Project Lead Project/Permit Description

Northwest 

Atlantic

USGS Geophysical surveys

Source: NMFS, 2019d

NEFSC = Northeast Fisheries Science Center; NMFS = National Marine Fisheries Service; NSF = National Science 

Foundation; NWR = National Wildlife Refuge; SEFSC = Southeast Fisheries Science Center; USFWS = U.S. Fish and 

Wildlife Service; USGS = U.S. Geological Survey

4.1.1.1.1 Great Lakes

There are no projects that require incidental take authorizations in the Great Lakes because there are no 

marine mammals; however, the Great Lakes region is one of NPS’s current benthic mapping priorities. 

NPS has collected multibeam sonar and backscatter data at all the Great Lakes Parks (NPS, 2018). More 

surveying and mapping projects are likely to occur in the Great Lakes region for habitat conservation and 

navigational purposes.

4.1.1.2 Southeast Region

Additional surveying and mapping projects are expected to occur in the Southeast region for oil and gas 

siting, offshore renewable energy project siting, ecological monitoring, fisheries management, and 

navigational purposes; a representative list of these projects is presented below in Table 4.1-2 (NOAA, No 

Date-i; NMFS, 2019d).

Table 4.1-2. Representative List of Surveying and Research Projects

within the Southeast Region

Type of 

Surveying 

and Mapping 

Activity

Project 

Category

General 

Location / 

Geographic 

Scope Project Lead Project/Permit Description

Ongoing Activities

Ecological 

Monitoring Research/Other 10 Major Bay systems of TX

Texas Parks and 

Wildlife

Fishery independent 

monitoring activities

Fisheries 

Management 

and Research

Research/Other

Eastern 

Caribbean; Gulf 

of Mexico; 

Western 

Caribbean

NMFS SEFSC

Fisheries and ecosystem 

research activities in the 

Atlantic Ocean

G&G Survey

Offshore Wind Offshore NC Avangrid 

Renewables, LLC

Site characterization surveys 

off NC

Oil and Gas Gulf of Mexico BOEM Seismic surveys in the Gulf of 

Mexico
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Type of 

Surveying 

and Mapping 

Activity

Project 

Category

General 

Location / 

Geographic 

Scope Project Lead Project/Permit Description

Activities within the Past 10 years

G&G Survey

Offshore Wind Offshore VA Dominion 

Energy Virginia

Unexploded Ordinance 

Survey in Lease of 

Submerged Lands for 

Renewable Energy 

Development on the Outer 

Continental Shelf (OCS-A 

0497) (Lease Area)

Research/Other

Atlantic Ocean 

off NC

Lamont Doherty 

Earth 

Observatory / 

NSF 

Seismic survey in the Atlantic 

Ocean off NC

Northwest Gulf 

of Mexico USGS Seismic survey in the deep water of the Gulf of Mexico

Source: NMFS, 2019d

BOEM = Bureau of Ocean Energy Management; NMFS = National Marine Fisheries Service; NSF = National Science 

Foundation; SEFSC = Southeast Fisheries Science Center; USGS = U.S. Geological Survey

4.1.1.3 West Coast Region

Hydrographic surveying projects planned along the Pacific Coast include geologic hazard assessments, 

seafloor mapping projects in the area provide multibeam bathymetry, acoustic backscatter data, and 

water column data that are used for earthquake, tsunami, and landslide hazard assessments and 

situational awareness products (NOAA, No Date-j). The NSF has funded marine geophysical surveys off 

the coasts of Oregon, Washington, and Central California and more specifically, the Cascadia Subduction 

Zone, which extends from northern Vancouver Island to Northern California (NSF, No Date). Additional 

surveying and mapping projects are expected to occur in the region for offshore energy siting, ecological 

monitoring, fisheries management, hazard assessment, and navigational purposes; a representative list 

of these projects is presented below in Table 4.1-3 (NOAA, No Date-j; NMFS, 2019d).

Table 4.1-3. Representative List of Surveying and Research Projects

within the West Coast Region

Type of 

Surveying 

and 

Mapping 

Activity

Project 

Category

General Location / 

Geographic Scope Project Lead

Project/Permit 

Description

Ongoing Activities

Ecological 

Monitoring Research/Other CA and OR UC Santa Cruz

PISCO rocky intertidal 

monitoring in CA and 

OR
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Type of 

Surveying 

and 

Mapping 

Activity

Project 

Category

General Location / 

Geographic Scope Project Lead

Project/Permit 

Description

Fisheries 

Managemen

t and 

Research

Research/Other

California Current 

Research Area; Lower 

Columbia River 

Research Area; Puget 

Sound Research Area

NMFS NWFSC

Northwest fisheries 

and ecosystem 

research activities

California Current 

Research Area NMFS SWFSC

Fisheries and 

ecosystem research 

activities in the Pacific 

Ocean

G&G Survey Research/Other

Northeast Pacific

Lamont Doherty 

Earth Observatory 

/ NSF 

Marine Geophysical 

Survey in the 

Northeast Pacific

Off Oregon North; 

Off Oregon South

Scripps Institution 

of Oceanography

Seismic survey in the 

Northeastern Pacific 

Ocean

Activities within the Past 10 years

Ecological 

Monitoring Research/Other

Palmer's Point; Point 

Dume; Point Arena; 

Ten Mile

UC Santa Cruz

PISCO rocky intertidal 

monitoring in CA and 

OR

G&G Survey Research/Other

Southeast Farallon 

Islands, CA

Gulf of the 

Farallones NMS, 

CA 

Abalone survey, CA

Line Islands

Lamont Doherty 

Earth Observatory 

/ NSF 

Low-energy seismic 

survey in the Pacific 

Ocean, Line Islands

Cascadia Thrust Zone 

north, WA; Cascadia 

Thrust Zone south, 

OR; Juan de Fuca 

Plate study area, 

Pacific Northwest

Lamont Doherty 

Earth Observatory 

/ NSF 

Seismic survey in the 

Northeast Pacific 

Ocean

Central Pacific Ocean Scripps

Research seismic 

survey in the Central 

Pacific Ocean

Source: NMFS, 2019d

NMFS = National Marine Fisheries Service; NMS = National Marine Sanctuary; NSF = National Science Foundation; 

NWFSC = Northwest Fisheries Science Center; PISCO = Partnership for Interdisciplinary Studies of Coastal Oceans; 

SWFSC = Southwest Fisheries Science Center; UC = University of California
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4.1.1.4 Alaska Region

Some parts of the Alaska coastline, including the vast majority of the Lisianski Inlet next to Chichagof Island 

in the Alexander Archipelago, were last surveyed in 1917 (NOAA, No Date-k). Some soundings in the Arctic 

region date back to the work of Captain Cook in the 18th century. In the time since these surveys, the 

retreat of arctic sea ice has increased vessel traffic in the region, resulting in an even greater need for 

updated maps. The Port of Kodiak has seen many groundings and near misses due to the number of 

dangers to navigation that exist in this area. Additional surveying and mapping projects are expected to 

occur in these areas for navigational purposes, ecological monitoring, fisheries management, offshore 

energy siting, and offshore Liquified Natural Gas (LNG) projects; a representative list of these projects is 

presented below in Table 4.1-4 (NOAA, No Date-k; NMFS, 2019d).

Table 4.1-4. Representative List of Surveying and Research Projects

within the Alaska Region

Type of 

Surveying and 

Mapping 

Activity

Project 

Category

General Location / 

Geographic Scope Project Lead

Project/Permit 

Description

Ongoing Activities

Ecological 

Monitoring Research/Other

Boulder Island; Flapjack 

Island; Geikie Rock; 

Lone Island

NPS - Glacier 

Bay National 

Park

Seabird research and 

monitoring in Glacier 

Bay National Park, AK

Kachemak Bay; Katmai 

National Park and 

Preserve; Kenai Fjords 

National Park

NPS - SWAN

Research and 

Monitoring Activities in 

Southern Alaska 

National Parks

Fisheries 

Management 

and Research

Research/Other

Bering Sea and Aleutian 

Islands; Chukchi and 

Beaufort Seas; Gulf of 

Alaska 

NMFS AFSC Fisheries Research

G&G Survey

Offshore LNG Cook Inlet, AK

ExxonMobil 

Alaska LNG 

LLC 

Geophysical and 

geotechnical survey in 

Cook Inlet, AK

Oil and Gas Cook Inlet, AK Apache 

Alaska Co.

Seismic survey in Cook 

Inlet, AK

Research/Other Alaska

Lamont 

Doherty 

Earth 

Observatory / 

NSF 

Marine Geophysical 

Survey in the Gulf of 

Alaska

Activities within the Past 10 years

Ecological 

Monitoring Research/Other

Boulder Island; Flapjack 

Island; Geikie Rock; 

Lone Island

NPS - Glacier 

Bay National 

Park

Seabird research and 

monitoring in Glacier 

Bay National Park, AK
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Type of 

Surveying and 

Mapping 

Activity

Project 

Category

General Location / 

Geographic Scope Project Lead

Project/Permit 

Description

G&G Survey

Offshore LNG Cook Inlet, AK

ExxonMobil 

Alaska LNG 

LLC 

Geophysical and 

geotechnical survey in 

Cook Inlet, AK (2016)

Oil and Gas

Cook Inlet, AK Apache 

Alaska Co.

Seismic survey in Cook 

Inlet, AK

Beaufort Sea, AK BP Open water seismic 

survey

Prudhoe Bay, AK BP Prudhoe Bay, AK 

seismic survey

Foggy Island Bay, AK BP

Shallow geohazard 

surveying Foggy Island 

Bay, AK 

Beaufort Sea, AK Hilcorp

Shallow geohazard 

survey in the Beaufort 

Sea, AK

Beaufort and Chukchi 

Seas, AK

ION 

Geophysical 

Seismic surveys in the 

Beaufort and Chukchi 

Seas, AK

Zone 1 Cook Inlet, AK; 

Zone 2 Cook Inlet, AK

SAExploration 

Inc.

Seismic survey in Cook 

Inlet, AK

Beaufort Sea, AK SAExploration 

Inc.

Seismic surveys in 

Beaufort Sea, AK

Ice gouge survey 

Beaufort Sea, AK Shell

Open water survey in 

the Beaufort and 

Chukchi Seas, AK

Ice gouge survey 

Chukchi Sea, AK Shell

Open water survey in 

the Beaufort and 

Chukchi Seas, AK

Shallow hazards survey 

Beaufort Sea, AK Shell

Open water survey in 

the Beaufort and 

Chukchi Seas, AK

Strudel scour survey 

Beaufort Sea, AK Shell

Open water survey in 

the Beaufort and 

Chukchi Seas, AK

Chukchi Sea, AK Shell Seismic survey in the 

Chukchi Sea, AK

Chukchi and Beaufort 

Seas, AK

Shell Gulf of 

Mexico Inc.

Ice overflight surveys in 

the Chukchi and 

Beaufort Seas, AK
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Type of 

Surveying and 

Mapping 

Activity

Project 

Category

General Location / 

Geographic Scope Project Lead

Project/Permit 

Description

Chukchi Sea, AK StatOil 3D seismic survey in 

Chukchi Sea, AK

Alaskan Chukchi Sea StatOil

Shallow hazards seismic 

survey in the Alaskan 

Chukchi Sea

Chukchi Sea, AK

TGS-NOPEC 

Geophysical 

Co.

Seismic survey in the 

Chukchi Sea, AK

Research/Other

Unidentified island, 

Eastern Aleutian 

Islands, AK

BLM

Survey activities in the 

Eastern Aleutian 

Islands, AK

Western Gulf of Alaska

Lamont 

Doherty 

Earth 

Observatory / 

NSF 

Seismic survey in the 

Western Gulf of Alaska

Central Gulf of Alaska USGS

Geophysical survey in 

the Central Gulf of 

Alaska

Central-Western Bering 

Sea

USGS

Geophysical survey in 

the Central-Western 

Bering Sea

Central Gulf of Alaska USGS

Research seismic 

survey in the Central 

Gulf of Alaska

Source: NMFS, 2019d

AFSC = Alaska Fisheries Science Center; BLM = Bureau of Land Management; LNG = Liquified Natural Gas; NMFS = 

National Marine Fisheries Service; NPS = National Parks Service; NSF = National Science Foundation; SWAN = 

Southwest Alaska Inventory and Monitoring Network; USGS = U.S. Geological Survey

4.1.1.5 Pacific Island Region

The USGS plans to map coral reefs including sediment- or pollutant-impacted reefs, and those of special 

significance and concern such as reefs in state or national parks, national wildlife refuges, or national 

marine sanctuaries as part of a Pacific Coral Reefs Project (USGS, 2019b). Additional surveying and 

mapping projects are expected to occur in the region for habitat conservation, fisheries management, and 

navigational purposes; a representative list of these projects is presented below in Table 4.1-5 (NMFS, 

2019d).
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Table 4.1-5. Representative List of Surveying and Research Projects

within the Pacific Island Region

Type of 

Surveying 

and Mapping 

Activity

Project 

Category

General Location / 

Geographic Scope Project Lead

Project/Permit 

Description

Ongoing Activities

Fisheries 

Management 

and Research

Research/ 

Other

American Samoa 

Archipelago Research 

Area; Hawaiian 

Archipelago Research 

Area; Mariana 

Archipelago Research 

Area; Western and 

Central Pacific 

Research Area

NMFS PIFSC

Pacific Islands fisheries 

and ecosystem research 

activities

Activities within the Past 10 years

G&G Survey Research/ 

Other

Central Pacific Ocean

Lamont 

Doherty Earth 

Observatory / 

NSF 

Seismic survey in 

Central Pacific Ocean

CNMI

Lamont 

Doherty Earth 

Observatory / 

NSF 

Seismic survey in CNMI

Emperor Seamounts; 

Main Hawaiian Islands

LamontDoherty Earth 

Observatory

Marine Geophysical 

Surveys by the R/V 

Marcus G. Langseth in 

the North Pacific Ocean, 

2018/2019

Wake island

Scripps 

Institution of 

Oceanography

Low-energy seismic 

survey in the Western 

Tropical Pacific Ocean

Central Pacific Ocean University of 

Hawai’i

Marine Geophysical 

Survey in the Central 

Pacific Ocean

Source: NMFS, 2019d

CNMI = Commonwealth of the Northern Mariana Islands; NMFS = National Marine Fisheries Service; PIFSC = Pacific 

Island Fisheries Science Center; SWFSC = Southwest Fisheries Science Center; NSF = National Science Foundation

4.1.1.6 Expected Increases in Ocean Surveying and Mapping

Over the next decade, surveying and mapping projects are expected to increase throughout the action 

area to meet the existing regional needs described above and to meet new mapping goals. The November 

2019 Presidential Memorandum on Ocean Mapping of the United States Exclusive Economic Zone and the 
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Shoreline and Nearshore of Alaska (2019 Presidential Memo) cited the importance of the ocean economy 

to the nation and the need for updated and complete mapping of the EEZ to support it. Sections 2 and 3 

of the memorandum specifically address the need to develop a strategy for mapping the entire EEZ and 

Alaska, respectively (The White House, 2019). In light of the 2019 Presidential Memo, the number and 

frequency of surveying and mapping projects in the action area, specifically in the Alaska region, are 

expected to increase.

NOAA has also committed to supporting and contributing to Seabed 2030, an international joint project 

between the Nippon Foundation and the General Bathymetric Chart of the Oceans (GEBCO) Guiding

Committee with the goal of producing a complete, high-resolution bathymetric map of the world’s seabed 

from the coasts to the deepest trenches by the year 2030 (OCS, 2018). While the majority of the project 

is outside the geographic scope of this analysis, future hydrographic surveys and mapping within the U.S. 

EEZ will be driven by data gap assessments completed in support of this project and the 2019 Presidential 

Memo. Future hydrographic surveying methods could include collaborative mapping missions, 

crowdsourced bathymetry from essential partners such as fishing boats, ocean-going carriers, and 

recreational vessels, and technological innovations that force-multiply capacities to collect sonar data 

efficiently in remote and challenging locations (OCS, 2018). 

Both Seabed 2030 and the 2019 Presidential Memo make comprehensive ocean mapping a priority for 

the coming decade (IOCM, No Date-b). With this increase, new and more efficient technologies to rapidly 

characterize the ocean are expected to be developed. For example, NOAA has announced a four-year 

Cooperative Research and Development Agreement (CRADA) with a private company, Ocean Infinity, to 

develop deep-water autonomous technologies that can gather ultra-high-resolution ocean information 

(NOAA, 2020c). 

In addition to the use of various active acoustic sources, other impact causing factors associated with all 

types of surveying and mapping projects include seafloor disturbance to collect bottom samples, vessel 

presence, impacts to the water column, vessel and equipment noise, and the potential for accidental 

discharges. Other surveying and mapping efforts in the action area would likely contribute cumulative 

impacts related to all resources covered in this PEIS.

4.1.2 Offshore Oil and Natural Gas Development

BOEM manages the exploration and development of offshore energy by the O&G industry on the 2.5 

billion-acre U.S. outer continental shelf (BOEM, 2018b). The U.S. outer continental shelf comprises the 

portion of the seabed lying seaward of State coastal waters to the out border of the EEZ. As per the Outer 

Continental Shelf Lands Act (OCSLA), BOEM can grant leases for the exploration, development, and 

production of O&G and other mineral resources on the outer continental shelf. Each lease covers up to 

2,331 hectares (ha) (6.8 nm2

) and is generally a square measuring 4.8 by 4.8 km (3 by 3 mi) (BOEM, No 

Date-a).

Interested companies must submit plans to BOEM prior to initiating any activity to explore a block for 

resources and/or to develop and produce O&G resources (BOEM, No Date-b). Following the preliminary 

G&G surveys described in Section 4.1.1, offshore oil and natural gas development generally involve the 

following phases with corresponding impact causing factors:

1) Exploration, which may include the use of mobile drilling units to drill a series of individual wells 

to locate and test the recoverability of oil and gas reserves and increased vessel traffic to and from 

the site;
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2) Development, which generally involves continued vessel traffic in the area, barge operations, 

drilling multiple wells in close proximity to each other, and the construction and installation of a 

platform to collect recovered oil and gas and a pipeline to transfer the oil and gas to the shore;

3) Production/extraction, which involves continued vessel traffic and the extraction of the oil and 

gas and its transport to shore for processing; and

4) Decommissioning/platform removal, which involves the demolition of oil and gas infrastructure 

or abandonment of structures; demolition involves increased boat and barge traffic to and from 

the site and could potentially involve the use of explosives.

Each phase of oil and natural gas development would involve active underwater acoustic sources, seafloor 

disturbance including sampling and drilling, dredging, vessel presence, vessel and equipment noise, 

impacts to the water column, potential accidental discharges and oil spills, and air emissions (BOEM, 

2019b).

4.1.2.1 Oil and Gas Energy Programs

The National Outer Continental Shelf Oil and Gas Leasing Program (National Outer Continental Shelf 

Program) specifies the size, timing, and location of potential leasing activity. For this reason, reviewing 

the program lease sale schedules in addition to reviewing the incidental take authorizations granted to oil 

and gas projects by NMFS under the MMPA provides a good understanding of previous, current, and 

reasonably foreseeable O&G projects. Projects which are currently in the preliminary G&G surveying 

phase were presented in the previous section (Section 4.1.1). Currently, BOEM is working under the 2017-

2022 National Outer Continental Shelf Program. BOEM updates the program in five-year increments, and 

has published a draft proposed National Outer Continental Shelf Program for 2019-2024 (BOEM, No Datec; BOEM, 2018c). The 2019-2024 Draft Proposed Program Lease Sale Schedule is summarized in Table 4.1-

6 below.

Table 4.1-6. BOEM 2019–2024 Draft Proposed Program Lease Sale Schedule

Sale Year Region Program Area

2019 Alaska Beaufort Sea

2020

Alaska Chukchi Sea

Pacific Southern California

Gulf of Mexico Western, Central, and Eastern Gulf of Mexico*

Western, Central, and Eastern Gulf of Mexico*

Atlantic South Atlantic

Mid-Atlantic

2021

Alaska Beaufort Sea

Cook Inlet

Pacific

Washington/Oregon

Northern California

Central California

Atlantic North Atlantic

Gulf of Mexico Western, Central, and Eastern Gulf of Mexico*

Western, Central, and Eastern Gulf of Mexico*

2022 Alaska Chukchi Sea
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Sale Year Region Program Area

Pacific Southern California

Atlantic Mid-Atlantic

South Atlantic

Gulf of Mexico Western, Central, and Eastern Gulf of Mexico*

Western, Central, and Eastern Gulf of Mexico*

2023

Alaska

Beaufort Sea

Cook Inlet

Hope Basin

Norton Basin

St. Matthew-Hall

Navarin Basin

Aleutian Basin

St. George Basin

Bowers Basin

Aleutian Arc

Shumagin

Kodiak

Gulf of Alaska

Pacific Central California

Northern California

Gulf of Mexico

Western, Central, and Eastern Gulf of Mexico*

Western, Central, and Eastern Gulf of Mexico*

Eastern and Central Gulf of Mexico **

Atlantic Straits of Florida

North Atlantic

2024

Alaska Chukchi Sea

Gulf of Mexico

Western, Central, and Eastern Gulf of Mexico*

Western, Central, and Eastern Gulf of Mexico*

Eastern and Central Gulf of Mexico **

Atlantic South Atlantic

Mid-Atlantic

Source: BOEM, 2018c

*All available areas, not including those subject to the Gulf of Mexico Energy Security Act (GOMESA) moratorium 

through June 30, 2022. The GOMESA mandates that the states of Texas, Louisiana, Mississippi, and Alabama 

receive a portion of revenues from new oil and natural gas development in federal waters adjacent to the 

respective state (BOEM, 2018c).

**Those areas available following the expiration of the GOMESA moratorium.

4.1.2.2 Alaska Outer Continental Shelf Region

The Arctic region in total contains an estimated 13 percent of the world’s undiscovered oil and 30 percent 

of undiscovered natural gas (USCG, 2018). The Alaska outer continental shelf encompasses the Beaufort 

and Chukchi Seas, the Bering Sea, Cook Inlet, and the Gulf of Alaska, spanning more than 404,685,642 ha 
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(1,179,875 nm2). Alaska contains more than 9,656 km (6,000 mi) of coastline – more coastline than in the 

rest of the U.S. combined (BOEM, No Date-c). There are 54 active leases in the Alaska region (BOEM, 

2019c; BOEM, 2019d). The O&G leasing program areas are depicted below in Figure 4.1-2.

Source: BOEM, No Date-c

Figure 4.1-2. Alaska Outer Continental Shelf Program Areas

Decreasing sea ice and diminishing onshore oil production are creating incentives for further exploration 

offshore in the Arctic region as a whole (USCG, 2018). With the exception of the take authorization granted 

to ExxonMobil in the Santa Barbara Channel, all projects that have been granted incidental take 

authorizations for construction and operation relating to oil and gas development have occurred in the 

Alaska region (NMFS, 2019d). A summary of these projects is presented below in Table 4.1.7 as a 

representative, not exhaustive, list of offshore oil and gas development projects. Projects with an active 

take authorization status and projects with a take authorization application in-process are considered 

reasonably foreseeable to occur within the next five years and are categorized as ongoing activities. 

Projects that have been granted the requested take authorizations that have expired within the past 10 

years are considered activities that have occurred within the past 10 years. Although projects that require 

take authorization are not the only projects occurring in the action area, they are used as a representative 

list because projects that require take authorization are expected to be the projects with the greatest 

impact.
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Table 4.1-7. Representative List of Oil and Gas Projects within the Alaska Region

General Location/ 

Geographic Scope Project Lead Project/Permit Description

Ongoing Activities

Cook Inlet, AK Hilcorp Alaska LLC Oil and Gas activities

Cook Inlet, AK Harvest Alaska (Hilcorp) Cook Inlet Pipeline Cross Inlet Extension

Arctic, AK Hilcorp Alaska Liberty Drilling and Production Island1

North Slope, AK Hilcorp Alaska, Eni Ice road Construction

Activities within the Past 10 years

Chukchi Sea, AK Shell Gulf of Mexico Inc. Drilling program in the Chukchi Sea, AK

Beaufort Sea, AK Hilcorp Alaska Operation of NorthStar facility in the 

Beaufort Sea, AK

Beaufort Sea, AK Shell Beaufort Sea exploratory drilling 

Chukchi Sea, AK Shell Chukchi Sea exploratory drilling 

1 – The Liberty Drilling and Production Island project is on hold. 

Source: NMFS, 2019d

4.1.2.3 Atlantic Outer Continental Shelf Region

The Atlantic outer continental shelf region is divided into four planning areas: North Atlantic, Mid-Atlantic, 

South Atlantic, and Straits of Florida. No active O&G leases currently exist in the Atlantic outer continental 

shelf region; and none are proposed under the current 2017-2022 Outer Continental Shelf Oil and Gas 

Leasing Program (BOEM, No Date-d).

4.1.2.4 Gulf of Mexico Outer Continental Shelf Region

The Gulf of Mexico outer continental shelf consists of three planning areas (Western, Central, and Eastern 

Gulf of Mexico); however, the Gulf of Mexico region also manages the four Atlantic outer continental shelf 

planning areas which all together span 174,014,826 ha (507,346 nm2

). The Gulf's Central and Western 

planning areas (offshore Texas, Louisiana, Mississippi, and Alabama) remain the nation's primary offshore 

source of O&G, generating about 97 percent of all offshore O&G production (BOEM, No Date-e). As 

described in BOEM’s Gulf of Mexico region Oil and Gas Production Forecast: 2018-2027, annual oil 

production is anticipated to continue to increase through 2024. Annual gas production volumes are 

anticipated to remain relatively consistent from 2018 to 2027 with an average rate of decline of less than 

1 percent annually (BOEM, 2017b).

4.1.2.5 Pacific Outer Continental Shelf Region

The Pacific outer continental shelf region has issued 470 leases and currently has 34 active leases, which 

together cover 72,248 ha (211 nm2

) in offshore California, Oregon, Washington, and Hawai’i. O&G 

production facilities have been installed in 23 of the active leases, all of which are located off the coast of 

California (BOEM, No Date-a). However, NMFS granted a marine mammal take authorization to only one 

project in the region (ExxonMobil conductor pipe installation activities at Harmony Platform in Santa 

Barbara Channel, CA in 2014), which has since expired (NMFS, 2019d).

Offshore oil and natural gas development would likely contribute cumulative impacts related to all of the 

resources covered in this Final PEIS.
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4.1.3 Offshore Renewable Energy Development

Offshore renewable energy consists of several sources, including wind energy and ocean wave and current 

energy, also known as hydrokinetic energy. BOEM is the agency responsible for overseeing offshore 

renewable energy development in federal waters (BOEM, No Date-f).

4.1.3.1 Wind Energy

Both nationally and globally, wind power is one of the fastest growing forms of electricity generation. 

Wind turbines convert the kinetic energy of wind into electricity. Offshore winds tend to blow harder and 

more uniformly than on land because there are no mountains, trees, and artificial structures to obstruct 

wind currents. Since higher wind speeds can produce much more electricity, and do so more reliably than 

onshore wind farms, developers are increasingly interested in pursuing offshore wind energy resources. 

There are extensive, potentially productive areas for wind energy available offshore on the continental 

shelf (DOSITS, No Date-a). 

Offshore wind facility design and engineering depends on site-specific conditions, particularly water 

depth, seabed geology, and wave loading. Following the preliminary G&G surveys described in Section 

4.1.1, the remaining three phases of a wind farm’s life cycle entail underwater sounds of varying intensity 

and duration:

1) Construction, which may include drilling, pile driving, use of explosives, dredging, cable laying, 

increased vessel traffic to and from the site, and barge operations;

2) Operation, including long-duration sound associated with mechanical vibrations when the turbine 

blades are spinning as well as periodic maintenance vessel traffic, continuing over the 20- to 25-

year lifetime of the installation; and

3) Decommissioning, which may include mechanical cutting and explosive detonation as well as 

increased boat and barge traffic to and from the site.

In the coming years, the majority of offshore wind project activity is expected to be in the pre-construction 

and construction phase. During the operational phase (Figure 4.1-3), by far the longest of these phases, 

low-frequency sound is generated when the turbine blades are spinning. Vibrations inside the nacelle 

(housing for the generator, gearbox, and other parts) are transmitted down the main turbine shaft and 

into its foundation under the seabed. These vibrations then propagate both into the seafloor and the 

water column. The sound is primarily below 1 kilohertz (kHz) (generally below 700 hertz [Hz]), with 

a source level of 80-150 decibels (dB) re 1 μPa (micropascal) @ 1 m. Aerodynamic noise produced by the 

motion of the rotor blades through the air may also penetrate the water through an airborne path. Sound 

levels increase somewhat as wind speed increases and blades rotate faster. The type of wind turbine 

foundation also affects the propagation of underwater sound (DOSITS, No Date-a). 
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Image Credit: DOSITS, No Date-a, modified from Kikuchi, 2010

As of May 2022, the U.S. generates about 42 megawatts (MW) of offshore wind energy. There are 

currently two offshore wind farms in operation: the first, Block Island Wind Farm in Rhode Island, began 

operating in 2016 with a capacity of 30 MW, and the second, by Dominion Energy off the coast of Virginia, 

began operating in 2020 with a capacity of 12 MW (Musial et al., 2022). 

The offshore wind industry in the U.S. is poised for an exponential increase in project activity, especially 

by coastal states aiming to take advantage of offshore wind energy, such as New York, New Jersey, 

Massachusetts, Connecticut, Maryland, Virginia, and California. Two new wind farms are currently under 

construction: Vineyard Wind 1 located off the coast of Massachusetts would produce 800 MW once it is 

operational in 2024, and Sound Fork Wind Farm located off the coast of Massachusetts and Rhode Island

would produce 132 MW once it is operational in 2023. There are 18 lease areas in development at the 

permitting stage, which means that the developer has surveyed the lease area and submitted its 

Construction and Operations Plans to BOEM and is awaiting approval of the proposed project. The 

projects in the permitting stage have the potential to yield about 18,851 MW of offshore wind energy if 

the projects are approved and the sites become operational. BOEM has announced that it expects to 

complete the review of at least 16 of these Construction and Operations Plans by 2025, clearing the path 

for the development of offshore wind farms in the near future. Another 17 lease areas are at the site 

control stage, which means the developer has acquired the rights to develop the lease area and has begun 

surveying the area. The projects in the site control stage could potentially yield almost 16,000 MW. 

Additionally, two areas off the coast of California, Humboldt Bay and Morro Bay, were designated as wind 

energy areas in November 2021, meaning these areas can be put up for a lease sale in the future. These 

locations would likely be subdivided into five new lease areas and could potentially yield up to 4,532 MW 

of offshore wind energy. BOEM also designates certain areas as “Call Areas” which are locations that have 

been identified for their wind potential (Musial et al., 2022). The locations of U.S. offshore wind energy 

projects and areas for potential wind development are shown in Figure 4.1-4. 

Figure 4.1-3. Acoustic 

Pathways for Underwater 

Noise from an Offshore 

Wind Turbine in 

Operation
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Source: Musial et al., 2022; Dormant Wind Areas are previously categorized wind energy areas that are no longer 

being actively reviewed or developed by BOEM.

Figure 4.1-4. Locations of U.S. Offshore Wind Energy Projects and Areas for Potential 

Wind Development in the North Atlantic, South Atlantic, and Pacific
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In 2021, the Biden Administration announced its national goal of deploying 30 GW of offshore wind energy 

by 2030. The effort would support the creation of approximately 77,000 new jobs, with more than 44,000 

workers employed in offshore wind and nearly 33,000 additional jobs in communities supported by 

offshore wind activities. It would generate enough electricity to power over 10 million homes in the U.S. 

and cut 78 million metric tons of carbon dioxide emissions. The goal would spur $12 billion in capital 

investment annually, including the construction of up to 10 new manufacturing plants for offshore wind 

turbine components, new ships to install offshore wind turbines, and up to $500 million in port upgrades. 

This plan also establishes a pathway to deploy 110 GW or more of offshore wind energy in the U.S. by 

2050, which would create 77,000 offshore wind jobs and more than 57,000 additional jobs in communities 

supported by offshore wind activity (DOE, 2021).

The U.S. offshore wind energy supply chain saw significant growth in 2021 and 2022 with 10 new major 

domestic manufacturing facilities announced at ports along the East Coast. These facilities would 

contribute to the wind energy supply chain by building components such as turbine blades, towers, 

platforms, arrays and export cables, and offshore substations. The U.S. supply chain is anticipated to grow 

as more projects begin construction and could generate between $1.6 and 6.2 billion of added value to 

the economy each year, along with 12,300 to 49,000 new manufacturing jobs (Musial et al., 2022).

4.1.3.2 Other Offshore Renewable Energy

Tidal, wave, and current energy are clean, renewable resources that can be harnessed wherever changing 

tides, waves, or currents move a significant volume of water, especially off the coasts of urban centers 

where there is high electricity demand. Marine and Hydrokinetic (MHK) energy is an untapped resource 

for the U.S. and though still a new industry, the U.S. Department of Energy’s (DOE) Water Power Program 

is researching projects to accelerate wave, tidal, and current projects and overall development of the MHK 

market. These projects include project siting activities, market assessments, environmental impact 

analyses, and research supporting technology commercialization (DOE, No Date-a). Due to the relatively 

steep continental slope and deep water off the West Coast and Hawai’i, different types of offshore 

renewable energy technologies have been proposed for the Pacific region than for the Atlantic region 

(BOEM, No Date-g). While the U.S. is pursuing ocean current energy, it is still in the early stages of 

development. Submerged water turbines, similar to wind turbines, may also be deployed on the outer 

continental shelf in the coming years to extract energy from ocean currents (BOEM, No Date-h).

Ocean Thermal Energy Conversion (OTEC) is a process to power a turbine to produce electricity by 

harnessing the temperature differences (thermal gradients) between ocean surface waters and deep 

ocean waters. OTEC systems using seawater as the working fluid can use the condensed water to produce 

desalinated water. As of 2015, the Natural Energy Laboratory of Hawai’i Authority, a leading test facility 

for OTEC technology, has supplied electricity to the local electricity grid. Conditions for OTEC systems exist 

in tropical coastal areas such as Hawai’i, south Florida, and the Caribbean (DOE, No Date-b).

Impact causing factors associated with other offshore renewable energy projects would likely include 

vessel presence, vessel and equipment noise, impacts to the water column, potential accidental 

discharges, the construction and installation of structures and cables connected to the shore (BOEM, 

2019b). The development of offshore renewable energy would likely contribute cumulative impacts 

related to all resources covered in this PEIS.
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4.1.4 Climate Change

For more than 200 years, since the beginning of the industrial revolution, the concentration of carbon 

dioxide (CO2) in the atmosphere has increased due to the burning of fossil fuels and land use change (e.g., 

increased vehicular and power plant emissions and deforestation). Increased concentrations in CO2 and 

other greenhouse gases in earth’s atmosphere trap the sun’s heat and raise temperatures, changing the 

earth’s climate system. The years between 2013 and 2021 all rank among the ten warmest years on 

record; 2021 was the sixth warmest year on record with a global temperature that was 0.84°Celcius (C) 

(1.51 °Fahrenheit [F]) above the 20th century average. The world’s oceans are of particular concern 

because the ocean absorbs about 90 percent of the heat generated by rising emissions (NCEI, 2022). In 

addition, the ocean absorbs about 30 percent of the CO2 that is released in the atmosphere (NOAA, 2013). 

Therefore, as global temperatures and the level of atmospheric CO2 increase, so does the level of CO2 in 

the ocean. In order to fully understand the impacts of climate change, the spatial boundary for analysis 

will be increased in this section to include international waters.

Warming. Between 1900 and 2016, global ocean surface waters have warmed on average 0.7° ± 0.08°C 

(1.3° ± 0.14°F) (USGCRP, 2018). In 2021, global ocean surface temperatures were 0.65 ± 0.16°C (1.17 ± 

0.29°F) above average, which is the sixth highest average on record since 1880. This translates to an 

increase in the amount of energy absorbed by the ocean, also known as the ocean’s heat content (OHC). 

Since records of OHC started in 1955, the seven highest OHC measurements have all occurred in the last 

seven years; 2021 exceeded the previous record set in 2020 (NCEI, 2022). In the last decade, the ocean 

has absorbed a large amount of heat resulting in record temperatures.

The warming of the ocean impacts sea levels, circulation and currents, productivity, and the functioning 

of entire ecosystems (USGCRP, 2018). For example, higher global temperatures have led to the melting of 

glaciers and icecaps which has caused sea levels to rise. In addition, as the ocean heats up, the water 

expands and contributes to sea level rise (NCEI, 2022). Sea levels in the U.S. have risen up to 0.6 meters 

(m) (2 feet [ft]) in the past century. As much as 4,921 km2 (1,900 mi2

) of coastal wetlands have been lost 

in Louisiana alone during this period. The amount of future sea-level rise will depend on the expansion of 

ocean volume and the response of glaciers and polar ice sheets. A rise in sea level of up to 1.2 m (4 ft) in 

this century has been predicted, but even another 0.6-m (2-ft) rise would cause major loss of coastal 

wetlands (USGCRP, 2009).

Deoxygenation. Increased CO2 levels in the atmosphere are also causing a decline of dissolved oxygen 

(DO) concentrations in the ocean. Ocean warming leads to deoxygenation because temperature has a 

direct influence on how much oxygen is soluble in water. Oxygen is less soluble in warmer waters; 

therefore, the concentration of DO is lower in waters that have been warmed by climate change (USGCRP, 

2018). Low levels of oxygen can suffocate fish and other marine life, leading to fish kills and other marine 

life mortalities.

Deoxygenation can also occur from “oxygen demanding” pollutants entering the water, mostly from 

nitrogen and phosphorus nutrients associated with agricultural/fertilizer runoff (USGCRP, 2018). This has 

become an annual occurrence in the Gulf of Mexico, which receives nutrient runoff from the Mississippi 

River and incurs large areas of very low dissolved oxygen, also known as dead zones. The Gulf of Mexico’s 

dead zone in 2021 was 6,334 square miles, which was larger than the five-year average of 5,380 square 

miles, as seen in Figure 4-1.5. The resulting low levels of oxygen are insufficient to support most marine 

life, rendering that area unusable for species and forcing them to move to other areas. The Hypoxia Task 
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Force (HTF), which includes federal and state agencies and tribes, has set a goal of reducing this dead zone 

to below 2,000 square miles by 2035 (NOAA, 2021).

Source: NOAA, 2021

Figure 4.1-5. Size of Annual Dead Zone (green bars) in the Gulf of Mexico (1985 to 2021)

Acidification. The ocean absorbs about 30 percent of the CO2 that is released in the atmosphere; as more 

CO2 is emitted into the atmosphere, more CO2 is absorbed by the ocean. When CO2 is absorbed by 

seawater, a series of chemical reactions occur, resulting in the increased concentration of hydrogen ions. 

Acidity is measured as a function of the concentration of hydrogen ions (pH), so the increased 

concentration of hydrogen ions causes the seawater to be more acidic. The ocean’s average pH is typically 

about 8.1 pH units. During the last 200 years, the pH of surface ocean waters has fallen by about 0.1 pH 

units. Since pH is measured on a logarithmic scale, this change represents approximately a 30 percent 

increase in acidity. As the ocean continues to absorb more CO2, the pH would continue to decrease and 

the ocean would become more acidic (NOAA, 2013).

A portion of the excess hydrogen ions react with carbonate (CO3

2-

) ions to form bicarbonate (HCO3

-

), this 

causes carbonate ions to be relatively less abundant (Hardt and Safina, 2008; NOAA, 2020d). Carbonate 

ions are a critical component of calcium carbonate (CaCO3), which many marine macroinvertebrates use 

to manufacture shells and exoskeletons. When the concentration of carbonate ions in ocean water is low 

enough, exposed CaCO3 structures such as shells, exoskeletons, and coral skeletons are more difficult to 

build and maintain and can even begin to dissolve or disintegrate (NOAA, 2020d; USGCRP, 2018).

These processes (warming, deoxygenation, and acidification) represent only a few ways that the ocean 

environment would be stressed as a result of climate change. Overall, these stressors are expected to 

persist at current levels or increase above current levels as the effects of climate change continue to 

evolve and impact the ocean environment. Impact causing factors associated with climate change include 

changes to water characteristics (including temperature, acidity, and oxygen concentration), sea level rise, 

increased storm severity and frequency, and coastal erosion, all of which contribute to coastal 

infrastructure damage and the increased need to construct protective infrastructure such as barriers and 
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seawalls (BOEM, 2019b). Climate change would likely contribute cumulative impacts related to habitats; 

marine mammals; sea turtles; fish; aquatic macroinvertebrates; essential fish habitat (EFH); seabirds, 

shorebirds and coastal birds, and waterfowl; cultural and historic resources; and Environmental Justice.

4.1.5 Commercial Shipping and Recreational Boating

About 90 percent of imports and exports enter and exit by ship through the nation’s 40,233 km (25,000 

mi) of navigable channels. By 2025, global demand for waterborne commerce is expected to more than 

double, which will increase the level of vessel traffic in the action area. Compared to land-based 

transportation by road and rail, the transportation of goods by waterways is considered to be a more 

economical, efficient, and environmentally sound mode of transport. For example, one Great Lakes bulk 

carrier has approximately the same cargo capacity as seven 100-car freight trains (USCG, 2018). Part of 

maintaining waterways for safe navigation includes dredging to maintain channel depths in harbors and 

inland waterways. The USACE dredges nearly 300 million cubic yards of material each year to keep the 

nation's waterways navigable. Much of this dredged material is reused for environmental restoration 

projects, including the creation of wetlands (USACE, No Date).

Designated shipping lanes occur throughout all regions of the action area with a higher concentration 

around urban centers with major ports. Shipping lanes and other areas with operational restrictions within 

the action area are shown below in Figure 4.1-6.

Figure 4.1-6. Shipping Lanes and Vessel Traffic Restrictions within the Action Area
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Shipping trends in the Alaska region are expected to vary in the near-term future because the Arctic region 

is undergoing dramatic changes due to the effects of climate change. Temperatures in the Arctic are rising 

more than two times faster than the rest of the planet, and increasing ocean temperatures have caused 

a decrease in the amount of seasonal sea ice (Boylan and Elsberry, 2019; Hoegh-Guldberg and Bruno, 

2010). Currently, Arctic vessels require icebreaker escorts, but projections show that as early as 2030, 

unescorted navigation in the Arctic may be possible; by 2050, it is probable. Three principal Arctic shipping 

routes connect the Atlantic and Pacific: The Northwest Passage, the Northern Sea Route, and the 

Transpolar Sea Route illustrated in Figure 4.1-7 below (Boylan and Elsberry, 2019).

Source: Boylan and Elsberry, 2019

Figure 4.1-7. Arctic Vessel Routes

The Northwest Passage (shown in green in Figure 4.1-7) refers to the sea route that extends from the

Pacific Ocean, over Alaska, through the Canadian archipelago, between Canada and Greenland, and into 

the Atlantic Ocean. The Northern Sea Route (shown in blue in Figure 4.1-7) is the route along the north 

coast of Russia, extending from the Kara Sea in the west through the Bering Strait in the east. It is a large 

component of the Northeast Passage, which runs along the north coasts of Russia and Europe and 

connects the Pacific Ocean to the Atlantic Ocean. The Transpolar Sea Route (shown in orange in Figure

4.1-7) would represent a third Artic shipping route; however, this route is hypothetical since it involves 

ice-free conditions through the Central Arctic which have not been observed yet.

New maritime navigational opportunities are expected as ice coverage in the Artic Ocean changes with 

rising temperatures. The ice along both the Northwest Passage and the Northern Sea Route is being 
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reduced at the highest rate across the Arctic (Boylan and Elsberry, 2019). Observations have shown 

decreasing multi-year ice and increasing open water during the Arctic summer and early fall, making 

seasonal maritime navigation more feasible and increasing the potential for commercial shipping during 

summer months (USCG, 2018). These sea routes are advantageous to the commercial shipping industry 

because they have the potential to reduce the time it takes to transport goods between Asian and 

European ports by several days; they also provide an alternative to routes passing through the Panama or 

Suez Canals (Boylan and Elsberry, 2019; USCG, 2018). In addition, economic development drives much of 

the current maritime activity in the region. The Arctic contains an estimate 13 percent of the world’s 

undiscovered oil and 30 percent of undiscovered natural gas. As sea ice decreases, these untapped 

resources create incentives for further exploration offshore to extract these commodities.

With an increase in vessel traffic, secondary trends to consider include an increase in operational and illicit 

vessel emissions, anthropogenic sounds in the sea, opportunities for the propagation and spread of 

invasive species, and an increased risk of vessel strikes. Impact causing factors associated with commercial 

shipping and recreational boating include vessel presence, vessel noise, impacts to the water column, 

potential accidental discharges, and air emissions (BOEM, 2019b). Increases in commercial shipping and 

recreational boating within the action area would likely contribute cumulative impacts related to all 

resources covered in this PEIS. 

4.1.6 Assessment and Extraction of Marine Minerals

BOEM is responsible for identifying non-energy resources on the outer continental shelf; this includes 

managing the use of mineral and sand resources (BOEM, 2019e). BOEM’s Marine Minerals Program 

(MMP) manages non-energy minerals (primarily sand and gravel) for coastal restoration, and commercial 

leasing of gold, manganese, and other hard minerals (BOEM, 2019e). Following preliminary G&G surveys, 

marine mineral projects typically involve the dredging of sediment using either a hopper dredge which 

suctions the material or a cutterhead dredge which pumps material to be closer to the project area at 

which point the material is transferred to a pipeline connected to the shore (BOEM, 2019b).

As of 2018, the MMP had executed 55 negotiated agreements and completed 45 coastal restoration 

projects for more than 512 km (318 mi) of shoreline in Florida, Louisiana, Maryland, Mississippi, New 

Jersey, North Carolina, South Carolina, and Virginia. To complete these projects, the MMP has provided 

nearly 150 million cubic yards of offshore sand resources to coastal communities and federal agencies—

that amount of sand would cover Manhattan, New York to a depth of more than 1.8 m (6 ft). In the past 

few years, BOEM has experienced a substantial increase in the number of requests for negotiated 

agreements from governmental agencies to use offshore sand resources. This trend is most likely due to 

a diminishing supply of available material in near shore waters, increased coastal erosion as a result of 

more frequent and intense storms, and sea level rise. The MMP is planning to sponsor new offshore 

sediment surveys from Maine to Texas that build on MMP’s plans following Hurricane Sandy in 2012, 

when BOEM supported coastal restoration projects in several Atlantic states. Sediment studies are also 

being conducted offshore of California (BOEM, 2019e).

In addition to using mineral resources for restoration projects, pursuant to Executive Order 13817 issued 

in December 2017, the MMP and the USGS are collaborating to research 35 critical minerals (i.e., minerals 

used in manufacturing, consumer products, or are otherwise economically important) along the outer 

continental shelf (BOEM, 2019e).
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In addition to seafloor disturbance and dredging, impact causing factors associated with these activities 

would likely include vessel presence, vessel and equipment noise, impacts to the water column, potential 

accidental discharges, and air emissions (BOEM, 2019b). The assessment and extraction of marine 

minerals would likely contribute to cumulative impacts related to habitats; marine mammals; sea turtles; 

fish; aquatic macroinvertebrates; EFH; seabirds, shorebirds and coastal birds, and waterfowl; cultural and 

historic resources; and socioeconomic resources.

4.1.7 Offshore Carbon Storage Resource Assessments

Carbon storage is the process of removing carbon from the atmosphere or capturing it and depositing it 

for storage in a reservoir beneath the earth’s surface. While there are no offshore carbon storage or 

sequestration projects currently underway or planned, the National Energy Technology Laboratory (NETL) 

in coordination with the DOE, BOEM, state geologic surveys, and other institutions have and continue to 

support offshore carbon storage resource assessments in the Mid-Atlantic, Southeast, and Gulf Coast 

regions. These projects utilize existing G&G data from existing or abandoned wells, available seismic 

surveys, and existing core samples to conduct prospective storage resource assessments. These projects 

have identified offshore sites with the potential to store at least 30 million metric tons (MMT) of CO2 and

are preliminary steps to identify regions of interest for offshore carbon storage projects (NETL, No Date). 

Once a site is identified and leased, carbon storage projects would likely require building infrastructure 

including the drilling of CO2 injection wells and construction of a pipeline to transport CO2 from the shore 

(BOEM, 2019b; Cameron et al., 2018). Following preliminary G&G surveys, offshore carbon storage 

projects would likely involve seafloor disturbance including drilling carbon injection wells, anchoring, and 

constructing structures and pipelines to shore. The operation of an offshore carbon storage project would 

include the capture of CO2 emissions and transport via submarine pipeline to injection wells; however, 

within the next several years these projects are unlikely to progress beyond the initial G&G surveying 

phase (BOEM, 2019b).

Impact causing factors associated with offshore carbon storage resource assessments would likely include 

vessel presence, vessel and equipment noise, impacts to the water column, potential accidental 

discharges, and air emissions. Offshore carbon storage resource assessments would likely contribute 

cumulative impacts to habitats; marine mammals; sea turtles; fish; aquatic macroinvertebrates; EFH; 

seabirds, shorebirds and coastal birds, and waterfowl; socioeconomic resources; and Environmental 

Justice. 

4.1.8 Construction and Operation of Offshore Liquified Natural Gas (LNG) 

Terminals

Liquefied natural gas (LNG) is a form of natural gas that has been cooled down so that it has a reduced 

volume (only 1/600th of its gaseous state) such that it can be more readily transported across the ocean 

via specialized ships (EIA, 2022a). At terminals on the coasts, the liquid is re-gasified and distributed via 

pipeline networks. LNG is imported to and exported from the U.S. through both offshore and onshore 

terminals. Licensing of offshore LNG terminals (deepwater ports) is under the jurisdiction of the U.S. Coast 

Guard (USCG) and the Maritime Administration (MARAD) (BOEM, 2014a).

The design and construction activities required to build new offshore LNG terminals varies depending on 

the capacity needed and location of the terminal. New LNG terminals use existing infrastructure if possible 

or require the construction of new infrastructure such as platforms and underwater pipelines and cables 

(CEE, 2006). To ensure the stability of these structures, the company constructing the LNG facility typically 

conducts G&G surveys of the area to determine if the seabed is suitable for such infrastructure 
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installations. These preliminary G&G surveys are described above in Section 4.1.1. Following these 

preliminary surveys, LNG projects generally involve three phases: construction and installation, operation, 

and decommissioning (BOEM, 2019b).

There are currently three operational facilities: Louisiana Offshore Oil Port and Neptune and Northeast 

Gateway, which are both located offshore Massachusetts. Other deepwater port license and application 

statuses located around the continental U.S. are shown in Figure 4.1-8 below (MARAD, 2021). In addition 

to the ports shown in the figure below, there are LNG ports and interests in Alaska including the Kenai 

LNG Terminal and the Alaska LNG Project (North Slope Borough).

Source: Adapted from MARAD Deepwater Port Licensing Program Map (MARAD, 2021)

Figure 4.1-8. Deepwater Port Location and Status Map

Overall, activities pertaining to the operation and construction of offshore LNG terminals are expected to 

continue at current levels or increase over the next several years in the Greater Atlantic, Southeast, and 

West Coast regions of the action area. The impact causing factors associated with the construction and 

installation of LNG terminals would involve seafloor disturbance for construction, vessel presence, vessel 

and equipment noise, impacts to the water column, potential accidental discharges, and air emissions. 

Similarly, the operation of LNG terminals would include vessel presence, vessel and equipment noise, 

impacts to the water column, potential accidental discharges, and air emissions. The decommissioning of 

LNG facilities may include demolition activities and structure removal (BOEM, 2019b). The construction 

and operation of offshore LNG terminals would likely contribute cumulative impacts related to all the 

resources considered in this Final PEIS. 
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4.1.9 National Defense and Homeland Security Activities

The U.S. Navy, USCG, U.S. Customs and Border Protection, U.S. Air Force, U.S. Marine Corps, and U.S. 

Army conduct operations and training exercises within the EEZ to ensure national security (NOS, 2016; 

NMFS, 2019d). Operations that are not compatible with commercial or recreational transportation are 

confined to Operating Areas (OPAREAs) away from commercially used waterways and/or inside Special 

Use Airspace (U.S. Fleet Forces, 2009). Military activities can include fleet training and testing, submarine 

and anti-submarine training, gunnery exercises, launch activities, missile training, and other training 

activities. These activities can involve the deployment of surface and subsurface vessels from small craft 

to large ships, high speed pursuits, live fire actions, underway refueling, and vessel anchoring (NOS, 2016). 

In addition to these activities, the Navy uses Surveillance Towed Array Sensor System (SURTASS) Low 

Frequency Active (LFA) sonar systems, Mid-Frequency Active Sonar (MFAS), and High-Frequency Active 

Sonar (HFAS) for training and testing activities.

SURTASS LFA sonar systems are long-range sensors that transmit in the low frequency band (i.e., below 1 

kHz). The two basic types of sonar used in the SURTASS LFA sonar system are passive and active sonar. 

Passive sonar detects sound created by a source and active sonar detects objects by creating a sound 

pulse that is transmitted through the water, reflects off a target object, and returns in the form of an echo 

to be detected. The Navy plans to upgrade SURTASS LFA sonar systems to a more compact LFA (CLFA) 

system that has a transmission frequency between 100 to 500 Hz; however, the operational 

characteristics and environmental impacts are expected to remain the same. The typical LFA sonar signal 

is not a constant tone but rather a series of sound transmissions referred to as a “wavetrain,” lasting on 

average 60 seconds with 6 to 15 minutes between wavetrains. Hydrophones on the vessel then detect 

the returning echoes from submerged objects. The Navy plans to increase the annual number of LFA sonar 

transmission hours from 496 to 592 hours within the next five years and expects to continue operating at 

this higher level into the foreseeable future. Prior to 2018, the Navy used SURTASS LFA sonar in the nonpolar areas of the Atlantic, Pacific, and Indian oceans and the Mediterranean Sea. The Navy currently uses 

SURTASS LFA sonar in the western and central North Pacific and eastern Indian oceans, overlapping with 

the Pacific Island region of the action area (Navy, 2018b).

Similar to LFA sonar, the Navy uses MFAS and HFAS emit non-impulsive sound waves to detect objects, 

safely navigate, and communicate. MFAS transmits sound at frequencies between 1 kHz and 10 kHz. MFAS 

is the Navy’s primary tool for detecting and identifying submarines. HFAS transmits sound at frequencies 

between 10 kHz and 100 kHz. HFAS has a small effective range, but provides higher resolution of objects 

and is able to detect smaller objects. Active sonar is rarely used continuously during training and testing 

activities and operates using a low duty cycle when in use. Training activities that use sonar typically 

employ several hours to hundreds of hours of sonar use per exercise. These sources are expected to 

continue to be used in training and testing activities throughout the action area (Navy, 2015; Navy, 2018a).

A summary of national defense and homeland security projects that have required incidental take 

authorizations from NMFS is presented below in Table 4.1-8 as a representative, not exhaustive, list of 

projects. Projects with an active take authorization status and projects with a take authorization 

application in-process are considered reasonably foreseeable to occur within the next five years and are 

categorized as ongoing activities. Projects that have been granted the requested take authorizations that 

have expired within the past 10 years are considered activities that have occurred within the past 10 years. 

Although projects that require take authorization are not of the only projects occurring in the action area, 

they are used as a representative list because projects that require take authorization are expected to be 

the projects with the greatest impact.
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Table 4.1-8. Representative List of National Defense and

Homeland Security Projects within the Action Area

Military 

Branch

General Location/ 

Geographic Scope Project/Permit Description

Greater Atlantic Region

Activities within the Past 10 years

U.S. Navy

Eastern seaboard and PR, 

USVI Atlantic Fleet Training and Testing (AFTT)

North East Atlantic Operations of SURTASS low frequency active sonar

Southeast Region

Ongoing Activities

U.S. Air 

Force

Gulf of Mexico Testing and training activities in the Eglin Gulf Test and 

Training Range (EGTTR)

U.S. Marine 

Corps

Brandt island, Pamlico 

Sound, NC Training activities in Pamlico Sound, NC

Piney island, Pamlico 

Sound, NC Training activities in Pamlico Sound, NC

U.S. Navy

Eastern seaboard and PR, 

USVI Atlantic Fleet Training and Testing (AFTT)

Gulf of Mexico Atlantic Fleet Training and Testing (AFTT)

Camp Lejeune, NC Joint logistics over-the-shore training in VA and NC

Fort Story, VA Joint logistics over-the-shore training in VA and NC

Little Creek, VA Joint logistics over-the-shore training in VA and NC

Eastern Indian Ocean Operations of SURTASS low frequency active sonar

Activities within the Past 10 years

U.S. Air 

Force

Eglin AFB, FL Eglin AFB gunnery exercises, FL

Eglin AFB, FL Eglin AFB NEODS training operations

Eglin AFB, FL Eglin AFB precision strike weapons and air-to-surface 

gunnery exercises, FL

Eglin AFB, FL Maritime strike operations at Eglin AFB, FL

FL panhandle Maritime weapon systems evaluation program (WSEP) 

near FL panhandle

offshore FL Maritime weapons systems evaluation program, offshore 

FL

offshore FL Maritime weapons systems evaluation program, offshore 

FL

U.S. Marine 

Corps

Brandt island, Pamlico 

Sound, NC

Training activities in Pamlico Sound, NC

Piney island, Pamlico 

Sound, NC

Training activities in Pamlico Sound, NC

U.S. Navy

Gulf of Mexico Atlantic Fleet Training and Testing (AFTT)

Cherry Point, NC Cherry Point (CHPT) range complex mission activities, NC
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Military 

Branch

General Location/ 

Geographic Scope Project/Permit Description

Corpus Christi OPAREA Gulf of Mexico (GOMEX) range complex training exercises

Pensacola OPAREA Gulf of Mexico (GOMEX) range complex training exercises

Jacksonville, FL Jacksonville range complex, FL

Jacksonville, FL Jacksonville range complex, FL

Panama City, FL Naval Surface Warfare Center Panama City, FL

South West Atlantic Operations of SURTASS low frequency active sonar

Panama City test range, 

FL

Testing mine reconnaissance sonar system at Panama 

City test range, FL

Virginia capes, VA Virginia capes (VACAPES) range complex, VA

West Coast Region

Ongoing Activities

U.S. Air 

Force

North sites Vandenburg 

AFB, CA

Vandenberg AFB launch activities, CA

South sites Vandenburg 

AFB, CA

Vandenberg AFB launch activities, CA

U.S. Navy

Southern California 

Range Complex

Hawai’i Southern California Training and Testing (HSTT)

San Nicolas Island, CA Missile launches from San Nicolas Island, CA

Pacific Northwest Northwest training and testing activities (NWTT)

North Pacific Operations of SURTASS low frequency active sonar

Activities within the Past 10 years

U.S. Air 

Force

North sites Vandenburg 

AFB, CA

Vandenberg AFB launch and harbor maintenance 

activities, CA

South sites Vandenburg 

AFB, CA

Vandenberg AFB launch and harbor maintenance 

activities, CA

Vandenburg AFB, CA Vandenburg AFB space launch vehicle and missile 

operations, CA

U.S. Navy

Southern California 

Range Complex

Hawai’i Southern California Training and Testing (HSTT)

Dabob Bay, WA Keyport range complex expansion and activities, WA

Keyport, WA Keyport range complex expansion and activities, WA

Quinault site, coastal WA Keyport range complex expansion and activities, WA

San Nicolas Island, CA Missile launches from San Nicolas Island, CA

North Pacific Operations of SURTASS low frequency active sonar

Western Pacific Operations of SURTASS low frequency active sonar

San Diego Bay, CA Silver Strand Training Complex exercises near San Diego 

Bay, CA

Northwest Training Range 

Complex

Training in the Northwest Training Range Complex 

(NWTRC)

Silver Strand Training 

Complex, CA

Training in the Silver Strand Training Complex, CA
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Military 

Branch

General Location/ 

Geographic Scope Project/Permit Description

Ports of LA/Long Beach, 

CA

West Coast civilian port defense activities

Alaska Region

Ongoing Activities

U.S. Navy Gulf of Alaska Training activities in the Gulf of Alaska temporary 

maritime activities area

Activities within the Past 10 years

U.S. Navy Beaufort Sea, Arctic 

Ocean

2018 IceX

Gulf of Alaska Training activities in the Gulf of Alaska temporary 

maritime activities area

Pacific Island Region

Ongoing Activities

U.S. Air 

Force

Kauai, HI Weapon Systems Evaluation Program

U.S. Navy Hawai’i Range Complex Hawai’i Southern California Training and Testing (HSTT)

Mariana Islands Mariana Islands Training and Testing (MITT)

Central Pacific Operations of SURTASS low frequency active sonar

Activities within the Past 10 years

U.S. Air 

Force

Kauai, HI Long Range Strike Weapon Systems Evaluation Program 

U.S. Navy Hawai’i Hawai’i range complex

Hawai’i Range Complex Hawai’i Southern California Training and Testing (HSTT)

South Pacific Operations of SURTASS low frequency active sonar

Mariana Islands Range 

Complex

Training in the Mariana Islands Range Complex (MIRC)

Source: NMFS, 2019d

AFB = Air Force Base; NEODS = Naval Explosive Ordnance Disposal School; SURTASS = Surveillance Towed Array 

Sensor System

Impact causing factors associated with national defense and homeland security activities would likely 

include the use of active underwater acoustic sources, the use of explosives, seafloor disturbance, 

dredging, vessel presence, vessel and equipment noise, impacts to the water column, potential accidental 

discharges, and air emissions (BOEM, 2019b). Prior to testing and training activities, the Navy issues 

notices to mariners and will clear the ocean range; therefore, it is unlikely that impact causing factors 

from the majority of these activities will overlap with those of other cumulative actions considered or NOS 

activities. NOS will coordinate with the Navy to ensure that surveys would not occur on or near ranges

during exercises. Overall, national defense and homeland security activities are expected to increase 

above the present level due to the ongoing and planned programs, and would likely contribute to 

cumulative impacts for habitats; marine mammals; sea turtles; fish; aquatic macroinvertebrates; EFH; 

seabirds, shorebirds and coastal birds, and waterfowl; and Environmental Justice.
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4.1.10 Construction of New Submarine Telecommunication Cable Infrastructure

Submarine cables play a critical role in global interconnected networks, carrying about 99 percent of 

international communications traffic. Sharp growth in demand for data, fueled by bandwidth-intensive 

applications such as video and a proliferation of cloud-based services, has driven a considerable increase 

in global submarine cable deployments (Brake, 2019). The U.S.’s existing submarine cable infrastructure 

is already substantial and is concentrated along coastal urban centers such as New York City, Washington 

D.C., and San Francisco where demand on communication networks is larger; however, new cable 

infrastructure is needed to support growing capacity demand throughout the action area. Submarine 

cables typically have a 25-year lifespan, so the replacement and repair of existing cables is also expected 

in the next several years as current cables reach the end of their effective lifespan or become obsolete. 

Within the EEZ, installing or laying telecommunication cable infrastructure involves coordination with the 

Federal Communications Commission (FCC), USACE, and NOAA. Depending on the particular project and 

route characteristics, construction and maintenance of submarine cable infrastructure may include 

surveys of proposed cable routes; the use of specialized vessels, equipment, and divers to lay the cable; 

the use of equipment to bury the cable; construction of connection to onshore systems; and operation 

and maintenance of the cables (BOEM, 2019b).

Following preliminary G&G surveys of the cable route, the construction of new submarine 

telecommunication cable infrastructure generally involves the use of equipment to lay and bury the 

cables, the construction of a coastal landing station to connect the cables to onshore systems, 

maintenance and repairs, and eventual removal of cables. The impact producing factors associated with 

these activities include seafloor disturbance, vessel presence, vessel and equipment noise, impacts to the 

water column, potential accidental discharges, and air emissions (BOEM, 2019b). The construction of new 

submarine telecommunication cable infrastructure would likely contribute cumulative impacts related to 

habitats; marine mammals; sea turtles; fish; aquatic macroinvertebrates; EFH; seabirds, shorebirds and 

coastal birds, and waterfowl; cultural and historic resources; and Environmental Justice.

4.1.11 Commercial and Recreational Fishing

Commercial fishing is catching and selling fish and shellfish for profit, while recreational fishing is for sport 

or pleasure. The annual total landings, or poundage of fish, brought in by commercial fisheries has 

fluctuated between 4.3 and 4.4 billion kilograms (kgs) (9.4 and 9.6 billion pounds [lbs]) from 2011 to 2018. 

Alaska contributes the most to commercial fisheries, accounting for 58 percent of landings in 2018, 

followed by the Gulf of Mexico (16 percent), Atlantic (14 percent), Pacific (12 percent) and Hawai’i and 

the Great Lakes (less than 1 percent each) (NMFS, 2020). Over the past decade, while the amount of wildcaught seafood has remained relatively consistent from year to year, the amount raised through 

aquaculture has increased, though it is still less than 10 percent of the wild harvest by weight. National 

marine aquaculture production increased an average of 3.3 percent per year from 2009-2014 and in 2017, 

freshwater and marine aquaculture production was 284 million kgs (626 million lbs) (NMFS, No Date-i; 

NMFS, 2020). Most marine aquaculture production consists of oysters, clams, salmon, mussels, and 

shrimp. In addition to contributing to the seafood industry, aquaculture is also a tool to restore habitats 

and species. Hatchery stock is used to rebuild oyster reefs, grow wild fish populations, and rebuild 

threatened and endangered abalone and corals (NMFS, No Date-i).

Recreational fishing includes fishing from private/rental boats, party/charter boats, and onshore (e.g., a 

dock or the shore). In 2018, recreational fishers took approximately 194 million saltwater fishing trips, 

with 55 percent in estuaries, 35 percent in state territorial seas, and 10 percent in the U.S. EEZ. Of the 163 

million kgs (359 million lbs) of harvested fish, the majority were from the Atlantic (60 percent) and Gulf of 
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Mexico (37 percent) (NMFS, 2020). All saltwater recreational fishing together harvested about 1/30th the 

combined catch (by weight) of commercial fishing in 2018. 

Commercial and recreational fishing activities directly impact fishery stocks and indirectly impact seabirds 

and marine mammals that prey and depend on fishery stocks. Additionally, commercial and recreational 

fishing contribute to overall vessel traffic in the action area and therefore, the cumulative noise in the 

ocean. Over the 5-year project period, the amount of commercial and recreational fishing in the action 

area is expected to remain the same or increase. Impact causing factors associated with commercial and 

recreational fishing include seafloor disturbance, dredging, vessel presence, vessel and equipment noise, 

impacts to the water column, potential accidental discharges, and air emissions (BOEM, 2019b). 

Commercial and recreational fishing would likely contribute cumulative impacts related to habitats; 

marine mammals; sea turtles; fish; aquatic macroinvertebrates; EFH; seabirds, shorebirds and coastal 

birds, and waterfowl; cultural and historic resources; and Environmental Justice.

4.1.12 Coastal Development

Coastal development includes the construction, maintenance, renovation, and removal of infrastructure 

such as piers, lighthouses, shipping ports and storage facilities, harbors, dams, bridges, roads, buildings, 

and other structures to support increased levels of safe navigation, tourism, and residential, commercial, 

and industrial land uses. While coastal construction is concentrated along urban centers, it is expected to 

occur throughout the U.S. coastline in all regions of the action area. The expected increase in marine 

traffic, fishing operations, and offshore energy development would increase the use of existing coastal 

infrastructure and increase demand for the construction of new infrastructure and port facilities (BOEM, 

2019b). Due to their potential impact to marine mammals, coastal construction projects require incidental 

take authorizations granted by NMFS under the MMPA (NMFS, 2019d). A summary of these projects is 

presented below in Table 4.1-9 as a representative, not exhaustive, list of coastal development projects. 

Projects with an active take authorization status and projects with a take authorization application inprocess are considered reasonably foreseeable to occur within the next five years and are categorized as 

ongoing activities. Projects that have been granted the requested take authorizations that have expired 

within the past 10 years are considered activities that have occurred within the past 10 years. Although 

projects that require take authorization are not of the only projects occurring in the action area, they are 

used as a representative list because projects that require take authorization are expected to be the 

projects with the greatest impact.

Table 4.1-9. Representative List of Coastal Development Projects within the Action Area

General Location/ 

Geographic Scope Project Lead Project/Permit Description

Greater Atlantic Region

Ongoing Activities

Off NY and NJ Transcontinental Gas Pipe 

Line Company, LLC

Construction Activities for Raritan Bay Pipeline

New London, CT U.S. Navy Dock construction project

Kittery, ME U.S. Navy Dock expansion project

Activities within the Past 10 years

DE and NJ Bluewater Wind, LLC Meteorological tower installation
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General Location/ 

Geographic Scope Project Lead Project/Permit Description

Atlantic City windfarm, 

NJ

Fishermen's Atlantic City 

Windfarm, LLC

Pile placement

Eastport, ME Maine DOT Pier and breakwater replacement project

Kittery, ME U.S. Navy Waterfront improvement project

Southeast Region

Ongoing Activities

Tampa Bay, FL USACE Tampa Harbor Bay Big Bend Channel expansion

Jacksonville, FL U.S. Navy South Quay Wall recapitalization project 

Kings Bay, GA U.S. Navy Submarine base waterfront construction

Activities within the Past 10 years

Port of Miami, FL USACE Blasting operations

Chesapeake Bay 

entrance

Chesapeake Tunnel Joint 

Venture

Parallel Thimble Shoal Tunnel Project

Jacksonville, FL U.S. Navy Wharf maintenance project

West Coast Region

Ongoing Activities

Coos Bay, OR USACE North Jetty Maintenance and Repairs Project

Santa Cruz, CA Caltrans Murray Street Bridge seismic retrofit project

CA Carnival Corp, City of 

Alameda, San Francisco 

Bay Area Water 

Emergency 

Transportation Authority, 

and Port of San Francisco

Three ferry and cruise terminal improvement 

and construction projects

Richmond, CA Chevron Wharf maintenance project

Kalama, WA Port of Kalama Proposed construction activities

Sant Cruz, CA Sant Cruz Port District Aldo's Seawall Replacement Project

Jenner, CA Sonoma County Water 

Agency

Estuary Management Activities

Columbia River USACE Jetty System Rehabilitation, King Pile Markers 

Project, and Sand Island Pile Dike Test Project

Seal Beach, CA U.S. Navy Construction of Pier and Turning Basin

Puget Sound, WA U.S. Navy Structure maintenance and pile replacement

Bangor, WA U.S. Navy Pier extension project

Bremerton, WA WA DOT Dolphin Relocation project

WA WA DOT Two multimodal construction projects

Aberdeen, WA WA DOT US 101/Chehalis River Bridge-Scour Repair

Activities within the Past 10 years

Columbia River USACE Jetty rehabilitation

San Francisco, CA USACE Pier 36/ Brannan Street wharf project
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General Location/ 

Geographic Scope Project Lead Project/Permit Description

Newport, OR Bergerson Construction, 

Inc.

Front Street transload facility construction

Elkhorn Slough, 

Monterey, CA

California Dept of Fish 

and Wildlife

Tidal marsh restoration project

San Francisco, CA Caltrans Bridge construction and demolition and seismic 

safety tests

Trinidad Pier, CA Cher-Ae Heights Indian 

Community

Pile-driving and renovation operations

Carpinteria, CA Chevron Casitas Pier Fender Pile Replacement Project

Richmond, CA Chevron Wharf Maintenance project

WA City of Astoria and Kitsap 

Transit

Two dock construction and expansion projects

Monterey County, CA NOAA Restoration Center Parsons slough project

Friday Harbor, WA Port of Friday Harbor Marina reconstruction project

Kalama, WA Port of Kalama Proposed construction activities

San Francisco Bay, CA Port of San Francisco Activities for the America's Cup

Port of Vancouver, WA Port of Vancouver Port of Vancouver, WA

San Diego, CA San Diego Construction and demolition activities and 

Coast Blvd sidewalk Improvements 

CA San Francisco Bay Area 

Water Emergency 

Transportation Authority

Three ferry terminal expansion and 

reconstruction projects and Central Bay 

operations and maintenance project

Seattle, WA Seattle DOT Seawall and pier restoration projects

Russian River estuary Sonoma County Water 

Agency

Estuary management project

San Francisco, CA The Exploratorium Exploratorium relocation

Monterey, CA USCG USCG Monterey Waterfront Improvement 

Project

Naval Base Kitsap, WA U.S. Navy Naval Base Kitsap Bangor pile replacement 

program, test pile program, and wharf 

construction project.

WA U.S. Navy Three pier maintenance projects

San Diego, CA U.S. Navy Naval Base Point Loma fuel pier replacement 

project

San Nicolas Island, CA U.S. Navy County Roads and Airfield Repairs Project

Vandenburg AFB, CA United Launch Alliance Harbor activities related to the Delta IV/EEL 

vehicle

Aberdeen, WA WA DOT Chehalis River Bridge Repair

Woodard Bay, WA WA Dept of Natural 

Resources

Restoration activities

Anacortes, WA WA DOT Anacortes tie-up slips replacement
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General Location/ 

Geographic Scope Project Lead Project/Permit Description

WA WA DOT Dolphin Relocation project and wingwall 

replacement project

Whidbey Island, WA WA DOT Coupeville timber towers preservation project

Manette Bridge, WA WA DOT Manette Bridge replacement project

WA WA DOT Four multi-modal construction projects

WA WA DOT Two ferry terminals construction projects

Vashon Island, WA WA DOT Vashon Ferry Terminal trestle seismic project

WA WA Ferries Span replacement project

Alaska Region

Ongoing Activities

AK Alaska DOT Four ferry terminal construction projects

AK Alaska DOT, Federal 

Aviation Administration 

(FAA), Skagway, AK, and 

White Pass and Yukon 

Route

Five dock construction, replacement, and 

expansion projects

AK Donlin Gold, LLC Gold mining and marine barging in coastal 

waters

Ketchikan, AK City of Ketchikan Removal of Berth II Rock Pinnacles

Hoonah, AK Duck Point Development 

II, LLC

Cruise Ship Berth Construction

Juneau, AK Jim Erickson Erickson residence marine access project

Juneau, AK Juneau Three harbor and waterfront projects

Sitka, AK Sitka Alaska Lightering float pile replacement project

Activities within the Past 10 years

AK Alaska DOT and Huna 

Totem Co.

Four ferry terminal improvement projects

AK City of Unalaska, UniSea, 

Inc., FAA, Sitka Alaska, 

and Ketchikan Dock Co

Five dock construction, replacement, and 

expansion projects

St. Paul Island, AK NMFS Alaska Region Repair of observation towers and walkways

Port of Anchorage Port of Anchorage Test pile program

Pacific Island Region

Activities within the Past 10 years

Honolulu, HI Honolulu Seawater Air 

Conditioning, LLC Honolulu seawater air conditioning project, HI

Source: NMFS, 2019d

DOT = Department of Transportation; USACE = U.S. Army Corps of Engineers; USCG = U.S. Coast Guard

Impact causing factors associated with coastal construction include seafloor disturbance, vessel presence, 

vessel and equipment noise, impacts to the water column, potential accidental discharges, and air 

emissions (BOEM, 2019b). Coastal construction would likely contribute cumulative impacts related to 
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habitats; marine mammals; sea turtles; fish; aquatic macroinvertebrates; EFH; and seabirds, shorebirds 

and coastal birds, and waterfowl.
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4.2 CUMULATIVE EFFECTS ON THE ENVIRONMENT

As described in Section 4.1, NOS is considering actions taking place in the action area during a 17-year 

period from 2010 to 2027 in the assessment of cumulative effects. The following sections analyze the 

cumulative impacts for each resource covered in Chapter 3. The analysis first summarizes the cumulative 

effects of the cumulative actions identified in 4.1, then considers how the NOS-related incremental 

impacts of Alternatives A, B, and C, when added to or acting synergistically with the cumulative effects of 

other past, present, and reasonably foreseeable future actions, would contribute to overall cumulative 

impacts. The analysis of cumulative effects also considers other human actions and activities that 

contribute to the existing condition of coastal habitats, including encroachment from onshore, nearshore, 

and offshore development (e.g., coastal population growth, light pollution); flows and runoff of pollutants 

into coastal waters from onshore land uses, including urban, residential, industrial, and agricultural; and 

accidental or illicit discharges of oil, fuel, chemicals, or waste. 

4.2.1 Habitats

All past, present, and reasonably foreseeable actions described in Section 4.1 would contribute 

cumulative effects to habitats. The following section addresses habitats in general, but discussion of 

cumulative impacts on habitats for other more specific resources may be found in these other sections of 

this chapter: 4.2.2.4 (Marine Mammals), 4.2.3.3 (Sea Turtles), 4.2.4.4 (Fish), 4.2.5.3 (Aquatic 

Macroinvertebrates), 4.2.6 (Essential Fish Habitat), and 4.2.7.3 (Sea Birds, Shorebirds and Coastal Birds, 

and Waterfowl).

The cumulative impacts in the following subsections are categorized by their relevance to the following 

essential characteristics of habitat:

• space needed for individual and population growth and normal behavior;

• food, water, air, light, minerals, and other nutritional or physiological requirements;

• cover or shelter requirements;

• sites needed for breeding, reproduction, or rearing of offspring.

4.2.1.1 Physical Impacts to Habitat Bottom Substrate

NOS activities under the Proposed Action including anchoring, collection of bottom grab samples, 

installation of tide gauges and remote global positioning system (GPS) reference systems, use of 

dropped/towed camera systems, and self-contained underwater breathing apparatus (SCUBA) operations 

could contribute to overall cumulative impacts associated with the presence and movement of vessels 

and construction, operation, and decommissioning of long-term installations (e.g., LNG terminals, energy 

infrastructure, and submarine telecommunications) on the bottom substrate throughout marine, 

freshwater, and estuarine areas in the action area. These cumulative impacts could reduce the availability 

of space, shelter, cover, and nutrients for dependent species. 

The agitation of ocean, lake, or river bottom sediments during NOS projects and other cumulative actions 

requiring the presence and movement of crewed vessels or the construction, operation, and 

decommissioning of long-term installations could cumulatively reduce the availability of space, shelter, 

cover, and nutrients for dependent species throughout the action area by physically removing or altering 

underwater structure. Many cumulative actions requiring crewed vessel operations could also entail 

anchoring, collection of bottom samples, or trailing of camera systems and other equipment. Equipment, 

vessels, or displaced water from vessel wakes could potentially contact bottom substrate throughout the 
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action area, removing or damaging underwater structures such as submerged vegetation, macroalgae, 

and coral reefs. 

This reduction of underwater structure would reduce the shelter and cover necessary for the survival or 

offspring development of many marine and freshwater taxa, particularly those organisms at lower levels 

of the aquatic food chain, and could potentially reduce the overall aquatic biodiversity of the area through 

cascading trophic impacts (i.e., reduced prey availability reduces the abundance of higher-level 

predators). However, impacts from NOS activities to bottom substrates would be temporary and would 

be mitigated by avoiding repeated NOS surveys in the same location. For both NOS projects and other 

actions these impacts would be largely confined to the immediate vicinity of their source and would not 

likely appreciably impact the total amount of underwater structure within the action area. Long-term 

installations, including renewable or fossil fuel energy installations, could also damage underwater 

structural features and would likely cumulatively reduce the total amount of space available to dependent 

species for the lifetime of the installation. However, any potential reductions in space would be limited to 

the immediate vicinity of constructed manmade structures, which could also serve as settlement strata 

for many species of marine and freshwater macroinvertebrates and subsequently attract and retain 

organisms from higher levels of the aquatic food chain. 

The majority of cumulative impacts on bottom substrates would be limited to the immediate vicinity of 

vessels, trailed equipment, or onshore, nearshore, and offshore renewable and fossil fuel energy 

development and would not likely cause long term changes in the availability of space, shelter, cover, or 

nutrients for dependent species outside of the range of natural variation. The above-described NOS 

effects can also occur in almost all human use of water. These effects would be indistinguishable in type 

from other human uses. Overall, aggregate cumulative bottom substrate impacts would occur regardless 

of the chosen alternative, would be short-term and long-term, and could result in adverse and negligible

to minor impacts on habitat areas throughout the action area. The contribution to these aggregate, 

adverse cumulative impacts on bottom substrate from any of the three NOS alternatives would be 

negligible. 

4.2.1.2 Increase in Sedimentation, Turbidity, and/or Chemical Contaminants in 

Habitats

Crewed vessel , ROV, and autonomous vehicle operations; anchoring; dropped/towed camera systems; 

collection of bottom grab samples; installation of tide gauges and remote GPS reference systems; and 

SCUBA operations under the Proposed Action could contribute to overall cumulative impacts associated 

with the presence and movement of vessels, construction, operation, and decommissioning of long-term 

installations (e.g., LNG terminals, energy infrastructure, and submarine telecommunications), coastal 

erosion resulting from climate change, and runoff from expanding coastal development in conjunction 

with coastal population growth. The result would be a cumulative increase in sedimentation, turbidity and 

the presence of chemical contaminants throughout marine, freshwater, and estuarine areas in the action 

area, reducing the availability of space, shelter, cover, and nutrients for dependent species. 

The presence and movement of vessels and trailing equipment during both NOS projects and other 

cumulative actions, in conjunction with underwater construction activities, such as blasting and leveling, 

could potentially stir up bottom sediment, cumulatively increasing the level of sedimentation and 

turbidity within the action area. Rising sea levels as a result of climate change will also continually erode 

coastlines along the EEZ over the next five years and could further contribute to increased turbidity within 

these areas. High levels of sedimentation and turbidity can potentially cause direct respiratory damage 
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to aquatic species and block sunlight necessary for photosynthesis by aquatic plants, macroalgae, and 

phytoplankton. 

These impacts could cumulatively lower the overall nutrient availability or reduce the cover and structure 

available to dependent species from submerged vegetation or macroalgae within the action area. 

Furthermore, increases in sedimentation and turbidity reduce the penetration of sunlight through the 

water column, which changes the wavelengths of light reaching fish and benthic species. Photosynthetic 

marine species are dependent on sunlight and often have a narrow band of wavelengths of light that they 

are able to use; increased sedimentation and turbidity could cumulatively hinder or prohibit 

photosynthesis in oceanic habitat areas, reducing nutrient cycling and primary production by marine 

phytoplankton and reducing shelter and cover provided by submerged plants and macroalgae. 

Suspended material may also react with DO in the water and result in temporary or short-term oxygen 

depletion to aquatic resources, including vegetation and aquatic macroinvertebrates, and could further 

exacerbate impacts to habitat areas from reduced nutrient and cover availability. 

During both NOS projects and other cumulative actions, the presence and movement of vessels, 

construction and presence of long-term renewable or fossil fuel energy installations could cumulatively 

increase the concentration of contaminants within the water column when considered in tandem with 

current agricultural or urban runoff from onshore commercial development in conjunction with coastal 

population growth and accidental or illicit discharges of oil, fuel, or chemical contaminants. The magnitude 

of the majority of these impacts is contingent on the size, location, and chemical composition of the source 

discharge or spill. The majority of contaminants, including oil and fuel, currently entering the aquatic 

environment are less dense than water and float on the surface until they evaporate, typically within 

several days. Floating contaminants typically do not affect habitat characteristics below the surface of the 

water, however contaminants introduced to shallow marine habitat areas harm seagrass ecosystems 

close to the water surface and could potentially cause extensive mortality of the seabed and reduce the 

available cover and shelter that many marine species require to avoid predation, reproduce, and rear or 

develop offspring. 

Additionally, seagrass mortality reduces the nutrient availability for seagrass foragers in these areas, 

including echinoderms, fish, manatees, and sea turtles. Chemical contaminants also cling or adhere to 

structural features in all aquatic habitat areas, which serve as additional exposure vectors to fish and 

aquatic macroinvertebrates and result in changes in growth rates or behavior, injuries, and death of 

exposed individuals. Coastal runoff includes chemical contaminants such as fertilizers or detergents with 

high levels of nitrates and phosphates. Influxes of nutrients or chemicals in shallow marine, estuarine, and 

coastal wetland habitat areas elicit algal blooms, which often are toxic for many marine species and 

reduce DO concentrations as dying algae are oxidized, thereby reducing the overall habitat quality of the 

affected area. Denser contaminants sink below the surface of the water and negatively impact coral 

colonies in shallow marine habitat areas through mortality, tissue death, reduced growth, impaired 

reproduction, bleaching, and reduced photosynthetic rates. Ongoing reduction of coral coverage reduces 

the structure and shelter necessary for prey species and will continue to reduce the overall biodiversity 

of affected areas through cascading impacts throughout the food chain. Bioaccumulation of some toxic 

chemicals also disproportionately impacts higher level predators which consume contaminated prey 

items and ultimately reduces top-down ecosystem regulation and nutrient availability of affected habitat 

areas.

Overall, increased sedimentation, turbidity, and chemical contamination within the action area would 

predominantly be dissipated by prevailing currents or winds in seconds to minutes. Temporary reductions 
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in water quality are not expected to cumulatively reduce the availability of space, shelter/cover, nutrients, 

or breeding/rearing grounds in any of the habitat types found throughout the action area outside the 

range of natural variability. It is also an NOS practice to generally avoid repeated NOS surveys in the same 

location, thereby mitigating impacts of increased sedimentation, turbidity, and chemical contamination 

within the action area. The above-described NOS effects can also occur in almost all human use of water. 

These effects would be indistinguishable in type from other human uses. Overall, aggregate cumulative 

impacts to all aquatic habitat areas from increased sedimentation, turbidity, and/or chemical 

contamination would be adverse and negligible to minor in magnitude. The contribution to these 

aggregate, adverse cumulative impacts from any of the three NOS alternatives would be negligible.

4.2.1.3 Increased Ambient Sound Levels in Habitats

Crewed vessel, remotely operated vehicle (ROV), and autonomous vehicle operations and the use of echo 

sounders, acoustic communications systems and ADCPs under the Proposed Action, could contribute to 

overall cumulative impacts on ambient sound levels associated with the presence and movement of 

vessels, other surveying and mapping activities, and construction, operation, and decommissioning of 

long-term installations (e.g., LNG terminals, energy infrastructure, and submarine telecommunications). 

These could result in a cumulative increase in the ambient sound environment throughout marine, 

freshwater, and estuarine areas in the action area, reducing the availability of space, shelter, cover, and 

nutrients for dependent species. 

Crewed vessel, ROV, and autonomous vehicle operations from both NOS projects and other actions and 

underwater construction activities in support of long-term installations, would generate underwater 

sound and vibrations at low- to mid-frequencies that overlap with the hearing ranges of many aquatic 

prey species. Increases in the ambient sound level of aquatic habitat areas could potentially reduce the 

habitat quality of preferred feeding or breeding grounds and displace disturbed animals from these areas. 

Increased ambient sound can also mask biologically important sounds which elicit predator-avoidance or 

mating behaviors, cause hearing loss, and/or generally have an adverse effect on an organism’s stress 

levels and immune system. Reduction of prey species would reduce food and nutrient availability for toplevel predators in aquatic habitat areas and could potentially result in cascading impacts throughout the 

local aquatic food chain and reduced biodiversity. However, crewed vessel transits would be infrequent 

in any given area and the exposure of prey species to vessel sound would be limited to the immediate 

vicinity of vessels and would only persist for the duration of vessel transit through the habitat area. The 

cumulative contribution to background sound in the ocean from vessels operated by NOS would not be 

substantial and the exposure of prey species to these sounds at the levels and lengths of time that may 

cause anything other than minimal adverse effects would be unlikely. NOS sound sources would be 

localized and short term and would not likely overlap with other sound sources.

The use of active underwater acoustic sources in other surveying mapping activities, national defense and 

homeland security activities, and oil, gas, carbon storage, or renewable energy assessments would involve 

directional and brief repeated signals which could cumulatively increase the ambient sound environment 

of aquatic habitat areas. Although the active underwater acoustic sources used by NOS described in 

Chapter 2 would not be perceptible to most marine prey species, other active underwater acoustic 

sources commonly used in support of cumulative actions have a greater propensity to injure marine prey 

due to the high intensity and large-scale propagation of the broadband sound they produce. These high 

intensity sources, including airguns, could have a more substantial impact on habitat areas than the NOS 

sources described in Section 3.4, especially when considered cumulatively. Exposure of marine prey to 

this sound could result in the same adverse impacts to the aquatic food chain as those discussed in the 
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preceding paragraph. However, active underwater acoustic sources used by NOS are typically only 

operated while a ship is in motion and habitat areas would only be exposed to emitted acoustic energy 

for a very short duration. Furthermore, these sources are highly directional in nature, and the energy of 

their emitted acoustic signals would drop off rapidly with distance from the source. Therefore, impacts 

on marine prey species would be predominantly limited to temporary behavioral and stress-startle 

response, and the likely cumulative impact on the overall habitat quality would be negligible to minor in 

any given area. 

Sound from vessel operations (both NOS and other) and underwater construction activities from other 

actions, which would generate sounds in the mid- and low-level frequencies, are within the hearing range 

of most prey species but would be infrequent, geographically widely distributed, and likely to cumulatively 

elicit a minimal or temporary response. It is also an NOS practice to generally avoid repeated surveys by 

NOS in the same location, thereby mitigating increased ambient sound levels within the action area. A 

majority of the sounds generated by underwater acoustic sources are well above the hearing frequencies 

of the most prey species, thus they are unlikely to cause cumulative behavioral disturbance and hearing 

impairment. Increased ambient sound levels throughout the action area would not likely cause cumulative 

long-term changes in the availability of space, shelter, cover, or nutrients for dependent species outside 

of the range of natural variation. The above-described NOS effects can also occur in almost all human use 

of water. These effects would be indistinguishable in type from other human uses. Overall, the cumulative 

impact of increased ambient sound levels throughout the action area would be adverse and negligible to

minor in magnitude. The contribution to these aggregate, adverse cumulative impacts on ambient 

underwater sound levels from any of the three NOS alternatives would be negligible.

4.2.1.4 Facilitated Dispersal of Invasive Species in Habitats

All activities under the Proposed Action which entail the use of the same physical equipment and 

instruments in geographically disparate regions (e.g., crewed vessel, ROV, and autonomous vehicle 

operations; anchoring; and the use of echo sounders), could contribute to cumulative impacts from all 

actions detailed in Section 4.1 in conjunction with ongoing climate change. Cumulatively, they could 

facilitate the dispersal of invasive species throughout marine, freshwater, and estuarine areas in the 

action area, reducing the availability of space, shelter, cover, and nutrients for dependent endemic 

species. 

Cumulative actions from both NOS and other entities would occur in all freshwater and marine regions of 

the action area and could involve transit and surveying across large swaths of the action area using the 

same physical equipment and survey instrumentation. These larger voyages or projects could potentially 

inadvertently transport invasive macroinvertebrate larvae, vertebrate eggs or animals, plant seeds, or 

algae propagules in ballast water or on equipment surfaces to novel areas, thereby facilitating their 

dispersal and establishment. Invasive species often have large numbers of offspring and limited or no 

natural threats or predators outside of their native habitat, allowing them to outcompete locally endemic 

species for space and nutrients. 

Over time, invasive species could propagate far beyond the initial site of establishment, which could 

cumulatively result in cascading impacts to the local food chains through the extirpation of local predators 

and prey due to reduced nutrient cycling and availability. These impacts would cumulatively change 

habitat structure and reduce the habitat value of affected areas in the long-term or permanently after the 

establishment of invasives; these species and their resulting impacts would persist until all invasive 

organisms were removed from a given area through aggressive trapping, harvesting, or use of pesticides 
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such as glyphosate. Global rising sea temperatures as a result of ongoing climate change could 

cumulatively exacerbate these impacts by shifting the distribution of ideal abiotic habitat conditions (e.g., 

water temperature or acidity) for endemic species. Invasive species typically have wider ranges of 

tolerability for abiotic environmental conditions, allowing them to withstand climate-related stresses and 

either outcompete less tolerant endemic species or establish themselves in habitat areas vacated by 

endemic species dispersed by altered abiotic environmental conditions.

Physical equipment and instruments used in consecutive projects in disparate geographically regions 

could potentially serve as transmission vectors for invasive species, which could cumulatively reduce the 

habitat value of their area of introduction by outcompeting endemic plants, animals, and algae. After 

establishment, cumulative impacts could potentially spread beyond project areas and persist until 

invasive species are suppressed or removed from these areas via aggressive management techniques and 

procedures, reducing the availability of space, shelter, cover, or nutrients for dependent species outside 

of the range of natural variation. However, vessel crews on NOS projects would implement invasive 

species control procedures such as deballasting or equipment washing as required by law, reducing the 

likelihood of invasive propagation. It is also an NOS practice to generally avoid repeated surveys by NOS 

in the same location, thereby mitigating dispersal of invasive species within the action area. The abovedescribed NOS effects can also occur in almost all human use of water. These effects would be 

indistinguishable in type from other human uses. Overall, given its relatively low likelihood of occurrence, 

the aggregate, adverse cumulative impact of invasive species dispersal would be minor to moderate in 

magnitude. The contribution to these aggregate, adverse cumulative impacts on invasive species dispersal 

from any of the three NOS alternatives would be negligible.

4.2.1.5 Impacts to the Water Column in Habitats

Crewed vessel, ROV, and autonomous vehicle operations; use of sound speed data collection equipment 

and bottom grab samplers; operation of drop/towed cameras and video systems; and SCUBA operations 

under the Proposed Action could contribute to cumulative impacts from the presence and movement of 

vessels associated with all cumulative actions, including raising and lowering of equipment, and 

construction, operation, and decommissioning of long-term installations (e.g., LNG terminals, energy 

infrastructure, and submarine telecommunications). In aggregate, these could cumulatively disturb the 

water column throughout marine, freshwater, and estuarine areas in the action area, reducing the 

availability of space, shelter, cover, and nutrients for dependent species. 

Wakes from crewed vessels, ROVs, and autonomous vehicles used in support of other surveying and 

mapping activities; fossil fuel, renewable, or carbon storage assessments; homeland security activities; 

and expanded recreational boating and commercial fishing would create turbulence and generate wave 

and surge effects in the water column. This displacement of water could cumulatively disrupt important 

environmental gradients, including temperature, salinity, DO, turbidity, and nutrient supply. Propellers 

from vessels could also cause water column destratification and elevated water temperatures. Vessel 

movements through the water column could cumulatively disrupt benthic communities in shallow areas 

and other prey species and cause mortality to floating eggs and larvae by physically damaging them with 

the hull or other ship parts, including the propulsion system. These disruptions would likely reduce the 

availability of space, shelter, and nutrients for dependent species within oceanic and shallow marine 

habitat areas and could cumulatively disrupt food chains, ultimately reducing the overall biodiversity of 

the study area. However, the vast majority of cumulative disturbance impacts to habitat areas would be 

limited to the immediate vicinity of vessels, and would only persist for the duration of transit or survey 

activities within the affected area. 
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Instruments, gear, and personnel that interact with the water column, including anchors and chains, 

bottom sampling equipment, echo sounders, airguns, and fishing lines or nets could cumulatively disturb 

or displace nearby benthic communities and other prey species. Reduction of prey species would reduce 

food and nutrient availability for top-level predators in aquatic habitat areas and could potentially result 

in cascading impacts throughout the local aquatic food chain and reduced biodiversity. Lines connecting 

equipment to a vessel could also become entangled with, damage, or kill underwater structural habitat 

features such as seagrass or corals. Reduction of underwater structure would likely cumulatively reduce 

the space, shelter, and cover necessary for the avoidance of predators by prey species and the rearing or 

development of offspring. Additionally, the expansion of commercial or recreational fishing could disturb, 

entangle, or directly target aquatic predators and prey species, which could drastically cumulatively alter 

food chains and energy flows throughout the action area. However, the vast majority of cumulative 

disturbance impacts to habitat areas would be limited to the immediate vicinity of instruments, gear, or 

personnel and would only persist for the duration of the activity. Mobile species would likely only be 

minimally displaced from project areas and would not experience long-term changes in the availability of 

space, structure, shelter, or nutrients outside the range of natural variability. 

Most of the cumulative disturbance and displacement impacts to the water column would still likely be 

limited to the immediate vicinity of the source and would not persist beyond the conclusion of a project. 

It is also an NOS practice to generally avoid repeated surveys by NOS in the same location, thereby 

mitigating increased disturbance and displacement impacts to the water column within the action area. 

The above-described NOS effects can also occur in almost all human use of water. These effects would be 

indistinguishable in type from other human uses. Overall, aggregate impacts of all actions described in 

Section 4.2.1.5 would not likely cause cumulative, long-term changes in the availability of space, shelter, 

cover, or nutrients for dependent species in habitat areas throughout the action area outside of the range 

of natural variation; thus, aggregate, adverse cumulative impacts would be considered negligible to minor

in magnitude. The contribution of the NOS Proposed Action to these aggregate, adverse cumulative 

impacts from any of the three NOS alternatives would be negligible.

4.2.1.6 Impacts to Terrestrial Habitats

Installation of tide gauges and remote GPS reference systems under the Proposed Action could contribute 

to cumulative impacts on terrestrial habitats from construction, operation, and decommissioning of longterm installations (e.g., LNG terminals, energy infrastructure, and submarine telecommunications), 

coastal erosion resulting from climate change, and currently expanding coastal development in 

conjunction with coastal population growth. Cumulatively, these actions could degrade or reduce 

terrestrial habitat areas throughout the action area, reducing the availability of space, shelter, cover, and 

nutrients for dependent species. 

The installation of or access to semi-permanent to permanent structures or equipment, such as LNG 

terminals, energy infrastructure, submarine telecommunications, and coastal commercial development, 

in conjunction with ongoing coastal erosion resulting from climate change could cumulatively reduce the 

quantity and quality of coastal terrestrial habitat throughout the action area. Many species of marine and 

terrestrial animals, including all Endangered Species Act (ESA)-listed bird species described in Section 3.10 

and ESA-listed sea turtles, breed and nest along the coast. During onshore access or construction 

activities, vegetation in and adjacent to the project area could be trampled by foot traffic, damaged, or 

cleared, cumulatively reducing cover and shelter necessary for terrestrial or marine animals to avoid 

predation, breed, and nurture offspring. Repeated disturbances could result in long-term changes in 
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terrestrial prey distributions and could ultimately reduce the overall biodiversity of habitat areas due to 

reduced nutrient cycling and availability. Light pollution from these structures could also disorient 

terrestrial animals, further disrupting terrestrial and aquatic food chains within the area. 

Similarly, ongoing coastal erosion and commercial and residential development of coastal areas will 

continue to encroach upon existing coastal terrestrial habitat areas in all directions, further cumulatively 

reducing the space available for terrestrial animals. However, the majority of NOS onshore installations 

would only occupy very small portions of terrestrial habitat and any affected terrestrial components 

would likely recover post-installation. Disturbances resulting from the accessing of NOS installations 

would be limited to the immediate vicinity of the project area and would not persist beyond the 

conclusion of activity in the area. NOS’s onshore installations are not expected to reduce the availability 

of space, shelter, cover, or nutrients necessary for dependent species in the long term.

Generally, cumulative impacts to terrestrial habitat areas would persist for the entirety of the foreseeable 

future, but would not cumulatively reduce the availability of space, shelter, cover, or nutrients for 

dependent aquatic or terrestrial species. Disturbances to terrestrial taxa would also be limited to the 

immediate vicinity of onshore installations or activities and would only persist for the duration of the 

activity in question. It is also an NOS practice to generally avoid repeated surveys by NOS in the same 

location, thereby mitigating increased disturbance to terrestrial habitat within the action area. The abovedescribed NOS effects can also occur from almost all human uses of water. These effects would be 

indistinguishable in type from other human uses. Overall, the aggregate, adverse cumulative impacts to 

terrestrial habitat would likely be negligible to minor in magnitude. The contribution to these aggregate, 

adverse cumulative impacts on terrestrial habitats from any of the three NOS alternatives would be 

negligible.

4.2.1.7 Conclusion

When considered in tandem with the NOS Proposed Action, other surveying and mapping efforts in the 

action area, offshore oil and natural gas development, offshore renewable energy development, climate 

change, commercial shipping and recreational boating, assessment and extraction of marine minerals, 

offshore carbon storage resource assessments, construction and operation of offshore LNG terminals, 

national defense and homeland security activities, construction of new submarine telecommunication 

cable infrastructure, commercial and recreational fishing, and coastal development would create adverse 

cumulative impacts to habitats. Adverse impacts to habitats could occur through bottom substrate 

contact, increased sedimentation, turbidity and/or chemical contamination, increased ambient sound 

level, facilitated dispersion of invasive species, disturbances to the water column, and terrestrial 

disturbance within the action area. In the short-term, the presence and movement of vessels; use of active 

acoustic sound sources; vessel sound; and underwater activities in conjunction with current accidental or 

illicit discharges of oil, fuel, chemicals, or waste, and ongoing onshore, nearshore, and offshore 

development could temporarily adversely affect habitat by degrading water quality and displacing marine 

or terrestrial prey species in the immediate vicinity of NOS activities. Disturbances and displacements 

resulting from activities are not expected to persist beyond the duration of activities. Onshore, nearshore, 

and offshore development in conjunction with ongoing anthropogenic climate change would reduce the 

total amount of available terrestrial habitat in the long-term, however no other activities or actions would 

contribute long-term impacts to habitat areas except the unlikely occurrence of widespread propagation 

of invasive species facilitated by a given cumulative action.
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Overall, the short and long-term aggregate adverse cumulative impacts from the cumulative effects 

scenario (i.e., actions described in Section 4.1) on habitats throughout the action area are negligible to

moderate in magnitude, with moderate impacts occurring only in the event of widespread propagation 

of invasive species, and are therefore expected to result in insignificant impacts to habitats.

Cumulative, adverse impacts from the Proposed Action in combination with the cumulative effects 

scenario could potentially be considered either synergistic or additive depending on the timing and 

location of activities and impacts. Synergistic impacts could result if any activities or actions occur in close 

spatial or temporal proximity within the study area. Similarly, additive cumulative impacts to habitat areas 

could occur if activities or actions are conducted sequentially within adjacent areas of the study area. 

Although the exact timing and location of NOS projects have not been finalized and are subject to change, 

the Southeast and Alaska regions contain the largest proportion of NOS’s total miles of vessel movement 

in the EEZ (Section 2.4.1) and relatively high levels of marine oil and gas development. Therefore, 

synergistic or additive cumulative impacts are most likely to occur in either of these regions. The vast 

majority of cumulative impacts are confined to the immediate vicinity of project areas and would likely 

not impact the overall availability of space, shelter, cover, or nutrients within habitat areas outside of the 

range of natural variability.

The NOS Proposed Action would contribute to and have the potential to increase these cumulative 

impacts, but their relative contribution would be negligible as compared to the aggregate contributions 

of other cumulative actions. These impacts would occur regardless of the chosen alternative since projects 

under each alternative would be composed of similar activities and take place in the same geographic 

areas and timeframes; however, Alternatives B and C would be expected to have slightly higher 

cumulative impacts because these alternatives include more projects, activities, and nautical miles 

traveled than Alternative A.

4.2.2 Marine Mammals

All past, present, and reasonably foreseeable future actions described in Section 4.1 would contribute 

cumulative effects on marine mammals. Based on the analysis presented in Section 3.5 Marine Mammals, 

impacts of the Proposed Action would result in negligible to minor, or possibly moderate, impacts to 

marine mammals. The main impacts from the Proposed Action that could contribute to cumulative 

impacts on marine mammals are injury acoustic exposures [permanent threshold shifts or PTS] due to 

underwater acoustic sources; entanglement; exposure to oil, fuel, and other contaminants; and a very low 

likelihood of vessel strikes) and disturbance or behavioral modification (from acoustic exposures due to 

underwater acoustic sources; vessel noise and masking; presence and movement of vessels; and human 

activity). The analysis also considers that additional actions and activities contribute to the existing 

condition of marine mammals, including the accidental or illicit discharge of oil, fuel, chemicals, or waste. 

To a lesser degree, the Proposed Action could also contribute cumulative impacts to animal fitness, 

habitat alteration, and even animal mortality.

The following analysis considers how the NOS-related incremental impacts of the NOS Proposed Action, 

when added to or acting synergistically with other past, present, and reasonably foreseeable future 

actions, would contribute to overall cumulative impacts.

4.2.2.1 Mortality and Injury to Marine Mammals

Marine mammal mortality and injury from other cumulative actions could result from contact with spilled 

oil and other contaminants, vessel strikes, fishing bycatch, and entanglement. Accidental or illicit 
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discharges of oil, fuel, chemicals, or waste contribute to the existing mortality and injury of marine 

mammals. Contact with spilled oil leads to loss of life or life-threatening injury to marine mammals, and 

can seriously threaten the continued viability of the population, potentially having a major impact if the 

level of mortality or debilitating injury was in sufficiently high numbers that the continued viability of the 

population was seriously threatened. 

Vessel strikes have been and will continue to be a cause of marine mammal mortality and injury. In 

particular, the most vulnerable marine mammals are likely those that spend extended periods at or just 

below the water surface, slow-moving species, or species whose unresponsiveness to vessel sound makes 

them more susceptible to vessel collisions (Gerstein, 2002; Nowacek et al., 2004). Marine mammals such 

as dolphins, porpoises, and pinnipeds that can move quickly throughout the water column are not as 

susceptible to vessel strikes. Vessel strikes likely have a less than perceptible impact on the status of most 

marine mammal populations, but for small populations, vessel strikes may have considerable populationlevel impacts. Commercial fishing activities are expected to result in some injury and mortality of marine 

mammals because of animals taken as fisheries bycatch or entangled in fishing gear. NOS does not expect 

any mortality and very little injury of marine mammals as a result of the Proposed Action. The probability 

for collisions of vessels used by NOS with most marine mammal species is extremely unlikely considering 

the relatively slow speeds of survey vessels, visual observation, and the speed and agility of most marine 

mammal species. 

Likewise, the likelihood of occurrence of an accidental spill from a vessel used by NOS would be very low. 

In the event that an accidental spill does occur, the volume of oil, fuel, and/or chemicals would be fairly 

small given the small amounts of fuel and other chemicals used for consumption that are typically 

onboard, as well as the proper handling of all hazardous or regulated materials in accordance with 

applicable laws. Injury that might occur under the NOS actions would be additive to injury and mortality 

associated with other cumulative actions. NOS does not anticipate mortalities to marine mammals as a 

result of any of the NOS alternatives. The relative contribution of the Proposed Action to overall injury 

would be negligible compared to other cumulative actions. Thus overall, all three alternatives would be 

expected to contribute negligible cumulative impacts due to mortality and injury of marine mammals.

In addition to injury impacts associated with vessel strikes, bycatch, and entanglement as discussed above, 

marine mammals could also be injured by underwater noise. Such noise can occur from activitiesincluding 

use of Navy sonar systems, seismic airgun surveys, HRG surveys, underwater drilling, underwater pile 

driving, and underwater use of explosives, all of which produce low to high frequency underwater noise. 

Direct physical injury, which may result in death, may occur from exposure to high levels of impulsive 

sound, such as shock waves associated with in-water explosions. Exposure to non-impulsive acoustic 

energy also has the potential to cause indirect death of marine mammals, which has been associated with 

use of Navy sonars; while the sound itself may not have directly caused death or injury, it is assumed to 

be a causal factor in behavior (i.e., in such cases as strandings) that led to deaths (Marine Mammal 

Commission, 2006; ICES, 2005). If underwater noise (at a level that causes mortality or injury) occurred at 

the same time and place, they could synergistically contribute to adverse cumulative acoustic impacts on 

marine mammals; if they do not occur at the same time and place, they could additively contribute to 

adverse cumulative impacts. However, the vast majority of impacts expected from cumulative underwater 

noise are behavioral in nature, temporary and comparatively short in duration, relatively infrequent, but 

which may result in behavioral disruption exposures (disturbance and behavior modification). The NOS 

Proposed Action could also result in both PTS/injury and behavioral disruption exposures to individuals of 

some marine mammal species from underwater acoustic sound sources. Although it is possible that injury 

that might occur under the NOS actions would be additive to injury associated with other cumulative 
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actions, NOS projects are not likely to occur at the same time and place as other cumulative actions 

because conducting the NOS activities near other active acoustic activities could cause survey 

interference. It is also possible that the proposed action could cause a more serious behavioral response 

in an animal already injured by another cumulative activity. However, injury exposures would not likely 

be accumulative because other acoustic activities would not likely overlap in time and space with NOS 

projects. In addition, acoustic activities are typically temporary and localized. Additionally, the relative 

contribution of all three alternatives to the overall injury exposures of marine mammals in the action area 

would be negligible as compared to other cumulative actions. 

Overall, the aggregate, adverse cumulative impacts to marine mammals from mortality and injury would 

likely be minor to moderate. The contribution to these aggregate, adverse cumulative impacts from all 

three NOS alternatives would be negligible.

4.2.2.2 Marine Mammals Disturbance and Behavioral Modifications

Disturbance and behavioral modifications of marine mammals are associated with underwater surveying 

and mapping equipment and construction sounds, vessel and aircraft sound, and vessel and human 

presence. Low frequency vessel sound occurs in the same bands in which most large whale calls and songs 

occur (Richardson et al., 1995) and could interfere with animals’ abilities to detect important sounds 

(Francis and Barber, 2013). Noise is of particular concern to marine mammals because many species use 

sound as a primary sense for navigating, finding prey, and communicating with other individuals. Noise 

can cause behavioral disturbances, mask other sounds (including their own vocalizations), and result in 

injury (as discussed above) (Tyack, 2009). 

Other anthropogenic sound sources in the action area include dredging, O&G operations, nearshore 

construction activities, G&G research operations, shipping and other large vessel noise, and military 

training and testing exercises. Increasing ambient sound levels may steadily erode marine mammals’ 

abilities to communicate, find food, mate, and navigate. Noise and visual presence of aircraft would 

similarly disturb and stress marine mammals. Overall, there would be localized disturbance and behavioral 

impacts due to vessel sound, vessel movement, and human presence within specific portions of the action 

area during NOS projects. However, impacts are expected to be spatially localized and temporary or shortterm in duration. Implementation of mitigation measures such as animal approach restrictions and low 

vessel speeds (see Section 3.5.2.3) are expected to minimize potential impacts on animal behavior. Other 

cumulative actions are unlikely to overlap in time and space with NOS projects because these activities 

are dispersed and the sound sources are intermittent. It is likely that distant shipping sound, which is more 

universal and continuous, would overlap in time and space with actions under the NOS Proposed Action. 

However, the Proposed Action would likely only contribute negligible cumulative impacts caused by 

disturbance and behavior modification of marine mammals. 

Overall, the aggregate, adverse cumulative impacts to marine mammals from disturbance and behavioral 

modifications would likely be minor. The contribution to these aggregate, adverse cumulative impacts 

from all three NOS alternatives would be negligible.

4.2.2.3 Reduced Fitness of Marine Mammals Due to Pollutants

Pollutants from multiple sources are present in, and continue to be released into, the oceans. Long-term 

exposure to pollutants poses potential risks to the health and fitness of marine mammals (Reijnders et al., 

2008). Reduced animal fitness associated with air emissions and water pollution due to the accidental 

leakage or spillage of oil, fuel, and chemicals could have potential impacts such as organ anomalies and 
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impaired reproduction and immune function (Reijnders et al., 2008). In an oil spill, whales, dolphins, and 

pinnipeds may be exposed to volatile chemicals during inhalation. Marine mammals with hair, such as fur 

seals or sea otters, would be at risk of insulation effects. Oil and other chemicals on skin and body may 

result in skin and eye irritation, burns to the mucous membranes of the eyes and mouth, and increased 

susceptibility to infection. For mysticetes, oil can foul the baleen they use to filter-feed, thereby 

potentially decreasing their ability to eat. 

Inhalation of volatile organics from oil or dispersants can result in respiratory irritation, inflammation, 

emphysema, or pneumonia. Ingestion of oil or dispersants may result in gastrointestinal inflammation, 

ulcers, bleeding, diarrhea, and maldigestion. If the health of an individual marine mammal were 

compromised by long-term exposure to pollutants, it is possible that it could alter the animal’s expected 

response to other environmental stresses, such as underwater noise. 

Considering that the amount of air emissions from vessels used by NOS would continue to be a tiny 

fraction as compared to emissions from all other vessel activity, and the small number of vessels used by 

NOS that could accidently spill oil, fuel, and chemical contaminants into the ocean, as well as the small 

amounts of fuel and other chemicals used for consumption that are typically onboard, the incremental 

increase in cumulative impacts of the NOS alternatives on marine mammal health and fitness would be 

negligible. The potential also exists for the impacts of ocean pollution associated with the NOS Proposed 

Action to be additive or synergistic as it is possible that the response of a previously stressed animal would 

be more severe than the response of an unstressed animal.

Overall, the aggregate, adverse cumulative impacts to marine mammals from reduced fitness would likely 

be minor. The contribution to these aggregate, adverse cumulative impacts from all three NOS 

alternatives would be negligible.

4.2.2.4 Alteration of Marine Mammal Habitat

Habitat alteration is associated with reduced prey/food sources and degraded water quality due to other 

cumulative actions, and to climate change. Overfishing of many fish stocks has resulted in significant 

changes in trophic structure, species assemblages, and pathways of energy flow in marine ecosystems 

(Jackson et al., 2001; Myers and Worm, 2003). These ecological changes may have adverse consequences 

for populations of marine mammals (DeMaster et al., 2001) as prey food sources are reduced. Air and 

water pollution can not only have adverse impacts on marine mammals themselves, as discussed above, 

but also on habitat as air and water quality are degraded. Increased emissions of anthropogenic 

greenhouse gases (GHG) [CO2, methane (CH4), and nitrous oxide (N2O)] are warming the atmosphere, and 

rising levels of CO2 in particular are producing changes in seawater carbon chemistry. Climate change 

effects include changes in air and sea temperatures, precipitation, the frequency and intensity of storms, 

pH level of sea water, and sea level. These changes could affect overall marine productivity, leading to 

altered migratory routes and timing, and changes in prey/food availability and reproductive success of 

marine mammals. Changes in seasonal sea ice as a result of climate change may lead to additional 

increases in commercial shipping, recreational boating, and other vessel traffic in marine mammal habitat 

in the Alaska Region. Although the NOS Proposed Action would have some adverse impacts on fish and 

aquatic macroinvertebrates that make up the prey/food sources for marine mammals (see Sections 3.7 

Fish and 3.8 Aquatic Macroinvertebrates), these impacts would be very small as compared to other 

cumulative actions affecting these resources. Likewise, the impacts of the Proposed Action from 

accidental spills and air emissions that could contribute to degraded water quality in marine mammal 

habitat or to climate change would also be negligible as compared to all other cumulative actions affecting 
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water quality and climate change. Thus, the NOS Proposed Action would only contribute negligible 

cumulative impacts that could alter marine mammal habitat. 

Overall, the aggregate, adverse cumulative impacts to marine mammals from alteration of their habitat 

would likely be minor to moderate. The contribution to these aggregate, adverse cumulative impacts 

from all three NOS alternatives would be negligible.

4.2.2.5 Conclusion

When considered in tandem with activities associated with the NOS Proposed Action, other surveying and 

mapping efforts in the action area, offshore oil and natural gas development, offshore renewable energy 

development, climate change, commercial shipping and recreational boating, assessment and extraction 

of marine minerals, offshore carbon storage resource assessments, construction and operation of 

offshore LNG terminals, national defense and homeland security activities, construction of new submarine 

telecommunication cable infrastructure, commercial and recreational fishing, and coastal development 

would create adverse cumulative impacts to marine mammals. These adverse impacts occur through 

mortality and injury (due to vessel strikes, bycatch in fisheries, entanglement in fishing and other gear, 

contact with contaminants, and underwater noise); disturbance and behavior modification (due to 

underwater equipment and construction sounds, vessel and aircraft sounds, and vessel and human 

presence); reduced animal fitness (due to air and water pollution); and habitat alteration (due to reduced 

prey/food sources, degraded water quality, and climate change). 

These past, present, and reasonably foreseeable future actions are expected to result in insignificant 

impacts to most marine mammal species, and significant impacts on some marine mammals in the action 

area. Overall, the cumulative impacts of all actions described in Section 4.1 affecting disturbance and 

behavioral modification, animal fitness, and habitat alteration are adverse and moderate as the continued 

viability of populations would not be threatened. These impacts would therefore be insignificant. Other 

impacts are considered major and thus significant because the cumulative effects of other cumulative 

actions described in Section 4.1 (particularly from vessel strikes, bycatch, entanglement, and reduced 

prey) are expected to result in relatively high rates of injury and mortality that could cause population 

declines in some marine mammal species. Therefore, cumulative impacts on marine mammals would be 

significant without consideration of the impacts of the Proposed Action.

Cumulative, adverse impacts from any of the alternatives in combination with the cumulative effects 

scenario could potentially be considered either synergistic or additive depending on the timing and 

location of activities and impacts. Cumulative adverse impacts could be synergistic if activities associated 

with the NOS Proposed Action and other cumulative actions occur in close spatial or temporal proximity. 

Similarly, additive effects to marine mammals may occur if actions taken by others are performed 

sequentially with activities associated with the NOS Proposed Action. The Proposed Action would 

contribute to and have the potential to increase cumulative impacts, but their relative contribution would 

be negligible as compared to aggregate contributions from other cumulative actions because the NOS 

impacts would be temporary or short-term, would be confined to the immediate vicinity of project areas, 

and would be small as compared to impacts from all other cumulative actions. NOS impacts would occur 

regardless of the chosen alternative since projects under each alternative would be composed of similar 

activities and take place in the same geographic areas and timeframes; however, Alternatives B and C 

would be expected to have slightly higher cumulative impacts because these alternatives include more 

projects, activities, and nautical miles traveled than Alternative A.
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4.2.3 Sea Turtles

All past, present, and reasonably foreseeable actions described in Section 4.1 would contribute 

cumulative effects to sea turtles. The analysis of cumulative effects also considers that other actions and 

activities contribute to the existing condition of sea turtles, including habitat encroachment from onshore 

and nearshore development (e.g., coastal population growth, light pollution) and accidental or illicit 

discharge of oil, fuel, chemicals, or waste. 

4.2.3.1 Mortality and Injury to Sea Turtles

Crewed vessel operations and active acoustic surveying under the NOS Proposed Action could contribute 

to cumulative impacts from the use of high intensity active underwater acoustic sources used by several 

cumulative activities, such as seismic surveys or piledriving, and the presence and movement of vessels 

associated with any of the past, present, or reasonably foreseeable actions. In combination, these 

cumulative activities would likely contribute direct injury impacts to sea turtles or their prey. Sea turtles 

may be able to hear low frequency sources that go down to 0.5 kHz. These low frequency sources are 

used in deeper water, so sea turtles exposed would likely be farther away from the source. However, 

underwater sound produced by the NOS active underwater acoustic sources would mostly be at

frequencies reaching up to orders of magnitude above the documented sea turtle hearing range and 

would therefore be imperceptible to sea turtles. As such, there would not likely be cumulative effects 

from NOS sources even when considering that the active acoustic sources commonly used in other 

surveying and mapping activities, assessment and exploration of marine minerals, and offshore carbon 

storage assessments have a propensity to injure sea turtles. 

The presence and movement of crewed vessels within the action area, including all vessels used in 

conjunction with activities under the Proposed Action and all past, present, and reasonably foreseeable 

actions, could cumulatively contribute to collisions with sea turtles that could result in sea turtle injury or 

mortality. Propeller and collision injuries to sea turtles arising from interactions with crewed vessels are 

relatively common; 20.5 percent of observed leatherback sea turtles in the Atlantic Ocean and Gulf of 

Mexico had sustained propeller injuries in 2004 (NMFS and USFWS, 2008). Give the low speed and small 

size of most vessels used by NOS (see Section 2.4.1), and that all vessels used by NOS would constantly 

monitor for protected species, collisions are expected to be generally avoided during NOS projects. There 

is also a very small possibility of temporary or permanent hearing threshold shifts in sea turtles resulting 

from low-frequency vessel sound from the transit of vessels through the action area. Sound produced by 

vessels used by NOS would typically be outside the range of source levels that could induce avoidance 

behaviors, limiting their contribution to cumulative impacts.

Commercial fishing activities are expected to result in some injury and mortality of sea turtles due to 

entanglement in fishing gear. Expanded commercial fishing operations would likely increase bycatch of 

sea turtles and their prey, particularly in longline or trawled fisheries where operators cannot 

continuously monitor trailed lines, hooks, and nets for protected species. As such, the overall abundance 

of sea turtle prey could be reduced.

Accidental or illicit discharges of fuel, chemicals, or waste accompanying all vessel operations within the 

action area contribute to the existing direct injury of turtles and prey through ingestion and interaction 

with spilled substances, although the intensity of the impact would be contingent upon the size and 

location of the spill in question. Contaminated prey or forage could also potentially serve as an additional 

source of contaminant exposure to sea turtles, particularly of bioaccumulated hazardous materials. Such 

accidents may be caused by equipment malfunction, human error, or natural phenomena and are not 
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likely to occur during NOS activities. In the unlikely event of an accidental spill, NOS personnel are required 

to respond immediately to limit the extent of the spill. Also, NOS vessel operations are only a small fraction 

of all vessels operations in the U.S. EEZ, so they would contribute very little to overall cumulative impacts 

from accidental discharges of fuel, chemicals, or waste.

Light pollution from onshore and nearshore commercial, residential, or O&G development in close 

proximity to sea turtle nesting beaches contributes to the currently reduced likelihood of offspring survival 

to reproductive maturity. Nearshore NOS night operations, although not commonly conducted, could 

potentially contribute to cumulative coastal light pollution. Light pollution disorients sea turtle hatchlings 

or nesting sea turtle adult females, which navigate beaches using moonlight. Rising temperatures as part 

of ongoing climate change will continue to skew sea turtle sex-ratios due to temperature-dependent sex 

determination of sea turtle offspring. Over time, generally warmer incubation temperatures will skew the 

overall sex-ratio towards females and result in the reduction of overall sea turtle population numbers and 

genetic diversity. Ocean acidification accompanying climate change will harm the sea turtle 

macroinvertebrate prey species that are particularly sensitive to environmental conditions during their 

larval stages and will likely reduce their availability to sea turtles. 

The majority of cumulative direct injury impacts would be limited to the immediate vicinity of vessels or 

O&G development and would not likely cause long-term changes in turtle behavioral patterns, habitat 

availability and use, or the demographic structure and abundance of turtle and prey populations. Similarly, 

climate-related impacts would not likely substantially affect turtles, although impacts would likely 

continue to increase over time. Overall, the aggregate, adverse cumulative impacts to sea turtles from 

direct injury would likely be minor to moderate. The contribution to these aggregate, adverse cumulative 

impacts from all three NOS alternatives would be negligible to minor.

4.2.3.2 Disturbance and Displacement of Sea Turtles

Sound from vessel operations under the NOS Proposed Action could contribute to the disturbance of sea 

turtles in conjunction with other cumulative oceanic anthropogenic activities. Sound from survey vessels, 

shipping vessels, commercial fishing vessels, recreational boats and underwater construction activities in 

support of energy infrastructure, LNG terminals, and submarine telecommunications infrastructure could 

also cumulatively disturb and displace turtles and their prey from the respective project areas for the 

duration of the activity in question. The visual presence of vessels would also likely serve as an additional 

source of disturbance and displacement. 

Sea turtles are low frequency specialists with a generalized hearing range of 30 to 2,000 Hz (0.03 to 2 kHz) 

and are most sensitive to sound between 200 and 400 Hz (0.2 and 0.4 kHz). Sea turtles may be able to 

hear low frequency sources that go down to 0.5 kHz. Low frequency underwater acoustic sources from 

other cumulative actions are used in deeper water, so animals exposed would likely be farther away from 

the source. Underwater sound produced by NOS active underwater acoustic sources would mostly be at

frequencies reaching up to orders of magnitude above the documented sea turtle hearing range and 

would therefore be imperceptible to sea turtles and unlikely to cause behavioral changes. Vessel sound

has the potential to disrupt normal sea turtle behavior because of their high hearing sensitivity between 

200 and 400 Hz.

The NOS Proposed Action would contribute to cumulative underwater disturbance from vessel movement 

and presence and bottom sampling. However, sea floor disturbance would be limited to relatively small 

portions of a given project area, and any resulting changes to water quality would be quickly dissipated 
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by prevailing ocean currents. Reduced water quality and increased turbidity would result from the ongoing 

erosion of coastlines by rising sea levels, bottom sampling, or underwater construction activities, all of 

which could disturb and displace sea turtles/prey. Climate change will continue to raise sea levels globally 

for the foreseeable future, which results in continual erosion throughout the coastlines of the EEZ. Coastal 

erosion occurs at varying rates around the EEZ, but would be most pronounced near sea turtle breeding 

grounds along the Atlantic coastline, which carry a greater risk of impacting the overall sea turtle 

population.

Ongoing accidental or illicit discharges of fuel, chemicals, or waste from vessel operations and marine 

infrastructure can disturb and displace sea turtles and their prey from contaminated areas for the lifetime 

of the spill. The intensity of the impact is contingent upon the size and location of the spill in question and 

most small spills are dissipated by ocean conditions on a timescale of minutes to hours. However, there 

is only a very low likelihood of small spill occurrence from vessels used by NOS and no possibility of large 

spills given the size of vessels used by NOS. Energy installations included in the cumulative effects scenario 

carry a larger probability of large spills than NOS activities, particularly in offshore oil/gas installations with 

tankers and pipelines. 

Cumulative disturbance and displacement impacts would still likely be limited to the immediate vicinity 

of the source and would not persist beyond the conclusion of activities, although impacts could be 

magnified in the unlikely occurrence of a large spill. These aggregate, adverse cumulative impacts are not 

expected to cause long-term changes in habitat availability, overall turtle behavioral patterns, or overall 

prey availability and would be considered negligible to minor. The contribution to these aggregate, 

adverse cumulative impacts from all three NOS alternatives would be negligible.

4.2.3.3 Degradation and Reduction of Sea Turtle Habitat

Impacts associated with the construction and eventual decommissioning of long-term installations (e.g., 

LNG terminals, energy infrastructure, and submarine telecommunications) would likely reduce the total 

amount of oceanic habitat available to sea turtles and their prey for the lifetime of the installation. Sea 

turtles and their prey would likely be displaced from these areas for the duration of the installation due 

to reduced water quality and various disturbances related to the operation and maintenance of the 

infrastructure, such as vessel traffic, low flying aircraft, waste discharge, underwater disturbance from 

welders, divers and wakes, and vessel sound. Following decommissioning, the development area would 

be reclaimed and should return to previous habitat conditions. Onshore tide gauge installations and 

remote GPS reference station installations under the NOS Proposed Action could cumulatively contribute 

to these impacts, but the footprint of tide gauge installations and reference stations is extremely small, 

and sea turtles and their prey are expected to return to project areas after the completion of NOS onshore 

activities. No long-term changes to sea turtle habitat availability or habitat use are expected.

The ongoing accidental or illicit discharges of fuel, chemicals, or waste from vessel operations and marine 

infrastructure contributes to currently degraded sensitive coastal beach sea turtle nesting habitat. The 

intensity of the impact is contingent upon the size and distance of the spill in question from nesting 

beaches; most small spills are dissipated by ocean conditions on a timescale of minutes to hours. However, 

the operation of energy installations included in the cumulative effects scenario carry a greater probability 

of large spills with larger and longer-lasting impacts than do NOS activities, particularly in the case of 

offshore oil/gas installations with tankers, drilling rigs, production platforms, and pipelines.
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Coastal population growth contributes to currently degraded sea turtle nesting habitat through a variety 

of factors, including coastal water quality reductions from urban/agricultural runoff, encroachment by 

coastal development, and increased light pollution. Rising sea levels as result of climate change will 

continually erode coastlines along the EEZ and could potentially destroy or degrade sensitive sea turtle 

nesting beaches. Global rising temperatures could also shift sea turtle habitat and prey distributions 

northwards towards colder waters, and could ultimately reduce the total amount of available habitat or 

prey if the species dispersal rate is relatively lower than that of the rate of temperature changes. Seagrass, 

an important turtle forage, and coral reefs which shelter aquatic macroinvertebrate prey are also 

particularly susceptible to changes in abiotic environmental conditions and could be damaged or displaced 

from sea turtle habitat areas by eroding coastlines, rising temperatures, or ocean acidification. 

Generally, cumulative impacts to sea turtle habitat would persist for the foreseeable future, but would 

not substantially reduce overall habitat availability or quality and would not substantially impact the 

overall structure or abundance of sea turtle or prey populations. Nesting habitat reductions could 

potentially impact the overall sea turtle population since turtles return to the same beach to nest annually 

and would not be able to relocate in the event of the destruction or degradation of their predetermined 

nesting beach. However, nesting beaches are generally avoided by development given the federal 

protection of sea turtles. Aggregate cumulative impacts to sea turtle habitat from all actions and activities 

would likely be adverse, and minor to moderate. The contribution to these aggregate, adverse cumulative 

impacts from all three NOS alternatives would be negligible.

4.2.3.4 Conclusion

Activities associated with the Proposed Action and the cumulative effects scenario have the potential to 

contribute cumulatively to direct injury, disturbance and displacement, and habitat reduction impacts 

from past, present, and reasonably foreseeable actions within the action area. In the short-term, the 

presence and movement of vessels could potentially result in direct injury to turtles from collisions or 

entanglements and would likely disturb or displace nearby sea turtles for the duration of activities. 

Similarly, active acoustic sound sources; vessel sound; underwater construction activities; accidental or 

illicit discharges of oil, fuel, chemicals, or waste; and onshore, nearshore, and offshore development 

would displace sea turtles and their prey in the immediate vicinity of activities. Onshore and nearshore 

development and the accidental or illicit discharges of oil, fuel, chemicals, or waste contribute to the 

currently reduced total amount of sea turtle habitat. Climate change would reduce the total amount of 

available sea turtle habitat in the long-term, however no other activities or actions would contribute longterm impacts to sea turtles, except the unlikely occurrence of a large oil, fuel, or chemical spill. The vast 

majority of cumulative impacts would be confined to the immediate vicinity of project areas and would 

likely not impact the overall abundance or structure of sea turtle or prey populations outside of the range 

of natural variability. Overall, the cumulative impacts of all actions described in Section 4.1 would 

contribute negligible to moderate short-term and long-term adverse cumulative effects on sea turtles, 

depending on the timing and location of impacts.

Cumulative, adverse impacts from the Proposed Action in combination with the cumulative effects 

scenario could potentially be considered either synergistic or additive depending on the timing and 

location of activities and impacts. Synergistic impacts could result if any activities or actions occur in close 

spatial or temporal proximity within the study area. Similarly, additive cumulative impacts to sea turtles, 

their prey, or their associated habitat could occur if activities or actions are conducted sequentially within 

adjacent areas of the study area. Although the exact timing and location of projects have not been 

finalized and are subject to change, the Southeast and Alaska regions contain the largest proportion of 
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total vessel transit miles of the EEZ (Section 2.4.1) and relatively high levels of marine O&G development. 

Therefore, synergistic or additive cumulative impacts are most likely to occur in either of these regions. 

However, most affected animals would be located in the Southeast, because sea turtles are only 

occasional visitors to Alaska’s Gulf Coast waters.

The NOS Proposed Action would contribute to and have the potential to increase these cumulative 

impacts, but their relative contribution would be negligible as compared to the aggregate contributions 

of other cumulative actions. These impacts would occur regardless of the chosen alternative since projects 

under each alternative would be composed of similar activities and take place in the same geographic 

areas and timeframes; however, Alternatives B and C would be expected to have slightly higher 

cumulative impacts because these alternatives include more projects, activities, and nautical miles 

traveled than Alternative A. The contribution to these aggregate, adverse cumulative impacts from all 

three NOS alternatives would be negligible.

4.2.4 Fish

All past, present, and reasonably foreseeable future actions described in Section 4.1 would contribute 

cumulative effects on fish and fish habitat. Based on the analysis presented in Section 3.7 Fish, impacts of 

the NOS Proposed Action would result in negligible to minor impacts on fish and fish habitat. The Proposed 

Action could contribute to cumulative impacts on fish, including injury (hearing loss from underwater 

noise), disturbance or behavioral modification (from underwater sound, vessel wake and underwater 

turbulence, and bottom disturbance), and habitat alteration (from vessel wake and underwater 

turbulence; bottom disturbance; and air emissions). The analysis also considers that other actions and 

activities contribute to the existing condition of fish, including the accidental or illicit discharge of oil, fuel, 

chemicals, or waste which can cause mortality and marine debris (e.g., plastics, glass, metals, or rubber) 

and flows of pollutants, contaminants, sediments, and nutrients, which can reduce the fitness of fish. The 

following analysis considers how the NOS-related incremental impacts of the NOS Proposed Action, when 

added to or acting synergistically with other past, present, and reasonably foreseeable future actions, 

would contribute to overall cumulative impacts on fish.

4.2.4.1 Mortality and Injury to Fish

Fish mortality and injury from other cumulative actions could result from vessel strikes, underwater noise, 

fishing bycatch, and entanglement. Ongoing accidental or illicit discharges of oil, fuel, chemicals, or waste 

contribute to the existing mortality and injury of fish. All vessel operations, as well as other cumulative 

actions such as drilling and construction and placement of structures within the action area could 

cumulatively contribute to the mortality and injury of fish through ingestion and contact with spilled oil 

and fuel or released contaminants. Although most adult fish are mobile enough to avoid areas with higher 

concentrations of contaminants, less mobile eggs, larvae, and juvenile fish would be more susceptible 

than adults. Vessels and in-water devices do not normally collide with adult fish, most of which can detect 

and avoid them. However, early life stages of most fish could be displaced by vessels and a vessel’s 

propeller movement or propeller wash could entrain early life stages. 

The cumulative potential effects from underwater acoustic sources on any stock of fish from injury (i.e., 

permanent loss of hearing) are considered low because NOS acoustic sources are generally outside of fish 

hearing ranges, although these sources could affect shad, herring, and other fish that can hear these 

sounds if they are within several meters of a sound source. It is possible that shipping and aircraft sounds 

(which are pervasive and continuous) and sound associated with underwater explosions and sonar would 
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overlap in time and space; however, there is no evidence that the co-occurrence of these sounds would 

result in harmful additive impacts on fish. 

Overfishing is the most serious threat that has led to the listing of ESA-protected marine fish due to 

mortality and population declines (Kappel, 2005; Cheung et al., 2007; Dulvy et al., 2003; Limburg and 

Waldman, 2009). Approximately 17 percent of the U.S.-managed fish stocks are overfished (NMFS, 2018c). 

Overfishing occurs when fish are harvested in quantities above a sustainable level. Overfishing impacts 

targeted species, and non-targeted species (i.e., bycatch species) that often are prey for other fish and 

marine organisms. Commercial fishing and overfishing are also the primary causes of fish entanglement. 

Entanglement in abandoned commercial and recreational fishing gear has also caused declines for some 

marine fish (Musick et al., 2009). 

Although impacts that could occur under the Proposed Action would be additive to the injury and 

mortality of fish associated with other cumulative actions, NOS does not expect any mortality and very 

little likelihood for injury of fish (e.g., from accidental oil and fuel spills) as a result of implementing any of 

the alternatives. The likelihood of occurrence of an accidental spill from a vessel used by NOS would be 

very low. In the event that an accidental spill does occur, the volume of oil, fuel, and/or chemicals would 

be fairly small given the size of vessels used by NOS and the amounts of fuel and other chemicals they 

typically carry, as well as the proper handling of all hazardous or regulated materials in accordance with 

applicable laws. Likewise, the probability for strikes by vessels or underwater devices is unlikely. For fish 

species, the greatest potential for adverse impacts as a result of active underwater acoustic sources would 

be related to changes in behavior (see below) rather than auditory injury. The relative contribution of the 

Proposed Action to the overall mortality and injury of fish would be minimal as compared to other 

cumulative actions. The aggregate, adverse cumulative impacts to fish from mortality and injury would 

likely be minor to major. The NOS Proposed Action would be expected to contribute negligible cumulative 

mortality and injury impacts to fish.

4.2.4.2 Fish Disturbance and Behavioral Modifications

Disturbance and behavioral modifications in fish from other cumulative actions are associated with vessel 

operations, underwater sound, emplacement of structures, and use of underwater equipment. A 

significant amount of vessel traffic has taken place and is expected to continue for the foreseeable future 

under the cumulative effects scenario. Some studies found that most adult fish exhibit avoidance 

responses to vessels (Jørgensen et al., 2004; Misund, 1997) showing sudden escape responses when a 

vessel passes over them, including lateral avoidance or downward compression of the school. Conversely, 

Rostad et al. (2006) observed that some fish are attracted to different types of vessels (e.g., research 

vessels, commercial vessels) of varying sizes, sound levels, and habitat locations. Fish behavior in the 

vicinity of a vessel is therefore variable, depending on the type of fish, its life history stage, behavior, time 

of day, and the sound propagation characteristics of the water. Anthropogenic contributions to ambient 

sound in the ocean come primarily from vessel traffic, but also include other cumulative actions such as 

O&G operations, construction activities, dredging, and sonar. Most ambient sound is broadband and 

encompasses almost the entire frequency spectrum, with vessel traffic recognized as a major contributor 

to ocean sound in the low-frequency bands (< 1,000 Hz). The majority of soniferous fish are adapted to 

perceive and produce sounds in the low-frequency band, thus increased underwater sound could alter 

normal, biologically relevant behavior, disturbing basic life functions such as foraging, predator detection, 

and reproduction (Vasconcelos et al., 2007; Codarin et al., 2009). Other cumulative actions would 

contribute numerous sources of sound during the time period when NOS projects would take place, 

adding to ambient sound levels within the action area. Cumulative, low-frequency sound from multiple 
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anthropogenic activities could have additive or synergistic behavioral effects on fish and contribute to 

auditory masking. 

Fish could also be disturbed by structures and equipment in the water. Other cumulative actions, including 

O&G development, offshore renewable energy, carbon storage, and LNG terminals, have the potential for 

the emplacement of structures within the action area. Permanent and temporarily moored structures, 

including drilling rigs, barges, buoys, wind turbines, platforms, and other structures, would attract pelagic 

and demersal fish causing potential diversion of species from normal migratory pathways, feeding areas, 

and/or spawning areas. In addition, fish attracted to structures would then be subjected to chronic sound, 

routine discharges, and increased vulnerability to overfishing. Lights used at these structures could also 

enhance attractiveness for some species that are active at night. Water disturbance by underwater 

equipment used in other cumulative actions could also temporarily disturb and displace nearby fish. 

Because a towed in-water device is continuously moving, most fish are expected to move away from it or 

to follow behind it, in a manner similar to their responses to a vessel. When the device is removed, most 

fish are expected to return to the area and resume normal activities. 

As vessels used by NOS would represent a negligible proportion of all vessel traffic in the action area, 

disturbance and behavioral modifications due to vessel operations under the Proposed Action would be 

minimal. Sound from NOS activities would be project-based, occurring on an intermittent basis over the 

period of interest. Because only small sound impacts are expected from NOS activities, impacts associated 

with the Proposed Action would only have a negligible incremental increase in ambient sound levels. The 

mobile nature of NOS surveys and the propensity of fish to temporarily move away from water turbulence 

that is affecting them would only lead to very small behavioral impacts on fish from the Proposed Action. 

The aggregate, adverse cumulative impacts to fish from disturbance and behavioral modification would 

likely be minor to moderate. The relative contribution of the NOS Proposed Action to the overall 

disturbance and behavioral modification of fish would be minimal as compared to other cumulative 

actions, and each alternative would be expected to contribute negligible cumulative impacts on fish 

behavior. 

4.2.4.3 Reduced Fitness of Fish Due to Pollutants

Pollutants from multiple sources are present in, and continue to be released into, the oceans. A significant 

amount of vessel traffic is expected to occur under the cumulative effects scenario. All vessel operations 

are associated with a risk of oil and fuel spills and release of contaminants. Long-term exposure to 

pollutants from the accidental leakage or spillage of oil, fuel and chemicals; marine debris (e.g., plastics, 

glass, metals, or rubber); and flows of pollutants, contaminants, sediments, and nutrients in coastal 

waters stresses the health and fitness of fish. Pollution primarily impacts coastal fish that occur near the 

sources of land-based pollution and areas of heavy vessel traffic. However, global oceanic circulation 

patterns result in a considerable amount of marine pollutants and debris scattered throughout the open 

ocean (Crain et al., 2009). Spills of pollutants are not expected during the course of NOS operations. In the 

unlikely event of an accidental spill, there would be very low likelihood for large adverse effects because 

vessel operations personnel are required to respond immediately using established spill response 

procedures.

Contaminants in the marine environment that may impact marine fish include organic pollutants (e.g., 

pesticides, herbicides, polycyclic aromatic hydrocarbons, flame retardants, and oil), inorganic pollutants 

(e.g., heavy metals), and debris (e.g., plastics and wastes from dumping at sea) (Pews Oceans Commission, 

2003). High chemical pollutant levels in marine fish may cause behavioral changes, physiological changes, 
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or genetic damage in some species (Moore, 2008; Pews Oceans Commission, 2003; van der Oost et al., 

2003), contributing to overall reduced health and fitness of species. Bioaccumulation of pollutants (e.g., 

metals and organic pollutants) is also a concern that can reduce animal fitness. Bioaccumulation is the net 

buildup of substances (e.g., chemicals or heavy metals) in an organism directly from contaminated water 

or sediment through the gills or skin, from ingesting food containing the substance, or from ingestion of 

the substance itself (Newman, 2019; Moore, 2008). 

The aggregate, adverse cumulative impacts on the fitness of fish would likely be moderate. The relative 

contribution of the NOS Proposed Action to the overall fitness of fish would be minimal compared to other 

cumulative actions, and each alternative would be expected to contribute negligible cumulative impacts 

on fish fitness.

4.2.4.4 Alteration of Fish Habitat

Habitat alteration is associated with reduced prey/food sources, degraded water quality, and disturbance 

of bottom habitat due to other cumulative actions and to climate change. Prey and food sources are 

significantly directly reduced by overfishing, but also indirectly by changes in water quality from increased 

turbidity and sedimentation that create changes in the ecosystem that affect prey species and habitats. 

Spilled oil, fuel, and chemicals also stress the existing condition of fish habitat. Degraded water quality 

caused by other cumulative actions can cause increases in turbidity and sedimentation, increased water 

temperature, decreases in primary productivity and DO levels, introduction of invasive plant and animal 

species, and chemical contamination. Seafloor disturbance can damage or alter hard or soft demersal 

habitats important to fisheries resources. Other cumulative actions that would disturb the sea floor 

include commercial fishing (bottom trawling and dredging), carbon storage, dredged material disposal, 

LNG terminal placement, and new cable infrastructure. Seafloor disturbance can disturb, alter, or damage 

bottom habitat and can potentially smother demersal biota. However, these actions would affect a 

relatively small area of sea floor within the action area, and incremental impacts to fish habitat attributed 

to seafloor disturbance are expected to be minor. 

Climate change effects include changes in air and sea temperatures, precipitation, the frequency and 

intensity of storms, pH level of seawater, currents, and sea level. These changes could affect overall 

marine productivity, which could affect the food resources, distribution, and reproductive success of fish. 

Pelagic fish stocks have unique spatial and temporal distribution patterns related to their bioclimatic 

niche. Climate change and the associated shifts in primary and secondary production therefore have 

impacts on the distribution range, migratory habits, and stock size of many marine fish species. Some 

species may shift away from shallow coastal waters and semi-enclosed areas, where temperatures 

increase fastest, into deeper cooler waters. In general, fish tend to live near their tolerance limits of a 

range of factors, and as a result, increased temperature and acidity, lower DO, and changes to salinity may 

have deleterious effects on their populations (ClimeFish, No Date).

Habitat alteration expected from the NOS Proposed Action would be caused by bottom sampling, 

anchoring, accidental spills of oil, fuel, and contaminants, and underwater turbulence from vessels and 

equipment. The small footprint of seafloor impacts under the NOS Proposed Action would account for a 

tiny fraction of the total sea floor in the action area, would only contribute an extremely small amount of 

contaminants to the ocean environment, if any, as compared to all other cumulative actions; and vessels 

operated by NOS would represent a negligible proportion of all vessel traffic in the action area. The 

aggregate adverse cumulative impacts from all actions on fish habitat would be minor to moderate and 

the contribution of the NOS Proposed Action to these impacts would be negligible.
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4.2.4.5 Conclusion

All of the NOS alternatives would contribute to aggregate, adverse cumulative impacts on fish and fish 

habitat. This would occur through mortality and injury (vessel strikes, underwater sound, fishing bycatch, 

and entanglement); disturbance and behavior modification (due to vessel operations, underwater sound, 

emplacement of structures, and use of underwater equipment); and habitat alteration (reduced 

prey/food sources, degraded water quality, disturbance of bottom habitat, and climate change). Other 

actions and activities also contribute to the existing condition of fish, including the accidental or illicit 

discharge of oil, fuel, chemicals, or waste which can cause mortality and marine debris (e.g., plastics, glass, 

metals, or rubber) and flows of pollutants, contaminants, sediments, and nutrients, which can reduce the 

fitness of fish. 

The aggregate, cumulative impacts of past, present, and reasonably foreseeable future actions are 

expected to result in insignificant impacts to most fish species, and may have significant impacts on some 

fish populations in the action area. The combined impacts of other cumulative actions affecting 

disturbance and behavioral modification, animal fitness, and habitat alteration would be moderate and 

adverse as the continued viability of populations would not be threatened, and therefore cumulative 

impacts would be insignificant. However, overfishing, bycatch, entanglement and reduced prey associated

with other cumulative actions are expected to result in high rates of injury and mortality that could cause 

population declines to ESA-listed species or inhibit species recovery, resulting in major impacts that are 

significant. Although the impacts of commercial fishing are a concern for fisheries worldwide, fisheries in 

the action area are generally managed conservatively and in keeping with the requirements of the 

Magnuson-Stevens Fishery Conservation and Management Act. Many fish stocks within the action area 

that were historically overfished have recovered or are recovering from their overfished status and 

contributing to the overall trend of increasing abundance of U.S. marine fish stocks (NMFS, 2018c).

Cumulative, adverse impacts from any of the alternatives in combination with the cumulative effects 

scenario could potentially be considered either synergistic or additive depending on the timing and 

location of activities and impacts. Cumulative adverse impacts from the activities in the cumulative effects 

scenario could be synergistic if activities associated with the NOS Proposed Action and other cumulative 

actions occur in close spatial or temporal proximity. Similarly, additive effects on fish may occur if activities 

associated with the NOS Proposed Action and other cumulative actions are considered sequentially. 

Overall, cumulative impacts to fish would range from minor to major. The NOS Proposed Action would 

contribute to and have the potential to increase these cumulative impacts, but their relative contribution 

would be negligible because impacts would be temporary or short-term, would be confined to the 

immediate vicinity of project areas, and would be small as compared to impacts from all other cumulative 

actions. These impacts would occur regardless of the chosen alternative since projects under each 

alternative would be composed of similar activities and take place in the same geographic areas and 

timeframes; however, Alternatives B and C would be expected to have slightly higher cumulative impacts 

because these alternatives include more projects, activities, and nautical miles traveled than Alternative 

A. 

4.2.5 Aquatic Macroinvertebrates

All past, present, and reasonably foreseeable actions described in Section 4.1 would contribute 

cumulative effects on aquatic macroinvertebrates. Based on the analysis presented in Section 3.8 Aquatic 

Macroinvertebrates, impacts of the NOS Proposed Action would result in negligible to minor impacts on 

invertebrates and their habitat. The impacts from the Proposed Action that could contribute to cumulative 

impacts on aquatic macroinvertebrates are direct and indirect injury and disturbance (from vessel sound, 
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vessel wake and underwater turbulence, and bottom disturbance), and habitat alteration (from vessel 

wake and underwater turbulence; bottom disturbance; and air emissions). 

The analysis of cumulative effects also considers that the other human actions and activities enumerated 

above contribute to the existing condition of aquatic macroinvertebrates, including habitat encroachment 

from onshore and nearshore development (e.g., coastal population growth), non-point sources of 

pollution, and accidental or illicit discharge of oil, fuel, chemicals, or waste. The following analysis 

considers how the NOS-related incremental impacts of the three NOS alternatives, when added to or 

acting synergistically with other past, present, and reasonably foreseeable future actions, would 

contribute to overall cumulative impacts on aquatic macroinvertebrates.

4.2.5.1 Direct and Indirect Injury to Aquatic Macroinvertebrates

Sound from crewed vessel operations under the NOS Proposed Action would contribute to cumulative 

impacts from all of the past, present, or reasonably foreseeable actions. However, based on what is known 

of their ability to detect underwater sound, NOS sound sources would be unlikely to cumulatively 

contribute to direct injury impacts to aquatic macroinvertebrates. For example, the active acoustic 

underwater sources used by NOS would mostly not be perceptible to aquatic macroinvertebrates. 

However, other active acoustic sources commonly used in other surveying and mapping activities, 

assessment and exploration of marine minerals, and offshore carbon storage assessments may have a 

greater propensity to adversely affect some aquatic macroinvertebrates, at least at close range, due to 

the high intensity and widespread propagation of the broadband sound they generate. These high 

intensity sources, including airguns, could have somewhat greater effects on aquatic macroinvertebrates 

than the sources described in Section 3.8, especially when considered cumulatively. In addition, the 

presence and movement of crewed vessels within the action area, including all vessels used in conjunction 

with activities under the Proposed Action and all past, present, and reasonably foreseeable actions of the 

cumulative effects scenario, would likely cumulatively contribute to collisions or entanglement of certain 

aquatic macroinvertebrates in the water column. 

Accidental or illicit discharges of fuel, chemicals, or waste accompanying all vessel operations within the 

action area contribute to the existing direct harm to aquatic macroinvertebrates through ingestion and 

interaction with spilled substances, although the intensity of the impact would depend on the size and 

location of the spill in question. A major problem for aquatic macroinvertebrates is nutrient pollution from 

non-point sources onshore, principally fertilizers applied to farmlands; these nutrient loadings can cause 

red tides in coastal waters on both East and West Coasts, as well as a large “dead zone” of hypoxic or 

anoxic waters at the mouth of the Mississippi River in the Gulf of Mexico. Spills are not expected during 

the course of NOS operations. In the unlikely event of an accidental spill, there would be very low 

likelihood for large adverse impacts because vessel operations personnel are required to respond 

immediately using established spill response procedures.

Rising ocean temperatures as part of ongoing climate change will continue to damage coral reefs in 

particular, by thermally stressing coral polyps, leading to their bleaching (expelling their symbiotic algae 

known as zooxanthellae) and possible mortality. Ocean acidification accompanying climate change, in 

particular increasing atmospheric carbon dioxide concentrations, will interfere with shell and skeleton 

formation by certain marine calcifying aquatic macroinvertebrates that use calcium carbonate. 

Most cumulative direct injury impacts would occur in the immediate vicinity of vessels or O&G 

development. Over the time period of analysis, climate-related impacts that have already led to the listing 
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of many species of corals described in Section 3.8 would continue to stress these species. Aggregate, 

cumulative direct and indirect injury impacts from all actions range from short-term to long-term, and 

could result in adverse and minor to major impacts on aquatic macroinvertebrates. The contribution of 

the NOS Proposed Action to these aggregate, adverse impacts would be negligible. 

4.2.5.2 Disturbance and Displacement of Aquatic Macroinvertebrates

Sound-producing and vessel operation activities under the NOS Proposed Action could potentially 

contribute to aggregate, adverse cumulative impacts along with other active underwater sound sources, 

especially from high intensity sources used in O&G surveying, by temporarily displacing aquatic 

macroinvertebrates at sites throughout the EEZ. Sound from vessels used by NOS, shipping vessels, 

commercial fishing vessels, recreational boats and underwater construction activities in support of energy 

infrastructure, LNG terminals, and submarine telecommunications infrastructure could also cumulatively 

disturb and displace invertebrates from the respective project areas for the duration of the activity in 

question. 

Underwater disturbance from vessel movement and presence, and bottom sampling under the Proposed 

Action, in combination with reduced water quality and increased turbidity resulting from the ongoing 

erosion of coastlines by rising sea levels, bottom sampling, or underwater construction activities, would 

also disturb and displace aquatic macroinvertebrates. The small footprint of seafloor impacts under the 

NOS Proposed Action would account for a tiny fraction of the total sea floor in the action area, and impacts 

would be minimal and localized. Climate change will continue to raise sea levels globally for the 

foreseeable future, which results in continual erosion throughout the coastlines of the EEZ. The ongoing 

accidental or illicit discharges of fuel, chemicals, or waste from vessel operations and marine 

infrastructure contributes to currently disturbed and displaced aquatic macroinvertebrates from 

contaminated areas for the lifetime of the spill, though most small spills are dissipated by ocean conditions 

on a timescale of minutes to hours. Spills from NOS activities are unlikely to occur.

Cumulative disturbance and displacement impacts would still likely be limited to the immediate vicinity 

of the source and would not persist beyond the conclusion of activities. These aggregate, adverse impacts 

are not expected to cause long-term changes in habitat availability, or overall behavioral patterns, and 

would be considered negligible to minor. The contribution of the NOS Proposed Action to these 

aggregate, adverse cumulative impacts would be negligible. 

4.2.5.3 Degradation and Reduction of Aquatic Macroinvertebrate Habitat

Onshore tide gauge installations and remote GPS reference station installations under the Proposed 

Action would contribute to cumulative impacts related to the degradation and reduction of aquatic 

macroinvertebrate habitats from the construction, operation, and decommissioning of long-term 

installations such as LNG terminals, energy infrastructure, and submarine telecommunications. 

Cumulatively, these actions would likely reduce the total amount of oceanic habitat available to aquatic 

macroinvertebrates for the lifetime of the installation. Aquatic macroinvertebrates would likely be 

displaced from these areas for the duration of the installation due to reduced water quality and various 

disturbances related to the operation and maintenance of the infrastructure, such as vessel traffic, waste 

discharge, and underwater disturbance from welders, divers and wakes. After the lifetime of the 

installation, the development area would be reclaimed and should return to previous habitat conditions. 

While spills from NOS activities are unlikely to occur, the ongoing accidental or illicit discharges of fuel, 

chemicals, or waste from other vessel operations and marine infrastructure contribute to currently 
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degraded estuarine and marine habitats. The intensity of these impacts depends on the size and distance 

of the spill in question from invertebrate habitats; most small spills are dispersed and dissipated by ocean 

conditions on a timescale of minutes to hours. Coastal population growth and elevated nutrient loadings, 

other contaminants, and non-point source discharges and runoff contribute to currently degraded habitat 

conditions for aquatic macroinvertebrates through a variety of factors, including coastal water quality

reductions from urban/agricultural runoff, and encroachment by coastal development. This degradation 

is especially pronounced in bays and sounds with restricted water circulation, such as Chesapeake Bay in 

the Greater Atlantic Region and Puget Sound in the West Coast Region. The 7,000-square mile (18,130-

square km) hypoxic (low-oxygen) “dead zone” that appears during the summer months in the Gulf of 

Mexico at the mouth of the Mississippi River is an effect of the widespread use of fertilizers (nitrogen and 

phosphorus nutrients) in the large Mississippi Basin. 

Rising sea levels as a result of climate change will continually erode coastlines along the EEZ over the next 

five years and could potentially destroy or degrade habitats for aquatic macroinvertebrates. Global rising 

temperatures could also shift aquatic macroinvertebrate ranges northward towards cooler waters. 

Generally, ongoing cumulative impacts to aquatic macroinvertebrate habitats would persist for the 

entirety of the foreseeable future; these impacts would not substantially reduce overall habitat quantity 

or availability but would continue to substantially degrade aquatic macroinvertebrate habitat quality, 

although populations would be unlikely to be further adversely affected in the near term. Aggregate 

cumulative impacts to aquatic macroinvertebrate habitat would likely be adverse and minor to major and 

the contribution of the NOS Proposed Action to these would be negligible. 

4.2.5.4 Conclusion

Activities associated with the Proposed Action and the cumulative effects scenario have the potential to 

contribute cumulatively to direct and indirect injury, disturbance and displacement, and habitat reduction 

and degradation impacts from past, present, and reasonably foreseeable actions within the action area. 

In the short-term, the presence and movement of vessels could potentially result in direct injury to aquatic 

macroinvertebrates from collisions or entanglements and would likely disturb or displace nearby 

organisms for the duration of activities. Similarly, vessel sound and underwater construction activities 

could potentially displace aquatic macroinvertebrates in the immediate vicinity of activities. Disturbances 

and displacements resulting from activities are not expected to persist beyond the duration of activities, 

and short-term cumulative impacts would likely range from negligible to moderate. Onshore and 

nearshore development, non-point source pollution, and the accidental or illicit discharges of oil, fuel, 

chemicals, or waste all contribute to the currently reduced total amount of aquatic macroinvertebrate 

habitat. In conjunction with the NOS Proposed Action, ongoing climate change would reduce the total 

amount of available aquatic macroinvertebrate habitat in the long-term. As such, the long-term, 

aggregate, adverse cumulative impact of habitat reduction on aquatic macroinvertebrates would likely 

range from minor to major. 

Cumulative, adverse impacts from any of the alternatives in combination with the cumulative effects 

scenario could potentially be considered either synergistic or additive depending on the timing and 

location of activities and impacts. Synergistic impacts could result if any activities or actions occur in close 

spatial or temporal proximity within the action area. Similarly, additive cumulative impacts to aquatic 

macroinvertebrates, or their associated habitat, could occur if activities or actions are conducted 

sequentially within adjacent areas of the action area. Although the exact timing and location of projects 

have not been finalized and are subject to change, the Southeast and Alaska regions contain the largest 
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proportion of total vessel transit miles of the EEZ (Section 2.4.1) and relatively high levels of marine O&G 

development. Therefore, synergistic or additive cumulative impacts are most likely to occur in either of 

these regions. Most cumulative impacts would be confined to the immediate vicinity of project areas and 

would likely not impact the overall abundance or structure of invertebrate populations outside of the 

range of natural variability. Overall,the Proposed Action would contribute negligible short-term and longterm adverse cumulative effects, depending on the timing and location of impacts. These impacts would 

occur regardless of the chosen alternative since projects under each alternative would be composed of 

similar activities and take place in the same geographic areas and timeframes; however, Alternatives B 

and C would include more projects, activities, and nautical miles traveled than Alternative A, and would 

therefore have slightly greater impacts.

4.2.6 Essential Fish Habitat

All past, present, and reasonably foreseeable future actions described in Section 4.1 would contribute 

cumulative effects on EFH, including Habitat Areas of Particular Concern (HAPCs). Based on the analysis 

presented in Section 3.9 Essential Fish Habitat, impacts of the NOS Proposed Action would result in 

negligible to minor impacts on EFH. The impacts from the Proposed Action that could contribute to 

cumulative impacts on EFH are physical impacts to bottom habitat (e.g., from anchoring, collection of 

bottom grab samples, tide gauge installation, and SCUBA operations); increase in sedimentation, 

turbidity, and/or chemical contaminants (e.g., from operation of crewed sea-going vessels; operation of 

ROVs and autonomous vehicles; anchoring; collection of bottom grab samples; installation of tide gauges 

and GPS reference stations; and SCUBA operations); increase in sound (e.g., from operation of crewed 

sea-going vessels; operation of ROVs and autonomous vehicles; use of echo sounders; ADCPs; and 

acoustic communication systems); and impacts to the water column (e.g., from operation of crewed seagoing vessels; operation of ROVs and autonomous vehicles; anchoring; use of sound speed data collection 

equipment and bottom grab samplers; operation of drop/towed cameras and video systems; and SCUBA 

operations). The following analysis considers how the incremental impacts of the NOS Proposed Action, 

when added to or acting synergistically with other past, present, and reasonably foreseeable future 

actions, would contribute to overall cumulative impacts on EFH.

4.2.6.1 Physical Impacts to Essential Fish Habitat Bottom Habitat

Physical impacts to bottom habitat from other cumulative actions could result from such activities as 

commercial fishing (bottom trawling), dredging, carbon storage, O&G development, dredged material 

disposal, structure emplacement, and new cable infrastructure. Seafloor disturbance can alter or damage 

bottom habitat and can potentially smother demersal biota. 

Adverse impacts from fishing, especially those using bottom-contact fishing gear, could be substantial in 

heavily fished areas and could affect EFH and component HAPC areas to various degrees. Bottom trawl 

fishing intensity has seen a rapid global expansion since the 1950s in order to meet an increasing global 

food demand (Watson et al., 2006); and although the highest trawling intensities are found in shallow 

coastal waters, bottom trawling is expanding into deeper waters (Eigaard et al., 2016). 

In addition to seafloor disturbance from fishing, other cumulative actions that sample, anchor, dredge, 

cover, drill into, or otherwise come into contact with ocean bottom habitat can cause re-suspension of 

sediments into the water column, changes in bathymetric contours, and potential alteration or loss of 

benthic habitat. Dredging activities within the coastal zone have greatly intensified in recent decades in 

connection to harbor expansion work, maintenance and deepening of navigable waterways, land 
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reclamation, coastal protection, and energy provision through the construction of wind farms (OSPAR 

Commission, No Date). 

Globally, dredging involves the excavation of greater than 2 billion tons of sediment per year, of which 

approximately 80 percent is redeposited in the marine environment (EuDA, 2005). Some activities, such 

as mining, destroy hard substrate and severely disturb the seabed and the benthic soft substrate 

community. Recolonization can occur from unmined areas; but reestablishment of a community similar 

to that originally present is usually not possible (Thiel, 1992). Other activities also directly or indirectly 

introduce marine debris into the water (e.g., monofilament fishing line, nets, plastic) that often ends up 

on the sea floor or wrapped onto a shallow reef and causes stress on bottom habitat in EFH areas.

Although impacts that could occur under the NOS Proposed Action would be additive to the physical 

impacts of bottom habitat associated with other cumulative actions, NOS activities such as anchoring, 

installation of equipment on the sea floor, and sample collection would cause relatively very small 

footprints of disturbance over the very large action area as compared to all of the seafloor disturbance of 

all other cumulative actions. The relative contribution of the NOS Proposed Action to the overall 

disturbance of bottom habitat would be minimal. While aggregate, adverse cumulative impacts on 

bottom habitat in EFH areas from all actions and activities throughout the EEZ would be considered 

moderate, the contribution of the NOS Proposed Action to these adverse cumulative effects would be 

negligible.

4.2.6.2 Increase in Sedimentation, Turbidity, and/or Chemical Contaminants in 

Essential Fish Habitat

Increase in sedimentation, turbidity, and chemical contaminants in EFH from other cumulative actions are 

associated with the activities that would disturb bottom habitat as discussed above, as well as activities 

that deposit sediments into receiving waters, and vessel operations. Disturbance of the sea floor would 

stir up bottom sediment and cause turbidity in the vicinity of the activity. Additionally, sedimentation and 

turbidity can occur due to input of sediments into the ocean environment from upland activities that 

cause erosion (e.g., coastal development, beach nourishment, mining, timber harvesting, and agriculture) 

and from water-based actions (e.g., dam construction, port activities, drag fishing, dredging, and water 

diversions). Sedimentation can cause loss of important or sensitive aquatic habitat, decrease in fishery 

resources, loss of coral reef communities, changes in fish migration, loss of wetlands, nutrient balance 

changes, circulation changes, loss of submerged vegetation, and coastline alteration (Pollution Issues, No 

Date). Turbidity affects organisms that are directly dependent on light, like aquatic plants, because it limits 

their ability to carry out photosynthesis. Other organisms that depend on these plants for food and oxygen 

are then also impacted. For example, turbidity can harm fish by reducing food supplies, degrading 

spawning beds, and affecting gill function. 

In addition to sedimentation and turbidity, there are large numbers of potential sources of both direct 

and indirect marine contamination, including tankers and other marine vessels, derelict fishing gear, 

military operations, ocean dumping, airborne deposition, and runoff from industrial and agricultural 

sources on land. The accidental leakage or spillage of oil, fuel and chemicals; marine debris (e.g., plastics, 

glass, metals, or rubber); and flows of pollutants, contaminants, sediments, and nutrients in coastal 

waters stresses the condition of EFH. A significant amount of vessel traffic is expected to occur under the 

cumulative effects scenario. All vessel operations are associated with a risk of oil and fuel spills and release 

of contaminants. Contamination from spills and discharges can accumulate in the sea floor and marine 

life and have a toxic effect on plants, animals, and humans through the food chain. Some chemical 

compounds, such as polychlorinated biphenyls (PCBs) and pesticides, can persist for many years while 
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others, such as petroleum products, breakdown and get diluted relatively quickly. Pollution is a long-term 

and widespread issue in the marine environment, although it varies substantially in intensity on a local 

basis. 

NOS activities associated with the Proposed Action, including vessel and ROV operations, anchoring, 

collection of bottom grab samples, installation of tide gauges and GPS reference stations, and SCUBA

operations, could increase sedimentation, turbidity, and chemical discharges in EFH. As vessels used by 

NOS would only represent a negligible proportion of all vessel traffic in the action area, increases in 

sedimentation and turbidity due to vessel operations under the NOS Proposed Action would be minimal. 

While there would be no intentional discharges of pollutants from vessels used by NOS, there is potential 

for accidental spills to occur. However, the likelihood of occurrence of an accidental spill and the 

magnitude of a potential spills are likely to be very small and the contribution to the cumulative effects of 

contamination is considered negligible. Likewise, sedimentation and turbidity from NOS anchoring and 

land-based projects would be minimal given that they would be conducted infrequently and across a 

geographically widespread area, and that the footprints of disturbance would be small. Thus, the relative 

contribution of the NOS Proposed Action to the overall increases in sedimentation, turbidity, and chemical 

contaminants in EFH would be minimal as compared to other cumulative actions. Aggregate, adverse

cumulative impacts on EFH from all sources of water pollution would be moderate, while the contribution 

from the NOS Proposed Action would be expected to be negligible. 

4.2.6.3 Increase in Sound in Essential Fish Habitat

Increases in sound from other cumulative actions could result from vessel and aircraft operations; sonar

and other underwater acoustic sources; construction, which may include drilling, pile driving, use of 

explosives, and dredging; and operation of facilities and structures, such as long-duration sound 

associated with mechanical vibrations when wind turbine blades are spinning. Noise from other 

cumulative actions would affect EFH by impacting different life stages of fish and aquatic 

macroinvertebrate prey species (prey is a potential habitat characteristic of EFH). Behavioral changes can 

occur, resulting in animals leaving feeding or breeding grounds (Slabbekoorn et al., 2010) or becoming 

more susceptible to mortality through decreased predator-avoidance responses (Simpson et al., 2016). 

Noise can also mask biologically important sounds and alter the natural soundscape, cause hearing loss, 

and/or have an adverse effect on an organism’s stress levels and immune system. Cumulative sound 

impacts on fish are discussed in Section 4.2.4 and on aquatic macroinvertebrates in Section 4.2.5. 

NOS activities under the Proposed Action that could result in an increase in underwater sound in EFH 

would consist of operation of crewed sea-going vessels; operation of ROVs, Uncrewed Surface Vehicles 

(USVs, and autonomous underwater vehicles (AUVs); and use of underwater acoustic equipment including 

echo sounders, ADCPs, and acoustic communication systems. The potential effects of sound associated 

with vessel operations, which would represent less than 0.3 percent of total vessel traffic in the action 

area, would be minimal as compared to the effects from sound generated by vessels and aircraft from all 

other cumulative actions. Sound associated with underwater acoustic sources used by NOS would be 

intermittent and highly directional, potential impacts on prey species would be limited to temporary 

behavioral and stress-startle responses, and adverse impacts are unlikely to occur due to the much higher 

frequencies of these instruments relative to the hearing capabilities of most prey species. The relative 

contribution of NOS Proposed Action to the overall increase in sound in EFH would be minimal compared 

to the contributions from all other cumulative actions. Overall, the aggregate, adverse cumulative impact 

from the increase in sound in EFH areas would be minor to moderate, while the contribution from the 

NOS Proposed Action would be negligible.
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4.2.6.4 Impacts to the Water Column in Essential Fish Habitat

Impacts to the water column are caused by vessels or equipment moving through the water as part of 

activities that are part of other cumulative actions. Impacts on EFH due to climate change are also 

considered here. Wakes from vessels and other disturbance to the water column from equipment moving 

through it would create turbulence and generate wave and surge effects in the water column where 

habitat gradients including temperature, salinity, DO, turbidity, and nutrient supply would be temporarily 

disrupted. Vessel propellers could also cause water column destratification and elevated water 

temperatures. Vessel and equipment movement through the water column may disrupt benthic 

communities and other prey species in shallow areas and cause mortality to floating eggs and larvae by 

physically damaging them with the hull or other ship parts, including the propulsion system. Lines 

connecting equipment to a vessel could also become entangled with, damage, or kill submerged aquatic 

vegetation such as seagrass. 

Climate change may affect the marine environment in a variety of ways, including changes in sea level, 

changes in water temperatures, more frequent or extreme weather events, and alteration of ocean 

currents (NMFS, 2019e). These changes and others are expected to continue over the reasonably 

foreseeable future and could aggregate with the effects of other cumulative actions to impact the physical 

water environment. These changes would in turn contribute to changes in the population and distribution 

of prey species such as fish and aquatic macroinvertebrates; and changes in the population and 

distribution of fishery resources harvested in commercial fisheries, with related socioeconomic effects 

(see Section 4.2.9). In addition to changes in air and water temperatures, a related effect of climate change

is increased acidification in the ocean caused by dissolved CO2. Changes in the acidity of the world’s oceans 

are expected to continue and accelerate over the reasonably foreseeable future. Ocean acidification can 

harm organisms that build shells of CaCO3, including calcareous phytoplankton and zooplankton, corals, 

bryozoans, mollusks, and crustaceans. These organisms provide shellfish resources for humans, play vital 

roles in marine food webs, generate sand for beaches, and add to the physical structure of the sea floor. 

Although the dynamics of climate change and the potential magnitude and timing of its effects are poorly 

understood, there is general acknowledgement that the potential impacts resulting from climate change 

could be substantial.

Impacts to the water column expected from the NOS Proposed Action would be caused by vessels or 

equipment moving through the water column in activities including operation of crewed sea-going 

vessels; operation of ROVs, USVs, and AUVs; anchoring; use of sound speed data collection equipment 

and bottom grab samplers; operation of drop/towed cameras and video systems; and SCUBA operations. 

These impacts would be temporary, mobile prey species would not likely move too far away, and 

conditions would be expected to stabilize and species would return once water column turbulence ceased. 

The NOS Proposed Action would only contribute a very small impact on the water column as compared 

to all other cumulative actions. Although CO2 emissions from vessels used by NOS would contribute to 

atmospheric CO2 levels, the contribution would be a very small fraction compared to other anthropogenic 

CO2 sources. Aggregate, adverse cumulative impacts to the water column in EFH from all actions would 

be moderate. When aggregated with the impacts of past, present, and reasonably foreseeable future 

actions in the action area, the NOS Proposed Action would make a negligible additive contribution to 

cumulative adverse effects on the water column in EFH.

4.2.6.5 Dispersal of Invasive Species in Essential Fish Habitat

Dispersal of invasive species could occur from all other cumulative actions listed in Section 4.1 and in 

conjunction with ongoing climate change. Cumulatively, these actions could facilitate the dispersal of 
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invasive species throughout EFH in the action area, reducing the availability of space, shelter, cover, and 

nutrients for dependent endemic species. Cumulative actions would occur in all regions of the action area 

and could involve transiting and surveying across large swaths of the action area using the same physical 

equipment and survey instrumentation as NOS activities. These larger transits or projects could 

inadvertently transport invasive macroinvertebrate larvae, vertebrate eggs or animals, plant seeds, or 

algae propagules in ballast water or on equipment surfaces to novel areas, thereby facilitating their 

dispersal and establishment. Invasive species often have large numbers of offspring and limited or no 

natural threats or predators outside of their native habitat, allowing them to outcompete locally endemic 

species for space and nutrients.

Over time, invasive species could propagate far beyond the initial site of establishment, which could 

cumulatively result in cascading impacts to the local food chains through the extirpation of local predators 

and prey due to reduced nutrient cycling and availability. These impacts would change habitat structure 

and reduce the habitat value of affected areas in the long term or permanently after the establishment of 

invasives; these invasive species and their resulting impacts would persist until all invasive organisms were 

removed from a given area through aggressive trapping, harvesting, or use of pesticides such as 

glyphosate. Global rising sea temperatures as a result of ongoing climate change could cumulatively 

exacerbate these impacts by shifting the distribution of ideal abiotic habitat conditions (e.g., water 

temperature or acidity) for endemic species. Invasive species typically have wider ranges of tolerance for 

abiotic environmental conditions, allowing them to withstand climate-related stresses and either 

outcompete less tolerant endemic species or establish themselves in habitat areas vacated by endemic 

species dispersed by altered abiotic environmental conditions.

Physical equipment and instruments used in consecutive projects in disparate geographically regions 

could potentially serve as transmission vectors for invasive species, which could cumulatively reduce the 

habitat value of their area of introduction by outcompeting endemic plants, animals, and algae. After 

establishment, cumulative impacts could potentially spread beyond project areas and persist until 

invasive species are suppressed or removed from these areas via aggressive management techniques and 

procedures, reducing the availability of space, shelter, cover, or nutrients for dependent species outside 

of the range of natural variation. However, vessel crews on NOS projects would implement invasive

species control procedures such as deballasting or equipment washing as required by law, thereby 

reducing the likelihood of invasive propagation. The above-described NOS effects can also occur in almost 

all human use of water. These effects would be indistinguishable in type from other human uses. Overall, 

given its relatively low likelihood of occurrence, the aggregate, adverse cumulative impact of invasive 

species dispersal would be minor to moderate. The contribution to these aggregate, adverse cumulative 

impacts on invasive species dispersal from the NOS Proposed Action would be negligible.

4.2.6.6 Conclusion

NOS actions would contribute to the adverse cumulative impacts from all actions on EFH. This would occur 

through physical impacts to bottom habitat (from other cumulative actions could result from such 

activities as commercial fishing, carbon storage, O&G development, dredged material disposal, structure 

emplacement, and new cable infrastructure), increase in sedimentation, turbidity, and chemical 

contaminants (from activities that would disturb bottom habitat, activities that deposit sediments into 

receiving waters, and vessel operations), increases in sound (from vessel and aircraft operations; sonar

and other underwater acoustic sources; construction, which may include drilling, pile driving, use of 

explosives, and dredging; and operation of facilities and structures), and impacts to the water column 

(from vessels or equipment moving through the water column and climate change). 
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The aggregate impacts of past, present, and reasonably foreseeable future actions are expected to result 

in insignificant impacts to EFH in the action area. The cumulative impacts of other cumulative actions 

affecting physical impacts to bottom habitat; increase in sedimentation, turbidity, and chemical 

contaminants; and increase in sound would be moderate and adverse as EFH would not be degraded over 

the long term or permanently, would continue to support sustainable fisheries, and the continued viability 

of prey populations would not be threatened; therefore, cumulative impacts would be insignificant. In 

recent years, there have been efforts to reduce pollution of ocean environments through restrictions on 

discharges and design features of ocean-going vessels that reduce the probability and severity of spills. As 

a result, more recent incidents involving unauthorized spills or discharges have either been localized and 

limited or, if large and widespread, have generated cleanup and mitigation responses. However, impacts 

to the water column from climate change could be substantial; therefore, cumulative impacts on EFH

would be overall moderate to major from other cumulative actions contributing large atmospheric CO2 

levels leading to increased rates of climate change. Overall, aggregate, adverse cumulative impacts of all 

actions described in Section 4.1 result in moderate cumulative impacts. 

Cumulative, adverse impacts from any of the alternatives in combination with the cumulative effects 

scenario could potentially be considered either synergistic or additive depending on the timing and 

location of activities and impacts. Cumulative adverse impacts from these activities could be synergistic if 

activities associated with the NOS Proposed Action and other cumulative actions occur in close spatial or 

temporal proximity. Similarly, additive effects on EFH may occur if activities associated with the NOS 

Proposed Action and other cumulative actions are considered sequentially. Overall, cumulative impacts 

would be considered negligible under the NOS Proposed Action because the impacts would be temporary 

or short-term, would be confined to the immediate vicinity of project areas, and would be small as 

compared to impacts from all other cumulative actions. The Proposed Action would contribute to and 

have the potential to increase cumulative impacts on EFH, but their relative contribution would be 

negligible as compared to the aggregate contributions of other cumulative actions. These impacts would 

occur regardless of the chosen alternative since projects under each alternative would be composed of 

similar activities and take place in the same geographic areas and timeframes; however, Alternatives B 

and C would include more projects, activities, and nautical miles traveled than Alternative A, and would 

therefore have slightly greater impacts.

4.2.7 Seabirds, Shorebirds and Coastal Birds, and Waterfowl

Given the ecological concordance between bird groups, impacts that would affect all groups are hereafter 

referred to as impacts on birds. Specific impacts based on behavior or habitat of an individual group or 

species are explicitly stated throughout the analysis. 

All past, present, and reasonably foreseeable actions described in Section 4.1 would contribute 

cumulative effects to birds. The analysis of cumulative effects also considers other actions and activities 

on birds, including habitat encroachment from onshore and nearshore development (e.g., coastal 

population growth); marine debris (e.g., plastics, glass, metals, or rubber) and accidental or illicit discharge 

of oil, fuel, chemicals, or waste. 

4.2.7.1 Direct Injury to Sea Birds, Shorebirds and Coastal Birds, and Waterfowl

Crewed vessel operations and active acoustic surveying under the NOS Proposed Action would contribute 

to cumulative impacts on birds along with the use of high intensity active underwater acoustic sources 

and the presence and movement of vessels associated with any of the past, present, or reasonably 
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foreseeable actions. In aggregate, they would likely cumulatively contribute direct injury impacts to birds 

or their prey. Although exposure to the active underwater acoustic sources proposed by NOS would only 

occur for diving birds and would not likely be harmful, other active acoustic sources commonly used in 

other surveying and mapping activities, assessment and exploration of marine minerals, and offshore 

carbon storage assessments have a greater propensity to injure diving birds due to the high intensity and 

large-scale propagation of the broadband sound they produce. These high intensity sources, including 

airguns, could have a more substantial impact on birds than the NOS sources described in Section 3.10, 

especially when considered cumulatively. 

The presence and movement of crewed vessels within the action area, including all vessels used in 

conjunction with activities under the Proposed Action and all past, present, and reasonably foreseeable 

actions of the cumulative effects scenario and offshore renewable energy installations, would likely 

cumulatively contribute to collisions or entanglement of all species of birds or their prey. All vessel 

movements could potentially result in collisions with airborne or floating birds and would cumulatively 

contribute direct injury or mortality impacts. Offshore renewable energy installations, particularly wind 

turbines, could similarly contribute to cumulative collision impacts since birds often are unable to 

recognize and avoid dangerous features of installations. Expanded commercial fishing operations would 

likely increase numbers of birds or their prey in bycatch, particularly in longline or trawled fisheries where

operators cannot continuously monitor trailed lines, hooks, and nets for protected species. As such, the 

overall abundance of birds and their finfish prey would likely be reduced. Accidental collisions with birds 

occasionally occur at night; however, NOS will use appropriate lighting to comply with navigation rules 

and best safety practices, limiting the exposure of birds to onboard lighting. All project areas would be 

continually monitored for protected species by posted crewmembers during vessel operations, further 

reducing the risk of collision with birds. While spills from NOS activities are not likely, accidental or illicit 

discharges of fuel, chemicals, or waste accompanying other vessel operations within the study area 

contribute to the existing direct injury of birds and prey through ingestion and interaction with spilled 

substances, although the intensity of the impact would be contingent upon the size and location of the 

discharge in question. Contaminated prey could also potentially serve as an additional source of spill 

exposure to birds, particularly of bioaccumulated hazardous materials. Discharged waste is of particular 

concern to birds, given their propensity to ingest and entangle themselves in many forms of marine debris 

(e.g., plastics, glass, metals, or rubber). 

When considered in tandem with crewed vessel operations, tide gauge installations, and remote GPS 

reference station installations under the Proposed Action, changing abiotic environmental characteristics 

related to ongoing climate change could potentially contribute direct injury impacts to birds or their prey. 

Other actions and activities that are sources of environmental stress, including ongoing habitat 

encroachment from onshore or nearshore development and coastal development, contribute to the 

current direct injury of birds. Increased light pollution from onshore and nearshore commercial or O&G 

development attracts or disorients bird fledglings, particularly alcids, and causes them to land in 

dangerous areas. Artificial-light-induced landings can result in broken limbs, internal injuries, or even 

fatalities when fledglings collide with buildings, electric wires and pylons, fences, and posts. Grounded 

fledglings are sometimes unable to take flight again, and light-induced landings leave fledglings vulnerable 

to predation by terrestrial animals, collisions with terrestrial vehicles or to starvation and dehydration in

the event they are unable to find their way back to sea. 

Similarly, ongoing climate change will continually alter marine environmental conditions throughout the 

timespan of this analysis, which could result in direct injury of bird prey. Although environmental 

conditions will not likely change to the point of directly injuring birds, ocean acidification accompanying 
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climate change could potentially harm macroinvertebrate prey species (bivalves, gastropods, and 

cephalopods) that are particularly sensitive to environmental conditions during their larval stages and will 

likely reduce their availability to birds. Rising surface water temperatures will also reduce the solubility of 

oxygen in seawater (resulting in lower dissolved oxygen levels) and could inhibit or stress the respiration 

of all marine prey species, further cumulatively reducing prey availability for birds within the EEZ. 

The majority of cumulative direct injury impacts would be limited to the immediate vicinity of vessels or 

O&G development and would not likely cause long-term changes in bird behavioral patterns, habitat 

availability and use, or the demographic structure and abundance of bird and prey population. Similarly, 

climate-related impacts would not likely substantially affect birds, although the magnitude of the impact 

will likely continue to increase over time. Overall, cumulative direct injury impacts on birds would occur 

regardless of the chosen alternative, would be short-term to long-term, adverse, and negligible to minor. 

The contribution of the NOS Proposed Action to these aggregate, adverse cumulative impacts would be 

negligible. 

4.2.7.2 Disturbance and Displacement of Sea Birds, Shorebirds and Coastal Birds, 

and Waterfowl

Sound-producing and vessel operation activities under the NOS Proposed Action would contribute to 

cumulative effects produced by other active acoustic sound sources, especially from high intensity sources 

used in O&G surveying. In combination, these actions could temporarily displace diving birds and their 

prey throughout the EEZ and cause cumulative adverse impacts to birds. Sound from survey vessels, 

shipping vessels, commercial fishing vessels, recreational boats, and underwater construction activities in 

support of energy infrastructure, LNG terminals, and submarine telecommunications infrastructure could 

also cumulatively disturb and displace all species of birds and their prey from the respective project areas 

for the duration of the activity in question. The visual presence of vessels would also likely serve as an 

additional source of disturbance and displacement. 

When considered in tandem with underwater disturbance from vessel movement and presence and 

bottom sampling under the NOS Proposed Action, reduced water quality and increased turbidity resulting 

from the ongoing erosion of coastlines by rising sea levels, bottom sampling, and underwater construction 

activities would also disturb and displace birds and prey; such activities conducted by NOS would be 

extremely limited. Climate change will continue to raise sea levels globally for the foreseeable future, 

which results in continual erosion throughout the coastlines of the EEZ. Coastal erosion occurs at varying 

rates around the EEZ, but would be most pronounced along the Atlantic coastline. Reduced water quality 

and increased turbidity in these areas from ongoing coastal erosion would likely shift prey distributions 

and could result in increased bird foraging effort; travel time to foraging areas could increase due to 

shifted prey distributions; and foraging success could decrease due to reduced visibility of prey species in 

turbid waters. While spills from NOS activities are unlikely, the ongoing accidental or illicit discharges of 

fuel, chemicals, or waste from other vessel operations and marine infrastructure contribute to currently 

disturbed and displaced birds and their prey from contaminated areas for the lifetime of the spill. The 

intensity of the impact is contingent upon the size and location of the spill in question; most small spills 

are dissipated by ocean conditions on a timescale of minutes to hours.

Cumulative disturbance and displacement impacts would likely be limited to the immediate vicinity of the 

source and would not persist beyond the conclusion of activities. These impacts are not expected to cause 

long-term changes in habitat availability, overall bird behavioral patterns, or overall prey availability and 

would be considered adverse and negligible to minor. The contribution of the NOS Proposed Action to 

these adverse cumulative impacts would be negligible. 
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4.2.7.3 Degradation and Reduction of Habitat for Sea Birds, Shorebirds and Coastal 

Birds, and Waterfowl

Onshore tide gauge installations and remote GPS reference station installations under the NOS Proposed 

Action would contribute to cumulative impacts along with the construction, operation, and 

decommissioning of long-term installations such as LNG terminals, energy infrastructure, and submarine 

telecommunications. In aggregate, these would likely reduce the total amount of oceanic and coastal 

habitat available to birds and their prey for the lifetime of the installations. Long-term installations would 

occupy space within viable habitat areas, reducing the total habitat available to birds and their prey. 

Furthermore, activities or actions related to the maintenance and operation of these long-term structures 

would degrade the habitat quality of surrounding areas. However, NOS onshore activity would likely only 

displace birds and prey within the immediate vicinity of the project area and would not cause any 

mortality or direct injury. Onshore installations would only occupy very small portions of available habitat 

and birds and their prey are expected to return to project areas after the completion of NOS onshore 

activities. 

The ongoing accidental or illicit discharges of fuel, chemicals, or waste from other vessel operations and 

marine infrastructure contribute to currently degraded sensitive coastal nesting habitat; accidental spills 

from NOS activities are very unlikely. Coastal ground-nesting birds such as piping plovers and red knots 

breed and nest in areas below the high-water line that are particularly susceptible to contamination from 

spilled materials. The overall intensity of the impact is contingent upon the size and distance of the spill 

in question from nesting beaches; most small spills are dissipated by ocean conditions on a timescale of 

minutes to hours. 

The existing stress from coastal population growth also contributes to the degradation of bird habitat 

through a variety of factors, including coastal water quality reductions from urban/agricultural runoff, 

encroachment by coastal development, and increased light pollution. Rising sea levels as a result of 

climate change will continually erode coastlines along the EEZ over the next five years and could 

potentially destroy or degrade coastal nesting areas, particularly of sensitive coastal ground-nesting 

species. However, the magnitude of these impacts is contingent upon the amount of coastal erosion 

within a given area.

Reduced water quality would also displace finfish prey species from eroded areas and could potentially 

increase the foraging energy expenditures of birds. Changing climate conditions, such as rising surface 

water temperatures, shifting currents, and shifting wind patterns, will change the location and intensity 

of deep-water upwellings, an important source of oceanic nutrients. Prey distributions will likely shift 

along with oceanic nutrients, which could ultimately reduce the total amount of available prey if the bird 

dispersal rate is relatively lower than that of their prey. Seabirds are particularly susceptible to habitat 

reduction because their high levels of behavioral resilience and experience-based learning limit their 

ability to disperse to new areas and follow shifting prey distributions. 

Generally, cumulative impacts to bird habitat would persist for the entirety of the foreseeable future, but 

would not substantially reduce overall habitat availability or quality and would not substantially impact 

the overall structure or abundance of bird or prey populations. Shifting prey distributions in response to 

changes in oceanic nutrient cycling could potentially impact the overall population of some seabird 

species that return to the same areas or islands to breed or forage annually. These birds have high levels 

of behavioral resilience and foraging specialization and would not likely be able to follow their original 

prey or adapt to include new species in their diet. However, nesting areas are generally avoided by 
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development given the federal protection of most birds under the Migratory Bird Treaty Act (MBTA), and 

aggregate, adverse cumulative impacts to bird habitat would likely be minor. The contribution of the NOS 

Proposed Action to these aggregate, adverse cumulative impacts would be negligible. 

4.2.7.4 Conclusion

Activities associated with the Proposed Action and the past, present, and reasonably foreseeable actions 

described in the cumulative effects scenario have the potential to contribute cumulatively to direct injury, 

disturbance and displacement, and habitat reduction in the action area. In the short-term, the presence 

and movement of vessels and the development of offshore renewable energy installations could 

potentially result in direct injury to birds from collisions or entanglements and would likely disturb or 

displace nearby birds for the duration of activities. Similarly, changing abiotic environmental conditions 

resulting from ongoing climate change and the stress already placed on birds due to habitat encroachment 

from onshore or nearshore development could serve as additional sources of cumulative direct injury to 

birds and their prey. Active acoustic sound sources; vessel sound; underwater activities; and ongoing 

climate change would displace birds and their prey in the immediate vicinity of activities. Disturbances 

and displacements resulting from activities are not expected to persist beyond the duration of activities, 

and short-term cumulative impacts would likely range from negligible to moderate. Onshore and 

nearshore development and accidental discharges of oil, fuel, chemicals or waste already reduce the total 

amount of available bird habitat and climate change would cumulatively impact the total amount of 

available bird habitat in the long term. As such, the long-term cumulative impact of habitat reduction on 

birds would likely be minor. 

Cumulative adverse impacts from any of the alternatives in combination with the cumulative effects 

scenario could potentially be considered either synergistic or additive depending on the timing and 

location of activities and impacts. Synergistic impacts could result if any activities or actions occur in close 

spatial or temporal proximity within the action area. For example, a mapping project in close proximity to 

an operating offshore oil well could substantially disturb birds through the visual presence and sound of 

both vessels used by NOS and the installation and could result in bird avoidance of project areas for longer 

periods of time than would be elicited by either of the impact-causing factors independently. 

Similarly, additive cumulative impacts to birds, their prey, or their associated habitat could occur if 

activities or actions are conducted sequentially within adjacent areas of the action area. For example, 

water quality in coastal areas could be additively degraded if a bottom sampling project was conducted 

shortly after the installation of a wind turbine. Although the exact timing and location of projects have 

not been finalized and are subject to change, the Southeast and Alaska regions contain the largest 

proportion of total vessel transit miles of the EEZ (Section 2.4.1) and relatively high levels of marine O&G 

development. Therefore, synergistic or additive cumulative impacts are most likely to occur in either of 

these regions. The vast majority of cumulative impacts are confined to the immediate vicinity of project 

areas and would likely not impact the overall abundance or structure of bird or prey populations outside 

of the range of natural variability. 

Overall, the Proposed Action would contribute a negligible amount to the aggregate cumulative effects 

from all actions described in Section 4.1 depending on the timing and location of impacts within the fiveyear forward projection of the entire five-year timespan of the analysis. These impacts would occur 

regardless of the chosen alternative since projects under each alternative would be composed of similar 

activities and take place in the same geographic areas and timeframes; however, Alternatives B and C 
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would include more projects, activities, and nautical miles traveled than Alternative A, and thus contribute 

slightly greater impacts.

4.2.8 Cultural and Historic Resources

All past, present, and reasonably foreseeable future actions described in Section 4.1 would contribute 

cumulative effects to cultural and historic resources. The analysis of cumulative effects also considers the 

impact of other actions and activities on cultural and historic resources, including IUU fishing; accidental 

or illicit discharges (e.g., nutrient runoff, oil spills, or other introduction of contaminants); and flows of 

pollutants, contaminants, sediments, and nutrients into coastal waters. 

4.2.8.1 Damage and Destruction of Submerged Cultural and Historic Resources

Anchoring, bottom sampling, and other activities that would disturb the sea floor, such as the installation 

of ADCPs, under the Proposed Action would contribute to cumulative impacts associated with increases 

in the number of vessels and boats anchoring or conducting surveying and mapping throughout the EEZ, 

the construction, operation, and decommissioning of long-term installations such as LNG terminals and 

submarine telecommunications cable and associated infrastructure, offshore and OCS oil and natural gas 

development, offshore renewable energy development, and the assessment and extraction of marine 

minerals. In combination, all these actions would likely cumulatively increase the risk of damage to 

submerged cultural and historic resources. 

Coral reefs, vital to subsistence cultures and thus considered a cultural resource, would also be at 

increased risk of cumulative damage from these activities. Coral reefs host more than one quarter of all 

marine fish species, in addition to many other marine animals. Reefs also provide subsistence food and 

sustain the fishing and tourism industries (IUCN, 2022). Cultural and historic resources (including coral 

reefs) could be impacted by physical contact with anchors, submarine cables, equipment used for mineral 

extraction, and other underwater construction activities. As with vessels used by NOS operators, most 

vessels would anchor whenever practicable in designated areas and would avoid anchoring on shipwrecks 

and downed aircraft, coral reefs, and hard bottomed areas. This practice would also be followed during 

construction of underwater infrastructure and other activities described in Section 4.1. This practice 

would limit the likelihood of direct damage to known submerged cultural and historic resources, including 

coral reefs. 

Inadvertent discovery of cultural and historic resources during construction of infrastructure such as LNG 

terminals is often associated with damage or destruction of the resource. These impacts would be adverse 

and permanent. It is possible that the inadvertent discovery of cultural and historic resources could be 

considered a beneficial impact due to the research potential that discovery would afford if the resource 

were not damaged or destroyed. For federal activities (including those requiring a federal authorization 

or permit), adverse impacts could be avoided or minimized to some degree through consultation between 

the lead agency and the State Historic Preservation Officer (SHPO) in compliance with Section 106 of the 

National Historic Preservation Act (NHPA) prior to construction. This communication serves to ensure 

avoidance of known culturally and historically significant sites, and to ensure that if cultural and historic 

resources are encountered, standard protocols related to protection and documentation of the resource 

would be followed. Generally, if a cultural or historic resource is discovered during construction, work 

stops until the SHPO can properly evaluate the resource. 

The majority of cumulative damage impacts would be limited to the locations in which anchors are 

dropped or bottom sampling related to NOS projects and activities occurs, and in the immediate vicinity 
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of offshore O&G development, assessment and extraction of marine minerals, and construction of 

submarine infrastructure, and would cause permanent impacts to cultural and historic resources, 

including coral reefs. Impacts could be either adverse or beneficial, depending on whether the resources 

were damaged or destroyed or protected and documented. Overall cumulative impacts to submerged 

cultural and historic resources from direct damage would likely be negligible to moderate; the 

contribution of any of the NOS alternatives to these adverse, cumulative impacts would be negligible. 

Submerged cultural and historic resources are currently stressed due to accidental leakage or spillage of 

oil, fuel, and chemicals and the unintentional disposal of trash and debris, though NOS does not contribute 

to these actions (See Section 3.15). While not considered a cumulative impact, the stress has contributed 

to the existing condition of cultural and historic resources and is noteworthy. Cultural and historic 

resources may be exposed to hydrocarbon contamination (the result of oil spills). The effects of oil vary 

depending on the type of material and the condition it is in— sun-dried wood, for example, may absorb 

the oil more readily than shells in middens (NPS, 2010). The absorption of oil by cultural and historic 

resources can make radiocarbon dating impossible. Impacts from oil spills to cultural and historic 

resources could be permanent. Other contaminants, sediments, and nutrients can adversely impact the 

structural integrity of cultural and historic resources, with the greatest adverse effects occurring in waters 

with limited circulation such as bays, sounds, and estuaries. Impacts to cultural and historic resources 

from these actions and activities depend on the extent of contamination and the nature of the pollutant 

or other substance introduced by vessels throughout the action area. 

When considered in tandem with all past, present, and reasonably foreseeable projects listed in Section 

4.1, impacts stemming from climate change would cumulatively increase the likelihood of damage to 

submerged cultural and historic resources. Increased temperatures cause accelerated rusting in 

submerged resources, more rapid decay of organic materials, damage from increased biological activity 

at shallow underwater sites, and increased risk of damage due to decline and loss of protective sea grass 

or nearby coral reefs. Rising temperatures also lead to faster deterioration of newly exposed artifacts and 

sites. Ocean acidification will cause increased risk of damage to shipwrecks due to loss/decline of 

protective concretions and/or nearby coral reefs. It will also cause decline in reefs from coral bleaching. 

Adverse climate change impacts will occur regardless of the chosen alternative, are long-term, and could 

result in minor to moderate impacts on cultural and historic resources within the next five years; the 

contribution of any of the NOS alternatives to these cumulative impacts would be negligible. 

4.2.8.2 Degradation of Cultural and Historic Viewsheds

Installation of tide gauges and GPS reference stations under the Proposed Action would contribute to 

cumulative effects on historic viewsheds from the activities listed in Section 4.1 that involve nearshore or 

coastal construction activities. In aggregate, these individually negligible to minor actions would change 

historic viewsheds and thus cause cumulative, adverse impacts to cultural and historic viewsheds. 

Activities occurring within the viewshed of a nearshore historic property or designed cultural landscape 

could change these designed views, vistas, or view corridors and impact the integrity of the property’s 

design, not simply cause visual effects on the integrity of a historic property’s setting or other historic 

characteristics. 

However, federal construction work proposed within the area of potential effect (APE) of coastal 

structures listed or eligible for listing on the National Register of Historic Places (NRHP) generally requires 

consultation with the appropriate SHPO prior to construction. Adherence to this protocol would help to 

minimize or avoid potential impacts to coastal structures listed or eligible for listing on the NRHP. Thus, 
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the likelihood of adverse impacts to cultural and historic resources for which viewshed is a contributing 

element would be low, given the likely avoidance of NRHP-listed sites during the site selection process or 

avoidance of impacts to historic coastal structures following communication with the SHPO. Impacts 

would occur only within the APE of the cultural or historic resource, and would be adverse and minor; the 

contribution of any of the NOS alternatives to these adverse cumulative impacts would be negligible. 

4.2.8.3 Disruption to Subsistence Hunting and Fishing, Including in TCPs

Activities producing sound and visual disturbances under the Proposed Action (e.g., the use of active 

underwater acoustic sources, vessel and equipment sound, physical presence of vessels and equipment 

in water, and human activities such as tide gauge and GPS reference station installation, and SCUBA

operations), the operation and presence of vessels, equipment, and humans would contribute to 

cumulative impacts on subsistence hunting and fishing associated with any of the past, present, or 

reasonably foreseeable actions described above. Together, these would create short- and long-term 

adverse cumulative impacts to subsistence hunting and fishing, including those taking place in Traditional 

Cultural Places (TCPs). Activities that create sound and visual disturbance would cause species to move 

away from the shore, and subsistence hunters could be forced to temporarily abandon common hunting 

areas. Increased recreational and commercial fishing could reduce the availability of species important to 

subsistence communities; this could have long-term adverse impacts on these communities. Subsistence 

harvests in the marine environment could be disrupted or prolonged, or subsistence resources could be 

unavailable for use. 

In the short-term, the presence and movement of vessels could potentially result in disturbance of 

traditional use in TCPs and subsistence hunting and fishing areas for the duration of project activities. 

Disturbance to subsistence activities and sociocultural systems are discussed in greater detail in Section 

4.2.10.1. Impacts could also occur if a species important to subsistence communities were overfished or 

contaminated. Subsistence resources are currently stressed due to accidental leakage or spillage of oil, 

fuel, and chemicals and the unintentional disposal of trash and debris. Contaminated, or perceived 

contaminated, resources could make subsistence resources unavailable or undesirable for use (BOEM, 

2015b). Contamination from oil/chemical spills would render the affected subsistence resource unsafe to 

eat. If the skin or fur of the animal is coated with oil, the pelt would no longer be desirable to be made 

into coats and other handicrafts. Spill cleanup operations could result in the closure of harvesting areas 

until cleanup is complete. Other actions and activities causing the contamination of subsistence resources 

are discussed further in Section 4.2.10.3. 

However, federal actions that would have effects within a reservation or Alaska Native village; affect tribal

trust resources or the rights of a federally recognized Tribe; affect a facility or entity owned or operated 

by a tribal government; affect Tribes, tribal governments, or a Tribe’s traditional way of life; or affect TCPs 

or Traditional Use Areas would trigger the need for communication with Tribes. It is possible that projects 

that would occur in traditional hunting and fishing areas would be coordinated to avoid peak hunting and 

fishing seasons (e.g., whales, seals, and salmon) or times of year to the extent possible, based on 

information obtained from the Tribes. Activities planned to occur in any NRHP-listed TCP would need to 

comply with federal regulations related to the protection of these culturally significant places. Even if peak 

seasons and times are not avoided, cumulative disruption of subsistence hunting and fishing and other 

traditional practices by tribes from additional vessels in TCPs and Traditional Use Areas would be 

temporary, adverse, and negligible to moderate. 
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When considered in tandem with all past, present, and reasonably foreseeable projects listed in Section 

4.1, impacts stemming from climate change would cumulatively increase the likelihood of impacts to 

subsistence hunting and fishing, including in TCPs. Climate change-induced factors such as changes in 

thickness and extent of sea ice, increased snowfall, drier summers and falls, and increased storms and 

coastal erosion could adversely affect subsistence harvest patterns by altering traditional hunting 

locations, impacting subsistence travel, and result in resource patterns shift and seasonal availability 

changes, making access to subsistence resources more difficult (NOAA, 2016). The impacts of changes in 

sea ice and other vital components of subsistence hunting and fishing areas on subsistence communities 

are described in detail in Section 4.2.10.2. 

Overall, climate change could lead to changes in diversity, abundance, and distribution of traditional 

subsistence resources and harvest patterns, leading to long-term impacts on the availability of some 

subsistence resources. This could potentially threaten indigenous lifestyle and subsistence practices 

(NOAA, 2016). Adverse, cumulative climate change impacts will occur regardless of the chosen alternative, 

are long-term, and could result in moderate to major impacts on subsistence hunting and fishing; the 

contribution of any of the NOS alternatives to these adverse, cumulative impacts would be negligible. 

4.2.8.4 Conclusion

When considered with the NOS Proposed Action, other surveying and mapping efforts in the action area, 

offshore oil and natural gas development, offshore renewable energy development, climate change, 

commercial shipping and recreational boating, assessment and extraction of marine minerals, offshore 

carbon storage resource assessments, construction and operation of offshore LNG terminals, national 

defense and homeland security activities, construction of new submarine telecommunication cable 

infrastructure, commercial and recreational fishing, and coastal development would create adverse 

cumulative impacts to cultural and historic resources. Adverse impacts to cultural and historic resources 

could occur through the damage and destruction of submerged cultural and historic resources including 

coral reefs, degradation of historic viewsheds, and disruption of subsistence hunting and fishing, including 

in TCPs. 

Overall, the short-term and long-term adverse cumulative impacts from the cumulative effects scenario 

on cultural and historic resources range from negligible to major. Cumulative impacts to submerged 

cultural and historic resources from direct damage would likely be negligible to moderate. These impacts 

would be permanent, since damage cannot be reversed. Adverse climate change impacts will occur 

regardless of the chosen alternative, are long-term, and could result in minor to moderate impacts on 

cultural and historic resources within the next five years. Ongoing damage to cultural and historic 

resources from other actions and activities such as oil spills and flows of other pollutants, contaminants, 

sediments, and nutrients into coastal waters would be negligible to moderate, depending on the extent 

of contamination and the nature of the pollutant or other substance introduced by vessels throughout 

the project area. The likelihood of adverse cumulative impacts to cultural and historic resources for which 

viewshed is a contributing element from nearshore or coastal construction activities would be low, given 

the likely avoidance of NRHP-listed sites during the site selection process or avoidance of impacts to 

historic coastal structures following communication with the SHPO. Impacts would occur only within the 

APE of the cultural or historic resource, and would be minor. Even if peak seasons and times for 

subsistence hunting and fishing are not avoided, cumulative disruption of these and other traditional 

practices by tribes from additional vessels in TCPs and Traditional Use Areas would have negligible to 

moderate impacts. Impacts stemming from climate change would cumulatively increase the likelihood of 

impacts to subsistence hunting and fishing, including in TCPs. Adverse climate change impacts will occur 
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to subsistence hunting and fishing practices regardless of the chosen alternative and are long-term. 

Impacts would be moderate to major. Cumulative impacts from climate change on subsistence hunting 

and fishing practices are therefore significant. As such, cumulative impacts on cultural and historic 

resources would be significant without consideration of the impacts of the Proposed Action.

Cumulative, adverse impacts from any of the alternatives in combination with the cumulative effects 

scenario could be considered as either synergistic or additive depending on the timing and location of 

activities and impacts. Synergistic impacts could result if any activities or actions occur in close spatial or 

temporal proximity within the study area. Similarly, additive cumulative impacts to cultural and historic 

resources could occur if activities or actions are conducted sequentially within adjacent areas of the action 

area. Although the exact timing and location of projects have not been finalized and are subject to change, 

the Southeast and Alaska regions contain the largest proportion of total miles of NOS vessel movement in 

the EEZ (Section 2.4.1) and relatively high levels of marine O&G development. Therefore, synergistic or 

additive cumulative impacts are most likely to occur in either of these regions. The vast majority of 

cumulative impacts are confined to the immediate vicinity of project areas and are not likely to occur 

within TCPs, where certain types of activity and development are not permitted. 

The NOS Proposed Action would contribute to and have the potential to increase these cumulative 

impacts, but their relative contribution would be negligible as compared to the aggregate contributions 

of other cumulative actions. These impacts would occur regardless of the chosen alternative since projects 

under each alternative would be composed of similar activities and take place in the same geographic 

areas and timeframes; however, Alternatives B and C would include more projects, activities, and nautical 

miles traveled than Alternative A and thus contribute slightly greater impacts.

4.2.9 Socioeconomic Resources

Other surveying and mapping efforts in the action area, offshore oil and natural gas development, 

offshore renewable energy development, commercial shipping and recreational boating, assessment and 

extraction of marine minerals, offshore carbon storage resource assessments, the construction and 

operation of offshore LNG terminals, construction of new submarine telecommunication cable 

infrastructure, commercial and recreational fishing, and coastal development described in Section 4.1 

would all contribute cumulative beneficial impacts to socioeconomic resources. 

4.2.9.1 Economic Benefits to the Ocean Economy 

All mapping and surveying activities under the NOS Proposed Action would contribute to cumulative 

impacts along with other surveying and mapping efforts in the action area associated with the past, 

present, and future reasonably foreseeable actions (including offshore carbon storage and carbon storage 

assessments, offshore O&G development, offshore renewable energy development, and the assessment 

and extraction of marine minerals). In aggregate, these actions would likely cumulatively contribute 

indirect economic benefits described in Section 3.12.2. 

The high-resolution oceanographic data collected during mapping and surveying activities would be used 

by collecting agencies or third parties to create or improve navigational maps/charts and 

forecasts/nowcasts of ocean or meteorological conditions. The increased accuracy and precision of these 

resulting data products would benefit all major sectors of the ocean economy, including health and safety 

activities (including coastal or climate resilience planning), recreational activities, transportation, energy, 

and commercial fishing. These sectors would primarily benefit through operational cost reductions from 

optimized route or development planning, enhanced risk management from enhanced ocean condition 
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forecasts and nowcasts, and increased revenues from higher landed values or enhanced precision and 

accuracy in the location, quantification, and extraction of oceanic energy resources. Indirect, cumulative 

effects would occur from further increasing operational efficiency and reducing risks (e.g., route-planning, 

fishing ground selection, targeting of O&G resources, closing/opening recreational areas). 

Although mapping and surveying activities would not directly create large numbers of jobs or stimulate 

migrations of workers, mapping and surveying related to offshore carbon storage assessments and 

offshore development of renewable and fossil fuel energy sources would have greater indirect economic 

cumulative impacts compared to other sectors. The oceanographic data collected would facilitate the 

leasing and development of future oceanic carbon storage or offshore/nearshore energy projects, which 

would entail large scale job creation and capital expenditures in coastal areas near project sites. 

These impacts would persist as long as the data collected and resulting data products are available for 

review by the public, and certainly for the entirety of the duration considered in the cumulative effects 

analysis. As such, other surveying and mapping efforts in the action area would cumulatively contribute 

long-term, indirect, moderate, beneficial impacts to socioeconomic resources. The contribution of the 

NOS Proposed Action to these aggregate, beneficial cumulative effects would likewise be long-term, 

indirect, moderate, and beneficial.

4.2.9.2 Indirect Effects on Jobs and Revenue

Indirect economic benefits resulting from all mapping and surveying activities under the Proposed Action 

would contribute to cumulative effects on jobs and revenue from all past, present, and future reasonably 

foreseeable revenue-generating actions. In combination, these would cumulatively result in indirect 

cumulative economic benefits to the ocean economy. Offshore O&G development, offshore renewable 

energy development, the expansion of commercial shipping and recreational boating, assessment and 

extraction of marine minerals, and the construction of LNG terminals would all generate substantial 

amounts of revenue within the study area. Although mapping and surveying would not directly impact

these economic sectors, the enhanced accuracy and precision of ocean data resulting from mapping 

efforts would expedite and facilitate greater development of offshore energy resources, both from fossil 

fuels and renewable energy. Marine energy developments create large numbers of jobs related to the 

construction, operation and maintenance, and eventual reclamation in coastal areas near project sites. 

Similarly, the expansion of commercial shipping will require hiring of additional crewmembers and port 

employees. The majority of revenue-generating cumulative actions would also require large capital 

expenditures in coastal regions for raw materials or necessary equipment. Second order economic 

benefits would be generated in coastal economies from consumer or retail expenditures by newly 

employed workers or the growing number of recreational boaters. These impacts would persist for the 

entirety of the duration of the cumulative effects analysis and beyond into the foreseeable future.

The enhanced accuracy and precision of ocean data resulting from mapping efforts would expedite and 

facilitate greater development of offshore energy resources. Due to the resulting revenue and jobs that 

would be created, cumulative impacts on socioeconomic resources would be long-term, indirect, 

moderate, and beneficial; the contribution of the NOS Proposed Action would also be long-term, indirect, 

moderate, and beneficial.
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4.2.9.3 Conclusion

When considered with the NOS Proposed Action, other surveying and mapping efforts in the action area, 

offshore oil and natural gas development, offshore renewable energy development, commercial shipping 

and recreational boating, assessment and extraction of marine minerals, offshore carbon storage resource 

assessments, the construction and operation of offshore LNG terminals, construction of new submarine 

telecommunication cable infrastructure, commercial and recreational fishing, and coastal development 

would create cumulative impacts to socioeconomic resources. Impacts to socioeconomic resources could 

include impacts to the ocean economy and on jobs and revenue.

Overall, the short- and long-term beneficial cumulative impacts from the cumulative effects scenario on 

socioeconomics would be moderate. All NOS projects and activities associated with the Proposed Action 

and other surveying and mapping efforts considered in the cumulative effects scenario have the potential 

to contribute indirect cumulative impacts to socioeconomic resources through the collection of highresolution oceanographic data. Data products (e.g., maps and charts) resulting from these collection 

efforts would benefit all sectors of the ocean economy primarily through operational cost savings, 

improvement of risk management, and coastal or climate resilience planning. These data products would 

enhance and facilitate revenue-producing activities, advantaging future oceanic carbon storage and 

offshore energy projects in particular, which would subsequently cause job creation and capital 

expenditures within coastal regions closest to project sites. Indirect, cumulative economic benefits would 

result from consumer or retail expenditures in coastal areas by newly employed workers or the growing 

number of recreational boaters. All cumulative socioeconomic impacts would likely persist for the 

duration of the cumulative effects study period and beyond. As such, the socioeconomic cumulative 

indirect benefits of these actions would be short-term and long-term and moderate in magnitude. No 

cumulative adverse impacts to socioeconomic resources are expected from any of the actions or activities. 

Potential cumulative, adverse impacts from the Proposed Action in combination with the cumulative 

effects scenario could be considered either synergistic or additive depending on the timing and location 

of activities and impacts. Synergistic impacts could result if any activities or actions occur in close spatial 

or temporal proximity within the study area. For example, updated charts around popular coastal 

recreational areas would increase operational efficiency and safety of local boating activities; these 

synergistic benefits would likely result in larger expansions of recreational boating in these areas than in 

areas that are not surveyed. Similarly, increased accuracy and precision of ocean condition forecasts and 

nowcasts within a given area would act synergistically to facilitate greater implementation of local coastal 

or climate resilience planning in the development of commercial real estate or onshore/nearshore energy 

infrastructure. Additive socioeconomic cumulative impacts could also occur if activities or actions are 

conducted sequentially within adjacent areas of the study area. Although the exact timing and location of 

projects have not been finalized and are subject to change, the Southeast and Alaska regions contain the 

largest proportion of total vessel transit miles of the EEZ (Section 2.4.1) and relatively high levels of marine 

O&G development. Therefore, synergistic or additive cumulative impacts are most likely to occur in either 

of these regions.

The contribution of the NOS Proposed Action to beneficial, aggregate cumulative impacts would be 

moderate depending on the timing and location of impacts. These impacts would occur regardless of the 

chosen alternative since projects under each alternative would be composed of similar activities and take 

place in the same geographic areas and timeframes; however, Alternatives B and C would include more 

projects, activities, and nautical miles traveled than Alternative A and thus contribute slightly greater 

impacts.
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4.2.10 Environmental Justice

All past, present, and reasonably foreseeable actions described in Section 4.1 would contribute 

cumulative effects on environmental justice. The cumulative effects analysis also considers that other 

actions and activities contributing to the existing condition of subsistence resources, including marine 

debris (e.g., plastics, glass, metals, or rubber); IUU fishing; and accidental or illicit discharges (e.g., nutrient 

runoff, oil spills, or other introduction of contaminants).

4.2.10.1 Disturbance to Subsistence Activities and Sociocultural Systems

Activities producing sound and visual disturbances under any of the three NOS alternatives (e.g., the use 

of active underwater acoustic sources, vessel and equipment sound, physical presence of vessels and 

equipment in water, and human activities such as tide gauge and GPS reference station installation, and 

SCUBA operations), the operation and presence of vessels, equipment, and humans would contribute to 

cumulative impacts associated with any of the past, present, or reasonably foreseeable actions mentioned 

above. In combination, these actions would create short- and long-term adverse cumulative impacts to 

environmental justice communities. Activities creating sound and visual disturbances would cause species 

to move away from the shore, and subsistence hunters could be forced to temporarily abandon common 

hunting areas. Subsistence harvests in the marine environment could be disrupted, prolonged; or 

subsistence resources could be unavailable for use. Communities which are primarily dependent on 

marine mammals for subsistence, such as the bowhead harvesters of northern and western Alaskan 

villages, would be especially impacted. Subsistence users may be required to travel farther to harvest 

subsistence foods at a greater cost in terms of time, fuel, wear and tear on equipment and people, and 

lost wages. A decline in the harvest efficiency of marine resources would likely lead to an increase in 

hunting pressure on terrestrial wildlife, and to an increase in competition and territorial conflicts among 

subsistence harvesters (BOEM, 2015b). 

Activities producing sound and visual disturbances under any of the three NOS alternatives (e.g., vessel 

and equipment sound, physical presence of vessels and equipment in water, and SCUBA operations) 

would contribute to cumulative impacts that potentially disrupt subsistence fishing from the operation 

and presence of vessels, equipment, and humans associated with any of the past, present, or reasonably 

foreseeable actions and commercial and recreational fishing activities. The presence of NOS and other 

vessels could startle fish, making them harder to catch by subsistence fishers. Subsistence fish species 

could become less available or unavailable from overfishing due to commercial and recreational fishing 

activities, particularly in Alaska. Also, as mentioned in Section 4.2.8.3, IUU fishing activities already 

contribute to the reduced availability of fish, other marine species, or coral reefs important to subsistence 

cultures. However, in the Gulf of Mexico the impact of such activities on subsistence fishing communities 

would be negligible since their largest source of subsistence foods are from removals from commercial 

fishery catches and from activities similar to recreational harvesting (BOEM, 2012). 

The cumulative impacts of past and present actions that cause disturbance to subsistence activities would 

adversely affect the rates of sharing between communities (NMFS, 2016d). This could adversely impact 

sociocultural systems by disrupting the social organization and/or institutional formation of communities, 

eroding cultural values, and/or disrupting the economy of households and village communities through 

changes in employment, personal income, and overall community prosperity. Sharing efforts among core 

kinship relations would likely intensify, but diminish among more remote networks of exchange. Such 

pressures could potentially undermine transmission of cultural aspects of subsistence activities to youth 

populations (BOEM, 2015b). 
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In general, the sound and visual disruptions from vessels, equipment, and humans are considered a 

common source of disturbance in the marine environment. Relative to most other cumulative actions 

described in Section 4.1, there would be lower impacts from the sound generated by the active 

underwater acoustic sources proposed by NOS. The vessels used for NOS projects would be smaller than 

most industrial and commercial vessels and cause less disruption. The sound and visual impacts from 

vessels, equipment, and humans would cause disturbances in their immediate vicinity and would not 

persist beyond the conclusion of project activities. To minimize adverse impacts to subsistence

communities, repeated surveys by NOS in the same area would be avoided. However, due to limited prior 

exploration in the Alaska region and the 2019 Presidential Memorandum on Ocean Mapping, the number 

and frequency of cumulative actions mentioned above, particularly surveying and mapping projects, is 

expected to increase over the next five years. Overall, cumulative impacts of the actions described in 

Section 4.1 could result in adverse and minor to moderate aggregate, cumulative impacts on EJ 

communities, depending on the type of activity, seasonal timing, and animal migration. The contribution 

of the NOS Proposed Action to these adverse, cumulative impacts would be minor. 

4.2.10.2 Disturbance to Subsistence Activities and Sociocultural Systems from 

Climate Change

Air emissions under any of the three NOS alternatives would contribute to cumulative effects on climate 

from greenhouse gas emissions associated with past, present, and reasonably foreseeable actions, 

particularly related to oil and natural gas development and operation of offshore LNG terminals. In 

aggregate, these actions would lead to long-term adverse cumulative impacts to environmental justice 

communities. However, these impacts would result from the overall global climate change phenomenon, 

since potential air emission impacts from NOS activities are expected to be imperceptible or nondetectable as described in Section 3.15.1. In recent years, Alaska has experienced concerning trends in 

subsistence harvest activities due to climate change-induced factors such as changes in thickness and 

extent of sea-ice, increased snowfall, drier summers and falls, and increased storms and coastal erosion. 

These could adversely affect subsistence harvest patterns by altering traditional hunting locations, 

impacting subsistence travel, and resulting in resource patterns shift and seasonal availability changes; 

making access to subsistence resources more difficult (NMFS, 2016d). 

Changes in sea-ice could have dramatic impacts on marine mammal migration routes which could impact 

harvest patterns of subsistence communities and increase the danger of hunting on sea-ice. Thawing of 

permafrost and melting of sea-ice could result in the habitat loss of important subsistence species. 

Warmer summers have already started impacting the timing of subsistence hunting. For example, whalers 

in Kaktovik are accustomed to hunting in August, but now whaling season occurs primarily in September. 

It is also becoming increasingly difficult to preserve meat during the warmer months. Common hunting 

and harvesting areas could recede away from the shore, requiring subsistence harvesters to travel farther 

to harvest subsistence foods at a greater cost in terms of time, fuel, wear and tear on equipment and 

people, and lost wages. 

Shore erosion has become increasingly common in certain Alaskan communities, which delays sea-ice 

formation, allowing wave action from storms to cause greater damage to the shoreline and change use 

patterns of local and regional subsistence use areas. As described in Section 4.1.6, the BOEM MMP has 

several coastal restoration projects that could slow down these impacts in the long-term. Changes to 

subsistence harvest patterns caused by climate change could also disrupt the social organization in 

subsistence communities and impact harvest sharing activities. Serious declines in productivity could 

result in stresses within a community or between communities, affecting the way of life for the residents 

(NMFS, 2016d). 
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Climate change, with resultant loss of summer sea ice and open Northwest Passage and other shipping 

lanes, will likely attract visitors associated with recreation and tourism industries and encourage increase 

in commercial shipping along those routes. The addition of vessel traffic, especially cruise ship traffic, local 

traffic, and cargo ships could impede subsistence harvests, resulting in impacts similar to the ones 

described in detail in Section 4.2.10.1. 

As mentioned in Section 4.2.4.4, effects of climate change may include changes to the water temperatures 

and increased acidification of the ocean caused by dissolved carbon dioxide. These changes are expected 

to continue over the reasonably foreseeable future and would contribute to changes in the population 

and distribution of fishery resources harvested by subsistence communities. While the dynamics of 

climate change and the potential magnitude and timing of its effects are poorly understood, it is expected 

that rising temperatures and increase in ocean acidification would disrupt subsistence harvest patterns 

by decreasing the fish species available for harvest, disrupting the seasonality of harvest activities and 

locations of fishing areas, and inducing stress within or between communities by adversely impacting 

subsistence resource sharing activities.

Overall, climate change could lead to changes in diversity, abundance, and distribution of traditional 

subsistence resources and harvest patterns, leading to long-term impacts on the availability of some 

subsistence resources. This could potentially threaten indigenous lifestyle and subsistence practices 

(NMFS, 2016d). These impacts would occur regardless of the chosen alternative and could result in 

adverse and moderate to major impacts on EJ communities. The contribution of the NOS Proposed Action 

to these adverse, cumulative, climate-change related impacts on EJ communities would be negligible. 

4.2.10.3 Contamination of Subsistence Resources

Subsistence resources are currently stressed due to accidental leakage or spillage of oil, fuel, and 

chemicals and the unintentional disposal of trash and debris, though NOS does not contribute to these 

actions (see Section 3.15). Such events associated with any of the past, present, or reasonably foreseeable 

actions mentioned above, particularly offshore and OCS oil and natural gas development, construction 

and operation of offshore LNG terminals, and commercial fishing would further stress subsistence

resources. While not technically considered a cumulative impact to environmental justice communities, 

the additional stress that could occur to subsistence resources is noteworthy and is therefore described 

below. 

Contaminated resources, or those perceived to be contaminated, from an accidental oil, fuel, or chemical 

leak or spill could make subsistence resources unavailable or undesirable for use (BOEM, 2015b). For 

example, contamination from oil/chemical spills would render the affected subsistence resource unsafe 

to eat. If the skin or fur of the animal is coated with oil, that pelt would no longer be desirable to be made 

into coats and other handicrafts. Spill cleanup operations could result in the closure of harvesting areas 

until cleanup is complete. Any impacts to known archaeological or cultural sites from spill events would 

also result in adverse impacts to EJ communities in the affected region; these impacts are discussed 

further in Section 4.2.8 (BOEM, 2016).

Contaminated, or perceived contaminated, resources from marine debris could also render subsistence

resources undesirable for consumption if plastics and other marine debris are found in whales and other 

marine species. Contaminants present in small quantities may be deemed harmless, but may accumulate 

and have serious, long-term, and ongoing health consequences for subsistence communities and the 
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species they rely on for subsistence (MMS, 2007). Plastic debris could adsorb and concentrate potentially 

damaging toxic compounds from sea water, further contaminating subsistence resources (Gregory, 2009). 

Additionally, entanglement in commercial fishing debris such as trawl net webbing, plastic packing straps, 

ropes, and monofilament line could cause drowning, death from injury, starvation, and/or general 

debilitation of subsistence resources, making them less available to, or more difficult to harvest by 

subsistence hunters and fishers (NMFS, 2016d). 

Minority and low-income fishing communities, like the Louisiana Vietnamese fisherfolk community in the 

Gulf of Mexico region, would be particularly sensitive to any oil spill and related fishery closures. Further 

stress to the condition of fisheries in the region would interrupt access to subsistence-based activities and 

resources (BOEM, 2012). Similarly, in the North Slope region in Alaska, the contamination of waters with 

fuel, oil, antifreeze, and other chemicals from military and oil and gas development activities in the midto late-20th century period resulted in the avoidance of these sites by subsistence harvesters and disrupted 

subsistence harvest patterns by impacting several acres of subsistence species habitat (BOEM, 2015b). 

Aggregate cumulative impacts would be considered moderately adverse and the contribution of the NOS 

Proposed Action to these adverse cumulative effects would be negligible. 

4.2.10.4 New Mapping and Charting Information

Surveying and mapping activities under any of the three NOS alternatives would contribute to cumulative 

impacts from other surveying and mapping efforts in the action area associated with any of the past, 

present, or reasonably foreseeable actions mentioned above. In aggregate, these actions would lead to 

long-term beneficial cumulative impacts to environmental justice communities. The availability of new 

and updated charts, maps, and data would result in safer navigation, availability of better forecasts of 

weather and storm surge events that affect local communities, and historic wrecks. However, the 

availability of such information about previously uncharted areas, or regions that have not been recently 

surveyed, particularly the Alaska Region, would elicit interest that could result in additional projects in the 

area, such as greater surveying and mapping efforts and oil and gas exploration and development, which 

would have the same adverse impacts on EJ communities as those described in detail above. The overall 

cumulative impacts to subsistence activities from the availability of new mapping and charting 

information would be beneficial, long-term and minor, and the contribution of the NOS Proposed Action 

would also be beneficial, long-term, and minor. 

4.2.10.5 Conclusion

When considered in tandem with activities associated with the NOS Proposed Action, other surveying and 

mapping efforts in the action area, offshore oil and natural gas development, offshore renewable energy 

development, climate change, commercial shipping and recreational boating, assessment and extraction 

of marine minerals, offshore carbon storage resource assessments, construction and operation of 

offshore LNG terminals, national defense and homeland security activities, construction of new submarine 

telecommunication cable infrastructure, commercial and recreational fishing, and coastal development 

would create adverse and beneficial cumulative impacts to EJ communities. 

Adverse impacts would occur through a potential decrease in the total annual subsistence catch numbers 

of a species hunted by low-income or minority communities, or increase in the time required and distance 

traveled to harvest the same amount compared to previous years in which NOS surveying and mapping 

activities did not occur, or both (due to sound and visual disturbances generated by vessels, equipment 

and humans, climate change, and commercial and recreational fishing); reduced availability of fish, other 

marine species, or coral reefs important to subsistence cultures (due to IUU fishing); and contamination 
National Ocean Service Surveying and Mapping Projects in U.S. Waters for

Final Programmatic Environmental Impact Statement Coastal and Marine Data Acquisition

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of subsistence resources (due to accidental spills of oil, fuel, chemicals, and/or marine debris). Beneficial 

impacts would occur through the availability of new mapping and surveying data and would result in safer 

navigation and more accurate weather forecasts for subsistence harvesters. 

These past, present, and reasonably foreseeable future actions are expected to result in insignificant 

impacts to EJ communities. Overall, the adverse cumulative impacts of all actions described in Section 4.1 

affecting the ability of EJ communities to secure subsistence resources are minor to moderate. The 

beneficial cumulative impacts from those actions resulting in higher quality data pertaining to 

hunting/fishing resources, navigation, and weather conditions are minor. These impacts would therefore 

be insignificant.

Cumulative impacts from any of the alternatives in combination with the cumulative effects scenario could 

potentially be considered either synergistic or additive depending on the timing, location of activities and 

impacts, and the communities impacted. Synergistic impacts could result if any activities or actions occur 

in close spatial or temporal proximity within the study area. Similarly, additive cumulative impacts to EJ 

communities could occur if activities or actions are conducted sequentially within adjacent areas of the 

study area. Although the exact timing and location of projects have not been finalized and are subject to 

change, the Southeast and Alaska regions contain the largest proportion of total miles of vessel movement 

in the EEZ (Section 2.4.1) and relatively high levels of marine oil and gas development. Therefore, 

synergistic or additive cumulative impacts are most likely to occur in either of these regions. For example, 

cumulative, adverse impacts would be synergistic and additive if activities producing sound and visual 

disturbances under the Proposed Action, oil and gas exploration in the Alaska region and the increased 

surveying and mapping associated with offshore and OCS oil and natural gas development, commercial 

shipping in the Northwest Passage, as well as other actions including the operation and presence of 

vessels, equipment, and humans take place at the same time in the Alaska region. Impacts to subsistence

hunting or fishing patterns that affect the availability and/or the quality of subsistence resources, 

community sociocultural practices and systems would be synergistic and additive. Additive beneficial 

impacts would occur in terms of better information pertaining to hunting/fishing resources, navigation, 

and weather conditions. The NOS Proposed Action would contribute to and have the potential to increase 

these cumulative impacts, but their relative contribution would be negligible as compared to the 

aggregate contributions of other cumulative actions because the NOS impacts would be temporary or 

short-term, would be confined to the immediate vicinity of project areas, and would be small as compared 

to impacts from all other cumulative actions. These impacts would occur regardless of the chosen 

alternative since projects under each alternative would be composed of similar activities and take place 

in the same geographic areas and timeframes; however, Alternatives B and C would be expected to have 

slightly higher cumulative impacts because these alternatives include more projects, activities, and 

nautical miles traveled than Alternative A.