THE SHELL LEAKS FILES: 4 SEPTEMBER 2026
SLF-2007-047
The Sakhalin Papers XXXVII: The Survey They Could Not Control — Rosneft, Twelve Governments and the Seismic Guns in the Whale Feeding Season
Sakhalin Energy’s own 2010 seismic survey had been postponed for a year, redesigned with independent scientists and subjected to real-time shutdown rules. Then another operator entered the same whale habitat. IUCN appealed to Vladimir Putin. The International Whaling Commission recommended postponement. A British-coordinated approach brought together twelve governments. Russia concluded that Rosneft’s own mitigation arrangements required no additional measures. The survey went ahead. Months later, the independent Western Gray Whale Advisory Panel examined acoustic records and found sound levels it considered capable of disturbing feeding whales — and inferred that parts of the feeding area may have experienced levels potentially capable of damaging hearing.
Archive reference: SLF-2007-047
Collection: The Sakhalin Papers
Principal scientific record: Western Gray Whale Advisory Panel, Report of the Ninth Meeting, Geneva, 3–6 December 2010
Principal government/scientific correspondence: WGWAP letter to Rinat Gizatulin, Russian Ministry of Natural Resources and Environment, 19 April 2010; IUCN appeal to Russian Prime Minister Vladimir Putin, May 2010; International Whaling Commission 62nd Annual Meeting record, June 2010
Authenticated Shell record: Royal Dutch Shell plc Sustainability Report 2010
Contemporaneous reporting: The Guardian, 14 July 2010; AFP, 24 June 2010; WWF material issued 7 September 2010
Court record: Export Credits Guarantee Department v Friends of the Earth [2008] EWHC 638 (Admin), used here solely for the earlier Sakhalin II environmental and public-finance context
Evidence standard: Measured acoustic data are distinguished from inferred exposure levels. NGO observations concerning whale displacement are identified as preliminary allegations, not established causation. The Russian government’s regulatory position is recorded alongside the WGWAP assessment. No court ruling identified for this instalment determined that Rosneft’s 2010 survey was unlawful.
Introduction
The previous Shell Leaks File examined a rare example of an environmental protection system directly constraining an industrial operation.
Sakhalin Energy’s Astokh 4-D seismic survey was conducted under an unusually elaborate monitoring programme.
The scientists helped design it.
Marine Mammal Observers could stop it.
And they did.
Four times.
Shell subsequently acknowledged in its own Sustainability Report that seismic operations had been shut down when whales were nearby. Shell identified its Sakhalin II interest at the time as 27.5 per cent. (Shell)
That was one company.
One survey.
One set of rules.
The whales, however, occupied a much larger marine environment.
And during the same summer, another seismic programme was approaching.
This one was associated with Rosneft’s Lebedenskoye licence area, north of the mouth of Piltun Lagoon, within the principal feeding habitat used by Western Gray Whales and particularly important to mothers and calves. (IUCN Cetacean Specialist Group)
WGWAP had no equivalent operational relationship with Rosneft.
That difference would expose one of the central weaknesses in the entire Sakhalin conservation structure.
WGWAP had been worried about Lebedenskoye since 2007
The December 2010 WGWAP report records that the Panel first learned in April 2007 of Rosneft’s proposal to conduct seismic work in the Lebedenskoye licence area.
The survey was originally expected in 2008.
It was delayed.
By 2010 it was back.
And the Panel said its concern had never gone away.
Its reports had repeatedly warned that a nearshore seismic survey in that location could cause significant disturbance to feeding whales and potentially direct harm, with particular concern for mothers and calves using the Piltun feeding area. (IUCN Cetacean Specialist Group)
The geography mattered.
This was not simply another survey somewhere on the Sakhalin shelf.
It was planned inside an area the scientists regarded as biologically critical.
19 April 2010: the warning was put in writing
On 19 April 2010, WGWAP chairman Randall Reeves wrote formally to Rinat Gizatulin, a senior official at Russia’s Ministry of Natural Resources and Environment.
The letter is unusually direct.
It said the Panel understood that the Lebedinskoye survey — spelling varies in the surviving English-language documents — would begin soon after Sakhalin Energy completed its Astokh survey and continue through much of the remainder of the summer.
The comparison with Sakhalin Energy was explicit.
WGWAP described Sakhalin Energy’s Astokh operation as supported by a rigorously designed, comprehensive monitoring and mitigation programme.
For Lebedinskoye, it said that no evidence then available to the Panel showed a similarly precautionary approach and that it had not been provided with information about the proposed monitoring and mitigation measures. (IUCN Cetacean Specialist Group)
The Panel therefore recommended postponement until at least 2011.
Its stated reason was not that seismic surveying must never occur.
It wanted time for a credible protection programme to be developed.
That distinction is important.
The scientists offered Rosneft the same expertise used by Sakhalin Energy
The April letter did not simply demand cancellation.
WGWAP offered assistance.
Its message was essentially:
wait a year, move the operation earlier in the season, and build a serious protection system first.
The Panel even offered to help develop that programme.
It highlighted features already incorporated into Sakhalin Energy’s Astokh plan — including safety buffers and real-time acoustic and visual monitoring intended to prevent dangerous sound exposure. (IUCN Cetacean Specialist Group)
This makes the later controversy harder to dismiss as a simplistic anti-industry campaign.
The Panel had already demonstrated that it was prepared to work with an oil and gas operator to make a seismic programme proceed.
It was not asking Rosneft to abandon exploration permanently.
It was asking Rosneft to adopt the same precautionary logic.
The concern reached Vladimir Putin
The Russian ministry did not end the dispute.
On 24 May 2010, IUCN escalated the matter publicly.
Its Director General, Julia Marton-Lefèvre, wrote to Russian Prime Minister Vladimir Putin urging government intervention.
IUCN described the proposed Rosneft 3-D survey as the greatest immediate threat then facing the Western Gray Whale population because of the risk of disturbing feeding and nursing.
The timing was central.
The survey was expected to begin in late July — just as large numbers of whales were arriving in the area to feed — and continue through much of the critical feeding season. (IUCN)
IUCN again recommended postponement for at least one year and conducting any later survey as early as practicable in the open-water season.
That was precisely the strategy followed for Sakhalin Energy.
Why the season mattered so much
Western Gray Whales do not feed continuously throughout the year.
The waters off northeastern Sakhalin function as a crucial seasonal feeding area.
The animals must accumulate energy reserves before undertaking long migrations.
Mothers and calves were of particular concern because of the reproductive importance of that small component of an already tiny population.
At the time, the International Whaling Commission described the population as numbering only about 130 animals. IUCN’s contemporary estimate was approximately 135, including roughly 30–35 reproductive females. (International Whaling Commission)
That is why the seemingly mundane question of June versus August became biologically important.
Sakhalin Energy had been pushed to operate early.
Rosneft was preparing to operate later.
The International Whaling Commission intervened
The concern was not confined to IUCN.
At the International Whaling Commission’s annual meeting in Agadir in June 2010, its Scientific Committee formally addressed the Rosneft proposal.
The official IWC record says the Committee strongly recommended postponement until the following year because the survey was planned for an area of high whale density. (International Whaling Commission)
Contemporaneous AFP reporting on 24 June 2010 described the warning in still sharper terms.
The IWC scientists were particularly concerned that Rosneft intended to operate when the largest numbers of feeding whales — including mothers and calves — would be present.
Delegates from the United States, Mexico, Britain and other countries supported postponement.
A Russian negotiator nevertheless indicated that the work was likely to proceed. (Phys.org)
The dispute had now moved beyond scientific correspondence.
It had become an international diplomatic issue.
Britain coordinated a twelve-government approach
On 14 July 2010, The Guardian reported that British officials had coordinated a joint diplomatic letter to Russia.
Representatives of twelve countries were involved — Britain plus eleven others.
The newspaper specifically identified France, Germany and the United States among the signatories.
The governments asked Russia to consider postponement because the proposed survey coincided with the critical feeding season. (The Guardian)
This contemporary report is significant because later references to “twelve governments” are sometimes repeated without explaining their origin.
There really was a multi-government intervention.
But care is still required.
The surviving material examined for this file does not provide a complete verified list of all twelve signatories.
Accordingly, only the countries expressly identified in the contemporary reporting are named here.
The Russian ministry took a different view
WGWAP’s December report records the Russian government’s response.
The Ministry of Natural Resources reviewed Rosneft’s submitted monitoring and mitigation plan.
It concluded that no further measures were necessary to protect the whales. (IUCN Cetacean Specialist Group)
That is an important part of the record and should not be omitted.
The story is not that Rosneft simply carried out an operation in total regulatory absence.
Rosneft had submitted a protection plan.
The relevant Russian ministry reviewed it.
The ministry decided that further measures were not required.
The later WGWAP analysis reached a much more troubling scientific assessment.
Those are two different institutional judgments.
Both belong in the historical record.
The survey went ahead
By December 2010, there was no longer any doubt about the outcome.
The Lebedenskoye seismic survey had been carried out during the summer and autumn.
WGWAP’s acoustic data indicated that the first seismic activity occurred around 18 August 2010, intermittently at first, then regularly through at least 27 September, which was the final date covered by the data presented to the Panel.
The Panel was told that the operation reportedly continued into November. (IUCN Cetacean Specialist Group)
That last point should be treated cautiously.
The Panel had direct acoustic evidence through late September.
Continuation into November was reported to it.
The public record examined here does not establish continuous seismic acquisition throughout the entire period.
WWF observers were already raising alarms
On 7 September 2010, WWF issued a highly critical account of what its observers said they were seeing.
It alleged that before Rosneft’s activities began, observers had been recording roughly 10–15 whales feeding in the area.
After work started, WWF said whales were being observed passing through rather than feeding.
It argued that the animals might have been displaced. (Science Daily)
That was a serious allegation.
It was not yet a scientific conclusion.
WWF’s observers were conducting field monitoring, but the later WGWAP report explicitly noted that the sample size was small and treated reports of whale displacement as preliminary evidence requiring further investigation. (IUCN Cetacean Specialist Group)
This distinction is essential.
The historical record establishes that NGOs reported an apparent change.
It does not establish from those observations alone that Rosneft caused the whales to stop feeding.
The night-time allegation was different
WWF also alleged something more concrete.
It said seismic acquisition had occurred at night, despite restrictions in Rosneft’s own monitoring and mitigation arrangements. (Science Daily)
When WGWAP reviewed the matter in December, it recorded the NGO allegation that Rosneft had violated its own plan by acquiring seismic data at night.
But here the Panel had another source of evidence.
Acoustic recordings presented at the meeting showed that seismic pulses did in fact occur at night. (IUCN Cetacean Specialist Group)
That does not by itself establish every element of a regulatory breach.
The Panel was not a court.
But it provides independent corroboration for the factual core of the NGO allegation:
the airgun pulses were occurring during night-time periods.
Then came the acoustic evidence
This is the most serious part of the documentary record.
Alexander Rutenko presented WGWAP with acoustic measurements from several buoys operated under the Sakhalin Energy–Exxon Neftegas joint monitoring programme.
Those sensors were not all inside the Lebedenskoye licence area.
Yet the Panel said sound recorded even outside the licence area exceeded levels previously associated with behavioural disturbance of feeding gray whales. (IUCN Cetacean Specialist Group)
From that evidence, WGWAP reasoned that sound exposure inside the feeding area must at times have been higher still.
That conclusion was partly measurement and partly inference.
The distinction matters.
WGWAP went further — but carefully
The Panel then made a particularly grave assessment.
Based upon the assumed location of the seismic vessel somewhere within the licence area, its distance from the monitoring buoys and the acoustic levels actually recorded, WGWAP concluded that portions of the nearshore feeding area were likely to have experienced sound levels expected under the scientific criteria it cited to cause hearing damage in gray whales. (IUCN Cetacean Specialist Group)
That wording must not be converted into a claim the documents do not support.
The Panel did not report finding an injured whale.
It did not identify an individual animal with documented hearing loss.
It did not prove that a particular whale received a particular acoustic dose.
It made a scientific inference about likely exposure levels in portions of habitat.
That is serious enough without embellishment.
The Panel did not declare the displacement allegation proven
WGWAP displayed similar caution over the NGO observations.
Its report said the NGO sample was small.
The NGO authors believed whales had been displaced.
The Panel described the available observations as preliminary and anecdotal.
It therefore called for statistical analysis of whale-distribution data alongside the acoustic record before reaching a firmer conclusion. (IUCN Cetacean Specialist Group)
That is exactly how this archive should treat the issue.
Noise exposure: documented.
Levels above recognised disturbance criteria at monitoring locations: documented in the WGWAP assessment.
Higher exposure inside portions of feeding habitat: scientific inference by WGWAP.
Whale displacement caused by the survey: alleged and plausible enough to warrant investigation, but not established by the material reviewed at that meeting.
WGWAP wanted Rosneft’s own acoustic data
There was another important evidential problem.
WGWAP learned that three acoustic sensors had been deployed in the Lebedenskoye area on Rosneft’s behalf.
The Panel wanted those data.
It recommended that IUCN obtain the resulting reports either directly from Rosneft or through the Russian government’s interdepartmental working group. (IUCN Cetacean Specialist Group)
That request tells us something about the limitations of WGWAP’s assessment.
Its alarming conclusions were based substantially on acoustic sensors operated through the Sakhalin Energy–Exxon monitoring network.
Rosneft apparently possessed another dataset closer to its own operation.
At the December meeting, WGWAP did not yet have it.
A rigorous archive must state that limitation.
A third seismic survey appeared almost simultaneously
Rosneft was not the only problem.
WGWAP also discovered evidence of another offshore seismic survey conducted between approximately 15 August and 9 September 2010.
The Panel was told it was apparently undertaken on behalf of Gazprom, although it expressly said that could not be confirmed at the meeting.
An acoustic sensor known as “Orlan” recorded sound levels that WGWAP described as well above those known to disturb feeding gray whales. (IUCN Cetacean Specialist Group)
Sakhalin Energy itself apparently learned of that activity during offshore sampling and informed the Panel chairman.
Even the institute operating the acoustic equipment had reportedly not been notified beforehand. (IUCN Cetacean Specialist Group)
That revelation transformed the problem.
It was no longer about one survey.
It was about cumulative industrial noise across a feeding range.
Three surveys, three parts of the feeding range
WGWAP’s December conclusion was stark.
Three seismic surveys had occurred in or near three different parts of the Western Gray Whale feeding range during 2010.
The Panel said that, from the material it had reviewed, only Sakhalin Energy’s Astokh 4-D survey appeared to have been conducted with a robust monitoring and mitigation programme designed to minimise prolonged intense noise exposure. (IUCN Cetacean Specialist Group)
That is an unusually strong independent comparison.
It also places Shell’s authenticated Sustainability Report in a different light.
Shell had publicly recorded the occasions on which the Sakhalin Energy survey was shut down to protect whales. (Shell)
WGWAP was now saying that the same standard apparently did not apply uniformly across neighbouring operations.
This was the structural weakness of the whole system
WGWAP could advise Sakhalin Energy because a formal relationship existed.
It could negotiate survey plans.
It could request data.
It could require the company to explain whether recommendations were accepted or rejected.
Lenders could observe the process.
Sakhalin Energy could empower Marine Mammal Observers to stop its airguns.
But WGWAP could not issue a legally binding order to Rosneft.
It could not compel another operator to adopt the Astokh protection programme.
It could not prevent Russia’s competent authorities from approving a different approach.
And it could not coordinate an entire industrial region through a bilateral relationship with one company.
The whales experienced the acoustic environment as a whole.
The governance system remained fragmented by corporate and regulatory boundaries.
Shell was not responsible for Rosneft’s survey
That boundary must also be respected.
Royal Dutch Shell held a minority interest in Sakhalin Energy.
Rosneft was a separate Russian oil company.
Nothing in the records examined for this instalment establishes that Shell directed, approved, controlled or participated in Rosneft’s Lebedenskoye seismic operation.
Indeed, the WGWAP evidence points in a different direction.
Sakhalin Energy’s monitoring network helped generate some of the acoustic evidence later used to assess Rosneft’s activity.
And Sakhalin Energy’s own seismic programme was cited by the Panel as the example of the more robust mitigation approach. (IUCN Cetacean Specialist Group)
This instalment belongs in The Shell Leaks Files because it exposes the limits of the conservation framework built around the Shell-linked Sakhalin II project.
It is not evidence that Shell operated the Rosneft survey.
Nor does the record justify pretending Sakhalin Energy was environmentally flawless
The converse would also be wrong.
WGWAP’s praise for the Astokh seismic mitigation programme did not mean that it endorsed every aspect of Sakhalin Energy’s environmental record.
At the same December meeting, the Panel criticised Sakhalin Energy’s proposed reduction in whale behaviour monitoring and described the move as puzzling at a time when the company was contemplating expansion of its industrial footprint. (IUCN Cetacean Specialist Group)
The Panel had a continuing record of disagreement with Sakhalin Energy.
That is precisely why its favourable comparison of the 2010 Astokh mitigation programme carries weight.
It was not uncritical of the company.
The English High Court case remains relevant — but only as background
Two years earlier, Sakhalin II’s environmental controversies had reached the English High Court through litigation over disclosure of environmental information held by Britain’s Export Credits Guarantee Department.
In Export Credits Guarantee Department v Friends of the Earth [2008] EWHC 638 (Admin), Mr Justice Mitting dealt with access to information generated during consideration of proposed UK financial support for Sakhalin II.
That litigation helped document how seriously Western Gray Whale concerns had entered the international public-finance process.
But the case does not establish anything about Rosneft’s 2010 survey.
The High Court did not review Lebedenskoye.
It did not rule on Rosneft’s mitigation plan.
It did not determine whether night-time seismic acquisition violated Russian law.
It did not adjudicate the WGWAP acoustic conclusions.
The court record supplies historical context.
It is not being used here as evidence of Rosneft liability.
Documentary Findings
Established
WGWAP had raised concerns about the proposed Rosneft Lebedenskoye seismic survey since 2007 and regarded the location as especially sensitive because it overlapped Western Gray Whale feeding habitat used by mothers and calves. (IUCN Cetacean Specialist Group)
On 19 April 2010, WGWAP formally urged a Russian environmental official to postpone the survey until at least 2011, saying that it lacked evidence of a monitoring and mitigation programme comparable with the one developed for Sakhalin Energy. (IUCN Cetacean Specialist Group)
On 24 May 2010, IUCN publicly appealed to Prime Minister Vladimir Putin to intervene and postpone the survey. (IUCN)
In June 2010, the International Whaling Commission Scientific Committee strongly recommended postponement until the following year. (International Whaling Commission)
Contemporaneous reporting records that British officials coordinated a diplomatic approach involving twelve governments, with France, Germany and the United States among those identified. (The Guardian)
The Russian Ministry of Natural Resources reviewed Rosneft’s monitoring and mitigation plan and concluded that no additional whale-protection measures were required. (IUCN Cetacean Specialist Group)
The Lebedenskoye seismic survey nevertheless proceeded during the summer and autumn of 2010.
WGWAP acoustic records indicated survey activity beginning around 18 August and continuing through at least late September, with later continuation reported to the Panel. (IUCN Cetacean Specialist Group)
The WGWAP assessment found acoustic levels at monitoring sites outside the licence area above levels associated in the cited scientific literature with disturbance of feeding gray whales. (IUCN Cetacean Specialist Group)
Acoustic records presented to WGWAP showed seismic pulses occurring at night. (IUCN Cetacean Specialist Group)
WGWAP Scientific Inference
From the measured sound levels, distance to the likely survey-vessel location and established acoustic criteria, WGWAP inferred that sound levels within portions of the feeding area would at times have been substantially higher.
The Panel further considered it likely that some nearshore areas experienced levels expected under the scientific criteria it cited to be capable of causing hearing damage. (IUCN Cetacean Specialist Group)
This was a scientific inference about acoustic exposure.
It was not a clinical finding of hearing damage in an identified whale.
NGO Allegations
WWF and other NGO observers alleged that feeding whales became less numerous in the survey area after industrial activity began and suggested that whales had been displaced.
They also alleged night-time seismic acquisition contrary to Rosneft’s own mitigation arrangements. (Science Daily)
WGWAP treated the displacement evidence as preliminary because of the small sample and requested further statistical investigation.
The separate factual proposition that seismic pulses occurred at night was supported by acoustic records presented at the Panel meeting. (IUCN Cetacean Specialist Group)
Not Established
It is not established from the material examined for this file that Rosneft’s survey caused permanent hearing damage to an individual Western Gray Whale.
It is not established that the observed changes reported by NGOs were caused solely by the Lebedenskoye survey.
It is not established that Shell controlled or participated in Rosneft’s seismic operation.
It is not established that a court declared the Lebedenskoye survey unlawful.
It is not established that WGWAP possessed legal authority to stop Rosneft’s work.
It is not established that the complete Rosneft acoustic-monitoring dataset was available to WGWAP when it made its December 2010 assessment.
And the apparent Gazprom-linked seismic operation discussed by the Panel was expressly described as unconfirmed as to operator at the meeting. (IUCN Cetacean Specialist Group)
Commentary
This episode exposes the difference between corporate environmental management and ecosystem environmental management.
Sakhalin Energy had a sophisticated whale-protection system.
That mattered.
Its seismic guns were shut down four times.
Its survey was timed early.
Its scientists had years of data.
Its observers had operational authority.
Shell even recorded the shutdowns in its own Sustainability Report. (Shell)
Then the whales moved through the same sea while another seismic survey operated under a different system.
The biology did not reset at the edge of the lease.
That was the fundamental problem.
A whale protected from Sakhalin Energy’s airguns on one day could encounter Rosneft’s sound field later in the season.
It could then encounter noise from yet another survey elsewhere in the feeding range.
From the whale’s perspective, there were no corporate boundaries.
There was only cumulative exposure.
WGWAP understood this.
Its December report explicitly warned about the cumulative effects of multiple seismic surveys and complained that it often lacked even basic advance information about what other companies were doing on the Sakhalin shelf. (IUCN Cetacean Specialist Group)
That may be the most important finding in this instalment.
The celebrated Sakhalin Energy mitigation programme was real.
So was its limitation.
It could control Sakhalin Energy.
It could not control Sakhalin.
The diplomatic history sharpens the point.
An international conservation organisation appealed directly to Vladimir Putin.
The International Whaling Commission’s scientists recommended postponement.
Twelve governments intervened.
The Russian ministry considered Rosneft’s submitted plan and concluded that nothing more was required.
The survey happened.
Months later, WGWAP examined acoustic evidence and reached a much more disturbing view of the likely sound exposure.
None of that proves deliberate environmental wrongdoing.
It proves something more structurally significant.
The institutions looking at the same risk were applying very different standards.
And while they disagreed, the airguns were firing.
There is a final irony.
WGWAP had just spent years showing that oil exploration and independent whale science did not have to be mutually exclusive.
The Panel had helped Sakhalin Energy redesign and eventually conduct a seismic survey.
It was willing to do the same for Rosneft.
The request was essentially procedural and precautionary:
wait;
move the timing;
develop proper monitoring;
and then proceed.
Rosneft’s survey went ahead without that WGWAP process.
That does not establish that every WGWAP recommendation was necessarily correct.
It does demonstrate why voluntary environmental governance tied to one operator cannot by itself manage a shared ecosystem.
And the cumulative problem was about to become even larger.
Because even as WGWAP was documenting the uncontrolled surveys of 2010, Sakhalin Energy was preparing to expand again.
This time it was not another temporary seismic campaign.
It was considering a third offshore platform.
Source Record
The principal primary source is the Western Gray Whale Advisory Panel, Report of the Ninth Meeting, 3–6 December 2010. It records the history of concern over Lebedenskoye, the Russian ministry’s response, the acoustic evidence from the Rosneft survey, the night-time seismic pulses, preliminary NGO observations, the additional offshore survey and WGWAP’s warning about cumulative impacts. (IUCN Cetacean Specialist Group)
WGWAP Report of the Ninth Meeting — December 2010
The 19 April 2010 letter from WGWAP chairman Randall Reeves to Rinat Gizatulin of the Russian Ministry of Natural Resources and Environment documents the Panel’s pre-survey concern, its comparison with the Sakhalin Energy protection programme and its recommendation that Lebedenskoye be postponed until at least 2011. (IUCN Cetacean Specialist Group)
WGWAP letter to the Russian Ministry — 19 April 2010
The IUCN press release of 24 May 2010 records Director General Julia Marton-Lefèvre’s appeal to Vladimir Putin, the biological reasoning behind the request and the recommendation to postpone Rosneft’s survey for at least a year. (IUCN)
IUCN — Seismic threat to Critically Endangered whales, 24 May 2010
The official International Whaling Commission record of its 62nd Annual Meeting confirms that the Scientific Committee strongly recommended postponement of the Rosneft survey until the following year. (International Whaling Commission)
Contemporaneous AFP reporting dated 24 June 2010 records the IWC scientists’ concern that the survey would occur when the highest numbers of feeding whales, including mothers and calves, were present and records international support for postponement. (Phys.org)
Contemporaneous Guardian reporting dated 14 July 2010 records that British officials coordinated a joint letter involving representatives of eleven other governments, including France, Germany and the United States. (The Guardian)
The Guardian — Russia urged to halt oil survey during rare whale feeding season, 14 July 2010
The authenticated Shell record is the Royal Dutch Shell plc Sustainability Report 2010. It records Shell’s 27.5 per cent Sakhalin II interest and states that Sakhalin Energy seismic operations were shut down several times when whales were nearby following advice from WGWAP scientists. (Shell)
WWF’s 7 September 2010 material supplies the contemporaneous NGO account of alleged changes in feeding observations and alleged night-time seismic acquisition. Those claims are treated here as NGO evidence and are not converted into judicial or scientific findings. (Science Daily)
The earlier English judicial record remains Export Credits Guarantee Department v Friends of the Earth [2008] EWHC 638 (Admin). It is included solely as background to the broader Sakhalin II environmental scrutiny. It did not adjudicate Rosneft’s 2010 seismic activity.
Archive disclaimer: Acoustic measurements, WGWAP scientific inference, NGO field observations, Russian regulatory conclusions and Shell corporate statements are distinguished according to source. No finding is made here that an individual whale suffered proven hearing damage as a result of the Rosneft survey. No allegation concerning night-time operations is characterised as a court-proven regulatory offence. Shell is not attributed responsibility for Rosneft’s survey.
Site wide disclaimer also applies.
Next Archive File
SLF-2007-048 — The Sakhalin Papers XXXVIII: The Third Platform — When Sakhalin Energy Planned PA-C Before the Scientists Had Finished Assessing the Last Round of Disturbance
At the same December 2010 meeting where WGWAP was trying to understand three different seismic surveys across the whale feeding range, Sakhalin Energy introduced another proposal.
South Piltun.
A new offshore platform.
Its working designation:
PA-C.
The proposed structure would sit roughly halfway between the existing PA-A and PA-B platforms, filling a gap in hydrocarbon recovery that Sakhalin Energy said could not be reached efficiently from the existing installations. (IUCN Cetacean Specialist Group)
The scientists were immediately uneasy.
They had expected industrial activity to diminish after completion of PA-B construction and the 2010 Astokh seismic survey.
Instead, the footprint was about to expand again.
And WGWAP pointed out something uncomfortable:
the full effects of earlier construction activity had not yet been definitively resolved.
Its recommendation was explicit.
Construction of the third platform should not begin until there was a better understanding of noise effects on the whales and appropriate mitigation measures were in place. (IUCN Cetacean Specialist Group)
The Panel also warned against assessing each new project in isolation.
Oil spills.
Vessel traffic.
Continuous noise.
Seismic surveys.
Benthos disturbance.
Construction.
Permanent infrastructure.
All of it had to be considered together.
The phrase WGWAP would invoke for the growing problem was striking:
“urban whale syndrome.” (IUCN Cetacean Specialist Group)
SLF-2007-048 will examine Sakhalin Energy’s third-platform proposal, the scientists’ demand that construction wait, the unresolved evidence from PA-B, and the moment the debate shifted from protecting whales from individual projects to asking whether the entire Sakhalin shelf was becoming too industrialised for the population to recover.
*This website and sisters royaldutchshellgroup.com, shellnazihistory.com, royaldutchshell.website, johndonovan.website, shellnews.net, and shellwikipedia.com, are owned by John Donovan - more information here. There is also a Wikipedia segment, the Shell DPA Files, "Shell and the Spies", the Shell Leaks files, the Independent Shell Archive, as well as books written and published by John Donovan - Kindle eBooks. Timeline of the Donovan Shell Feud. Toxic History of Royal Dutch Shell Group. Shell and the Donovans: The Full Media Record — 550+ Articles, 110 Books, 40 Years. *All conjured up by internet wizz, Nick Gill.
