THE SHELL LEAKS FILES: 9 SEPTEMBER 2026
SLF-2007-052
The Sakhalin Papers XLII: The Airguns Return — How One 4-D Survey Became a Cumulative-Acoustic Crisis
Sakhalin Energy began planning its next Piltun-Astokh 4-D seismic survey as a reservoir-management exercise. By May 2015, the Western Gray Whale Advisory Panel was confronting something much larger. Exxon Neftegas and Rosneft also intended major seismic programmes. The independent scientists warned that almost the entire nearshore feeding and nursery habitat could be exposed to industrial noise, questioned whether all the surveys should proceed in the same season, and ultimately issued a formal Statement of Concern. Sakhalin Energy did not accept postponement — but neither did it simply ignore the Panel. The documentary record shows negotiation, redesign, reduced source strength, coordination between companies, and a fundamental disagreement over how much cumulative disturbance was acceptable.
Archive reference: SLF-2007-052
Collection: The Sakhalin Papers
Principal primary records: Western Gray Whale Advisory Panel, Report of the Fifteenth Meeting, 8–9 December 2014; WGWAP Statement of Concern, 8 May 2015
Supporting technical records: WGWAP Noise Task Force reports, 2013–2015; Sakhalin Energy response to WGWAP Statement, 23 May 2015
Authenticated Shell record: Royal Dutch Shell plc Annual Report and Form 20-F 2014
Contemporaneous public record: IUCN, Keeping whales safe in sound, 20 January 2014; Sakhalin Energy public response, May 2015
Court record: Export Credits Guarantee Department v Friends of the Earth [2008] EWHC 638 (Admin), used solely for the earlier Sakhalin II environmental and public-finance context
Evidence standard: WGWAP recommendations are identified as independent scientific advice, not regulatory orders. Sakhalin Energy’s technical and commercial explanations are identified as company positions. Exxon Neftegas and Rosneft were separate operators; nothing in the records examined establishes that Shell controlled their seismic programmes. Later scientific findings are distinguished from what was known before the 2015 surveys began.
Introduction
The previous instalment ended with a warning.
Sakhalin Energy had kept PA-C alive as a future option.
Its 2014 appraisal well had disappeared.
But another major operation was moving steadily toward the northeastern Sakhalin shelf.
A 4-D seismic survey.
The purpose was not simply exploration.
Sakhalin Energy said repeated seismic imaging was required to monitor changes in the producing Piltun-Astokh reservoirs — tracking hydrocarbon extraction and water injection and helping plan future production wells from existing infrastructure. (IUCN Cetacean Specialist Group)
The technical logic was straightforward.
Take a seismic image.
Produce oil and gas.
Take another image years later.
Compare them.
See how the reservoir has changed.
But what makes 4-D seismic commercially valuable also makes it environmentally unusual.
It comes back.
1. The 2015 survey was much larger than the 2010 pilot
The earlier 2010 Astokh 4-D survey had become a celebrated example of seismic mitigation.
In January 2014 IUCN publicly described the monitoring and mitigation programme developed with Sakhalin Energy as one of the most comprehensive yet devised for a seismic survey near vulnerable marine mammals. The approach combined modelling, acoustic monitoring, whale observation and operational shutdown rules. (IUCN)
That success mattered because the next survey was larger.
By December 2014, the planned Piltun-Astokh 4-D programme covered approximately 350 square kilometres, with another approximately 290 square kilometres at Lunskoye. WGWAP recorded that the scale and scope of the planned work were substantially greater than the 2010 Astokh pilot.
The old mitigation system could therefore not simply be copied without reconsideration.
The operation had changed.
And soon the industrial environment around it changed as well.
2. Early completion was the central protection strategy
Years of WGWAP work had produced one particularly important principle:
finish seismic acquisition before large numbers of whales arrive.
The whales congregated off northeastern Sakhalin during the ice-free season to feed.
The Panel therefore regarded an early start — as soon as sea-ice conditions allowed — as the single most important timing-based mitigation measure.
Its modelling assumed that whale abundance would rise through June and July toward a seasonal plateau. Completing the survey early potentially meant exposing fewer animals overall.
That created an uncomfortable trade-off.
A highly restrictive shutdown regime protects individual whales when they appear near the acoustic footprint.
But repeated shutdowns prolong the survey.
A longer survey can expose more whales later in the season.
The scientists were therefore balancing two different conservation objectives:
protect the whale immediately in front of the operation;
and minimise cumulative exposure of the population.
There was no mathematically perfect answer.
3. Even the shutdown rules became controversial
In the 2010 survey, behavioural protection extended broadly to whales exposed above the agreed disturbance threshold.
For 2015, a relaxation was considered.
Before mid-July, the proposed rule would give special mandatory shutdown protection at the behavioural threshold to mother-calf pairs, rather than automatically stopping for every whale.
The reason was the same population-level trade-off: avoiding excessive interruptions so that the survey could be completed earlier.
But WGWAP stressed that this relaxation must not become a precedent.
And it insisted that if a mother and calf were detected within the relevant exposure zone, the seismic source must be shut down even if doing so meant some survey lines could not be completed. Sakhalin Energy accepted that condition.
This is a useful example of what the WGWAP process actually involved.
It was not a simple argument between:
survey
and
no survey.
Scientists and engineers were debating how many whales should trigger shutdowns, at what sound level, during which part of the season, and with what effect on total exposure.
4. The airgun array itself became another issue
Earlier planning had assumed a source broadly comparable with the 2,620 cubic-inch array used in 2010.
By November 2014, however, the selected tender involved a larger 3,255 cubic-inch source.
Sakhalin Energy’s acoustic modelling nevertheless suggested that the actual directional acoustic output could be lower than that produced during the 2010 operation.
WGWAP did not simply accept the nominal cubic-inch number as the answer.
The Panel examined the modelling and ultimately concluded that it was adequate for pre-survey planning — but insisted that actual sound levels must be measured in the field before full acquisition proceeded.
If reality differed materially from the model, mitigation arrangements would have to change.
That distinction matters.
Airgun volume is not identical to received acoustic exposure.
Array configuration, directionality, propagation conditions and water depth all matter.
But modelling is still modelling.
The Panel wanted verification.
5. Sakhalin Energy was investigating a quieter technological future
One potentially important alternative was Ocean Bottom Node — OBN — technology.
Instead of relying solely on conventional streamer acquisition, sensors positioned on the seabed could potentially allow future reservoir monitoring using smaller acoustic sources.
The concept mattered because successful OBN deployment might reduce — or eventually eliminate — the need for repeated large streamer surveys.
Originally, Sakhalin Energy considered obtaining baseline OBN data during the 2015 operation.
That did not happen.
The company told WGWAP that OBN would not be deployed in 2015 for logistical and/or cost reasons, with a smaller baseline programme then under consideration for a later season.
WGWAP understood the significance immediately.
If the quieter technology could work, why continue repeating the more acoustically intrusive survey?
Its December 2014 conclusion included a direct recommendation that Sakhalin Energy and the other operators reconsider whether further full streamer surveys were really necessary.
6. Then Exxon appeared in the same season
This changed everything.
WGWAP had begun working on Sakhalin Energy’s 2015 mitigation programme in October 2013.
It was not until October 2014 that the Panel learned that Exxon Neftegas Limited also planned a major seismic programme in adjacent waters during the same open-water season.
Some of that programme would also be conducted on behalf of Rosneft. (IUCN Cetacean Specialist Group)
The scientists were no longer considering one survey.
They were considering an acoustic landscape.
And they did not possess equivalent information from every operator.
WGWAP had detailed access to Sakhalin Energy because the company participated in the IUCN process.
Exxon and Rosneft did not have the same relationship with the Panel.
WGWAP explicitly acknowledged that Sakhalin Energy had provided far more information and cooperation than the other operators.
That point is essential.
The developing environmental crisis cannot fairly be presented as though Shell-linked Sakhalin Energy alone created it.
7. The geography was the real problem
Previous seismic operations had left portions of the feeding area relatively unaffected.
A whale disturbed in one location could potentially shift elsewhere.
WGWAP reviewed evidence suggesting that gray whales had changed their distribution during earlier seismic seasons, although it considered the causal evidence suggestive rather than conclusive.
That uncertainty became more serious for 2015.
If Sakhalin Energy and Exxon/Rosneft seismic operations proceeded in the same season, alongside other activities, the Panel warned that little if any of the nearshore feeding habitat might remain undisturbed for substantial periods.
It raised the possibility that local displacement could become something more serious:
abandonment of the entire feeding area.
The nearshore Piltun feeding area was especially important because mothers with calves did not normally use the offshore feeding area in the same way.
So the question was no longer merely:
How much noise does one whale hear?
It became:
Where can the whale go?
8. December 2014: WGWAP contemplated postponement
The conclusion of the Fifteenth Meeting is unusually clear.
The Panel acknowledged that the Sakhalin gray-whale population had been increasing.
That was encouraging.
But it warned that the combined disturbance planned for 2015 might exceed anything the population had previously experienced.
Its models suggested that Sakhalin Energy’s survey alone would produce greater acoustic exposure than the 2010 Astokh operation.
The proposed Exxon/Rosneft programme was expected to produce considerably greater exposure again.
WGWAP therefore concluded that, from a precautionary perspective, the preferred course would be to postpone seismic work until lower-energy technologies such as OBN could be used.
It particularly urged Exxon and Rosneft to consider postponing some or all of their programme.
But it also asked Sakhalin Energy to give serious consideration to postponing its own streamer survey and combining it later with OBN acquisition.
That is an important documentary threshold.
The Panel had moved beyond designing mitigation.
It was questioning whether the operation should occur in 2015 at all.
9. The scientists were frustrated by the timetable
There was another problem.
Time.
WGWAP recorded considerable frustration at having to complete its advice within a compressed schedule.
The Panel described the proposed Sakhalin Energy survey as much larger than the 2010 operation and noted that it was simultaneously trying to understand an even larger neighbouring programme for which far less information was available.
Its concern was not merely bureaucratic inconvenience.
The survey involved acoustic modelling, cumulative-exposure modelling, personnel training, communications systems, behavioural criteria, real-time monitoring, independent observation and emergency operational rules.
Those arrangements had to work at sea.
Not on paper.
Yet in December 2014 the Panel was still saying that Sakhalin Energy had not demonstrated that all necessary monitoring personnel were experienced, trained, equipped, prepared and ready for deployment.
The mitigation plan remained a work in progress.
10. May 2015: communication broke down
By spring 2015, the disagreement had become sufficiently serious for WGWAP to go public.
Its 8 May 2015 Statement of Concern begins with an extraordinary procedural fact.
IUCN had postponed the intended WGWAP-16 meeting because Sakhalin Energy had not provided expected information and documents in a timely fashion — and in some cases had not supplied them at all.
The Panel described itself as “very disappointed” by the deterioration in communication.
Because it lacked complete information, it could not conduct the formal meeting and produce the normal full report and recommendations.
Instead, it issued a public statement. (IUCN Cetacean Specialist Group)
For an advisory process built around information exchange, that was a serious development.
11. WGWAP said the planned combined seismic effort was unprecedented
The Statement of Concern set out the core problem.
Sakhalin Energy’s planned survey was approximately twice the area of its 2010 survey.
Exxon was also planning a major programme.
WGWAP said the combined seismic activity adjacent to and within the primary gray-whale feeding area would be greater than anything that had previously occurred there.
Its concern was not based on the assumption that every seismic pulse would injure a whale.
It concerned prolonged exposure above levels associated with behavioural disturbance across a very large proportion of the feeding and nursery area. (IUCN Cetacean Specialist Group)
The Panel again said serious consideration should be given to moving one company’s programme into 2016.
The companies needed to coordinate.
12. Sakhalin Energy did not accept postponement
On 23 May 2015, Sakhalin Energy issued its detailed response.
The company did not dispute that the Panel had contributed extensively to survey planning.
Indeed, it emphasised its long engagement with WGWAP and welcomed the Panel’s acknowledgment that Sakhalin Energy had demonstrated substantially greater cooperation and openness than other operators.
It also conceded that some important reports and information had not been provided before the April working meeting and said procedures had been discussed to prevent a recurrence. (IUCN Cetacean Specialist Group)
But on the central question — postponement — the company disagreed.
Sakhalin Energy said it had seriously considered delaying the survey.
It concluded that postponement was not feasible.
Its stated reasons included expected industrial activity in 2016–17 that could degrade seismic data quality or cause operational delays, together with the company’s view that 4-D information was important to future field-development decisions. (IUCN Cetacean Specialist Group)
That was the company’s commercial and technical case.
WGWAP’s precautionary recommendation did not prevail.
13. But Sakhalin Energy changed the plan
Rejecting postponement did not mean rejecting every WGWAP concern.
The company reported several changes.
The airgun source was further optimised, reducing its nominal volume from approximately 3,250 cubic inches to 2,888 cubic inches.
That reduced the predicted shoreward acoustic footprint and therefore the number of the most environmentally sensitive acquisition lines.
Sakhalin Energy and Exxon also rejected the idea of both companies firing on a 24-hour time-sharing basis.
Instead, they agreed to conduct the surveys sequentially.
The most sensitive portions of Exxon’s Odoptu work would go first.
Sakhalin Energy would wait.
That pushed the expected start of the Piltun-Astokh operation from around 10 June into July. (IUCN Cetacean Specialist Group)
This solved one problem.
And created another.
14. Coordination defeated the original early-start strategy
Remember the central WGWAP mitigation principle:
start early.
The original Sakhalin Energy strategy was to begin as soon as ice conditions permitted, when comparatively few whales were expected to be present.
Coordination with Exxon now meant that Sakhalin Energy could not do that.
The later WGWAP record confirms what happened.
Exxon completed its Odoptu survey on 7 July 2015.
Sakhalin Energy fired its first Piltun-Astokh shot on 8 July.
By that stage, substantial numbers of gray whales were normally already present in the feeding area. (IUCN Cetacean Specialist Group)
The companies had reduced simultaneous ensonification.
But the price was a later Sakhalin Energy start.
This is the essence of cumulative-impact management.
Improving one variable can worsen another.
15. The commercial backdrop remained substantial
Royal Dutch Shell’s authenticated 2014 Annual Report and Form 20-F records Shell’s continuing 27.5% interest in Sakhalin LNG, with the plant operating at approximately 9.6 million tonnes per annum of LNG capacity.
Shell’s equity LNG sales attributable to Sakhalin were approximately 2.9 million tonnes in 2014. (Shell)
The seismic debate was therefore occurring inside a large, producing integrated oil and gas business.
This was not speculative frontier exploration.
The purpose of 4-D imaging was to manage existing producing reservoirs more effectively and plan future wells.
That commercial reality matters when assessing why Sakhalin Energy regarded the seismic information as important enough not to postpone.
16. The contrast with IUCN’s 2014 celebration could hardly have been sharper
Only sixteen months earlier, IUCN had publicly celebrated the Sakhalin Energy seismic programme as an example of how industry and conservation scientists could work together.
The 2010 mitigation system had produced practical guidance that IUCN said could be adapted for sensitive seismic surveys elsewhere in the world. (IUCN)
By May 2015 the same advisory structure was issuing a Statement of Concern.
That does not mean the earlier cooperation had failed.
It means the problem had changed.
A sophisticated mitigation plan can manage one survey.
It cannot, by itself, prevent several companies from planning overlapping industrial activity across the same ecosystem.
17. The 2008 High Court record remained an important historical backdrop
The earlier British financing litigation had already documented the exceptional environmental sensitivity of Sakhalin II.
In Export Credits Guarantee Department v Friends of the Earth [2008] EWHC 638 (Admin), Mr Justice Mitting recorded that the proposed development could have a potentially great impact on Western Grey Whale habitat and feeding grounds and that approximately $650 million of UK-backed support had been sought. (vLex)
That case did not concern the 2015 seismic survey.
It did not decide whether the later operation should proceed.
It did not impose acoustic limits.
It did not determine whether Sakhalin Energy complied with WGWAP recommendations.
Its relevance is historical.
Years before the 2015 seismic conflict, whale protection had already become part of the project’s international financial and legal record.
Documentary Findings
Established
Sakhalin Energy planned a major 4-D seismic programme for 2015 to monitor reservoir changes and assist planning of future production wells.
The planned Piltun-Astokh survey was substantially larger than the 2010 Astokh pilot.
WGWAP regarded early-season completion as the principal timing-based mitigation measure because fewer gray whales were expected to be present before peak seasonal abundance.
The Panel required strict shutdown protection for mother-calf pairs exposed above its behavioural threshold and Sakhalin Energy accepted that requirement.
WGWAP learned in 2014 that Exxon Neftegas planned a substantial neighbouring seismic programme for 2015, including work associated with Rosneft. (IUCN Cetacean Specialist Group)
The Panel concluded that cumulative disturbance from the planned 2015 industrial activity could exceed what the population had previously experienced and recommended serious consideration of postponement.
On 8 May 2015 WGWAP issued a formal Statement of Concern after difficulties obtaining information required for its normal review process. (IUCN Cetacean Specialist Group)
Sakhalin Energy rejected postponement but reduced the proposed source strength and coordinated sequencing with Exxon. (IUCN Cetacean Specialist Group)
Sakhalin Energy’s Position
The company said 4-D seismic imaging was necessary for effective reservoir management and future development decisions.
It maintained that its Monitoring and Mitigation Plan incorporated recognised best practice and noted that the Russian State Environmental Expert Review had issued a positive decision concerning the environmental assessment and proposed mitigation.
Sakhalin Energy said it seriously considered postponement but concluded that later industrial activity would make a 2016 survey technically or operationally impractical and would not necessarily reduce whale exposure.
The company also stressed that it had cooperated extensively with WGWAP, provided large amounts of technical information and modified the operation in response to evolving environmental and logistical considerations. (IUCN Cetacean Specialist Group)
WGWAP’s Position
The Panel did not argue that all marine seismic work was inherently unacceptable.
It had spent years helping Sakhalin Energy develop one of the industry’s most elaborate mitigation systems.
Its objection was cumulative.
By late 2014 and spring 2015, it believed the combined industrial programme had become fundamentally different from the single-survey scenario for which earlier mitigation had been designed.
The Panel was particularly concerned that the combined operations could leave little undisturbed nearshore feeding habitat, including areas especially important to mothers and calves.
Its preferred precautionary solution was postponement of at least part of the planned seismic work and greater use of lower-energy technology.
Not Established
It is not established that the 2015 surveys caused population-level harm to Western Gray Whales.
It is not established from these pre-survey records that whales would abandon the feeding area. WGWAP identified that as a plausible risk, not a demonstrated outcome.
It is not established that nominal airgun-array volume alone determines environmental impact.
It is not established that WGWAP possessed legal authority to order Sakhalin Energy, Exxon or Rosneft to postpone their surveys.
It is not established that Shell controlled Exxon Neftegas or Rosneft’s operations.
And Sakhalin Energy’s decision not to postpone should not be described as a refusal to implement all WGWAP advice: the record documents significant redesign and mitigation changes alongside the disagreement over timing.
Commentary
This may be one of the clearest examples in the Sakhalin archive of why environmental protection cannot be reduced to a company-by-company compliance exercise.
Sakhalin Energy had done many of the things environmental management theory says an operator should do.
It engaged independent experts.
It modelled acoustic exposure.
It reduced source strength.
It installed real-time monitoring.
It established shutdown criteria.
It funded whale research.
It accepted independent observation.
It planned the survey around seasonal whale abundance.
Then another operator announced another survey.
The engineering did not fail.
The system boundary failed.
A mitigation plan designed around Sakhalin Energy could control Sakhalin Energy.
It could not control Exxon.
It could not control Rosneft.
And it could not make the whales recognise the boundaries between corporate licence blocks.
The 2015 problem therefore became ecological rather than corporate.
This is precisely what Rick Steiner, Dan Lawn and Jonathan Wills had been warning about years earlier when they argued that Sakhalin projects could not sensibly be assessed in isolation.
By 2015 the theory had become operational reality.
There is another revealing feature.
WGWAP’s criticism of Sakhalin Energy was sharp.
Information had arrived late.
Important material had been missing.
The planned operation had grown.
The Panel wanted postponement.
Yet the same Statement of Concern also acknowledged Sakhalin Energy’s unusually high level of cooperation compared with other operators.
That makes the episode much more interesting than a conventional corporate-environmental confrontation.
The company with the strongest independent oversight became the company against which the most sophisticated environmental demands could be made.
Meanwhile, companies outside that relationship supplied less information to the Panel.
This created a strange asymmetry.
The better Sakhalin Energy became at transparency, the more precisely WGWAP could criticise it.
The less WGWAP knew about neighbouring operators, the harder it became to assess their impacts with equivalent precision.
That is not an argument against transparency.
It is an argument for making equivalent transparency compulsory across an ecosystem.
The December 2014 meeting exposes another uncomfortable reality.
The science was sufficiently uncertain that reasonable people could disagree about mitigation.
Protect every individual whale and the survey may take longer.
Allow tightly controlled exposure early in the season and the operation may finish before most whales arrive.
Postpone the survey and future industrial schedules may make conditions worse.
Conduct it now and the acoustic burden may exceed anything previously experienced.
There was no option with zero consequence.
But there was one principle WGWAP kept returning to:
avoid unnecessary exposure.
That is why OBN technology became so important.
If reservoir information could ultimately be obtained with less sound, then increasingly elaborate mitigation of conventional airguns might no longer be the best answer.
The deeper question was not:
How safely can we fire them?
It was:
Do we still need to fire them this way at all?
By May 2015, however, that technological transition had not arrived.
The surveys were moving toward execution.
WGWAP had warned.
Sakhalin Energy had replied.
Exxon had its own programme.
The ice was disappearing.
And the whales were beginning to return.
Source Record
The principal scientific record is the Western Gray Whale Advisory Panel Report of the Fifteenth Meeting, 8–9 December 2014. It documents the scale of Sakhalin Energy’s proposed survey, acoustic modelling, shutdown criteria, the emergence of the Exxon/Rosneft programme, cumulative-exposure concerns and WGWAP’s recommendations that postponement be seriously considered.
WGWAP — Report of the Fifteenth Meeting, December 2014
The WGWAP Statement of Concern dated 8 May 2015 records the Panel’s concern about delayed or missing information, the unprecedented combined scale of the planned seismic activity and its continuing recommendation that the operators consider postponement and coordinate their activities. (IUCN Cetacean Specialist Group)
WGWAP — Statement of Concern on Proposed 2015 Seismic Activity
Sakhalin Energy’s 23 May 2015 response records the company’s reasons for rejecting postponement, its assertion that the seismic information was operationally important, the State Environmental Expert Review outcome, source optimisation and coordination arrangements with Exxon. (IUCN Cetacean Specialist Group)
Sakhalin Energy — Response to the May 2015 WGWAP Statement
IUCN’s 20 January 2014 public statement, Keeping whales safe in sound, provides the contemporaneous background to the earlier 2010 mitigation programme and explains why the Sakhalin methodology was being promoted internationally as a model for responsible seismic surveying. (IUCN)
IUCN — Keeping whales safe in sound, 20 January 2014
Royal Dutch Shell plc’s authenticated Annual Report and Form 20-F 2014 records the company’s 27.5% interest in Sakhalin LNG, plant capacity and Shell equity LNG sales attributable to Sakhalin. (Shell)
Royal Dutch Shell plc — Annual Report and Form 20-F 2014
The historical judicial record is Export Credits Guarantee Department v Friends of the Earth [2008] EWHC 638 (Admin). It documents the earlier British export-credit process and the recognised sensitivity of Western Grey Whale habitat but does not determine any issue concerning the 2015 seismic programme. (vLex)
Export Credits Guarantee Department v Friends of the Earth — [2008] EWHC 638 (Admin)
The modern IUCN SSC Cetacean Specialist Group archive preserves the WGWAP reports, Noise Task Force records, Statements of Concern and company responses after the original IUCN archive was taken offline following Russia’s 2022 invasion of Ukraine. (IUCN Cetacean Specialist Group)
IUCN SSC Cetacean Specialist Group — WGWAP Archive
Archive disclaimer: The environmental concerns described above were assessments made before and during planning of the 2015 seismic programme. They are not treated as proof of later biological harm. The regulatory approval cited by Sakhalin Energy is reported as the company described it and is not treated as equivalent to WGWAP scientific endorsement. Shell’s 27.5% shareholding is distinguished from the separate activities of Exxon Neftegas and Rosneft.
Site wide disclaimer also applies.
Next Archive File
SLF-2007-053 — The Sakhalin Papers XLIII: Twenty-One Days of Airguns — What Actually Happened During the 2015 Piltun-Astokh Survey
On 7 July 2015, Exxon completed its Odoptu seismic operation.
The following day, Sakhalin Energy fired the first shot of its Piltun-Astokh survey.
Thirty-six acquisition lines followed.
The most sensitive nearshore lines were completed first.
The entire operation lasted 21 days and ended on 29 July. (IUCN Cetacean Specialist Group)
WGWAP later concluded that Sakhalin Energy had “implemented satisfactorily” the mitigation component of its final plan — but that conclusion did not close the file.
There had been technical problems.
Some WGWAP recommendations had been modified by the company.
The survey started weeks later than the scientists had originally wanted.
Exxon and Rosneft had conducted their own large seismic programmes.
Pile driving and vessel activity added more noise.
And the scientists now faced the question that mattered most:
What had all that acoustic activity actually done to the whales?
The first answers were complicated.
The population was still increasing.
Field teams had accumulated an extraordinary acoustic and behavioural dataset.
But “no obvious catastrophe” was not the same thing as “no effect.”
SLF-2007-053 will reconstruct the 21-day operation itself: the shutdown rules, the independent observer, the technical failures and workarounds, the departures from WGWAP’s preferred mitigation plan, and the first scientific attempt to determine whether the unprecedented 2015 seismic season changed the behaviour, distribution or feeding opportunities of the Western Gray Whales.
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