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. read more
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