Via electronic submission: uploaded to COFEMER site (

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1 Noviembre 15, 2016 To Agencia de Seguridad, Energia e Medio Ambiente - ASEA Via electronic submission: uploaded to COFEMER site ( RE: Disposiciones administrativas de carácter general que establecen los lineamientos en materia de Seguridad Industrial, Seguridad Operativa y protección al medio ambiente para realizar las actividades de Reconocimiento y Exploración Superficial, Exploración y Extracción de Hidrocarburos. Dear Srs., The International Association of Geophysical Contractors (IAGC) appreciates the opportunity to support ASEA with comments on the draft proposed Disposiciones administrativas de carácter general que establecen los lineamientos en materia de Seguridad Industrial, Seguridad Operativa y protección al medio ambiente para realizar las actividades de Reconocimiento y Exploración Superficial, Exploración y Extracción de Hidrocarburos. IAGC is the international trade association representing the industry that provides geophysical services (geophysical data acquisition, processing and interpretation, geophysical information ownership and licensing, associated services and product providers) to the oil and natural gas industry. IAGC member companies play an integral role in the successful exploration and development of offshore and onshore hydrocarbon resources through the acquisition and processing of geophysical data. Seismic surveys are the only feasible technology available to accurately image the subsurface before a single well is drilled. For the energy industry, modern seismic imaging reduces risk by increasing the likelihood that exploratory wells will successfully tap hydrocarbons and decreasing the number of wells that need to be drilled in a given area, reducing associated safety and environmental risks and the overall footprint for exploration. Because survey activities are temporary and transitory, it is the least intrusive and most cost-effective means to understanding where recoverable hydrocarbons likely exist offshore and onshore all over the world.

2 2 Our comments and suggestion in detail follow attached in a spreadsheet. However, in order to facilitate the understanding and provide an overview of the same, we present below a briefing on the main topics. On art.2, VII Environmental Sensitive Areas and XXV Passive Acoustic Monitoring, we suggest some alterations on the definitions. For Environmental Sensitive Areas the edits aim to ensure that a given area is considered as sensitive due solely to their environmental characteristics, avoiding eventual decisions based on political matters at local level. In relation to PAM definition, our suggestion brings more accuracy to the definition and at the same time make clear that there are other possible techniques with similar objective. It is worth to mention that regarding Chapter II, requirements of arts.7, 8, 9, 10, 11, 12, 13, Chapter IV art.19, 20, 21 and Chapter V, art.27, 28, 29 that they are implemented by the as best practices as part of IOGP 432 (Managing HSE in a Geophysical Contract and IOGP 510 Operating Management System Framework). Apart from that, we would like to have clarified if art.17 requirements should be presented with the Risk Analysis. On art.14, we suggest to include the time limitation of five years to keep the operational documents for presentation to the Agency when requested. Not setting a time frame could lead to unnecessary documentation filing or, on the contrary, to companies not being able to comply with uncertain future Agency requests. On arts. 17 and 18 in relation to the Risk Analysis, we ask for limiting the service providers and contractors to be considered in these Analyses to only those considered as relevant. Including all service providers and contractors would be hardly feasible, not realistic either essential. On art.25 we would like to ask for clarification on how the process for safety review prior to operations start is going to be implemented for seismic operations. Regarding the intensity of the air source, for reference purposes and to facilitate values comparison we recommend on art.28 IV to include at 1 meter after db re. 1µPa in consonance to art.42. On art.35 our concern is to avoid that such requirement - to limit the use of air sources to only one vessel - in areas where the presence of listed species (NOM-059-SEMARNAT- 2010) is not enough known to allow the establishment of the spatial restrictions, may represent a limitation to acquisition methods that involve more than one vessel like Wide Azimuth. In this method of acquisition, for example, commonly referred as WAZ, the presence of more than one vessel with air sources (that are activated alternatively and

3 3 not at the same time) ensure better efficiency diminishing the duration of the acquisition and therefore the potential impacts in the area. On art.36 we recommend to include or other appropriate techniques after PAM to ensure the possibility of implementing other technologies with similar objective, such as thermal infrared. On art.40 we would like to emphasize that dolphins should not be included among species for what the operations must be ceased. First, dolphins are mid- to high-frequency specialists and, therefore, insensitive to the low frequency impulse sounds emitted by seismic operations. The E&P Sound and Marine Life Joint Industry Program has supported research to study the effects of multiple airgun pulses in odontocetes and, specifically, to study whether bottlenose dolphin exposure to airgun impulses results in temporary threshold shift ( TTS ). A recently published study that investigated whether bottlenose dolphin exposure to seismic air pulse at cumulative sound exposure levels of db re 1 μpa2-s results in a noise-induced TTS found that, even at that level of exposure, there was no evidence of TTS. 1 Even at ranges as close as 3.9 m and with the air gun operating at 150 in 3 and 2000 psi, resulting in cumulative Sound Exposure Levels of db re 1µPa 2 s, the impulses did not result in detectable TTS in any dolphin tested. As a result of the relative low-frequency content of airgun impulses compared to the relative high-frequency hearing ability of dolphins, no injuries or significant behavioral responses were observed in this study. 2 Industry observations corroborate this scientific evidence. For example, dolphins are frequently observed by personnel on seismic vessels to approach the vessels during operations to bow-ride and chase towed equipment a direct indication of insensitivity to seismic sound generation. PSO observation reports indicate that there is no statistically significant difference between the frequency of dolphin sightings and acoustic detections during seismic operations when the source is active or silent. Second, in areas of high-density dolphin populations, shutdown requirements for a species that enjoys bow-riding and approaching vessels could effectively bring all seismic 1 Finneran J.J., Schlundt C.E., Branstetter, B.K., Trickey, J.S., Bowman, V., and Jenkins, K. Effects of multiple impulses from a seismic air gun on bottlenose dolphin hearing and behavior. 137 J. Acoust. Soc. Am (April 2015). The results of this study also are useful to support inclusion of frequency weighting in updated acoustic criteria. 2 In a 2011 Programmatic EIS, the National Science Foundation recognized that [t]here has been no specific documentation that TTS occurs for marine mammals exposed to sequences of air-gun pulses during operational seismic surveys. Programmatic EIS/OEIS for NSF-Funded & USGS Marine Seismic Research, at (June 2011), (recognizing 180 db re 1 upa (rms) criterion for cetaceans is actually probably quite precautionary, i.e., lower than necessary to avoid TTS at least for delphinids, belugas and similar species ).

4 4 activity to a halt. Implementation of the proposed measure for dolphin shutdowns will substantially increase the number of shutdowns and delays in ramp-ups, which will result in much longer surveys and significantly increased costs with no environmental benefit. According to Barkaszi, 75% of delays in ramp-ups due to presence of protected species in exclusion zone during 30 minutes prior to ramp-up were due to dolphins. In conclusion, delphinids are mid-frequency hearing specialists and as consequence are unaffected by the lower frequency sounds produced by seismic operations. Exclusion zones should be based on the best available science and acoustic modeling. In relation to the definition of the Exclusion Zone on art.44, we suggest to include that it should be based on the acoustic criteria as per defined on Chapter I, XLVIV for accuracy purposes. On art.45 we are requesting to consider the distance of 500m instead of 2000m for the Exclusion Zone in cases when such radio is not defined by acoustic modeling. Many countries use 500m as the standard distance for marine mammals shutdowns (Brazil, Canada, GoM, UK). In addition to that, despite of the modern available equipment for sighting, it is still a challenge to PSOs not to spot but to identify animals in greater distance as 1000 and 2000m. The identification is key to define if the animal is enlisted in NOM- 059-SEMARNAT-2010 and consequently to request the shutdown. IAGC would support the following power-down procedures: (1) power-down would be implemented only if a marine mammal (excluding Dolphins) is observed in or entering the exclusion zone; (2) power-down procedures may involve a reduction in the volume and/or pressure of the array; and (3) if a marine mammal is observed within the 500 m exclusion zone, then the reduced array would be shut down and shutdown procedures would apply. Art.54 establishes that in onshore operations after the acquisition is completed, the seismic company shall restore the area of the Project and its surrounding areas that have been affected to similar conditions to the adjacent areas in order to provide for continuity of natural processes. We understand that this could lead to requirements such as replanting of small tress and to other measures that are not really in accordance with the industry standards. We suggest that the obligation should be to restore the area according to international standards instead of to similar conditions to the adjacent areas in order to provide for continuity of natural processes. Finally, as for the list of standards, on Annexes I and II we suggest to include some others references. To Annex I please consider:

5 5 - Guidelines for the Development and Application of Health, Safety and Environmental Management Systems - OGP Report # 210, - HSE Management - Working together in a Contract Environment - OGP Report #423, - HSE Aspects in a Contracting Environment for Geophysical Operations - OGP Report #432, - Operating Management System Framework - OGP Report #510. To Annex II we recommend to include: - IAGC Land geophysical safety manual, - IAGC Marine geophysical safety manual, - IAGC Environmental Manual, - IAGC Mitigation Measures for Cetaceans during Geophysical Operations, - IAGC Guidance on the Use of Towed Passive Acoustic Monitoring. Should you wish to discuss our suggestions and comments in more detail or have any clarification please do not hesitate to contact me (dustin.vanliew@iagc.org; ) or Andreia Leao Owens (andreia.l.owens@iagc.org ). Sincerely, Dustin Van Liew Director, Regulatory & Governmental Affairs International Association of Geophysical Contractors Attachment: Detailed comments to Disposiciones administrativas de carácter general que establecen los lineamientos en materia de Seguridad Industrial, Seguridad Operativa y protección al

6 medio ambiente para realizar las actividades de Reconocimiento y Exploración Superficial, Exploración y Extracción de Hidrocarburos by IAGC. 6