Coastal Conservation Association – Mississippi 109 South 27 th Ave, Suite 219 Hattiesburg, MS 39401 Phone 601-268-5534 Fax 601-268-9435 http://www.ccamississippi.org

Position Statement of the Coastal Conservation Association - Mississippi On Seismic Testing

Coastal Conservation Association – Mississippi (CCA-MS) opposes seismic testing in the Mississippi Sound north of a line twelve nautical miles south of the barrier islands.

The Mississippi Sound, a shallow estuarine ecosystem, is critical habitat for a multitude of commercially and recreationally valuable shellfish and finfish species. The Sound has been designated a “Habitat Area of Particular Concern” (HAPC) and is known to serve as a primary nursery area for many of these species. The very nature of this habitat, including its benthic structure, makes it particularly vulnerable to a wide range of negative impacts from seismic sources.

CCA-MS specifically objects to the “Rules and Regulations Governing Geophysical, Seismic or Other Type Exploration on State-Owned Lands.” proposed by the Mississippi Major Economic Impact Authority (MMEIA). The regulations ignore a number of environmental impacts associated with geophysical exploration, particularly in a shallow estuary area such as the Mississippi Sound. The regulations do not require a pre-survey impact analysis, nor do they require a detailed exploration plan. The regulations do not provide for the assessment of penalties, or require any mitigation should damage to the resource occur. Once exploration is underway, there is virtually no specific recordkeeping or reporting requirements to affirm that the permit holder is acting in accordance with the permit, or that sound environmental practices are being observed. The few restrictions placed on the permit holder are vague, and unenforceable. Rule 14.B provides for a complete waiver or modification of any provision of the regulations, at the discretion of the “Executive Director” and the “appropriate supervisory agency.” In effect, this provision makes every aspect of the regulations completely discretionary and subject to waiver without standards, guidelines, or public oversight.

CCA-MS believes the proposed rules governing seismic testing are substantially defective and inadequate to insure the future health of this sensitive marine environment.

--- June 2, 2005 ---