Mr. Alexey B. Miller
Deputy Chairman of the Board of Directors
JSC “GAZPROM”
16 Nametkina St.
117997, Moscow, V-420. GSP-7
Russia

Mr. Sergey Bogdanchikov
President of Rosneft
Chairman of Rosneft’s Management Board
26/1, Sofiyskaya Embankment
1, GSP-8 117997
Moscow, Russia

CEO Rex W. Tillerson
ExxonMobil Corporation
5959 Las Colinas Boulevard
Irving, Texas 75039-2298

CEO Peter Mather
British Petroleum
International Headquarters
1 St James’s Square
London, SW1Y 4PD UK

Exxon Neftegas Limited
28 Sakhalinskaya Street
Yuzhno-Sakhalinsk, Russia 693000

Mr. Mikhailov Y.N.
Acting Director General
CJSC Elvary Neftegaz
78, Chekhova Street
693008 Yuzhno-Sakhalinsk
Russian Federation

April 22, 2010

The Board of Governors of the Society for Marine Mammalogy urges all parties involved in hydrocarbon exploration and production on the Sakhalin shelf to participate in the conservation of western gray whales (Eschrichtius robustus).

Western gray whales have been listed as critically endangered by the International Union for Conservation of Nature (IUCN, http://www.iucn.org/wgwap/); the single remnant population contains approximately 130 individuals. The northeastern shelf of Sakhalin Island, Russia is the critical feeding ground for this population and western gray whales depend on this area for much of their food.

Hydrocarbon exploration and production activities in this area could have severe adverse impacts on this population by disrupting feeding in preferred areas, leading possibly to detrimental effects on individual whales and the gray whale population as a whole. Researchers reported the displacement of whales during a seismic survey in 2001 and behavioral observations made during that period indicated that some whales spent less time feeding and more time traveling when exposed to seismic noise. Deciphering the impact of such changes will require detailed studies of prey distribution, foraging ecology, and continued population monitoring.

In 2004, the International Union for the Conservation of Nature (IUCN) and the Sakhalin Energy Investment Company (SEIC) formed an Independent Scientific Review Panel, whose mandate was to evaluate the risks to gray whales from SEIC’s activities on the Sakhalin shelf. An important result of this review was a recommendation to relocate a major pipeline going from offshore platforms to Sakhalin Island. The originally planned route of the pipeline passed through some areas used most intensively by feeding gray whales. SEIC accepted the Panel’s judgment and chose a longer, but safer (from the point of view of the whales) route for the pipeline. The pipeline is now in operation and, although the relocation incurred some additional cost, it provided a tangible benefit to the whales. The success of this process led to the formation of the Western Gray Whale Advisory Panel, another partnership between IUCN and SEIC.

Oil and gas exploration and production activities will continue on the Sakhalin shelf for decades. Seismic air gun surveys will continue, as the industry needs to track the resources in the fields to maintain production. The planning of these seismic surveys by SEIC is another example of how the process administered by the Western Gray Whale Advisory Panel can minimize the impacts of industrial activity on gray whales. For example, an upcoming SEIC seismic survey has been scheduled to occur when the fewest whales are present on the feeding grounds, and the company has consulted extensively with the Western Gray Whale Advisory Panel to develop a detailed, robust monitoring and mitigation program.

The Western Gray Whale Advisory Panel process, in collaboration with SEIC, has clearly had some notable success. However, SEIC is only one of several oil companies operating on the Sakhalin shelf. To fully minimize impacts of hydrocarbon exploration and production on western gray whales, it is essential that all companies operating in the region participate in the process.

Therefore, the Board of Governors of the Society for Marine Mammalogy urges all parties involved in hydrocarbon exploration and production on the Sakhalin shelf and around the Sea of Okhotsk to participate in the WGWAP process and:

• inform the Western Gray Whale Advisory Panel of all exploration and production activities planned and occurring off Sakhalin;
• work co-operatively with the Western Gray Whale Advisory Panel to minimize adverse impacts of these activities on this critically endangered population of whales.
• adopt and follow the recommendations of the Western Gray Whale Advisory Panel.

Thank you for considering our suggestions about this important conservation matter.

Respectfully,

Andrew J. Read, Ph.D.
President, Society for Marine Mammalogy