Bob Stern
LONG BEACH ISLAND, NJ, January 6, 2026 — Save Long Beach Island, Inc. (Save LBI), a grassroots organization dedicated to sound energy policies and preserving our shore and ocean environment, has long contended that the high levels of noise generated during the surveying, construction, and operation phases of an offshore wind project have a detrimental effect on sea mammals — an assertion backed by previous scientific measurements and calculations.
Because hearing acuity plays a central role in the ability of a whale or dolphin to navigate its surroundings — especially during migration — elevated noise can cause serious harm, including impaired or permanent hearing loss, and behavioral disturbances that can also lead indirectly to harm and death.
For years, NOAA has ignored research presented by Save LBI and maintained there is no evidence that marine mammals are directly harmed by wind energy activities. This inaction prompted Save LBI to take two steps in November: (1) petition the U.S. Department of Commerce (DOC) and NOAA to overhaul the flawed methodology being used for calculating “Takes” — instances of fatality, serious harm, or behavioral disturbance to whales and other marine mammals — and (2) submit formal comments in response to the Regional Standards for Offshore Wind Project-Level Monitoring draft proposal released by NOAA’s Northeast Fisheries Science Center.
The Save LBI petition, which NOAA agreed to consider in late December, cites major scientific and mathematical errors in NOAA approved “Take estimation” methods and presents calculations that show significant harm and disturbance to whales and other mammals in the vicinity of offshore wind projects. The petition is available on SaveLBI.org.
Save LBI has also asked NOAA in a formal 11-page technical critique of its proposed monitoring standards to define and require a specific monitoring program that will either verify the assumptions and calculations in its Take estimation methods or, if not, revise those methods. Existing regulations require the agency to verify Take estimates, particularly under Endangered Species Act (ESA) regulations (50 CFR §402.14(i)(5), to do new take estimates based on measurements and animal observation and compare to those used for Biologic Opinion approvals, and if the new results exceed the prior, to re-initiate ESA consultation immediately. Toward that end, Save LBI has asked that any monitoring plan provide the data to verify (or not):
● The 10-decibel (dB) noise source reduction assumed from placing bubble curtains or similar systems around the pile driving operation, by measuring the noise level near the pile driver with the bubble curtains on and off
● The pile driving noise level versus distance numbers in the noise exposure modeling reports supporting project approval that were asked for in the BOEM “Recommendation Document for Offshore Wind Pile Driving Sound Exposure Modeling and Sound Field Measurement”
● The 30 dB and higher noise loss factors in the pile driving noise exposure modeling reports versus the 20 dB and lower factors that Save LBI has contended are valid and that show up in the recent sound field measurement study for the Vineyard Wind 1 project; since the elevated noise range and area increase exponentially with a lower dB noise loss factor, this discrepancy alone would result in a many-fold increase in the number of animal Takes
● That no permanent hearing loss will occur from the accumulated noise energy received by a whale passing by a pile driving activity or an operating wind complex, based on the noise versus distance measurements and observing the time it takes for a while to pass by; straightforward calculations by Save LBI show that such hearing loss will occur within 5 miles of pile driving and 2.25 miles of the perimeter of an operating wind complex, but the noise exposure modeling reports supporting project approval do not show that
● That the North Atlantic right whale’s migration will not be impaired or blocked by measuring the noise levels both within and outside the operating wind complex to find the distance where the noise level drops below the 120 dB whale disturbance level, and compare that distance to the width of any overlapping migration corridor
● That very little animal disturbance occurs at levels below 160 dB for pile driving and 120 dB for turbine operation as NOAA has contended by observing animal behavior at the distances corresponding to those noise levels
● That the elevated noise range from vessel surveying is small, as the approvals assumed versus the several miles that Save LBI calculated, by measuring the noise levels from the vessel for various sparker device energy inputs as was required in leases, but apparently never done, or if done, not publicly reported.
Save LBI President Bob Stern points out that “the decibel (dB) scale that measures noise level is logarithmic and that an incorrect 10 dB lower number underestimates the noise actually being received by the animal by 90%, so for the whale’s sake we humans need to get these dB numbers right”.
“The NOAA monitoring proposal also seeks to establish developer-defined plans in place of true standards, making it unlikely that any questionable assumptions that supported project approval will be culled out,” he added.
“It is heartening that NOAA leadership will consider our petition regarding our concerns with the underestimates of animal Takes,” Stern concluded. “We ask them to put forward a monitoring program in conjunction with that review that will either verify or disprove the concerns we have raised. If our concerns are verified, then NOAA should define and require the use of new mathematically and scientifically defensible methods for calculating marine mammal Takes.”
About Save LBI
Save LBI is a not-for-profit, non-partisan organization that has been active in ongoing litigation and other efforts to protect the coastal and marine environment from the senseless industrialization of our oceans. The organization is led by Beach Haven, N.J. resident Bob Stern, a Ph.D. scientist with experience in environmental planning and environmental law. He is a former manager of the U.S. Department of Energy office responsible for overseeing environmental reviews related to energy projects and of the Bureau of Air Quality Planning within the New Jersey Department of Environmental Protection (NJDEP). For more information on Save LBI and its efforts, please SaveLBI.org
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