so this one time I wrote a letter to the tribune (2011) and thought it would never be published. It was and I got in trouble with the Minister of the Environment. I was asked to write an apology for the contents of my initial letter.

Here is my apology to the minister of the Environment and the materials I attached to the apology. I think it is pretty good reading to set the evidentiary stage for information on the potential impacts and the corruption and bribery issues that were a potential threat that I recognized back in 2011.

The Apology Letter>>>

Dear Minister Deveaux,

It has come to my attention that my letter to the editor, of August 4th 2011, and published in the Tribune newspaper may be perceived to be overly aggressive or politically charged. I humbly apologize for any negative connotations you may have taken from the letter. I do respect the actions that your government has taken over the past years to protect the environment and support the proper management thereof.

Based on our previous discussions, I do see you as both level-headed and forward thinking. These characteristics are necessary to the protection of the environment of the Bahamas and I would never seek to malign your progress or your work. As you have encouraged me previously to continue my diligent work for the environment, I will. I hope that this issue does not sour our relationship in the future. I will be more circumspect in the future, to avoid ambiguity in my writing and also to communicate via less controversial means whenever possible.

I sincerely appreciate the opportunity to make amends to you by providing evidence of damages to the environment and fisheries, through the use of seismic survey equipment by means of the attached literature. As you know, the general lack of baseline data for the Bahamas is an issue we continue to grapple with. Therefore the literature provides a sound theoretical base for the statement, “damage…that has already begun”, though hard scientific data can not be collected after the fact.

With regard to anti-corruption laws and efforts in the Bahamas, I have also attached a broad list of oil related conventions, treaties, legislation and regulations that control petroleum production and harvesting around the world. Most of these regulations are geared toward environmental protection and protection of human lives and livelihoods outside the petroleum industry. I feel the only way the hydrocarbon resource harvesting activities and entities can be controlled is by ensuring local people and traditional industries are protected first.

Thank you again for both reading my letter and giving me an opportunity to respond to your concerns. If you have further concerns or questions regarding my original letter, or the attached documents, please feel free to contact me.


Ancilleno Davis

<<<end apology letter

Oil related legislation and corruption and bribery legal references>>>

RE: oil exploration in the Bahamas.

I am compiling here a list of references with some notes that address the issues of, impact resulting from seismic surveys, and potential laws to reduce the potential for corruption. I have also included a list of sources for regulations on the oil industry if it does become a Bahamian truth in the future.

There are two types of Marine Seismic survey equipment that would be used to survey for hydrocarbon reserves, compatible to the bank area of the Bahamas. Marine streamers are towed behind Ships along with power sources and Ocean Bottom Cables (OBC) which are laid along the bottom of the ocean. Of these, Streamer methods seem most likely due to the extra cost and the depth limitations of OBC’s and the fact that there are multiple leases granted to the Bahamas Petroleum Company. Below is a summary of the characteristics of each survey method.

I am including some references for the disturbance to fisheries resources, reduced fisheries catch potential and marine mammal impacts. Please find below synopses of some of the papers, though I would encourage reading them for yourselves as well. These papers are from my personal list of citations and some new research for this particular report. I am also including the list of citations for future oil regulation should it come up.

Effects of Seismic surveys on marine animals

Engas et al. (1993) Effects of Seismic Shooting on catch and catch-availability of cod and haddock. Fisken og Havet, nr. 9, 99. 117.

This paper shows the immediate effects of seismic wave use on the distribution of these fish species.

Scripps Institute for Oceanography: Environmental Assessment of planned low energy Marine Seismic testing May-August 2007.

This paper references the link between low and medium energy sonar waves and stranding of whales. It also specifically references the strandings in the Bahamas in March of 2000.

The National Resources Defense Council: Sounding the Depths, outlines the detrimental effects of the use of sonar and also briefly describes some of the control measures in place in the United States to conduct seismic surveys none of which are law in the Bahamas. Some of those recommendations are also noted as “insufficient” in the paper. The paper describes some of the limitations to US law regarding the use of seismic surveys and some international treaties addressing the issue.

Hirst, A.G. and Rodhouse, P.G. (2000) Impacts of geophysical seismic surveying on fishing success Reviews of Fish Biology and Fisheries Vol. 10, pp. 113-118.

This paper gives an in depth assessment of how impacts can be calculated and is highly focused on the physics, different types of injury and their prevalence.

Lokkeborg, S. and Soldal, A.V. (1993) The influence of seismic exploration with airguns on cod (Gadus morhua) behavior and catch rates. ICES Marine Science Symposium. 196, pp. 62-67.

Describes behaviour changes in fish in response to seismic surveys. And supports Engas and McCauley’s work.

McCauley, R., Fewtrell, J., and Popper, A. (2002) High Intensity Anthropogenic Sound Damages Fish Ears. Journal of the Acoustical Society of America. Vol. 113 (1) pp. 638- 642.

This paper is a biological study of the effects of the sound waves on the fish ears. Damage to ears may result in lower survival. This study was sponsored by the Australian Petroleum Production and Exploration Association.

McCauley et al. (2000) Marine Seismic Surveys- A Study of Environmental Implications. Australian Petroleum Production and Exploration Association Journal pp. 692-708

Discusses the environmental impacts of Seismic surveys and supports work from Engas et al (above) and others who describe lowered fisheries catch or changes in fish behavior.

National Science Foundation Appendix D: lists NSF funded studies of the effects of seismic testing on marine invertebrates and Fish.

2Patin, Stanislav (1999). Environmental Impact of the Offshore Oil and Gas Industry. East Northport, NY: EcoMonitor Publishing.

Skalski et al. (1992) Effects of sound from geophysical surveys device on catch-per-unit-effort in a hook-an-line fishery for rockfish (Sebastes spp.). Canadian Journal of Fisheries and Aquatic Sciences Vol. 49, pp. 1357-1365.

Wardle et al. (2001) Effects of seismic air guns on marine fish. Continental Shelf Research Vol. 21 pp. 1005-1027.

Here is a summary of Marine Seismic survey techniques that are currently industry standards.

Marine Seismic surveys involve towing an array of 15-45 pneumatic air guns below the ocean surface behind the survey vessel and emit sound pulses of a “predominantly low frequency (10–300 Hz), high intensity (215-250 dB). Seismic surveying can damage the reproductive processes, auditory functions and other damaging effects to highly lucrative marine species (lobster, crab) and it poses potentially fatal effects to marine mammals.[ Seismic
testing is not fully responsible for whales running ashore or becoming
stranded, but there is evidence that it plays a major role. Studies of seismic
effects on several whale species such as Gray, Bowhead, Blue, Humpback and
Sperm whales indicated substantial effects in behavior, breathing, feeding and
diving patterns. Dr. Bernd Würsig, a professor for marine biology at Texas
A&M University in Galveston, Texas states that the Gray whale will avoid
its regular migratory and feeding grounds by >30 km in areas of seismic
testing. Similarly the breathing of gray whales was shown to be more rapid,
indicating discomfort and panic in the whale.



Marine (streamer)

Deep water marine seismic
surveys are conducted using purpose built vessels capable of towing one or more
seismic cables or "streamers" (see figure) just below the sea
surface, along with an energy source towed just below the surface and between
the stern of the vessel and the head of the streamers. Modern 3D surveys use
multiple streamers deployed in parallel and often multiple energy sources
(commonly two), to record data suitable for the three-dimensional
interpretation of the structures beneath the sea bed. A single vessel may tow
anything up to 10+ streamers, each 6 km+ in length, spaced 50–150 m apart.
Hydrophones are built into the streamers at
regular intervals; these record and digitize the energy waves which are
reflected back from sub-sea structures. To accurately calculate where
subsurface features are located, navigators
compute the position of both the energy source and each hydrophone group which
records the signal. The positioning accuracy required is achieved using a
combination of acoustic networks, compasses and GPS
receivers (often used with a radio correction applied call a differential GPS
or DGPS).

A modification on this
basic technique can also be used to record sub surface data directly underneath
offshore structures, predominantly exploration and production platforms and
other permanent offshore structures such as FPSO's (floating production,
storage and offloading unit) which cannot be moved to facilitate a survey
vessel; this technique is known as undershooting. This requires a separate
source vessel and a streamer vessel to pass either side of the obstruction,
firing the energy source on the source vessel and recording the reflected data
on the towed streamers on the streamer vessel. Both vessels are linked by a
data telemetry system to co-ordinate and synchronise the firing and recording
operations. By varying the distance from the source and streamer vessel to the
obstruction (changing the offset), a wide swathe of data can be collected from
underneath the obstruction without any disturbance to the permanent offshore

[edit] Marine (OBC)

Marine surveys can also be conducted using sensors attached to an Ocean Bottom Cable (OBC) laid out on the ocean bottom rather than in towed streamers. Due to operational limitations, most of these types of surveys are conducted in water depths less than 70 meters, however OBC crews in recent years have acquired 3D surveys in depths up to 2000 meters. One operational advantage is that obstacles (such as platforms) do not limit the acquisition as much as they do for streamer surveys. Most of the OBC surveys use dual component receivers, combining a pressure sensor (hydrophone) and a vertical particle velocity sensor (vertical geophone). OBC surveys can also use four component, i.e. a hydrophone components plus the three orthogonal velocity sensors. Four component OBC surveys have the advantage of being able to also record shear waves, which do not travel through water. Multiple component OBC surveys hence can lead to improved subsurface imaging. Ocean Bottom Cable surveys can also cost significantly more than conventional streamer surveys over the same area. This additional cost is usually only justified when the improved imaging is required for accurate reservoir delineation, or when surface obstacles prevent a conventional streamer survey from being acquired in the area.

Should Oil drilling become one of our truths in the Bahamas, the following sources are good references for the reduction of environmental impacts. The list includes international conventions and treaties, Scientific papers, and local regulations from North America and Europe.

Oil Drilling impact reduction, laws and regulations

Boesch, D. F. and Rabalais, N. N. (eds.). 1987. Long-Term Environmental Effects of Offshore Oil and Gas Development. Elsevier Applied Science Publishers, London.

Canada-Newfoundland Offshore Petroleum Board, Canada-Nova Scotia Offshore Petroleum Board and Canada National Energy Board. 1996. Offshore Waste Treatment Guidelines. CNOPB. St Johns, NF.

Canada-Newfoundland Offshore Petroleum Board, Canada-Nova Scotia Offshore Petroleum Board and Canada National Energy Board. 1999. Guidelines Respecting The Selection of Chemicals Intended to be Used in Conjunction with Offshore Drilling & Production Activities on Frontier Lands. CNOPB. St Johns, NF.

CEFAS. 2000a. Guidelines for the UK Revised Offshore Chemical Notification Scheme in Accordance with the OSPARCOM Harmonised Offshore Chemical Notification Format.. London.

CEFAS, 2000b. UK Offshore Chemical Notification Scheme – List of Notified Chemicals. London

Det Norske Veritas. 2000. Technical Report – Drill Cuttings Joint Industry Project. Phase I Summary Report. Revision 2: 20th January 2000. DNV doc. order No. 29003500. Oslo.

Engelhardt, F. R., Ray, J. P. and Gillam, A.H.(eds.)1989. Drilling Wastes [proceedings
of an international conference on drilling wastes, held at Calgary, Alberta, in
1988]. Elsevier Science Publishers Ltd, Barking, England. ISBN 1851662782.

MARPOL [1997] Regulations for the Prevention of Pollution by Oil. MARPOL 73/78. Annex 1, Regulations 16, 17 & 21. IMO, London.

Neff, J. M. 1987. Biological Effects of Drilling Fluids, Drill Cuttings and Produced Waters, in Boesch, D. F. and Rabalais N. N. (eds.). 1987. Long-Term Environmental Effects of Offshore Oil and Gas Development, pp. 469-538. Elsevier Applied Science Publishers, London.

Norwegian State Pollution Control Authority [Statens forurensningstilsyn – SFT]. 1991. [English translation of] Regulations Concerning Discharge of Oil-Contaminated Drill Cuttings from Petroleum Activity on the Continental Shelf; Laid Down by the Ministry of Environment on 10 June 1991 [under the
Pollution Control Act, 1981:9(1.3)]. SFT, Oslo.

Norwegian State Pollution Control Authority [SFT]. 1998a. General conditions, given as a part of the permit for discharge of oil, drilling fluids and chemicals. SFT, Oslo

Norwegian State Pollution Control Authority [SFT]. 1998b. Requirements for Ecotoxicological Testing and Environmental Assessment of Offshore Chemicals and Drilling Fluids. SFT, Oslo.

Norwegian State Pollution Control Authority [SFT]. 1999a. Environmental Monitoring of Petroleum Activities on the Norwegian Shelf; Guidelines 99:01. SFT, Oslo.

Norwegian State Pollution Control Authority[SFT]. 1999b. Pollution Control Act, 1981 [described
and translated]. SFT, Oslo.

Olsgard, F., and Gray, J.S. 1995. A comprehensive analysis of the effects of offshore oil and gas exploration and production on the benthic communities of the Norwegian continental shelf. Marine Ecology Progress Series 122: 277-306.

Oslo-Paris Convention For The Protection Of The Marine Environment Of The North-East Atlantic [OSPAR – originally the Oslo and Paris Conventions]. 1992a. PARCOM Decision 92/2 on the Use of Oil-based Muds. London.

OSPAR. 1992b. PARCOM Recommendation 92/6 on Best Available Technology for Produced Water Management on Offshore Gas and Oil Installations. Brussels.

OSPAR. 1994. Decision 94/1 on Substances/Preparations Used and Discharged Offshore. Paris Commission. Paris.

OSPAR. 1996. PARCOM Decision 96/3 on a Harmonized Mandatory Control System for the Use and Reduction of the Discharge of Offshore Chemicals. Oslo.

OSPAR. 1997. PARCOM Decision 97/1 on Substances/Preparations Used and Discharged Offshore. Brussels.

OSPAR. 1999a. List of Substances / Preparations Used and Discharged Offshore Which Are Considered to Pose Little or No Risk to the Environment (PLONOR). 1999-9.

OSPAR 1999b. OSPAR Strategy On Environmental Goals And Management Mechanisms For Offshore Activities. 1999-12. Kingston upon Hull.

OSPAR. 1999c.[Annual Report on] Activities of OSPAR July 1998-June 1999 [and] Implementation of the OSPAR Action Plan 1998 – 2003. OSPAR Commission, London.

OSPAR. 2000. Draft Measures Proposed by the OSPAR Working Group on Sea-based Activities (SEBA), February 2000. Amsterdam.

Patin, S. A. 1999. Environmental Impact of the Offshore Oil & Gas Industry. Eco Monitor Publishing, East Northport, New York. ISBN 0-967 1836-0-X.

United Kingdom Department of Trade and Industry, Oil and Gas Directorate. 1999. Guidance Notes on the Offshore Petroleum Production and Pipelines (Assessment of Environmental Effects) Regulations 1999. Edition 2, March 1999. HMSO, London.

United States Department of the Interior (DOI), Minerals Management Service (MMS). 1996. Outer Continental Shelf Oil & Gas Leasing Program: 1997-2002. Final Environmental Impact Statement. Vol. 1. pp IV18-IV35. USMMS, Washington D.C.

United States Environmental Protection Agency (EPA). 1993. Final Modification of the NPDES General Permit for the Western Portion of the Outer Continental Shelf (OCS) of the Gulf of Mexico (GMG290000). Federal Register Vol. 58, No. 231, 12/3/93, pp. 63964-63986. Washington, D.C.

United States Environmental Protection Agency (EPA). 1996b. Oil and Gas Extraction Point Source Category; Final Effluent Limitations Guidelines and Standards for the Coastal Subcategory; Final Rule. 40 CFR Part 435. Federal Register 61:242. (66085-66130). 12/16/96. Washington D.C.

United States Environmental Protection Agency (EPA). 1998. Final NPDES General Permits for the Eastern Portion of Outer Continental Shelf of the Gulf of Mexico (GMG280000) and Record of Decision. Federal Register 63:200 (55717-55762) 10/16/98. Washington D.C.

United States Environmental Protection Agency (EPA). 1999a. Effluent Limitations Guidelines and New Source Performance Standards for Synthetic-Based and Other Non-Aquaeous Drilling Fluids in the Oil and Gas Extraction Point Source Category; Proposed Rule. Federal Register 40 CFR. Part 435:5488-5554. 2/3/99. Washington, D.C.

United States Environmental Protection Agency (EPA). 1999b. Final NPDES General Permit for Oil and Gas Exploration, Development and Production Facilities in Cook Inlet, Alaska. Federal Register 64:46 (11885-11908). 3/10/99. Washington, D.C.

United States Environmental Protection Agency (EPA). 1999c. Final NPDES General Permit for New and Existing Sources and New Dischargers in the Offshore Subcategory of the Oil and Gas Extraction Category for the Western Portion of the Outer Continental Shelf of the Gulf of Mexico (GMG290000) and Notice of a Proposed Modification to That Permit. Federal Register 64:74(19156-19177). 4/19/99. Washington, D.C.

United States Environmental Protection Agency (EPA). 2000 (April) Notice of Data Availability; Effluent Limitations Guidelines for the Oil and Gas Extraction Point Source Category [draft public consultation document on proposed new
rules governing offshore discharges of SBM/SBF]. CFR Part 435. Washington, D.C.

Anti-Corruption Laws, Policies and Regulations

In the Bahamas under Chapter 8: the Power and Privileges act section 27, bribery is addressed as pertains to sitting members of the house and senate. The law is fairly explicit in the transfer of fees, but does not include in kind gestures or rewards. Possible updates to this act would include such potential bribes.

Bribery is also touched on under the Penal code: Chapter 84.

UN Global Compact: Principle 10: Anti-corruption

“On 24 June 2004, during the UN Global Compact Leaders Summit it was announced that the UN Global Compact henceforth includes a tenth principle against corruption. This was adopted after extensive consultations and all participants yielded overwhelming expressions of support, sending a strong worldwide signal that the private sector shares responsibility for the challenges of eliminating corruption. It also demonstrated a new willingness in the business community to play its part in the fight against corruption.”

<<<< End legal references.

I did not expect any of you to make it this far and I certainly do not expect any of you to have searched for and read those references. suffice it to say, I did a lot of research on this nearly a decade ago. This coming year, I expect to be involved in legal battles as expert witness due to oil related impacts on the Cay Sal Bank, trying to help fishermen, crabbers and tourism industry professionals what they deserve and need to survive from a company registered in the USA with shareholders in europe and the backing of some of the most powerful politicians in the country. I’m not sure if I am ready for it, but if not, here is some ammunition for whoever else takes up the sword.

Ancilleno Davis, PhD
Principal/ CEO
Science and Perspective
twitter: @SciPerspective

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