Comment by Independent Scientists concerning SEIC’s Detailed Response to the IISG Report From: Alexander Vedenev, Doug Nowacek, Tim Ragen and Randall Reeves 24 June 2006 Item No. 40: (A) Mother/calf pairs are known to feed in water shallower than 10 m; (B) Using 10 m as a standard is not “conservative” because sound levels at 10 m depth are not generally higher than they are at the bottom. Although this can vary, it is usually vice versa; (C) Acoustic measurements are always taken near the sea bottom (as indicated in Fig. 3.1 of SEIC Document 13F_MNR_Report_Acoustic_Volume_2_2005.pdf) but JASCO’s modeled sound levels relate only to 10 m depth. The modeled data therefore need to be recalculated for comparison to received (empirical) values obtained at positions where the water depth is other than 10 m. Such comparisons would be informative and should be done. Item No. 41: To clarify, the IISG suggested a single, simple criterion based on a noise “dose” approach, which attempts to account for duration of exposure and not just level. We proposed a procedure that would use PEL dB as the control unit (PEL = Permitted Exposure Level), derived from RMS of sound pressure (dB) averaged over time (T). This supposes an equal acoustic impact using a 5 dB exchange rate, Q (from the U.S. Occupational Safety and Health Administration or OSHA). In the common case: PEL (T) dB = PEL (T ) dB - Q/3 T dB, ref * Where Q= 5, T dB = 10 log (T / T ), ...