As recently reported on Afloat.ie, Providence Resources has been granted a foreshore license for the Dalkey Island Prospect in the Kish Bank Basin to allow for a well site survey, and exploration well and a seismic survey.
But the IWDG has written to Minister of State Jan O'Sullivan suggesting that he Environmental Risk Assessment (ERA) conducted on the area is deficient.
The group argues that the ERA has not assessed the footprint of the seismic survey, saying the mitigation proposed is inadequate and that the disturbance and impact to cetaceans – especially harbour porpoise – is "potentially significant and in contravention of national legislation and EU Directives".
Moreover, the IWDG claims that an Environmental Impact Assessment (EIA) of the effect of a seismic survey on harbour porpoise "doesn’t seem to have been carried out".
The harbour porpoise, which is an Annex II species, is entitled to strict protection. The species has been recorded at very high densities in Dublin Bay during surveys carried out by the IWDG in 2008 on behalf of the National Parks and Wildlife Service (NPWS).
The group says that impact monitoring is needed to gather data on the effects of seismic surveys on harbour porpoises, and recommends it as an additional condition on the license.
"Compliance with the NPWS guidelines does not constitute monitoring and as porpoises are elusive and spend 95% of their time underwater and are difficult to see in a sea state greater than Force 1, the guidelines do not serve to protect them once the works are on-going.
"In addition there are specific data required on their site usage prior to the works and a monitoring plan to assess how they recover after the works."
Moreover, the IWDG claims that in this instance the NPWS "are negligent, as they are not providing strict protection to an Annex II species."
Earlier this year Environment Minister Phil Hogan rejected a call from Tánaiste Eamon Gilmore and others for a public enquiry into the Dalkey Island foreshore licence.