＞Japanese

◆Common Conclusions

・The methodology used for the collection, analysis and interpretation of the data for the EIA is grossly flawed.
・Even when compared to the inadequacy of requirements for Japanese Environmental　Impact Assessment Law, there are glaring deficiencies in this EIA, such as a lack of consideration of the impact of the development on the overall ecology.
・No assessment of international or cross-border impacts has been done in spite of the presence in the area of migratory animals which are known to frequently move between the different territorial jurisdictions.

　It must be concluded, therefore, that this EIA is not only completely inadequate as a basis for funding decisions, it cannot possibly provide the basis for a framework of environmental protection measures or monitoring activities. In light of this, funding institutions are called upon to provide an adequate response to the concerns and questions raised by the experts. And if funders are in possession of additional information that addresses the issues raised, they should make this public and strive to prevent or at the very least minimize any and all impacts on the environment. Before coming to a funding decision, it is urged that a neutral and independent panel of experts be established to analyze the EIA and consider measures to protect the environment.


◆Pinnipeds
(Steller's sea lion: Designated an endangered species by the IUCN, the Mammalogical Society of Japan and the Japanese Ministry of the Environment; Seals: Fall under the protection of Wildlife Protection and Hunting Law (Japan).)

Reviewer：Tsuyoshi ISHINAZAKA (Nihon University), Hiroshi HOSHINO (Graduate school of Fisheries 　　　　　　　　　　　Sciences, Laboratory of Marine ecology, Hokkaido University), Ayako MIZUNO (SOYA MARINE 　　　　　　　　　　MAMMAL NETWORK, JAPAN), Yukiko WATANABE (Steller's Sea Lions Working Group)

・Vol.2 1-34-40: As studies of habitat have only been carried out during the summer, the data collected is 　inadequate. In the case of seal species, no studies have been done in the winter which is their breeding season.
As for Steller's sea lion, no studies detailing the number of individuals in the development area have been done during the migration period from fall to spring, and the total number, therefore, may have been greatly underestimated. Although seals congregate in the area at the mouth of the lagoon and are thought to have haul out areas there, no studies of population and habitat use of these area. Data such as this is indispensable to this kind of impact assessment.

・Vol.5 1-47-50: The assessment lacks information on the waters of and around Aniva Bay from the fall to spring period, and although there are two important habitats for sea lions in southern part of Sakhalin, Kamen'Opasnosti Rock known as haul out site of Steller's sea lion and Northern sea lion, and Tuyleni Island known as major breeding site of Steller's sea lion and Northern sea lion, there are no ecological studies have been carried out. Basic information on the study methodology, the different species and numbers counted on land and seasonal use was not included for seals.
Furthermore, the impact of the planned assessment on seal populations was not addressed.
In addition, the study period (September) is incomprehensible for marine mammal specialists.

・Vol. 5 3-44, 3-47: Sea lions and seals are extremely wary when out of the water, and frequent approaches at the same haul out sites could lead these animals to abandon the sites. Another problem not touched upon in the assessment is the impact of the noise of boat propellers on the pinniped populations and on the fish which form their diet.

・Vol. 5 3-53: The toxicity of crude oil to marine mammals has been underestimated. Exposure leads to acute digestive, nervous and respiratory system and skin problems. The chronic affects are endocrinal disturbances, lowered immunity, and the development of cancer. Crude oil is particularly high in highly toxic polycyclic aromatic hydrocarbons (PAHs), and one type-benzopyrene-is a carcinogen similar in structure to Dioxin. In addition, a relationship between benzopyrene and the high incidence of cancer in the Belugas of Canada's St. Laurence Estuary is suspected.


General Comments on Pinnipeds:
　Since there is a lack of basic information on the geographic distribution and numbers of the pinnipeds which inhabit the area, the marker species of the coastal ecology, it is not only impossible to assess the impact of the planned develop but also to develop measures to deal with contingencies. As the assessment only refers to previously published literature or includes data on pinnipeds collected coincidentally when conducting studies on Western Grey Whales, it does not adequately reflect the present state of the pinniped habitat. (EIA studies on Western Grey Whales were conducted only in the summer and shoulder seasons when these whales are in the waters near the Sakhalin Island. It should be added that the studies were carried out in an extremely limited area near the North-Eastern shore. Moreover, it should be noted that the study methods, the waters, and the periods in which studies should be conducted on pinnipeds differ from those for said whales. )


◆Endemic Dunlin and Other Bird Species
(Among the species designated in the Japan-Russia Migratory Birds Treaty, there are eleven species which have been recorded as inhabiting the North-Eastern region of the Sakhalin Island and are listed as threatened with extinction or having very small populations. There are several species which the flyway has not been proved such as endemic subspecies of Dunlin.)

Reviewer: Yoshimitsu SHIGETA(Senior Researcher at Bird Migration Research Center, Yamashina Institute　　　　　　　　 for Ornithology)

・Vol. 2 1-59 (1.8.5): The location of where Calidris alpina actites, an endemic subspecies of Dunlin, was discovered is unclear.

・Vol. 4 1-81, Vol.5: It is unclear why the Spotted Greenshank and Calidris alpina actites are not mentioned here. It is not if this is because they are not found in the area or for other reasons.

・Vol. 2 1-59 (1.8.5), Vol. 4 1-81: There is inadequate treatment of the endangered Spotted Greenshank and endemic subspecies Calidris alpina actites, both of which, according to studies by Nachaev (1991)and others, are thought likely to breed in the area in question. And, in spite of referring to these bird species as inhabiting the area, almost no thought has been given to the possible impact of the planned oil fields on them.


General Comments on the Dunlin and Other Bird Species:
　It is inconceivable that the affects of the development on bird species were taken into account when the studies were conducted. Since the endangered species and subspecies such as Spotted Greenshank, endemic subspecies of Dunlin and Aleutian Tern have been identified as inhabiting the area, their geographic distribution over all of Sakhalin and the number of individual birds breeding and inhabiting the area should be determined, and the impact of oil development on said endangered species and subspecies should be clarified.


◆Concluding General Comments on the EIA

Reviewer：Hideki OSADA（Research Group for Ecological History of GATA）

・The EIA overall only deals with species on an individual basis and has not taken the whole ecosystem of the region into account. Neither has the assessment considered the impact of the project, nor given thought to protection measures, from this perspective. This fact must surely be seen as a fatal flaw in the overall structure of this EIA. In other words, there were serious problems with this EIA from its planning stages.

・Now, if the Japanese Environmental Impact Assessment Law was used as the standard, the impacts on the Steller's Sea Eagle, being at the top of the food chain, a marker species in the ecosystem and representative of it, of course, would have to be assessed. However, since this EIA lacks an ecosystem-based perspective, no assessment of the overall impact of the project on the river basin, the chain effect of this on the lagoon, the chain effect of this on the fish which form part of the Steller's Sea Eagle's diet, and finally the end effect on the species itself. Moreover, if attention is turned the ecology of the Sakhalin coast and to its pinnipeds, such as seals, these species should, of course, also be listed due to their use of the area throughout the year and the fact that are comparable to the Steller's Sea Eagle in terms of position in the food chain and being distinctive and representative of the ecosystem as a whole. However, a comprehensive assessment of the impact on pinnipeds has not been done.


　In light of this, it can only be concluded that this EIA is simply a review of past literature, and from the perspective of Japanese Environmental Impact Assessment law, amounts to a 'compilation of reference materials' on which to base a 'methodology study' formulated before an actual 'assessment' is done and nothing more.

Contact at ： Keisuke Saitou, Chairman at Institute for Raptor Biomedicine Japan(IRBJ)