August 17, 2009
By Electronic Mail
Michael Payne, Chief
National Marine Fisheries Service
Permits, Conservation and Education Division
Office of Protected Resources
1313 E – W Hwy
Silver Spring, MD 20910-3225
Re: 0648-AX88 NWTRC request Marine Mammal Take Permit rule change.
Chief Michael Payne:
I submitted 24 pages of comments on the NWTRC EIS/OEIS. 5,300 characters documented Navy’s sonar Taking kills 700 - 4000 endangered marine species a year. Navy expert said new sonar is felt for 300 miles.
Two dead whales near Olympia June 2009 were found after residents felt a pulse (sonar?) that knocked out electricity & locked doors. A sonar test at PSNS locked every car on auto row. In the 1,068 page NWTRC EIS nowhere were effects to shore populations from Puget Sound to San Diego of the Navy’s sonar frequencies going past the littoral mentioned. If 215 decibels of sonar explodes marine mammal brains at 180 decibels what does it do to humans?
NMFS has proposed a rule that would allow the Navy "to take" –harass, injure or kill marine mammals 130,000 times a year for five years for 650,000 acoustic assaults. Even within the 1.3% of the NWTR area that is the Olympic National Marine Mammal Sanctuary. There should be a 300 mile safe zone around the Sanctuary.
Why would you allow this violation? This is contrary to your stated Mission Statement.
There are major stressors on marine mammals: only 1.7 of 13 million sockeye returned to the Fraser River; Carbonic Acid ocean water killed a billion seed oysters and can dissolve salmon and thus marine mammal food sources. Together global warming and Navy sonar could cause mass extinction of marine mammal species.
If the Navy’s request of the “whole mango” is allow by NMFS how will you justify the extinctions? What is your back up plan to recreate marine mammals after they are gone? Please uphold your mission, protect marine mammals and deny the Navy its request for Take permits.
Theresa Marie Gandhi
Educated to protect earth and ocean species for our 7th generation.
P.O. Box 437, Clinton, WA 98236
Attachments: Northwest Training Complex –Comments submitted March 9, 2009
Marine Mammals Deaths and Naval Hubris – submitted March 9, 2009
cc: Rep. Rick Larsen
Senator Maria Cantwell
Senator Patti Murray
Various Media
Wednesday, August 19, 2009
Tuesday, August 18, 2009
Comments on NWTRC Navy's 1,068 EIS/OEIS
Commander, U.S. Pacific Fleet
Kimberly Kler, Environmental Planner
Naval Facilities Engineering Command Northwest
1101 Tautog Circle, Suite 203
Silverdale, WA 98315-1101 360-396-0927
http://www.nwtrangecomplexeis.com/NtrcCommentForm.aspx
March 9, 2009
Theresa Marie K. Gandhi
Whidbey Island Chemically Injured Network
P.O. Box 437
Clinton, WA 98236 tm@tmgandhi.com
Howdy Kimberly,
The three documents plus this one I submit as my “Comments on Northwest Training Range Complex EIS/OEIS Draft December 2008” Document three and four are references for statements made in document one and two. In the specific “Comment” document I have used italics for my statements and underlined my recommendations. Material taken from the EIS/OEIS Draft is in quotes with section and page number noted. I am qualified to make these statements because of: a year of college organic chemistry; eight years of immersion in “best available science” on toxic chemicals in the environment; marine species and humans. I have hundreds of documents on this topic that have been used to make comments on several draft Environmental Impact Statements. Official Comments have been submitted by this writer on topics related to: herbicides for roadside vegetation control; Salmon Plan for WIRA 6; Island County Critical Areas and Wetlands regulations and U.S. Department of the Interior’s BLM EIS to apply thousands of pounds of herbicides to one million acres in Western States for Fire Suppression.
Reading the draft EIS/OEIS has raised my blood pressure as I experience incredibility, disbelief, skepticism and even outrage at the hubris of Former President Bush, his Secretary of Defense, the Commander, U.S. Naval Fleet and those who assembled the draft NWTRC EIS/OEIS.
The Navy’s analysis of the potential environmental impacts to the human environment that “may” result from the U.S. Navy’s Historical “No change” Alternative of ongoing practices; Proposed Actions of the preferred Expanded Alternatives and proposed increased naval activities within a greatly expanded NWTRC are severely lacking in comprehensive credible science. “Science” referenced and references are found to be old and inaccurate when compared to “best available science”. Assumptions, declarations and statements extrapolated from the “science” referenced are thus found to be inaccurate. This means that historical, ongoing and preferred expanded alternatives will expose marine species, habitats, aquatic life and near shore inhabitants, i.e. people, too much greater harm than claimed by this EIS/OEIS draft. I found “scientific” studies lacking credibility with inaccurate conclusions. Whales that wash up dead on the beaches of Whidbey Island, there of been several, have to be disposed of at a hazardous waste facility. The draft writers’ assumptions that toxic chemicals and hazardous wastes from training activities and operations would not experience bioaccumulation up the food chain to human consumption marine species and marine mammals are not based on “best available science”. Southern Puget Sound Orca Whales are one of the most toxic burdened species on the planet.
As a Hanford Downwinder born north along the Columbia River in 1946 I had to research radiation in all it forms in order to overcome death by cancer from exposure to radiation. Department of Energy - DOE # TCDF58 is my number as part of the dose reconstruction project having received a minimum of 2,900,000 MREMS in my sixty three years. My greatest exposure came before birth and for the first two years of life. As part of a family and community cancer cluster I scattered my 41 year old brother’s ashes after he had tightened the bolts of a nuclear reactor in a submarine with paper booties for protection. Of the four out of six in my immediate family experiencing cancer, three are dead.
Radiation’s “No Apparent Danger” is not true. The NWTRC EIS/OEIS Draft referencing a thirty-five year old report: “Ecological Considerations of Depleted Uranium Munitions” assembled at Los Alamos, NM weapons laboratory before the most recent generation of DU weapons were used in combat and could not possibly addresses the issues raised after nineteen years of use. Nor could claims made by the U.S. Navy or any branch of the military on the “harmlessness” of deplete uranium weapons be credible. Testing large particles of uranium does not and can not be used to say what the pulverized matter created by use of these weapons would do to humans or aquatic life. Depleted Uranium weapons are fourth generation nuclear weapons and their use violates several international treaties, conventions and agreements. (See www.GulfWarVets.org)
Depleted “nano particles” of exploded Uranium, which forms a poison gas, are not less harmful just because large particles in another form had tested so. These are some of many government and military lies told in the “Name of National Security”. (See “Experts on Radiation, document 3 of 4).
The mists of exploding DU weapons into nanoparticiles are no where referenced in this NWTCR Draft EIS/OEIS. One thirty-five year old of two references used large particles of uranium in the studies referenced. If they had studied the poison mists of nanoparticiles of DU the results would have been kept secret. Military and government agents have threatened those whose investigations showed extreme cancer risk from the nanoparticiles with loss of job, homes burned and lives were threatened. Radiation experts, Japanese investigators and medical personnel were denied entry into Iraq.
I’ve prepared a six page abstract of “Experts in DU Radiation Effects” including the professional credentials of the researchers, doctors and investigators. Studies on the nano particles of tungsten are probably rare or lacking. And it maybe that the DU bombs vaporized to date that are greater than or equal to the fall out of 83,000 Hiroshima sized bombs also contained tungsten, I don’t know. The radioactivity trail of the uranium was easier to track.
“Marine Mammal Deaths and Naval Hubris” backs up the validity of my statements regarding marine mammal’s deaths with references. Data provided by the draft EIS/OEIS and a document search regarding the multiple “takings”, i.e. killing, of marine mammals with the use of mid-frequency active sonar use are cited.
These two documents are included as part of my comments for a total of four documents submitted as my Comments on the NWTRC EIS/OEIS draft. (Identified as document 1 of 4 TmkG.)
“Best available science” is often not considered if it is not looked for. Washington State Department of Transportation -WSDOT proved that in their EIS process by only considering comments from Chemicals Corporations on implications or effects of potential harm for humans and aquatic species of their products. Ignored were hundreds of “best available scientific studies” proving the link between the chemical formulations used and their endocrine dysfunction aspects on species exposed. Many of the chemicals in the formulations have been linked with the feminization of males, decreased sperm counts species wide and linked with erect penile dysfunction, testicular cancer in humans and a number of other terminal diseases. Island County had the scientific findings put before them until they stopped using all herbicides for roadside vegetation control.
WSDOT ignored the endocrine dysfunction “peer review scientific studies” submitted that resulted in the Secretary of Transportation requesting an EIS process to look at issues I had raised. Washington Toxics Coalition submitted eighteen pages addressing all of the issues ignored in the EIS and WSDOT, like the Navy is likely to do, deemed the comments “too comprehensive and complete” to be dealt with. The comments were not included in the final EIS document but rather the claim was made that WSDOT was taking care not to harm humans or the environment.
Including a report of a process of framing an EIS so as to not honestly examine very valid issues of potential harm done by WSDOT is not unlike what the Navy is doing with the current NWTRC EIS/OEIS draft. This puts the entire integrity of the process of securing a final NWTRC EIS/OEIS by the U.S. Navy in the column of dishonesty conducted with a lack of valor.
I am skeptical that the Navy will heed the implications of “best available science” because of my experience over seven years in dealing with WSDOT that held itself “an island onto itself”. It took five years of work by a small group of Whidbey Island citizens using “best available science” that resulted in WSDOT now using 30% less toxic chemicals on all State Routes. 2008 use of herbicides is a 70% reduction from the highest amount used in 1993.
It appears that the U.S. Navy does not honor the concept of a Sanctuary nor do they think they are subject to many current laws and international agreement regarding Olympic Coast National Marine Sanctuary - OCNMS. Instead the Navy WANTS every square nautical miles of the 122,440 and have secured a permit to kill, “take” marine mammals if when and where they so choose even from a small part of the totally vast NWTRC area. The OCNMS is only 1.3% of the 122,440 square nautical miles but the U.S. Navy must have even this small part.
Like the claim the Navy is making based on inappropriate scientific studies that no harm will come to humans, marine species, their habitats or the environment. This reasoning lacks Common Sense.
The Endangered Species Act carries fines against anyone, agency or government body who harms the habitat of Chinook salmon or salmonid at $15,000.00 to $25,000.00 per fish. As all of Whidbey Island near shore is Chinook habitat it is especially applicable to this draft EIS proposal. A lawsuit against the Navy for a massive fish kill from a small sized explosion off of NAS Whidbey using one of its smaller bombs does not bode well for endangered Chinook salmon. This fish kill was witnessed. How many are not?
Chinook, Coho, Sockeye, Atlantic, Chum salmon and Steelhead Trout with eight additional species of salmon are listed as Endangered. An additional twenty-five are threatened as the salmon population supports the whale populations which are in serious decline with eighteen marine mammals species listed as Endangered Species. This delicate balance for so many species of marine mammals that are close to tipping into extinction will surely be harmed and extinction hastened by the Navy’s proposed “Preferred Alternative”, its activities and insistence on using the 1.3% of 122,440 square nautical miles of the Olympic National Marine Mammal Sanctuary. Marine mammals and populations of fish in the tens of thousands will be eliminated because naval personnel lacked the will to figure out a way to not do so. This is embarrassing.
I know the Strategic Military Thinking that mandates the U.S. Navy carry out a mission as directed by the Commander in Chief, President Obama. This current draft that we are discussing was started when President Bush held that position. The whole process is flavored with the same hubris President Bush used to fabricate intelligence to take our valued troops to war against a country that had not attacked us on 9-11. Over 500,000 of those very same veterans wounded mentally or physically are currently homeless and denied health care by denying the link between military service and harm. (See www.GulfWarVets.org.)
In the Navy’s EIS scoping process the issue is that inappropriate scientific studies are being use to imply no harm will come to marine species and environment, humans and their environments. Thirty-five and fifty year old reports of studies are so out of date that the use of them as references to validate statements within the NWTRC EIS/OEIS contributes to the hubris that the Navy only need to carry out the form but not the substance of a valid look at what could and will in fact harm marine mammals, aquatic life and degrade the environment so valued by residents of the states impacted.
If it is true and is allowed to stand that President G.W. Bush signed an Executive Order authorizing the National Marine Fisheries Service to issue an LOA authorizing 10 million uses of the U.S. Navy’s new sonar through 2014 contrary to the Marine Mammals Act ensures the Death of The Last of Earth’s Whales and Marine Mammals. The hubris of authorizing the elimination of multiple marine species is a violation of multiple International Treaties, Agreements, Federal law, Federal and State Court decrees and laws of other Countries and their Court’s rulings is unacceptable.
The Navy has committed critical errors of omission of “best available science”, obvious obfuscation of data input and study parameters with the results of science based upon inadequate or comprehensive understanding of the true facts. This disregard of the implications of the effects of these toxic chemicals for multiple species generational integrity is unacceptable. Even if the makers of these agents of death had to fabricate or misdirect research efforts to gain approval and if this was done in the “Name of National Security” no one outside of “Need to Know” would be allowed to “Know”.
Manipulation of science has been done in the past by various aspects of government and the chemical industry. The only lawsuit filed against the Manhattan Project was to protect duPont Chemical Ltd of liability for killing a goat and all life on a New Jersey farm with a fluoride release from their plant making it for atomic bombs. Dr. Harold C. Hodge, chief of fluoride toxicity studies for the Manhattan project became the leading national proponent of fluoridating public drinking water. Dr. Hodge was sent to New York University at Rochester to fabricate science to prove fluoride harmless. Fluoride is not harmless. Reference “Project Censored” USC -Sonoma.
The ultimate result of shortening the lives of those who will be exposed to the toxic exhaust; weapon fragments; radioactive nano particles; salt water columns and bottoms littered with very toxic chemicals, hazardous waste and other byproducts of the U.S. Navy conducting training activity is unacceptable. No valid scientific studies were conducted to prove the assumptions that these materials will not harm marine life.
This lack of ingenuity, creative thinking, innovation and alternatives is disappointing given the good intentions of the majority of our military service naval commanders, officers, service men, women, support staff and support industries. Where is the American can do to preserve life? Has the expectation of acceptable collateral damage of innocents been woven into the military thinking of those we expect to protect us from enemies foreign and domestic?
I do not dispute the mandate given to the U.S. Naval Commander, U.S. Pacific Fleet. I was raised with patriotic pride as the step-daughter of a Korean War Navy veteran; daughter of thirty year Coast Guard cook; sister of brother serving the Navy for six years. My nephew, 20+ years with Army Special Forces has been in Iraq since 2003. I am the grandmother of an Air Force Registered Nurse in Germany and second cousin to Robert Hanley, a former Commander in the Sixth Fleet. I have the highest regard for the U.S. Navy and all who serve our country whether by water, air or land.
I do object to the process, road blocks with the comment computer and limited notice among other issues. Did you confer with Vice President Cheney on how to keep the process secret? The Senators and four Congressmen from Oregon would probably agree as they have written to the Secretary of the Navy to extend the Comment Period to April 11, 2009. They did so citing inadequate notice, restricted comment time and inadequate public meetings. Thank you for extending the comment time if not to April 11 at least to March 11th.
My remarks are limited as I have only had time to read one and one/third volumes. Based upon what I have read and combined with what I know and am providing is but a small part of that knowledge.
I request that there be no expansion beyond the mis-named “No Action” Alternative and that the Navy go back, examine and re-evaluate assumptions being made. I do not know if the Navy ever did a scoping process for the “No Action Alternative” or produced a properly reviewed EIS/OEIS or are attempting to grandfather in what is already taking place. Further investigation of the potential impacts of operating in near proximity to Endangered Species using technology that harms and kills are needed to be carried out by independent “best available scientific studies”.
Knowing that harm and death occur, having gone to the trouble of getting an exception not granted any other organization or government body; knowing that Endangered Marine Mammals follow Endangered salmon through, about and within the NWTRC Study Area activities should be suspended in the areas of sensitivity mid April through mid October. Areas of sensitivity are the traditional ocean to rivers path ways used for hundreds of years by resident aquatic species.
Unless and until recommendations made by Howard Garrett of the Orca Network, the National Resources Defense Council along with the Organizations that signed their submission, Conservation North West and my objections and questions can be addressed on the inadequacy of the NWTRC EIS/OEIS Draft training should stop and or be limited within 300 miles of the Olympic National Marine Mammal Sanctuary. Until these recommendations and questions can be address as submitted by the above organization no expansion should be allowed. Until recommendations can be put into place and appropriate training can be given to Sonar personnel all training should be suspended in critical areas rather than use technology that the Navy knows kills multiple Endangered Species.
Unless you can clone Clark Kent/Superman to be a look out with super sight and listening with super hearing for species that seeks not to be found to be present on sonar duty on all vessels the U.S. Navy should stop “takings” of multiple Endangered Species. How would a “look out” work on submarines? No human can detect marine mammals that are 200 to 300 miles away that are in sonar harm’s way. Current sonar technology does kill and its effects are heard much further than the draft EIS/OEIS admits. A Navy sonar expert has research that shows the sonar is heard 300 miles and maybe more from its source. This was not mentioned in the EIS/OEIS draft.
Please find the will, intelligence and ingenuity that the U.S. Navy is known for and find a way that training can occur and Endangered Species are not “taken” in the process. When did it become okay to kill, harm or damage that which the U.S. Navy is mandated to protect? The lives, environment, way of life and economic violability of multiple communities along the West Coast and within Puget Sound depend upon each of you to find a way to both protect and defend our quality of life. This means living in harmony and without harming our varied marine species, especially those that are threatened and or endangered.
For my part I will continue to communicate to the President, Secretary of State and United Nations members to find non-violent ways to achieve peace and justice. And I will pray that no person serving his Country in the Military will have to kill or be killed. And that no marine mammals ever again come within 300 miles of Navy sonar – an impossible hope.
Please remember that no member of any aquatic species has ever sought to “take” the life of anyone in the U.S. Navy. Please find a way to not have to “take” their lives.
I agree with the Comments submitted by the National Resources Defense Council, Organizations who signed on to their comments, Conservation North West. Please implement their recommendations along with the very intelligent and knowledgeable comments and suggestions made by Howard Garrett.
Please answer the questions I have raised. Please check out the complete reports I have referenced in my two supporting documents.
Thank you for the opportunity to be a part of this process in submitting my four part comments to the NWTRC EIS/OEIS Draft December 2008. I will be sending copies of these documents to my Congressional Representatives, President Obama, other organizations and the media.
More than the average person I know the importance of a well trained and mission ready Navy. I have studied extensively U.S. Strategic National Security theory and tactics; the moral and political thought of Mahatma Gandhi; participated in 1988 at Oxford as part of the Secretariat of the Global Forum on Human Survival of Religious and Parliamentarians on Human Survival; attended the Global Forum on Survival in Moscow in 1990; am the former wife of a Mahatma Gandhi relative; six of my family have served in the military and I joined the Veterans of Foreign Wars Auxiliary in 1970.
I support our troops and I believe that with the will to do so military personnel can do anything. Please create a win win and find ways to train without killing endangered species. The NWTRC EIS/OEIS Draft 2008 is a good beginning but does not represent the quality of work that I know the Navy can perform. I have given weeks of my life that I could have used to promote my just published book. A tenth surgery scheduled this month could be fatal. I have given above and beyond please do the same. Thank you.
Conclusion of Part 1 Introductory Remarks. (Attachment 1 of 2)
Part 2 Comments
Part 3 Experts in Radiation
Part 4 Marine Mammal Deaths and Naval Hubris. (Attachment 2 of 2)
Respectfully submitted,
Theresa Marie K. Gandhi
Whidbey Island Chemically Injured Network
Whidbey Island No Spray
Washington State resident since 1946
Veterans of Foreign Wars 2669 Auxiliary since 1970
Kimberly Kler, Environmental Planner
Naval Facilities Engineering Command Northwest
1101 Tautog Circle, Suite 203
Silverdale, WA 98315-1101 360-396-0927
http://www.nwtrangecomplexeis.com/NtrcCommentForm.aspx
March 9, 2009
Theresa Marie K. Gandhi
Whidbey Island Chemically Injured Network
P.O. Box 437
Clinton, WA 98236 tm@tmgandhi.com
Howdy Kimberly,
The three documents plus this one I submit as my “Comments on Northwest Training Range Complex EIS/OEIS Draft December 2008” Document three and four are references for statements made in document one and two. In the specific “Comment” document I have used italics for my statements and underlined my recommendations. Material taken from the EIS/OEIS Draft is in quotes with section and page number noted. I am qualified to make these statements because of: a year of college organic chemistry; eight years of immersion in “best available science” on toxic chemicals in the environment; marine species and humans. I have hundreds of documents on this topic that have been used to make comments on several draft Environmental Impact Statements. Official Comments have been submitted by this writer on topics related to: herbicides for roadside vegetation control; Salmon Plan for WIRA 6; Island County Critical Areas and Wetlands regulations and U.S. Department of the Interior’s BLM EIS to apply thousands of pounds of herbicides to one million acres in Western States for Fire Suppression.
Reading the draft EIS/OEIS has raised my blood pressure as I experience incredibility, disbelief, skepticism and even outrage at the hubris of Former President Bush, his Secretary of Defense, the Commander, U.S. Naval Fleet and those who assembled the draft NWTRC EIS/OEIS.
The Navy’s analysis of the potential environmental impacts to the human environment that “may” result from the U.S. Navy’s Historical “No change” Alternative of ongoing practices; Proposed Actions of the preferred Expanded Alternatives and proposed increased naval activities within a greatly expanded NWTRC are severely lacking in comprehensive credible science. “Science” referenced and references are found to be old and inaccurate when compared to “best available science”. Assumptions, declarations and statements extrapolated from the “science” referenced are thus found to be inaccurate. This means that historical, ongoing and preferred expanded alternatives will expose marine species, habitats, aquatic life and near shore inhabitants, i.e. people, too much greater harm than claimed by this EIS/OEIS draft. I found “scientific” studies lacking credibility with inaccurate conclusions. Whales that wash up dead on the beaches of Whidbey Island, there of been several, have to be disposed of at a hazardous waste facility. The draft writers’ assumptions that toxic chemicals and hazardous wastes from training activities and operations would not experience bioaccumulation up the food chain to human consumption marine species and marine mammals are not based on “best available science”. Southern Puget Sound Orca Whales are one of the most toxic burdened species on the planet.
As a Hanford Downwinder born north along the Columbia River in 1946 I had to research radiation in all it forms in order to overcome death by cancer from exposure to radiation. Department of Energy - DOE # TCDF58 is my number as part of the dose reconstruction project having received a minimum of 2,900,000 MREMS in my sixty three years. My greatest exposure came before birth and for the first two years of life. As part of a family and community cancer cluster I scattered my 41 year old brother’s ashes after he had tightened the bolts of a nuclear reactor in a submarine with paper booties for protection. Of the four out of six in my immediate family experiencing cancer, three are dead.
Radiation’s “No Apparent Danger” is not true. The NWTRC EIS/OEIS Draft referencing a thirty-five year old report: “Ecological Considerations of Depleted Uranium Munitions” assembled at Los Alamos, NM weapons laboratory before the most recent generation of DU weapons were used in combat and could not possibly addresses the issues raised after nineteen years of use. Nor could claims made by the U.S. Navy or any branch of the military on the “harmlessness” of deplete uranium weapons be credible. Testing large particles of uranium does not and can not be used to say what the pulverized matter created by use of these weapons would do to humans or aquatic life. Depleted Uranium weapons are fourth generation nuclear weapons and their use violates several international treaties, conventions and agreements. (See www.GulfWarVets.org)
Depleted “nano particles” of exploded Uranium, which forms a poison gas, are not less harmful just because large particles in another form had tested so. These are some of many government and military lies told in the “Name of National Security”. (See “Experts on Radiation, document 3 of 4).
The mists of exploding DU weapons into nanoparticiles are no where referenced in this NWTCR Draft EIS/OEIS. One thirty-five year old of two references used large particles of uranium in the studies referenced. If they had studied the poison mists of nanoparticiles of DU the results would have been kept secret. Military and government agents have threatened those whose investigations showed extreme cancer risk from the nanoparticiles with loss of job, homes burned and lives were threatened. Radiation experts, Japanese investigators and medical personnel were denied entry into Iraq.
I’ve prepared a six page abstract of “Experts in DU Radiation Effects” including the professional credentials of the researchers, doctors and investigators. Studies on the nano particles of tungsten are probably rare or lacking. And it maybe that the DU bombs vaporized to date that are greater than or equal to the fall out of 83,000 Hiroshima sized bombs also contained tungsten, I don’t know. The radioactivity trail of the uranium was easier to track.
“Marine Mammal Deaths and Naval Hubris” backs up the validity of my statements regarding marine mammal’s deaths with references. Data provided by the draft EIS/OEIS and a document search regarding the multiple “takings”, i.e. killing, of marine mammals with the use of mid-frequency active sonar use are cited.
These two documents are included as part of my comments for a total of four documents submitted as my Comments on the NWTRC EIS/OEIS draft. (Identified as document 1 of 4 TmkG.)
“Best available science” is often not considered if it is not looked for. Washington State Department of Transportation -WSDOT proved that in their EIS process by only considering comments from Chemicals Corporations on implications or effects of potential harm for humans and aquatic species of their products. Ignored were hundreds of “best available scientific studies” proving the link between the chemical formulations used and their endocrine dysfunction aspects on species exposed. Many of the chemicals in the formulations have been linked with the feminization of males, decreased sperm counts species wide and linked with erect penile dysfunction, testicular cancer in humans and a number of other terminal diseases. Island County had the scientific findings put before them until they stopped using all herbicides for roadside vegetation control.
WSDOT ignored the endocrine dysfunction “peer review scientific studies” submitted that resulted in the Secretary of Transportation requesting an EIS process to look at issues I had raised. Washington Toxics Coalition submitted eighteen pages addressing all of the issues ignored in the EIS and WSDOT, like the Navy is likely to do, deemed the comments “too comprehensive and complete” to be dealt with. The comments were not included in the final EIS document but rather the claim was made that WSDOT was taking care not to harm humans or the environment.
Including a report of a process of framing an EIS so as to not honestly examine very valid issues of potential harm done by WSDOT is not unlike what the Navy is doing with the current NWTRC EIS/OEIS draft. This puts the entire integrity of the process of securing a final NWTRC EIS/OEIS by the U.S. Navy in the column of dishonesty conducted with a lack of valor.
I am skeptical that the Navy will heed the implications of “best available science” because of my experience over seven years in dealing with WSDOT that held itself “an island onto itself”. It took five years of work by a small group of Whidbey Island citizens using “best available science” that resulted in WSDOT now using 30% less toxic chemicals on all State Routes. 2008 use of herbicides is a 70% reduction from the highest amount used in 1993.
It appears that the U.S. Navy does not honor the concept of a Sanctuary nor do they think they are subject to many current laws and international agreement regarding Olympic Coast National Marine Sanctuary - OCNMS. Instead the Navy WANTS every square nautical miles of the 122,440 and have secured a permit to kill, “take” marine mammals if when and where they so choose even from a small part of the totally vast NWTRC area. The OCNMS is only 1.3% of the 122,440 square nautical miles but the U.S. Navy must have even this small part.
Like the claim the Navy is making based on inappropriate scientific studies that no harm will come to humans, marine species, their habitats or the environment. This reasoning lacks Common Sense.
The Endangered Species Act carries fines against anyone, agency or government body who harms the habitat of Chinook salmon or salmonid at $15,000.00 to $25,000.00 per fish. As all of Whidbey Island near shore is Chinook habitat it is especially applicable to this draft EIS proposal. A lawsuit against the Navy for a massive fish kill from a small sized explosion off of NAS Whidbey using one of its smaller bombs does not bode well for endangered Chinook salmon. This fish kill was witnessed. How many are not?
Chinook, Coho, Sockeye, Atlantic, Chum salmon and Steelhead Trout with eight additional species of salmon are listed as Endangered. An additional twenty-five are threatened as the salmon population supports the whale populations which are in serious decline with eighteen marine mammals species listed as Endangered Species. This delicate balance for so many species of marine mammals that are close to tipping into extinction will surely be harmed and extinction hastened by the Navy’s proposed “Preferred Alternative”, its activities and insistence on using the 1.3% of 122,440 square nautical miles of the Olympic National Marine Mammal Sanctuary. Marine mammals and populations of fish in the tens of thousands will be eliminated because naval personnel lacked the will to figure out a way to not do so. This is embarrassing.
I know the Strategic Military Thinking that mandates the U.S. Navy carry out a mission as directed by the Commander in Chief, President Obama. This current draft that we are discussing was started when President Bush held that position. The whole process is flavored with the same hubris President Bush used to fabricate intelligence to take our valued troops to war against a country that had not attacked us on 9-11. Over 500,000 of those very same veterans wounded mentally or physically are currently homeless and denied health care by denying the link between military service and harm. (See www.GulfWarVets.org.)
In the Navy’s EIS scoping process the issue is that inappropriate scientific studies are being use to imply no harm will come to marine species and environment, humans and their environments. Thirty-five and fifty year old reports of studies are so out of date that the use of them as references to validate statements within the NWTRC EIS/OEIS contributes to the hubris that the Navy only need to carry out the form but not the substance of a valid look at what could and will in fact harm marine mammals, aquatic life and degrade the environment so valued by residents of the states impacted.
If it is true and is allowed to stand that President G.W. Bush signed an Executive Order authorizing the National Marine Fisheries Service to issue an LOA authorizing 10 million uses of the U.S. Navy’s new sonar through 2014 contrary to the Marine Mammals Act ensures the Death of The Last of Earth’s Whales and Marine Mammals. The hubris of authorizing the elimination of multiple marine species is a violation of multiple International Treaties, Agreements, Federal law, Federal and State Court decrees and laws of other Countries and their Court’s rulings is unacceptable.
The Navy has committed critical errors of omission of “best available science”, obvious obfuscation of data input and study parameters with the results of science based upon inadequate or comprehensive understanding of the true facts. This disregard of the implications of the effects of these toxic chemicals for multiple species generational integrity is unacceptable. Even if the makers of these agents of death had to fabricate or misdirect research efforts to gain approval and if this was done in the “Name of National Security” no one outside of “Need to Know” would be allowed to “Know”.
Manipulation of science has been done in the past by various aspects of government and the chemical industry. The only lawsuit filed against the Manhattan Project was to protect duPont Chemical Ltd of liability for killing a goat and all life on a New Jersey farm with a fluoride release from their plant making it for atomic bombs. Dr. Harold C. Hodge, chief of fluoride toxicity studies for the Manhattan project became the leading national proponent of fluoridating public drinking water. Dr. Hodge was sent to New York University at Rochester to fabricate science to prove fluoride harmless. Fluoride is not harmless. Reference “Project Censored” USC -Sonoma.
The ultimate result of shortening the lives of those who will be exposed to the toxic exhaust; weapon fragments; radioactive nano particles; salt water columns and bottoms littered with very toxic chemicals, hazardous waste and other byproducts of the U.S. Navy conducting training activity is unacceptable. No valid scientific studies were conducted to prove the assumptions that these materials will not harm marine life.
This lack of ingenuity, creative thinking, innovation and alternatives is disappointing given the good intentions of the majority of our military service naval commanders, officers, service men, women, support staff and support industries. Where is the American can do to preserve life? Has the expectation of acceptable collateral damage of innocents been woven into the military thinking of those we expect to protect us from enemies foreign and domestic?
I do not dispute the mandate given to the U.S. Naval Commander, U.S. Pacific Fleet. I was raised with patriotic pride as the step-daughter of a Korean War Navy veteran; daughter of thirty year Coast Guard cook; sister of brother serving the Navy for six years. My nephew, 20+ years with Army Special Forces has been in Iraq since 2003. I am the grandmother of an Air Force Registered Nurse in Germany and second cousin to Robert Hanley, a former Commander in the Sixth Fleet. I have the highest regard for the U.S. Navy and all who serve our country whether by water, air or land.
I do object to the process, road blocks with the comment computer and limited notice among other issues. Did you confer with Vice President Cheney on how to keep the process secret? The Senators and four Congressmen from Oregon would probably agree as they have written to the Secretary of the Navy to extend the Comment Period to April 11, 2009. They did so citing inadequate notice, restricted comment time and inadequate public meetings. Thank you for extending the comment time if not to April 11 at least to March 11th.
My remarks are limited as I have only had time to read one and one/third volumes. Based upon what I have read and combined with what I know and am providing is but a small part of that knowledge.
I request that there be no expansion beyond the mis-named “No Action” Alternative and that the Navy go back, examine and re-evaluate assumptions being made. I do not know if the Navy ever did a scoping process for the “No Action Alternative” or produced a properly reviewed EIS/OEIS or are attempting to grandfather in what is already taking place. Further investigation of the potential impacts of operating in near proximity to Endangered Species using technology that harms and kills are needed to be carried out by independent “best available scientific studies”.
Knowing that harm and death occur, having gone to the trouble of getting an exception not granted any other organization or government body; knowing that Endangered Marine Mammals follow Endangered salmon through, about and within the NWTRC Study Area activities should be suspended in the areas of sensitivity mid April through mid October. Areas of sensitivity are the traditional ocean to rivers path ways used for hundreds of years by resident aquatic species.
Unless and until recommendations made by Howard Garrett of the Orca Network, the National Resources Defense Council along with the Organizations that signed their submission, Conservation North West and my objections and questions can be addressed on the inadequacy of the NWTRC EIS/OEIS Draft training should stop and or be limited within 300 miles of the Olympic National Marine Mammal Sanctuary. Until these recommendations and questions can be address as submitted by the above organization no expansion should be allowed. Until recommendations can be put into place and appropriate training can be given to Sonar personnel all training should be suspended in critical areas rather than use technology that the Navy knows kills multiple Endangered Species.
Unless you can clone Clark Kent/Superman to be a look out with super sight and listening with super hearing for species that seeks not to be found to be present on sonar duty on all vessels the U.S. Navy should stop “takings” of multiple Endangered Species. How would a “look out” work on submarines? No human can detect marine mammals that are 200 to 300 miles away that are in sonar harm’s way. Current sonar technology does kill and its effects are heard much further than the draft EIS/OEIS admits. A Navy sonar expert has research that shows the sonar is heard 300 miles and maybe more from its source. This was not mentioned in the EIS/OEIS draft.
Please find the will, intelligence and ingenuity that the U.S. Navy is known for and find a way that training can occur and Endangered Species are not “taken” in the process. When did it become okay to kill, harm or damage that which the U.S. Navy is mandated to protect? The lives, environment, way of life and economic violability of multiple communities along the West Coast and within Puget Sound depend upon each of you to find a way to both protect and defend our quality of life. This means living in harmony and without harming our varied marine species, especially those that are threatened and or endangered.
For my part I will continue to communicate to the President, Secretary of State and United Nations members to find non-violent ways to achieve peace and justice. And I will pray that no person serving his Country in the Military will have to kill or be killed. And that no marine mammals ever again come within 300 miles of Navy sonar – an impossible hope.
Please remember that no member of any aquatic species has ever sought to “take” the life of anyone in the U.S. Navy. Please find a way to not have to “take” their lives.
I agree with the Comments submitted by the National Resources Defense Council, Organizations who signed on to their comments, Conservation North West. Please implement their recommendations along with the very intelligent and knowledgeable comments and suggestions made by Howard Garrett.
Please answer the questions I have raised. Please check out the complete reports I have referenced in my two supporting documents.
Thank you for the opportunity to be a part of this process in submitting my four part comments to the NWTRC EIS/OEIS Draft December 2008. I will be sending copies of these documents to my Congressional Representatives, President Obama, other organizations and the media.
More than the average person I know the importance of a well trained and mission ready Navy. I have studied extensively U.S. Strategic National Security theory and tactics; the moral and political thought of Mahatma Gandhi; participated in 1988 at Oxford as part of the Secretariat of the Global Forum on Human Survival of Religious and Parliamentarians on Human Survival; attended the Global Forum on Survival in Moscow in 1990; am the former wife of a Mahatma Gandhi relative; six of my family have served in the military and I joined the Veterans of Foreign Wars Auxiliary in 1970.
I support our troops and I believe that with the will to do so military personnel can do anything. Please create a win win and find ways to train without killing endangered species. The NWTRC EIS/OEIS Draft 2008 is a good beginning but does not represent the quality of work that I know the Navy can perform. I have given weeks of my life that I could have used to promote my just published book. A tenth surgery scheduled this month could be fatal. I have given above and beyond please do the same. Thank you.
Conclusion of Part 1 Introductory Remarks. (Attachment 1 of 2)
Part 2 Comments
Part 3 Experts in Radiation
Part 4 Marine Mammal Deaths and Naval Hubris. (Attachment 2 of 2)
Respectfully submitted,
Theresa Marie K. Gandhi
Whidbey Island Chemically Injured Network
Whidbey Island No Spray
Washington State resident since 1946
Veterans of Foreign Wars 2669 Auxiliary since 1970
Marine Mammal Deaths & Naval Hubris
August 18, 2009 Attachment 2 of 2 to NMFS Comments
Abstract of articles assembled by and comments by Theresa Marie K. Gandhi.
The U.S. Navy is being sued for exploding ordinance in Puget Sound waters near NSA Whidbey, allegedly killing thousands of fish and potentially harming federally protected species such as Chinook salmon, Stellar sea lions, humpback whales and bull trout filed in U.S. District Court in Seattle on July 29, 2008 by Public Employees for Environmental Responsibility (PEER) and the Wild Fish Conservancy. “Juvenile salmon and the food web of Puget Sound would be much better protected if the Navy would simply take the measures suggested by the government’s own scientists," said Kurt Beardslee, executive director of Wild Fish Conservancy.
LOS ANGELES (August 12, 2008) – The U.S. Navy’s use of low and mid-frequency active sonar will remain restricted to certain military training areas of the Pacific Ocean, according to an agreement approved by a U.S. district court in San Francisco today. The comprehensive agreement between the Navy and conservation organizations follows a court injunction issued early this year against the Navy’s Surveillance Towed Array Sensor System Low Frequency Active (LFA) sonar system, which blasts vast areas of ocean with harmful levels of underwater noise. In that decision, the court agreed with a coalition of organizations, led by the Natural Resources Defense Council (NRDC), that the Navy’s proposed LFA deployment in more than 70 percent of the world’s oceans was illegal. A separate lawsuit challenging the U.S. Navy’s use of mid-frequency active sonar is currently under consideration in the U.S. Supreme Court.
“We don’t have to choose between national security and protecting the environment,” said Michael Jasny, senior policy analyst with NRDC. “Today’s agreement maintains the Navy’s ability to test and train, while shielding whales and other vulnerable species from harmful underwater noise.”
Under the agreement, LFA testing and training is limited to defined areas of the North Pacific Ocean, and the Navy must adhere to other protective measures, including seasonal and coastal exclusions that will protect breeding grounds and other important whale habitat.
In Hawaii, for example, LFA training cannot occur near the Hawaii Humpback Whale National Marine Sanctuary or the Papahanaumokuakea Marine National Monument, and is limited to waters beyond 50 nautical miles of the main islands, an area known to contain vital habitat for several unique marine mammal populations.
LFA sonar relies on extremely loud, low-frequency sound to detect submarines at great distances. According to the Navy’s own studies, the LFA system generates noise intense enough to significantly disrupt whale behavior more than 300 miles away. Scientists have observed that, under certain oceanic conditions, sound from a single LFA system could be detected across entire oceans.
“Limiting sonar use in breeding grounds and other key habitat areas is essential for the conservation of whales, dolphins, and other marine mammals,” said Naomi Rose, Ph.D., marine mammal scientist for The Humane Society of the United States (HSUS). “This agreement protects both national security and our most treasured natural resources.”
The lawsuit asserted that a permit issued last year by the National Marine Fisheries Service, allowing deployment of the sonar system around the world, violated a number of federal laws including the Marine Mammal Protection Act and the National Environmental Policy Act. The district court agreed, noting in particular that the government had failed to protect marine life with adequate mitigation measures as required by law. In 2002, this same court held a prior permit unlawful, after which NRDC and the U.S. Navy entered into a negotiated agreement that restricted LFA training from important habitat until last year’s permit was issued.
The coalition consists of the Natural Resources Defense Council, International Fund for Animal Welfare, The Humane Society of the United States, Cetacean Society International, League for Coastal Protection, and Ocean Futures Society and its president and founder Jean-Michel Cousteau.
The military employs two types of active sonar: mid-frequency and low-frequency. Low-frequency sonar travels enormous distances in seawater. During testing off the California coast, noise from SURTASS LFA, the Navy's main low-frequency system, was detected across the breadth of the North Pacific. By the Navy's own estimates, even 300 miles from the source these sonic waves can retain an intensity of 140 decibels -- a hundred times more intense than the level known to alter the behavior of large whales. Mid-frequency sonar is more widely used and has been associated with mortalities of whales.
But stranded whales are only the most visible symptom of a problem affecting much larger numbers of marine lives. In the darkness of the ocean, marine mammals and many fish rely on sound to follow migratory routes, to locate each other over great distances, to find food, to breed and to care for their young. Naval sonar has been shown to disrupt feeding and other vital behavior and to cause a wide range of species to panic and flee. Scientists are concerned about the cumulative effect of all of these impacts on populations of animals.
Numerous mass stranding events and whale deaths across the globe have been linked to military sonar use.
October 1989: At least 20 whales of three species strand during naval exercises near the Canary Islands.
December 1991: Two Cuvier's beaked whales strand during naval exercises near the Canary Islands.
The Canary Islands authorities have asked NATO to halt a naval exercise in the area, fearing it may be responsible for the death of 17 whales washed up on the coast of Fuerteventura and Lanzarote this week. NATO participants included the US frigate De Wert, which specializes in anti-submarine warfare.
May 1996: Twelve Cuvier's beaked whales strand on the west coast of Greece as NATO ships sweep the area with low- and mid-frequency active sonar.
October 1999: Four beaked whales strand in the U.S. Virgin Islands during Navy maneuvers offshore.
May 2000: A beaked whale strands in Vieques as naval exercises are about to begin offshore.
May 2000: Three beaked whales strand on the beaches of Madeira during NATO naval exercises near shore.
March 2000:.13 beaked whales that stranded in the Bahamas in after exposure to active sonar, seven died.
April 2002: A beaked whale and a humpback whale strand near Vieques during an offshore battle group training exercise.
September 2002: At least 14 beaked whales from three different species strand in the Canary Islands during an anti-submarine warfare exercise in the area. Four additional beaked whales strand over the next several days.
May 2003: As many as 11 harbor porpoises beached along the shores of the Haro Strait, Washington State, as the USS Shoup tests its mid-frequency sonar system.
June 2004: As many as six beaked whales strand during a Navy sonar training exercise off Alaska.
July 2004: Four beaked whales strand during naval exercises near the Canary Islands.
January 2005: At least 34 whales of three species strand along the Outer Banks of North Carolina as Navy sonar training goes on offshore.
2008: A federal court prohibits the Navy from conducting major mid-frequency sonar exercises in California without safety measures in place and rejects a White House bid to excuse the Navy from environmental compliance. The Navy petitions to appeal the decision and the case will go before the U.S. Supreme Court during fall 2008.
2008: A federal court limits the regions where low-frequency sonar may be used and deemed certain species-rich areas, such as the Galapagos Islands and the Great Barrier Reef, off-limits.
2006: Two years after an earlier exercise caused the stranding of 200 whales in Hanalei Bay, a federal court halts sonar use during the Navy's massive Rim of the Pacific (RIMPAC) exercise off Hawaii. The Navy agrees to additional mitigation to remove the injunction.
2006: After years of pressure from NRDC, the Navy begins to conduct environmental reviews and seek permits for mid-frequency sonar training off the U.S. coasts. The first review, for a proposed training range off North Carolina, is so heavily criticized that the Navy takes the unusual step of withdrawing it and starting from scratch.
2005: An NRDC-led coalition sues the Navy in U.S. federal court after years of attempts at constructive dialogue could not convince the Navy to take common-sense precautions during peacetime training with mid-frequency sonar.
2004: Responding to NRDC and other groups, a suite of intergovernmental bodies begins to take action on sonar. The European Parliament calls on its 25 member states to stop deploying active sonar without more information about the harm to whales and other marine life. ACCOBAMS, a European agreement for marine mammals, commits to develop guidelines for sonar and other noise-producing activities in the Mediterranean and Black seas. The World Conservation Congress of the World Conservation Union calls for international action.
2003: NRDC wins a major victory when a federal court rules illegal the Navy's plan to deploy low-frequency sonar through 75 percent of the world's oceans. The Navy agrees to limit use of the system to a fraction of the area originally proposed, and that use of low-frequency sonar will be guided by negotiated geographical limits and seasonal exclusions. Ongoing NRDC campaigns have made strides toward requiring the Navy to use proper safeguards when employing sonar.
Naval Sonar Experts Know it Kills Marine Mammals:
Secures Exception to law to Kill, i.e., Take Marine Mammals within Sanctuaries!
July 2002 Surtass LFA was authorized for US naval use, despite having been responsible for the mass death of whales in the Mediterranean and off the Bahamas. Surtass LFA transmits signals as powerful as 215 decibels; a whale's eardrums can explode at 180 decibels. US navy says its use is vital in helping to detect super-quiet submarines.
Since 2002, the National Marine Fisheries Service and the U.S. Fish and Wildlife Service, the two civilian agencies charged with enforcing the Endangered Species Act, have urged the Navy to undertake alternative training practices to minimize damage to marine life, such as using bubble curtains or other containers to minimize blast impacts, or conducting the training in quarries, lakes or the open ocean rather than in the waters of Puget Sound.
Navy Requests LOA for Keyport Range Complex Extension
On July 3, 2008, the U.S. National Marine Fisheries Service provided public notice that the U.S. Navy has applied to NMFS for a five-year Letter of Authorization -LOA for the incidental harassment of marine mammals incidental to the research, development, test, and evaluation (RDT&E) activities within the NAVSEA NUWC Keyport Range Complex Extension. The Navy wants the LOA to cover the period September 2009 through April 2014. If granted, the LOA would be issued under the Marine Mammal Protection Act.
The Navy's application further explains that "the mission activities conducted within the Naval Sea Systems Command (NAVSEA) Naval Undersea Warfare Center (NUWC) Keyport Range Complex and the associated proposed extensions that could result in Level B harassment and possibly Level A harassment."
There are between 700 and 4,000 stranding events per year. Adding the stress of Surtass LFA that transmits signals as powerful as 215 decibels when a whale's eardrums can explode at 180 decibels. And Navy Sonar Experts reporting that marine mammals can hear these transmissions over 300 miles away the number of stranding events will raise and extinction will come faster. The justification for the probable extinction of multiple marine species is that the US navy says its use is vital in helping to detect super-quiet submarines.
This technology could mean the end of whales in our oceans in our lifetime.
Another issue not addressed within the draft EIS/OEIS NWTRC is the effect on the magnetic fields, magma and geological faults within a geologically active region. Repeated undersea sonic pulses from 20 # bombs and frequency penetration could unzip a huge volcanic ridge off the west coast from Vancouver Island south to Oregon.
It has been discovered that sound pulses fired into a similar Indonesian volcanic ridge for oil exploration unleashed the 2004 Tsunami.
Abstract of articles assembled by and comments by Theresa Marie K. Gandhi.
The U.S. Navy is being sued for exploding ordinance in Puget Sound waters near NSA Whidbey, allegedly killing thousands of fish and potentially harming federally protected species such as Chinook salmon, Stellar sea lions, humpback whales and bull trout filed in U.S. District Court in Seattle on July 29, 2008 by Public Employees for Environmental Responsibility (PEER) and the Wild Fish Conservancy. “Juvenile salmon and the food web of Puget Sound would be much better protected if the Navy would simply take the measures suggested by the government’s own scientists," said Kurt Beardslee, executive director of Wild Fish Conservancy.
LOS ANGELES (August 12, 2008) – The U.S. Navy’s use of low and mid-frequency active sonar will remain restricted to certain military training areas of the Pacific Ocean, according to an agreement approved by a U.S. district court in San Francisco today. The comprehensive agreement between the Navy and conservation organizations follows a court injunction issued early this year against the Navy’s Surveillance Towed Array Sensor System Low Frequency Active (LFA) sonar system, which blasts vast areas of ocean with harmful levels of underwater noise. In that decision, the court agreed with a coalition of organizations, led by the Natural Resources Defense Council (NRDC), that the Navy’s proposed LFA deployment in more than 70 percent of the world’s oceans was illegal. A separate lawsuit challenging the U.S. Navy’s use of mid-frequency active sonar is currently under consideration in the U.S. Supreme Court.
“We don’t have to choose between national security and protecting the environment,” said Michael Jasny, senior policy analyst with NRDC. “Today’s agreement maintains the Navy’s ability to test and train, while shielding whales and other vulnerable species from harmful underwater noise.”
Under the agreement, LFA testing and training is limited to defined areas of the North Pacific Ocean, and the Navy must adhere to other protective measures, including seasonal and coastal exclusions that will protect breeding grounds and other important whale habitat.
In Hawaii, for example, LFA training cannot occur near the Hawaii Humpback Whale National Marine Sanctuary or the Papahanaumokuakea Marine National Monument, and is limited to waters beyond 50 nautical miles of the main islands, an area known to contain vital habitat for several unique marine mammal populations.
LFA sonar relies on extremely loud, low-frequency sound to detect submarines at great distances. According to the Navy’s own studies, the LFA system generates noise intense enough to significantly disrupt whale behavior more than 300 miles away. Scientists have observed that, under certain oceanic conditions, sound from a single LFA system could be detected across entire oceans.
“Limiting sonar use in breeding grounds and other key habitat areas is essential for the conservation of whales, dolphins, and other marine mammals,” said Naomi Rose, Ph.D., marine mammal scientist for The Humane Society of the United States (HSUS). “This agreement protects both national security and our most treasured natural resources.”
The lawsuit asserted that a permit issued last year by the National Marine Fisheries Service, allowing deployment of the sonar system around the world, violated a number of federal laws including the Marine Mammal Protection Act and the National Environmental Policy Act. The district court agreed, noting in particular that the government had failed to protect marine life with adequate mitigation measures as required by law. In 2002, this same court held a prior permit unlawful, after which NRDC and the U.S. Navy entered into a negotiated agreement that restricted LFA training from important habitat until last year’s permit was issued.
The coalition consists of the Natural Resources Defense Council, International Fund for Animal Welfare, The Humane Society of the United States, Cetacean Society International, League for Coastal Protection, and Ocean Futures Society and its president and founder Jean-Michel Cousteau.
The military employs two types of active sonar: mid-frequency and low-frequency. Low-frequency sonar travels enormous distances in seawater. During testing off the California coast, noise from SURTASS LFA, the Navy's main low-frequency system, was detected across the breadth of the North Pacific. By the Navy's own estimates, even 300 miles from the source these sonic waves can retain an intensity of 140 decibels -- a hundred times more intense than the level known to alter the behavior of large whales. Mid-frequency sonar is more widely used and has been associated with mortalities of whales.
But stranded whales are only the most visible symptom of a problem affecting much larger numbers of marine lives. In the darkness of the ocean, marine mammals and many fish rely on sound to follow migratory routes, to locate each other over great distances, to find food, to breed and to care for their young. Naval sonar has been shown to disrupt feeding and other vital behavior and to cause a wide range of species to panic and flee. Scientists are concerned about the cumulative effect of all of these impacts on populations of animals.
Numerous mass stranding events and whale deaths across the globe have been linked to military sonar use.
October 1989: At least 20 whales of three species strand during naval exercises near the Canary Islands.
December 1991: Two Cuvier's beaked whales strand during naval exercises near the Canary Islands.
The Canary Islands authorities have asked NATO to halt a naval exercise in the area, fearing it may be responsible for the death of 17 whales washed up on the coast of Fuerteventura and Lanzarote this week. NATO participants included the US frigate De Wert, which specializes in anti-submarine warfare.
May 1996: Twelve Cuvier's beaked whales strand on the west coast of Greece as NATO ships sweep the area with low- and mid-frequency active sonar.
October 1999: Four beaked whales strand in the U.S. Virgin Islands during Navy maneuvers offshore.
May 2000: A beaked whale strands in Vieques as naval exercises are about to begin offshore.
May 2000: Three beaked whales strand on the beaches of Madeira during NATO naval exercises near shore.
March 2000:.13 beaked whales that stranded in the Bahamas in after exposure to active sonar, seven died.
April 2002: A beaked whale and a humpback whale strand near Vieques during an offshore battle group training exercise.
September 2002: At least 14 beaked whales from three different species strand in the Canary Islands during an anti-submarine warfare exercise in the area. Four additional beaked whales strand over the next several days.
May 2003: As many as 11 harbor porpoises beached along the shores of the Haro Strait, Washington State, as the USS Shoup tests its mid-frequency sonar system.
June 2004: As many as six beaked whales strand during a Navy sonar training exercise off Alaska.
July 2004: Four beaked whales strand during naval exercises near the Canary Islands.
January 2005: At least 34 whales of three species strand along the Outer Banks of North Carolina as Navy sonar training goes on offshore.
2008: A federal court prohibits the Navy from conducting major mid-frequency sonar exercises in California without safety measures in place and rejects a White House bid to excuse the Navy from environmental compliance. The Navy petitions to appeal the decision and the case will go before the U.S. Supreme Court during fall 2008.
2008: A federal court limits the regions where low-frequency sonar may be used and deemed certain species-rich areas, such as the Galapagos Islands and the Great Barrier Reef, off-limits.
2006: Two years after an earlier exercise caused the stranding of 200 whales in Hanalei Bay, a federal court halts sonar use during the Navy's massive Rim of the Pacific (RIMPAC) exercise off Hawaii. The Navy agrees to additional mitigation to remove the injunction.
2006: After years of pressure from NRDC, the Navy begins to conduct environmental reviews and seek permits for mid-frequency sonar training off the U.S. coasts. The first review, for a proposed training range off North Carolina, is so heavily criticized that the Navy takes the unusual step of withdrawing it and starting from scratch.
2005: An NRDC-led coalition sues the Navy in U.S. federal court after years of attempts at constructive dialogue could not convince the Navy to take common-sense precautions during peacetime training with mid-frequency sonar.
2004: Responding to NRDC and other groups, a suite of intergovernmental bodies begins to take action on sonar. The European Parliament calls on its 25 member states to stop deploying active sonar without more information about the harm to whales and other marine life. ACCOBAMS, a European agreement for marine mammals, commits to develop guidelines for sonar and other noise-producing activities in the Mediterranean and Black seas. The World Conservation Congress of the World Conservation Union calls for international action.
2003: NRDC wins a major victory when a federal court rules illegal the Navy's plan to deploy low-frequency sonar through 75 percent of the world's oceans. The Navy agrees to limit use of the system to a fraction of the area originally proposed, and that use of low-frequency sonar will be guided by negotiated geographical limits and seasonal exclusions. Ongoing NRDC campaigns have made strides toward requiring the Navy to use proper safeguards when employing sonar.
Naval Sonar Experts Know it Kills Marine Mammals:
Secures Exception to law to Kill, i.e., Take Marine Mammals within Sanctuaries!
July 2002 Surtass LFA was authorized for US naval use, despite having been responsible for the mass death of whales in the Mediterranean and off the Bahamas. Surtass LFA transmits signals as powerful as 215 decibels; a whale's eardrums can explode at 180 decibels. US navy says its use is vital in helping to detect super-quiet submarines.
Since 2002, the National Marine Fisheries Service and the U.S. Fish and Wildlife Service, the two civilian agencies charged with enforcing the Endangered Species Act, have urged the Navy to undertake alternative training practices to minimize damage to marine life, such as using bubble curtains or other containers to minimize blast impacts, or conducting the training in quarries, lakes or the open ocean rather than in the waters of Puget Sound.
Navy Requests LOA for Keyport Range Complex Extension
On July 3, 2008, the U.S. National Marine Fisheries Service provided public notice that the U.S. Navy has applied to NMFS for a five-year Letter of Authorization -LOA for the incidental harassment of marine mammals incidental to the research, development, test, and evaluation (RDT&E) activities within the NAVSEA NUWC Keyport Range Complex Extension. The Navy wants the LOA to cover the period September 2009 through April 2014. If granted, the LOA would be issued under the Marine Mammal Protection Act.
The Navy's application further explains that "the mission activities conducted within the Naval Sea Systems Command (NAVSEA) Naval Undersea Warfare Center (NUWC) Keyport Range Complex and the associated proposed extensions that could result in Level B harassment and possibly Level A harassment."
There are between 700 and 4,000 stranding events per year. Adding the stress of Surtass LFA that transmits signals as powerful as 215 decibels when a whale's eardrums can explode at 180 decibels. And Navy Sonar Experts reporting that marine mammals can hear these transmissions over 300 miles away the number of stranding events will raise and extinction will come faster. The justification for the probable extinction of multiple marine species is that the US navy says its use is vital in helping to detect super-quiet submarines.
This technology could mean the end of whales in our oceans in our lifetime.
Another issue not addressed within the draft EIS/OEIS NWTRC is the effect on the magnetic fields, magma and geological faults within a geologically active region. Repeated undersea sonic pulses from 20 # bombs and frequency penetration could unzip a huge volcanic ridge off the west coast from Vancouver Island south to Oregon.
It has been discovered that sound pulses fired into a similar Indonesian volcanic ridge for oil exploration unleashed the 2004 Tsunami.
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