Comments on Navy NWTRC draft EIS/OEIS Dec 2008

Comments from Theresa Marie K. Gandhi on Navy NWTRC draft EIS/OEIS Dec 2008
Whidbey Island Chemically Injured Network tm@tmgandhi.com
Comments to NWTRC EIS/OEIS draft December 2008 to conduct training, research, development, testing and evaluation of military hardware, personnel, tactics, munitions, explosives or electronic combat systems. NW Range Complex encompasses more than 122,440 square nautical miles of ocean and inland waters of Puget Sound. The range complex also includes more than 34,000 square nautical miles of airspace.
Achieving the Navy’s mandate and mission by any means necessary begins by mis-labeling the “No Action Alternative” as it is not a “No Action Plan” but continued training as usual.
At the least the U.S. Navy must not expand and adopt “Alternative 1 or 2”. Additionally the training must not take place within the Olympic Coast National Marine Sanctuary.
A search for “best available science” needs to be included even when it proves harm can come from standard operational procedures. Comments from the Orca Network need to be implemented and addressed. Comments from the National Resources Defense Council and organizations signing on to their comments need to be taken into consideration, investigated and recommendation adopted.
Volume 1 p. 3.6-1 Not in the Glossary but buried with the text of the EIS/OEIS draft was found the definition of “littoral zone”. As being: “near shore habitats that includes: islets, headlands, rocky inter-tidal areas, bottom-dwelling algaes (e.g., kelp forests), sea grass beds, soft substrate, estuarine and coastal salt marsh wetland, fjords and beaches. Mid-littoral beach is alternately submerged and exposed for moderate periods of time. In other words the NWTRC Study Area from within Puget Sound and south to California includes and “takes” all beaches and coastal salt march wetlands as would be DESIRED TO USE by the Naval Command. Tourists, residents, seed gatherers, clam diggers and fishermen could be restricted from their usual and accustomed shore line beaches. This could produce economic harm to multiple communities in all states on the West Coast.
Alternative 2 is the Navy’s preferred alternative because it would fully support the type and frequency of activities it believes are required to achieve complete Fleet readiness and allow the U.S. Navy to carry out its mission in the Pacific Northwest. RDT&E activities in the NWTRC are comprised primarily of unmanned aerial system (UAS) and underwater vehicle system activities.
Alternative 2 includes all elements of Alternative 1, plus: Increase the level of training activities over levels identified in Alternative 1; and Implement range enhancements, including: new air and sea surface targets; new electronic signal emitters; development of a small-scale underwater training minefield, and development of a portable undersea tracking range.
But missing in this Alternative is the ability of the Navy to maintain the long-term viability of the range complex while protecting human health and the environment not to mention the viability of fifty-one species of threatened or endangered salmon, aquatic species and marine mammals.
Acknowledge that the Navy is not equipped with the properly trained personnel capable of detecting multi-species who do not want to be detected. This is especially true when conducting training war games with multiple vessels, sonars and disrupted waters.
Make a commitment to further train sonar specialists to be able to detect the very elusive endangered marine species. Do not rely on high-frequency sonar technology to find marine mammals until independent researchers have determined its ability or not to harm the marine mammals in seeking to protect them.
Volume I: Hazardous Materials 3.3
P 3.3-14 Bomb and expended ordnance on the ocean floor would be “widely scattered” and have negligible adverse impacts and possibly some slight benefits.
To average the dispersion through out the whole NW Training Range does not make logical sense. To make the statement that “possibly some slight benefits” from bomb or expended ordnance – flies in the face of logic.
3.3.15 Missile’s solid propellant releasing ……ammonium perchlorate, potassium hydroxide, lithium chloride and other hazardous materials …. are expected to rapidly disperse …. that local concentration will be extremely low ….
Are assumptions that low concentrations will not harm those species exposed to them in their natural habitat? I could not find within the references any, or especially “best available scientific studies” to back up the above claim. To average the dispersion through out the whole NW Training Range without the missiles releasing these chemicals evenly throughout the entire range is not a credible statement.
Marine Mammals are immersed in this now toxic habitat, some consuming krill filter huge amounts of sea water through their consumption body parts.
All aquatic life bio-accumulates up the food chain. I saw no references regarding the possible bonding or absorption or not of these toxic materials to algae, krill or shrimp.
3.3.17 ……. molybdenum, titanium, tungsten or vanadium linked with the assumption that these toxic metals “will eventually oxidize …….. into benign by-products ……
Is an assumption not backed up with long term testing in comparable circumstances? No references could be found citing studies proving these heavy particles will ....... “eventually oxidize…into benign by-products”.

Depleted Uranium: 20-mm cannon shells of depleted uranium, their fragments and nano particles created when exploded are no where dealt with in the entire 1,068 pages. Claiming the depleted means the ordnance is only 60% as radioactive as uranium misses the entire point. Exploding DU weapons creates a nano particle poison gas that is carried on the wind inflicting rapid forming cancers in multiple organ systems in a very short amount of time one body at a time. These would widely disperse within the marine environment and then work their way up the food chain to human consumption aquatic species.
This would hold true for birds, like the ones in Afghanistan sitting on a wire that all fell to their deaths with blood flowing out every orifice after exposure to DU’s explosive poison gas cloud. Unless the bird deaths were from a detonated nuclear bomb that a “boots on the ground” veteran witnessed both in Afghanistan and Iraq. The Bunker Buster Nukes used in Afghanistan were encased in DU. As to whether it was the poison gas from exploded DU or the radioactive cloud from a nuclear weapon encased in DU that impacted and killed birds and humans can not be known by this writer. Afghani walking away from the explosion also had blood pouring from every orifice and died shortly there after according to witnesses with boots on the ground in our military.
See www.willthomasonline.net/investigations -“US Veteran with Boots on the Ground Witnessed……..”. And see also referenced studies in “Experts in DU Radiation” submitted with these comments.

Volume 2: References 8
p. 8-4: Reference cited is 35 years old – Hanson, W.C. 1974. Ecological Considerations of Depleted Uranium Munitions. Report LA-5559 Los Alamos Scientific Laboratory……. did not deal with the nanoparticiles that are created from the explosions of DU munitions. My references of credentialed experts accompany these comments in document called “Experts Reports of Findings on DU……”
The only other reference cited on Depleted Uranium was: “Toque, C. 2006. Marine Environmental Depleted Uranium Survey Report ………Gosport, UK”
p 8-50 “Goertner, J.F. 1982. Predication of underwater explosion safe ranges for sea mammals………. It is hard to image that munitions have not been changed or improved in 27 years. I would think that the Naval Surface Weapons Center would have more recent studies. If so then why was it that this study was referenced?
p 8-56 “Kryter, K.D. W.D. Ward, J.D. Miller and D.H. Eldredge. 1966. Hazardous exposure to intermittent and steady-state noise. …….. Forty-three years there isn’t there a more recent study on this topic?
p 8-87 “Hickie, B.E., R.W. Macdonald, J.K. B. Ford and P.S. Ross, 2007. ‘Killer whales (orcas) face protracted health risk associated with lifetime exposure to PCBs,’ Environmental Science and Technology, 41(18):6613-9,” Using Depleted Uranium with a half life of 40 million years will enable uncountable marine lives to have lifetime (however shortened by the process) exposure when moving through or living near by wherever the U.S. Navy decides to use and leave on the ocean floor those fragments of radioactive weapons. Nanoparticiles dispersion will greatly expand the radioactive areas of the marine environment. See references in “Experts in Radiation….”

3.3.18 Underwater Targets. Airborne and surface emitting magnetic or acoustic signals used in training do not mention the decibels, range or potential harm to marine mammals.
3.3.19 Repeated at the end of multiple paragraphs: ……appeared to be minimal and had no detectable effect on wildlife or sediment quality cites no “scientific studies” over time to prove these repeated assumptions as valid.
3.3.20 Torpedoes. Under the No Action Alternative ……..this will have no measurable impact on the PACNW OPAREA environment. No statement is made regarding the “Preferred Alternative” and the impact than increased use and exposure would have.
3.3.21 ….potentially toxic battery constituents with USEPA water quality criteria …. for protection of aquatic life or “best available literature” ………can not be exceeded once every three years. The preferred alternative would not limit exposure to one battery expended every three years. This is an omission as it is not stated how this limit would be overcome.
3.3.22 3.3.23 Explosive Sonobuoys – Potential Impacts of Detonation Byproducts ….in the water, the charges explode, creating aloud acoustic signal. No decibel readings or range of sound is mentioned thus omission claims no harm when in fact there very well could be. When a 4 # bomb of whatever source exploded underwater near NSA Whidbey 5,000 fish floating on top plus up to 20,000 that had fallen to the bottom were killed and a law suit was filed. This fish kill was witnessed. How many are not? No mention of potentially massive fish kills can be found within these pages. Is it that there are no computer codes to record such events?
3.3.23 3.3.23 – 25 Again with underwater detonations of C-4 there is no measurement of the acoustic signal or of the number of fish or marine mammals that would swim through these regions in the five hours that these exercises take to complete. There was no mention and probably no computer input code for reporting dead fish or marine mammals sighted during or after the exercises are complete for the day in the report filed under “test results”.
(Governor/President Bush’s No Child Left Behind achieved a no drop out rate because the computer code to record “drop outs” was eliminated.)
3.3.24 3.3.26 _.27 Aviation Fuel and Other Propellants …..fuel (dumped over water west of NAS Whidbey) ….dissipates in the air……small number of incidents………neither …….have an measurable impact on the environment. Downwind of this air dissipation the breast cancer rate in San Juan County is the highest of any County in Washington State. Even the Counties closest to Hanford had less. What could be in the air that could cause this…..jet exhaust, fuel dumped more than a few times or maybe exhaust from ships burning bunker diesel fuel?
3.3.25 3.3.28 .29 .30 Bombs, Missiles, Naval Gunfire, Targets and Countermeasures, Torpedoes and Small Caliber Rounds A repeated phrase…..”this increase would not have a measurable impact on the environment.” This statement is contrary to reality. Yet again, no mention of the acoustic byproduct on the resident aquatic life of firing and exploding these weapons ordnances are mentioned.
3.3.26 3.3-31 Underwater Detonations It is good news that the Navy will be relocating this process to Imperial Beach, CA from the near shore of Island and Jefferson County but not good news for marine life off of Imperial Beach. Implications for acoustic harm to marine life from underwater detonations in Imperial Beach, CA are not spoken too nor addressed in the No Action Alternative let alone in the Preferred Alternative.
3.3.27 3.3-32 -37 Repeated…..”will have no impact on the environment from bomb, missiles, etc…..” is not backed up with scientific proof of remarks and assumptions. Again no mention of the acoustical impact on marine life.

Through out the Hazardous Material sections there is an assumption that the toxic materials expended in exploding ordnances will have “no measurable impact of the environment” is not back up with any proof. Instead the Navy takes a particle and averages it dispersal against the whole area when in fact it is not dispersed throughout the whole 122,440 square nautical miles of the NWRRC.

Volume 1: 3.9 Marine Mammals
page 3.9-2 “There are 32 species of marine mammals known to occur in the NWTRC Study Area (Table 3.9-1). Again the “magic math” or “voodoo math” that has 0.00055 of one whale per squared km is not how reality presents itself. Whales and other marine species travel in “pods” and “schools” and occupy concentrated areas that are always moving. The “J” pod of Southern Resident Orcas do not spread throughout the 122,400 squared nautical miles- nm (420,163) square kilometers km of the PACNW OPAREA as shown within the EIS/OEIS draft.
3.9 -17: “Federal Agencies (i.e. U.S. Navy) must consult with NMFS to ensure actions will not destroy or adversely modify the Killer Whales (Orca) Habitat. Critical habitat means a more focused analysis on how the action would alter the habitat and how it will affect ability of habitat to support the populations conservation.”
Critical habitat designation encompasses parts of Haro Strait, waters around the San Juan Islands, the Strait of Juan de Fuca and all of Puget Sound – a total of just over 6,475 km squared …. excluded are 18 military sites covering 290 km squared of the designated area.
How will you warn the marine mammals to not trespass in these 18 “salt water island’s of harm”? Who will you warn Endangered Species to not use their usual and historic marine areas now that the Navy wants to use them to train to kill with weapons of war?

Volume 1 Fish 3.7
3.7-16 ESA Salmon runs overlap from mid May through late October.
Whales follow and feed on salmon, especially ESA listed Chinook salmon. Thus most of NWTRC would be a kill zone for Endangered Species.
Will training be suspended in the areas (all must pass Whidbey Island) where known salmon runs are?
Mitigation Measures, Page 5-23: “Limiting training activities to fewer than 12 months …. would not meet ….. readiness requirement of Navy’s mandate.”
Page 5-24 “Suspending training at night…… Prohibiting or limiting vessels from using MFA sonar in restricted visibility ….. violates international navigational rules… jeopardizes safety of ship and crew.” So much for “Marine Mammal Lookouts” as part of Mitigation Measures.

Volume 2 Appendix E Cetacean Stranding Report
p E-5 “Stranding report ……..Nationwide, between 1995-2004, there were approximately 700-1500 cetacean strandings per year…” Or possibly 13,500 strandings a year and even more for the years 1998, 2003 and 2004 are occurring.
It is known that from 2001 -2004 17,866 cetaceans and 5,928 pinnipeds were stranded. In three years from just two species the total is 27,794 strandings. Or 927 strandings per year.
Figure E-1 p E-6 Number of Stranding (Level A Data) shows: 1998 about 4500; 2003 about 4500 and 2004 about 4,000 a year. (The Figure did not allow an accurate number to be determined.) This seems like huge numbers of strandings are occurring. Are these mammal lives so discard-able that NMFS would give the Navy an LOA to “take”, harm and or kill, as the Navy pleases within Sanctuaries designated to insure marine mammal survival?
Source: Table E-1 page E-5 NMFS. Orca population in 1996 was 96 and has recovered to 87 animals within Puget Sound.
With increased terror producing underwater weapons and sonar this kill “take” rate per year can only increase. Five years another 45 marine mammals could be dead. If within the Orca population that could mean they are below the number needed to survive as a species.
Conclusions:
p E-22 “Subarachnoid and intracochlear hemorrhages were believed to have occurred prior to strandings and were hypothesized as being related to an acoustic event. ….no large-scale acoustic activity besides the Navy sonar exercise occurred in the time surround the stranding events.”
The U.S. Navy knows these facts related within the draft EIS/OEIS. Navy experts have reported on studies that show the ability of marine mammals to hear at greater distances than is admitted to within this draft up to 300 miles and maybe even further. And yet the Navy sought, most likely with the Bush administration’s help, a license to “take” i.e. kill marine mammals within their designated Sanctuaries. So with 122,440 square nautical miles the Navy must also use a very small portion of this total that is set aside for marine mammals in order to accomplish it’s training mission. At the least the Commander who is enabling this to happen should be ashamed. To those of us who are patriots and whose immediate family members have served, (42 years for my immediate family) in the Navy and Coast Guard, it shows a disregard for life that is near to extinction. Where is your courage of imagination to enable mission readiness and marine life to both win?

Volume 2 Draft EIS/OEIS December 2008
Mitigation Measures 5
P 5-23; 2nd line, third paragraph: “However, the fall habitat requirements for most marine mammals in NWTRC are unknown.” It is known that salmon migrate from mid April to mid October to and from historic spawning rivers and streams. Marine Mammals will be within Puget Sound and off of West Coast rivers following their desired aquatic food, i.e. Chinook and other Endangered Salmon species. March 8, 2009 two grey whales were spotted between Whidbey Island and Everett. This is very early for such a sighting. With global warming this could become more common for this and other species of "whales".

Volume 2 Other Considerations 6
p 6-2 Securing a LOA under Section 7 of the Marine Mammal Protection Act …..to permit “takes” as appropriate within the two Marine Mammal Sanctuaries in the NWTRC so as to not limit nor constrain the Navy’s DESIRED use of the entire NWTRC area even though the Sanctuaries are small areas compared to the totality of the huge NWTRC Study Area is an unconscionable act of planned Endangered Species Extinction. Such hubris shows a lack of imagination, creativity or even strategic planning. If the Naval Commander could look into the eye of a terrorized whale who was experiencing trauma and maybe even death from a state sponsored terrorist act against an ocean resident mammal within a designated sanctuary he might find the will to plan training activities in a different manner.
If an “Axis of Evil Nation-State or “Terrorist” would propose and or do the same we would declare war against them. Only our own military has the right to “take” harm unto death, designated Endangered marine mammals within their designated protected habitats and “Sanctuaries”.
If it is true that President Bush signed an Executive Order giving the U.S. Navy authorization to use marine mammal killing sonar ten million times in five years then multiple extinction events can be expected sooner rather than later.
What is your budget for true mitigation and replacement of dead or extinct marine mammals? Will you create a huge salt water inland sea in Utah beyond the reach of sonar that kills?
As one of two survivors of ten dead within a cancer cluster I can identify with marine species who die because the Navy must have every square nautical mile available for their use even when the activities planned will kill protected and endangered species even to extinction.
6.3 page 6-6 “Construction of the shallow water minefield would cause short term and temporary impacts during construction” Not addressed are the explosive and acoustic effects from any explosions within the shallow water minefield.
6.3 page 6-6 “No habitat associated with threatened or endangered species would be lost as result of implementation of the Proposed Action.” An yet within two designated Marine Mammals Sanctuaries the Navy applied for and secured an LOA in order to “take”, i.e. kill, harass or harm marine mammals. These restrictions were put into place because of threatened habitat and Endangered Species status of marine mammals.
Everyone except the U.S. Navy is required by law to respect, honor and protect these multiple marine mammal species and their prey, i.e. Chinook and other salmon.

Volume 2: References 8
Page 8-46. “Everitt, R.D., C.H. Fiscus, and R.L DeLong 1979. Marine mammal of northern Puget Sound …….November 1, 1977…..NOAA ……….
The populations are no longer the same as they were 32 years ago. Is there no more recent “report on investigations”?