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Cook
Inletkeeper Watershed Watch
Navy Bombing
& Training Exercises
in Gulf of
Alaska
THE ISSUE:
The U.S. Navy is planning to expand military training exercises
across 42,000 square miles of the Gulf of Alaska, which would
involve a massive armada with live fire munitions, hazardous
waste dumping and underwater sonar known to harm marine mammals.
Now, the Navy wants a permission from the National Marine
Fisheries Service (NMFS) under the federal Marine Mammal
Protection Act to “take” over 425,000 marine mammals each year
for five years. See
www.nmfs.noaa.gov/pr/permits/incidental.htm
BACKGROUND:
The U.S. Navy released a Draft Environmental Impact Statement (DEIS)
in late 2009 covering various alternatives for continuing to use
the Gulf of Alaska (GOA) and its rich fisheries as a military
bombing range and training area. The Navy plans to introduce –
for the first time – extensive sonar training in the GOA; its
preferred alternative would use many different sources of active
sonar, totaling over 1,160 hours of sonar use every year. The
Navy also plans to abandon at least 352,000 pounds of spent
material (both hazardous and non hazardous) in the GOA every
year; over 10,300 pounds of this expended material is hazardous
waste. These proposed sonar training activities would pose
significant risk to whales, fish, and other wildlife that depend
on sound for breeding, feeding, navigating, and avoiding
predators—in short, for their survival. The GOA training
activities would also affect fisheries and essential fish
habitat by releasing large amounts of hazardous and expended
materials into the waters.
SEND COMMENTS TO:
Michael Payne, Office of Protected Resources, National Marine
Fisheries Service, 1315 East-West Highway, Silver Spring, MD
20910-3225. Email: PR1.0648-XU14@noaa.gov
Talking Points:
(Adapted from
information provided by the
Natural Resources Defense Council)
-
The Navy estimates that its sonar
training exercises in the GOA from its Preferred Alternative
(Alternative 2) will result in more than 425,000 marine
mammal "takes" (behavioral impacts, harassment, injury,
death) every year - that's over 2.125 million takes during
the course of the Marine Mammal Protection Act permit it
must seek from NOAA. In all, the Navy expects to "take"
more than 20 different species of marine mammals, including
7 endangered species, in the GOA. Nearly all of the
mitigation measures that the Navy has proposed for the GOA
concern the operation of a small "safety zone" around the
sonar ship. Yet it is widely agreed in the scientific
community that this measure is inadequate given the
far-reaching effects of Navy sonar and the difficulty of
spotting marine mammals from fast-moving vessels. The Navy
has not proposed to establish any protection areas in the
GOA, despite the broad recognition that geographic
protection zones are the most effective available means to
mitigate sonar's impacts on marine wildlife. For
example, no protection areas are proposed for harbor
porpoises, which are acutely sensitive to sound; for
endangered gray whales, which migrate directly through the
TMAA; for endangered humpback whales and blue whales, which
gather to feed in the TMAA; for the critically endangered
North Pacific right whale, who's critical habitat is
directly adjacent to the TMAA; or for any other species or
habitat.
-
The Navy does not properly analyze
environmental impacts. For instance, it completely
disregards the serious impacts its sonar training will have
on the critically endangered North Pacific right whales,
whose critical habitat is only 12 nautical miles from the
training area or the endangered gray whales, which migrate
through the training area. Furthermore, it fails to discuss
and analyze the cumulative effects its activities may have
in conjunction with other projects and activities in the
area.
-
The Navy underestimates the number of
marine mammals (and fish) that will be harassed, injured and
killed because it simply does not have the density estimates
needed in order to accurately make this determination. The
National Environmental Policy Act (NEPA) specifically
requires federal agencies to obtain the data necessary to
their analysis. The simple assertion that "no information
exists" will not suffice; unless the costs of obtaining the
information are exorbitant, NEPA requires that it be
obtained. See 40 C.F.R. § 1502.22(a).
-
The Navy's acoustics impact analysis
ignores scientific studies contrary to its interests and
uses methodologies not supported by the scientific
community. Thus, the thresholds it sets for permanent
injury, temporary injury (hearing loss) and behavioral
change (which we would argue are too high and thus
completely underestimate the actual number of wildlife that
will be impacted) are invalid as a matter of science.
-
The Navy's alternative analysis is
inadequate. The Navy only presents three options - maintain
the status quo, add more training, or add even more
training. It does not consider - or blithely dismisses - any
other alternatives, some employed by the Navy itself in
other training exercises and ranges.
-
Most critically, the Navy does not set
forth adequate measures to mitigate the harmful effects of
sonar. Its proposed mitigation measures basically boil down
to "safety zones" (1,000 yard power-down and 200 yard shut
down) around the sonar maintained primarily by on-board
visual monitors. These are the same measures that federal
courts have found to be "woefully inadequate and
ineffectual." (For instance, studies show that visual
monitoring only spots about 5% of marine mammals.
Statistically, a 5% "success" rate clearly does not cut it.)
The Navy's refusal to employ better mitigation measures is
astounding, because it has used more protective measures
during previous training.
For more in-depth
information on the impacts of these proposed activities, see:
Comments from Natural Resources
Defense Council
Comments from Trustees for
Alaska
Comments from
Ocean Conservation Research
For more information:
Contact Cook Inletkeeper at 907.235.4068 x22;
keeper@inletkeeper.org
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