The Navy has opened public comments on their Atlantic Fleet Training and Testing (AFTT) Environmental Impact Statement (EIS)/Overseas Environmental Impact Statement. Comments must be postmarked or received online by August 29, 2017 to ensure that your concerns are considered and addressed in the Final EIS/OEIS.
You can post your online comments at the Navy's EIS web site here
The Navy offers three choices for action that they ask those who submit comments to choose from. I picked this one:
No Action Alternative – Under this alternative, the Navy would not conduct proposed training and testing activities, and a permit under the Marine Mammal Protection Act would not be issued.
The Navy is required by law to go through the EIS process before they can begin holding their new round of war games in the ocean including testing sonar in the southeast (Florida-Georgia coast) which happens to be the prime breeding ground of the North Atlantic Right Whale - one of the most endangered whales of all.
This proposed 'Atlantic Fleet Training and Testing' program will lead to the deaths of much sea life.
If you'd like more information about this you can watch artist/activist Russell Wray from Maine (who painted the banner above). You can see my recent public access TV interview with Russell here
Even though these EIS processes never really influence the Navy they are still a useful tool for educating the public about how these military war games impact sea life. So please help spread the word and send in your comments ASAP - tell the Navy - No Action Alternative!
Bruce
8 comments:
Posted the same absolutely not comment you did. This insanity must stop.
I sent the provided suggestion. Thank you.
This is silly. No one expects the Navy to stop training. Also, recommend you read the document first - your statement is misleading. The analysis does not show massive deaths in the ocean, as you put it. Just the opposite, shows the impacts are minor and transient, and no impacts to the right whale (the Navy has been training in those waters for over 100 years, the real threat to the right whale is commercial shipping). What you want is to end the military. If that's your goal, then be up front about it, but don't hide behind a fake concern over marine life. If you really are concerned about marine life, then focus on the real danger to marine life - commercial fishing, which kills hundreds of thousands of marine mammals and turtles every year, which is thousands of percent greater than any deaths caused by the Navy, and commercial shipping, that strikes hundreds of whales a year.
Bruce, thank you for posting this and bringing people's attention to the Navy's Atlantic Fleet Training and Testing. You were very right in stating that the Navy is required by law to go through the EIS process. Unfortunately for all of us, that process, as undertaken by the Navy, has consistently avoided doing what it is meant to do: investigating what the impacts to the environment will likely be from the proposed activities of the Navy. Instead, the Navy routinely underestimates behavioral disturbances, stress, injuries and mortalities in marine animals. It somehow, apparently magically, concludes that impacts to already endangered species such as the critically endangered North Atlantic right whale will be negligible, and will have no population level effects. It underestimates how its activities degrade sediments and water quality, explaining that pollutants will be dispersed and diluted, as if those pollutants just magically disappeared.
The Navy's EIS process fails to meet the standard of investigation required by law. In fact, it really is not an investigation...it is a document produced so as to make it appear as if the Navy has complied with the law. The Public Comment aspect of the EIS process is as much of an illusion as is its so-called investigation. Here, the Navy routinely ignores or dismisses comments and concerns addressed to specific issues in the EIS, which the law requires the Navy to directly respond to. In effect, the entire EIS process, as carried out by the Navy, is a sham. If our courts took US law more seriously, the Navy would not be allowed to get away with it.
As for what the anonymous commenter above had to say...I am curious if he or she actually read the entire document as anonymous recommends you do. Somehow, I doubt it. Its pretty lengthy. But the commenter is correct in stating that " the analysis does not show massive deaths in the ocean" and that impacts are "minor and transient". But, as I mentioned above, the Navy's so-called analysis is a sham. And, for the commenter's information, the Navy has killed right whales, by ship strike, and very likely through its use of explosives. Take, for example, the headless right whale calf found in the Gulf of Maine near the Sharrer Ridge Navy bombing range in 2002, and the 6 dead right whales found in 1997 near the Navy's gunnery and bombing exercises off of the right whale's calving grounds. Necropsies performed on 2 of those whales showed ear injuries, and the cause of death was likely barotrauma, which can result from an explosive blast.
Anonymous is correct in stating commercial shipping's threats to right whales, but that is no reason to ignore the Navy's threats. The same is true with threats from commercial fishing. Commercial fishing and shipping are both very large threats to marine mammals...but so is the Navy.
Anonymous states that no one expects the Navy to stop training...well, I don't expect it will, but it could start to train and test in a way which genuinely minimizes impacts to the environment. It is doing nothing of the sort now.
Russell Wray may have a strong opinion as to whether he believes the Navy's analysis is scientifically sound, but that's all it is - an opinion. Mr. Wray provides absolutely no proof to support his claims that the Navy is "understating" the impacts from their activities. I read the Ph II document, intend to read the ph III document, including the technical reports on how impacts are assessed using modeling and peer-reviewed analysis.
Did you know the Navy has third-party scientists review their findings? Did you know the Navy is the leading organization in the U.S. that funds marine mammal research of acoustic impacts (70% of US funding, and 50% of global funding)? That this research is carried out by prestigious academic institutions such as Duke University and Woods Hole?
If you read the technical reports behind the analysis, you would see that the Navy actually overstates the potential impacts by quite a bit. The Navy uses many very conservative assumptions behind their analysis.
When was the last time the Navy actually struck a right whale? I believe it has been close to 20 years now. Did you know the Navy was the major contributor to the right whale warning network which provides notice to all vessels as to the location of right whales off the coast of Florida? Did you know that the Navy does NOT train in the calving area of the right whale during calving season, but instead sails over 30 miles off the coast instead?
Other than innuendo, what proof do you have that the Navy was responsible for any of the deaths you comment on? Was the navy training on the days in question? When was the last time the navy even used a bombing range in Maine? There hasn't been a base up there for years. And what bombing range are you referring to in 1997? The only range in the south our terrestrial and near Vieques, which by 1997 was already nearly shut down.
The ear damage was blast injury? Can you back that up? Generally, ear damage from a whale results from decompression, and it may have nothing to do with the Navy. I checked the National Marine Fisheries Service website regarding unusual stranding events and saw nothing that implicates the Navy regarding right whale deaths. In fact, the last Government vessel to strike a right whale was NOAA's own research vessel, not the Navy.
Again - no proof.
And are you a naval expert? I am curious what you know about naval training, and what the Navy can do to "minimize impacts" that it isn't doing already? Did you read the document? There is an entire chapter (5) that discusses their mitigation, which is more than most any other organization, and is more than any other Navy in the world (since the U.S. Navy is the only externally regulated navy in the world - did you know that?).
Careful with unsupported and baseless allegations.
To Mr. Wray, what you provide is much allegation, but little proof.
I have read the document, have you? Have your read the technical reports that explain exactly how the Navy conducted its analysis, including having it peer-reviewed by independent scientists? The Navy's report evidences that the analysis actual overstates the potential impact by building a number of very conservative assumptions.
You have absolutely no proof that the Navy was responsible for the deaths you reference in your opinion. The Navy has not used a range in Maine in a long time since there isn't much navy there other than submarines, and they don't go around "bombing" things as you note, and there is no "bombing range" where the right whale calves in the southeast. There is one on land in Florida (clearly the right whale is not a terrestrial species), and Vieques was already nearly shut down by 1997, and which is NOT a right whale habitat. And what evidence do you have that the ear damage was acoustic? Whale ear damage is generally a result of decompression, not from impulsive sound. I have found absolutely no evidence that the Navy was even present, let alone responsible for the deaths you reference. So I am afraid you'll have to try again.
The Navy hasn't struck a right whale in over 20 years, which is something we can't say for NOAA, which ironically regulates right whales.
Instead the Navy is the single largest contributor to marine mammal research in the US (70% of all funding) to prestigious organizations such as Duke University and Woods Hole. The Navy has an entire chapter on mitigation that I recommend you read before opining about what the navy can do to reduce impacts.
I generally caution against baseless accusations.
Anonymous, the Navy does not overstate the potential impacts to marine life. It says it does, but I think that this is incorrect due to the unrealistically high thresholds it has created for injury, hearing loss, and behavioral change. Were those thresholds to be set realistically, based on the best available science, the levels of estimated takes would be greatly increased. Contrary to its claim, the Navy is not conservative in its analysis.
I am quite aware that the Navy funds much of the research on marine mammals. However, it is well known that in some cases, there is a tendency of a scientific study to show results that support the interests of the funder. I am not saying that all Navy funded research does this, but I think it is naive to believe that all research funded by the Navy on acoustic impacts on marine life is free of this bias. A little skepticism is pretty healthy. Especially when one considers how dominant the Navy is in this field.
As far as I know, the last right whale killed by the Navy as a result of ship strike happened in 2004. A Navy Amphibious Assault Ship struck it about 10 miles outside the entrance to Chesapeake Bay, and the whale later washed ashore on the Outer Banks of North Carolina.It was a pregnant female, so the Navy actually killed two right whales with one ship.
Continued from above comment.
While you are correct in stating that the Navy does not train in the calving area of the right whale during calving season as defined by the Navy, it does in fact train in waters near the officially designated calving grounds. The Navy also intends to train year round in its Undersea Warfare Training Range, which is now under construction and is just offshore of the designated calving grounds. What is important to say here is that, while the Navy defines the calving season and area in a specific way, right whales don’t necessarily stick to the Navy’s standards. Right whales have been, and will continue to be in those calving grounds even outside of the human defined calving season. They will also continue to give birth to and care for their young in areas outside of the human defined calving area. Beyond that, the Navy does not have to train within the human defined borders of the calving area to impact the whales that may be inside that area. Noise from sonar and explosives and aircraft and vessels travels through the water, and sometimes for very considerable distances.
You mention that vessels sail over 30 miles off the coast to train. Right. And those vessels represent quite a threat to the right and other whales in terms of ship strike. In fact, the National Marine Fisheries Service, in its biological opinion for the range, concluded that "ship strikes seem almost inevitable." Navy vessels will transit between the range and bases in Florida and Georgia, directly through the calving grounds.
The necropsy done on the right whale in 1997 did indeed find evidence of barotrauma, which could result from an explosive blast. While it is not absolute proof, it is a pretty good indication that the whale’s death may have occurred directly because of the Navy’s exercises… unfortunately for us, but fortunately for the Navy, the Navy’s victims don’t come with little signs on them that state “I was killed by Navy exercises.”
The headless right whale calf was discovered by NMFS in June of 2002. It was discovered just to the south of where the Navy later admitted to engaging in live-fire bombing exercises in the Gulf of Maine.So yes, the Navy was training shortly before the dead calf was found. While the body of the calf was too badly decomposed to allow for a necropsy, and no direct evidence was found linking its death to the exercises, the possibility remains that its head was blown off by a direct strike.
There is a huge amount the Navy could be doing to lessen its impacts on marine life.Its current mitigation is entirely deficient, for a number of reasons. It is widely recognized that one of the most effective mitigation measures is simply avoiding those areas where and when there are likely to be vulnerable species present. The Navy does not use this mitigation nearly as much as it could and should. There are many, many other mitigation measures that the Navy could put into effect that would reduce negative impacts, but it does not seem to be interested.
You ask if I’m a naval expert. No, I’m not. Nor am I a scientist. But I have been involved in this issue for many years now and know something about it. And really, it does not take a rocket scientist to understand that when you are blasting extremely intense noise into the oceans, it will impact many of the animals who live there, and not in a good way. A child understands that.
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