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I am shocked at the Navy's estimates of the far-reaching harm that will be inflicted on marine mammals during proposed training and testing activities off the coasts of Hawaii, Southern California, the Atlantic seaboard, and the Gulf states from 2014 to 2019, as stated in your Draft Environmental Impact Statements. The projected damage to whales and dolphins is staggering, with 33 million instances of "take" over five years, a vast increase over existing estimates of harm for the same regions. And I am appalled by the level of carnage reflected in these numbers: over 5 million instances of temporary hearing loss, 16,000 instances of permanent hearing loss, almost 9,000 lung injuries, and over 1,800 deaths.
Your analysis fails to present and analyze reasonable alternatives that would significantly reduce the unprecedented level of harm to marine life. The mitigation scheme that the Navy principally relies on centered on the ability of lookouts to detect whales and dolphins will not result in an appreciable decrease in marine mammal injuries. Federal courts have found this same scheme inadequate and ineffective for good reason: it is largely useless in conditions (common at sea) that impair visual surveillance, it is unsuitable for detecting cryptic and deep-diving species that spend little time at the surface and, even if it were fully effective at detecting whales and dolphins, would only protect species from the most serious injuries.
I call on the Navy to identify and set aside areas of high marine mammal density -- acknowledged to be the most effective means of reducing marine mammal injury. If the Navy wishes to be seen as an effective steward of the ocean environment, it simply must take steps to significantly reduce the level of harm that training and testing activities will inflict on marine life.
Thank you for the opportunity to comment.
Here's a video by the NRDC on the effects of high intensity sonar on marine mammals.
Source:
http://switchboard.nrdc.org/...
Whales and dolphins will be harmed more than 14 million times in Southern California and Hawaii waters by proposed Navy training and testing activitiesreleased this week. According to the Navy's draft environmental impact statement for its Hawaii and Southern California activities, 2 million of those 14 million "takes" will result in temporary hearing loss and 2,000 cases of permanent hearing loss. Temporary hearing loss is an incredibly serious issue for animals that use hearing the way we use sight and, in a similar vein, it's likely game over for any whales or dolphins that suffer permanent hearing loss. And speaking of game over, the Navy estimates that its training and testing with explosives will kill 1,000 animals over the next five years.
These numbers are staggering. About five years ago when the Navy analyzed the impact its training would have on Southern California and Hawaii whales and dolphins, it estimated that the animals would be harmed 770,000 times. Now the number has jumped to more than 14 million. While we need to spend more time reviewing the document, it appears that two things are driving this dramatic increase. First, the Navy is planning on ramping up the tempo of its training: more training means more harm to marine mammals. Second, the Navy has made changes to its analysis based on advances in the scientific literature on how noise impacts marine mammals. Every year we learn more about how whales and dolphins are impacted by sounds at much lower intensities than previously thought.
While the Navy's understanding of how much harm it's activities cause marine mammals has increased, it hasn't taken any corresponding steps to minimize this staggering level of harm. It's mitigation protocol remains largely unchanged, with the Navy refusing to set aside areas of high marine mammal density where sonar should not be used. This means sensitive breeding and foraging habitats and biologically unique areas within the training area can still be used for sonar and underwater explosives training. We know that safeguarding specific areas of sensitive habitat is the best way to lessen harm to whales and dolphins from sonar and other activities -- don't use the technology in the same areas where whale and dolphin numbers are high or during breeding seasons. Faced with such incredible numbers and levels of harm, the Navy must do more to identify and set aside portions of its training areas (areas often the size of large states, like California) where it will not conduct training and testing.