Important-time sensitive: Navy sonar expansion into orca territory
Naval Facilities Engineering Command Northwest,
Attention: Mrs. Kimberly Kler-NWTRC EIS/OEIS,
1101 Tautog Circle, Suite 203,
Silverdale, WA 98315-1101.
The Navy is planning to vastly expand its training activities in the Northwest Training Range Complex to include the north end of Admiralty Inlet and eastern Strait of Juan de Fuca and much of Washington (out 200 miles), Oregon and part of California coastlines, including the Olympic National Sanctuary(?).
When comments are made, in addition to recommending a "No Action Alternative," the Navy should improve the mitigation measures to include training by experienced whale biologists of monitoring personnel to improve recognition of marine mammals by visual and acoustic monitoring. The Navy has issued a "whale protection" wheel device with tiny graphics of ten whale species (not including orcas) and written descriptions of blows, backs and flukes, but it is not likely to be much use even in normal sea-state conditions. Recognizing acoustic calls is difficult in calm conditions, in ever shifting currents and thermoclines. These exercises would take place in the midst of multiple ships and high-powered and explosive sonars and munitions, making recognition virtually impossible.
Even with the best monitoring by experienced people, the mitigation measures are woefully inadequate. It's almost impossible to reliably detect marine mammals visually or acoustically underwater or in rough weather, especially when compounded by training conditions.
Given the current status of international tensions, homeland security will probably trump the minor matter of exploding and polluting our planet and its inhabitants beyond all recognition.
The challenge is to halt the need for these training exercises altogether, which is a problem of international relations and diplomacy. Our new president and Sec. Clinton can prevent this particular travesty by ending US government complicity in global corporate criminality, thus fostering improved international communications. It can't be that hard.
In the meantime, the new administration can possibly delay the start of training (NOAA has to comment on it, and the new NOAA administrator, Jane Lubchenco, is a marine biologist(!) with strong enviro cred, and eventually remove the need for it.
While recognizing the need for readiness through training, the No Action Alternative is all that we can support due to lack of information available to assess the impact on numerous endangered and declining marine species, especially with proposed testing of new systems.
See Navy training expansion draws criticism Coupeville Examiner, Feb. 5, 2009.
Below are some of the pearls in the IES:
4.2.6 Marine Plants and Invertebrates Potential cumulative impacts on marine plants and invertebrates in the NWTRC include releases of chemicals into the ocean, introduction of debris into the water column and onto the seafloor, and mortality and injury of marine organisms near the detonation or impact point of ordnance or explosives. Materials expended during training include sonobuoys; parachutes and nylon cord; towed, stationary, and remote-controlled targets; inert ordnance; unexploded ordnance, and fragments from exploded ordnance, including missiles, bombs, and shells. Materials include a variety of plastics, metals, and batteries. Most of these materials are inert and dense, and will settle to the bottom where they will eventually be covered with sediment or encrusted by physical or biological processes.
D.2.2 Explosives
Explosives detonated underwater introduce loud, impulsive, broadband sounds into the marine environment. Three source parameters influence the effect of an explosive: the weight of the explosive material, the type of explosive material, and the detonation depth. The net explosive weight (or NEW) accounts for the first two parameters. The NEW of an explosive is the weight of TNT required to produce an equivalent explosive power. The detonation depth of an explosive is particularly important due to a propagation effect known as surface-image interference. For sources located near the sea surface, a distinct interference pattern arises from the coherent sum of the two paths that differ only by a single reflection from the pressure-release surface. As the source depth and/or the source frequency decreases, these two paths increasingly, destructively interfere with each other, reaching total cancellation at the surface (barring surfacereflection scattering loss).
For the NWTRC there are three types of explosive sources: AN/SSQ-110 Extended Echo Ranging (EER) sonobuoys, demolition charges, and munitions (MK-48 torpedo, Maverick, Harpoon, HARM, HELLFIRE and SLAM missiles, MK-82, MK-83, MK-84, GBU-10, GBU- 12 and GBU-16 bombs, 5-inch rounds and 76 mm gunnery rounds). The EER source can be detonated at several depths within the water column. For this analysis a relatively shallow depth of 20 meters is used to optimize the likelihood of the source being positioned in a surface duct. Demolition charges are typically modeled as detonating near the bottom. For a SINKEX the demolition charge would be on the hull. The MK-48 detonates immediately below the hull of its target (nominally 50 feet). A source depth of 2 meters is used for bombs and missiles that do not strike their target. For the gunnery rounds, a source depth of 1 foot is used. The NEWs for these sources are as follows:
. EER Source—5 pounds
. Demolition charge—10 pounds in Explosive Ordnance Disposal (EOD), 100 pounds in a sinking exercise (SINKEX)
. MK-48—851 pounds
. Maverick—78.5 pounds
. Harpoon—448 pounds
. HARM—41.6 pounds
. HELLFIRE—16.4 pounds
. SLAM—164.25 pounds
. MK-82—238 pounds
. GBU-10—945 pounds
. GBU-12—238 pounds
. GBU-16—445 pounds
. 5-inch rounds—9.54 pounds
. 76 mm rounds—1.6 pounds
The exposures expected to result from these sources are computed on a per in-water explosive basis. The cumulative effect of a series of explosives can often be derived by simple addition if the detonations are spaced widely in time or space, allowing for sufficient animal movements as to ensure a different population of animals is considered for each detonation. The Navy prepared and filed with the U.S. Environmental Protection Agency a Draft Environmental Impact Statement/ Overseas Environmental Impact Statement (EIS/OEIS) for public release on December 29, 2008. The National Marine Fisheries Service (NMFS) is a Cooperating Agency for the EIS/OEIS. The Draft EIS/OEIS evaluates the potential environmental effects of maintaining Fleet readiness through the use of the Northwest Training Range Complex (NWTRC) to support current, emerging, and future training activities. The proposed action serves to implement range enhancements to upgrade and modernize range capabilities within the NWTRC, thereby ensuring critical Fleet requirements are met. Federal agencies, State agencies, and local agencies and interested individuals are invited to be present or represented at the public hearings. Navy representatives will be available during the open house sessions to clarify information related to the Draft EIS/OEIS.
In regard to marine mammals and their habitat:
"The Draft EIS addresses potential environmental impacts on multiple resources, including but not limited to: Air quality; water resources; airborne acoustic environment; biological resources, marine and terrestrial; cultural resources; socioeconomics; and public health and safety. No significant impacts are identified for any resource area in any geographic location within the NWTRC Study Area that cannot be mitigated, with the exception of exposure of marine mammals to underwater sound. The Navy has requested from NMFS a Letter of Authorization (LOA) in accordance with the Marine Mammal Protection Act to authorize the incidental take of marine mammals that may result from the implementation of the activities analyzed in the NWTRC Draft EIS/OEIS. In compliance with the Magnuson- Stevens Fisheries Conservation Management Act, the Navy is in consultation with NMFS regarding potential impacts to Essential Fish Habitat. In accordance with section 7 of the Endangered Species Act, the Navy is consulting with NMFS and U.S. Fish and Wildlife Service (USFWS) for potential impacts to federally listed species. The Navy is coordinating with the Washington Department of Ecology, the Oregon Department of Land Conservation and Development, and the California Coastal Commission for a Coastal Consistency Determination under the Coastal Zone Management Act for each respective state."
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D.2.2 Explosives
Explosives detonated underwater introduce loud, impulsive, broadband sounds into the marine environment. Three source parameters influence the effect of an explosive: the weight of the explosive material, the type of explosive material, and the detonation depth. The net explosive weight (or NEW) accounts for the first two parameters. The NEW of an explosive is the weight of TNT required to produce an equivalent explosive power. The detonation depth of an explosive is particularly important due to a propagation effect known as surface-image interference. For sources located near the sea surface, a distinct interference pattern arises from the coherent sum of the two paths that differ only by a single reflection from the pressure-release surface. As the source depth and/or the source frequency decreases, these two paths increasingly, destructively interfere with each other, reaching total cancellation at the surface (barring surfacereflection scattering loss).
For the NWTRC there are three types of explosive sources: AN/SSQ-110 Extended Echo Ranging (EER) sonobuoys, demolition charges, and munitions (MK-48 torpedo, Maverick, Harpoon, HARM, HELLFIRE and SLAM missiles, MK-82, MK-83, MK-84, GBU-10, GBU- 12 and GBU-16 bombs, 5-inch rounds and 76 mm gunnery rounds). The EER source can be detonated at several depths within the water column. For this analysis a relatively shallow depth of 20 meters is used to optimize the likelihood of the source being positioned in a surface duct. Demolition charges are typically modeled as detonating near the bottom. For a SINKEX the demolition charge would be on the hull. The MK-48 detonates immediately below the hull of its target (nominally 50 feet). A source depth of 2 meters is used for bombs and missiles that do not strike their target. For the gunnery rounds, a source depth of 1 foot is used. The NEWs for these sources are as follows:
. EER Source—5 pounds
. Demolition charge—10 pounds in Explosive Ordnance Disposal (EOD), 100 pounds in a sinking exercise (SINKEX)
. MK-48—851 pounds
. Maverick—78.5 pounds
. Harpoon—448 pounds
. HARM—41.6 pounds
. HELLFIRE—16.4 pounds
. SLAM—164.25 pounds
. MK-82—238 pounds
. GBU-10—945 pounds
. GBU-12—238 pounds
. GBU-16—445 pounds
. 5-inch rounds—9.54 pounds
. 76 mm rounds—1.6 pounds
The exposures expected to result from these sources are computed on a per in-water explosive basis. The cumulative effect of a series of explosives can often be derived by simple addition if the detonations are spaced widely in time or space, allowing for sufficient animal movements as to ensure a different population of animals is considered for each detonation. The Navy prepared and filed with the U.S. Environmental Protection Agency a Draft Environmental Impact Statement/ Overseas Environmental Impact Statement (EIS/OEIS) for public release on December 29, 2008. The National Marine Fisheries Service (NMFS) is a Cooperating Agency for the EIS/OEIS. The Draft EIS/OEIS evaluates the potential environmental effects of maintaining Fleet readiness through the use of the Northwest Training Range Complex (NWTRC) to support current, emerging, and future training activities. The proposed action serves to implement range enhancements to upgrade and modernize range capabilities within the NWTRC, thereby ensuring critical Fleet requirements are met. Federal agencies, State agencies, and local agencies and interested individuals are invited to be present or represented at the public hearings. Navy representatives will be available during the open house sessions to clarify information related to the Draft EIS/OEIS.
In regard to marine mammals and their habitat:
"The Draft EIS addresses potential environmental impacts on multiple resources, including but not limited to: Air quality; water resources; airborne acoustic environment; biological resources, marine and terrestrial; cultural resources; socioeconomics; and public health and safety. No significant impacts are identified for any resource area in any geographic location within the NWTRC Study Area that cannot be mitigated, with the exception of exposure of marine mammals to underwater sound. The Navy has requested from NMFS a Letter of Authorization (LOA) in accordance with the Marine Mammal Protection Act to authorize the incidental take of marine mammals that may result from the implementation of the activities analyzed in the NWTRC Draft EIS/OEIS. In compliance with the Magnuson- Stevens Fisheries Conservation Management Act, the Navy is in consultation with NMFS regarding potential impacts to Essential Fish Habitat. In accordance with section 7 of the Endangered Species Act, the Navy is consulting with NMFS and U.S. Fish and Wildlife Service (USFWS) for potential impacts to federally listed species. The Navy is coordinating with the Washington Department of Ecology, the Oregon Department of Land Conservation and Development, and the California Coastal Commission for a Coastal Consistency Determination under the Coastal Zone Management Act for each respective state."

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