Comments on the U.S. Navy Northwest Training & Testing Environmental Impact Report (EIS/OEIS)

The Surfrider Foundation is a grassroots environmental organization dedicated to the protection and enjoyment of the world’s oceans, waves, and beaches for all people. On behalf of our Mendocino Coast Chapter supporters, activists, and members, we submit the following comments on the proposed Navy Northwest Training & Testing EIS/OEIS.

The Mendocino Coast Chapter of the Surfrider Foundation has significant concerns with the actions proposed by the Navy to occur within the Northwest Training and Testing Study Area, including air and water space off the Northern California Coast.

Alternatives 1 and 2 involving sonar testing and explosive testing would cause significant environmental harm to marine life and the ocean ecosystem. Pursuant to the Marine Mammal Protection Act (MMPA), the use of sonar, other active acoustic sources, and explosive sources may result in Level A harassment or Level B harassment of certain marine mammals. The Marine Mammal Protection Act defines Level A Harassment as the potential to injure a marine mammal or marine mammal stock, and Level B Harassment as any act that disturbs or is likely to disturb a marine mammal by causing disruption of natural behavioral patterns including migration, surfacing, nursing, breeding, feeding, or sheltering to a point where such behaviors are abandoned or significantly altered.  Pursuant to the Endangered Species Act (ESA), sonar, other active acoustic sources, and explosive sources may affect, and are likely to adversely affect, certain ESA-listed marine mammals.

Anti-submarine warfare sonar can produce intense underwater sounds in the Study Area. It is well established that the high-intensity pulses produced by airguns can cause a range of impacts on marine mammals, fish, and other marine life, including broad habitat displacement, disruption of vital behaviors essential to foraging and breeding, loss of biological diversity, and, in some circumstances, injuries and mortalities. These sounds are likely within the audible range of most marine mammals and can produce both Temporary Threshold Shift (TS) and Permanent Threshold Shift (PTS), resulting in temporary or permanent hearing loss. Until their hearing recovers, these animals will have a reduced ability to detect relevant sounds such as predators, prey, or social vocalizations

The use of sonar and other active acoustic sources for testing activities as described under Alternative 1:

• May expose marine mammals up to 88,544 times annually to sound levels that would be considered Level B harassment
• May expose marine mammals up to 119 times annually to sound levels that would be considered Level A harassment

• May affect, and is likely to adversely affect the following Endangered Species Act-Listed whales: humpback whale, blue whale, fin whale and sei whale

The use of explosive sources for training activities as described under Alternative 1:

• May expose marine mammals up to 10 times annually to sound or energy levels that would be considered Level B harassment
• May expose Dall’s porpoise up to 2 times annually to sound or energy levels that would be considered Level A harassment.

In addition to the previously described injuries, the proposed plan would also significantly increase risks to marine mammals in regards to the following stressors:

-entanglement in fiber optic cables, guidance wires, and parachutes

-ingestion of military expended materials from munitions

- injury or mortality from vessel strike

- nitrogen decompression caused by behavior or avoidance responses

The Mendocino County Chapter of the Surfrider Foundation believes that such impacts to our nation’s marine resources are not an acceptable price to pay for an increase in military training and testing.