Comments to share (will be sent to Guam lawmakers) submitted on Federal register 068-BD69, Takes of Marine Mammals Incidental to Specified Activities; U.S. Navy Training and Testing Activities in the Marianas Islands Training and Testing Study Area, May 3, 2014. regulations.gov ……I protest the Navys desire to increase sonar and undersea activities, as outlined in this Federal Register report, for the following reasons: 1. No quantifiable data exists on how exposure of sound to marine mammal effects reproduction and survival (p 15405). 2. Several authors have established that long-term and intense disturbance stimuli can cause population declines (p15405). 3. Navy reports that PCAD model of connecting observable data through a series of transfer functions using a case study is not complete; therefore, there is not way to connect and apply outcomes linking behavior and life functions and life functions to vital rates of humans to marine mammals (p15405). 4. Navy claims that 13% of 48 strandings that took place between 1960 and 2006 were Navy related, but does not back up its claim with methodological explanations and stated margins of error. In short, wheres the empirical data to back up their desires to justify the sheer volumes of proposed training activities? (p15406). …...I protest the Navys desire to seek a 5 year authorization to take marine mammals incidental to training and testing activities in the Mariana Islands Testing and Training study area from 2015 to 2020. 1. On pages 15406 and 15407, the Navy claims that there have been five stranding events associated with military mid-frequency sonar use. How is it known that this information is both complete and accurate? From what the Navy says, sonar is obviously a contributing factor, if not the main factor in strandings but does not define in the Federal Register report the word stranding. 2. The Navy, on page 15406, does not define stranding events either. How is an event defined because based the content of the section entitled Strandings Associated With MFAS (referring to Multi-Function Active Sensor) how will readers such as myself know if other events took place and what evidence is there to demonstrate that this is or is not the case? In the Navys own words (page 15407) it states that a number of other stranding events coincident with the operation of mid-frequency sonar, including the death of beaked whales or other species (minke whales, dwarf sperm whales, pilot whales) have been reported; however, the majority have not been investigated to the degree necessary to determine the cause of the stranding and only one of these stranding events. Because the Navy, claims in its own words that other incidences have occurred where sonar activities have resulted in marine mammal strandings, without follow-up investigations, warrants that the Navys request for authorization from NMFS to take marine mammals from 2015 to 2020 be denied, not approved. For example, the Navy references Greece, Bahamas, Madeira, Canary Islands and Spain and RIMPAC exercises where they conducted sonar activities. The RIMPAC exercise alone, according to the Navy, resulted in 150 to 200 pelagic melon headed whales going to shallow waters in Hanalei Bay, Kauai for over 28 hours. That to me qualifies as stranded but the Navy does not clearly define what is stranded from their perspective. The Navy and NMFS do not work together to address the potential for strandings. Both parties have detailed a Stranding Response Plan that outlines reporting, communication and response protocols intended to minimize the impacts. If the Navy and NMFS dont have a series of operationalized actions in place, then the Navys desire to be given authorization to take marine mammals incidental to training and testing in the MITT should be denied or given a one year extension, not a five year extension. The Navy, on page 15407, also states that other potential causes of marine mammal takings include major pollution events, prominent tectonic activity, usual physical or meteorological events, magnetic anomalies, etc. which I believe will not result in harm or death to marine mammals because in addition to major pollution events being almost non-existent in the Marianas Islands unrelated to military activities, the Navy has not even performed full necropsies to precisely determine causes of death. The Navy states, also pin page 15407, that there were multi-species strandings in the Bahamas in 2000 after Navy ships passed through two channels operating Sonar Sets AN/SQS-53C (most advanced anti-submarine warfare sonar in the naval inventory) and AN/SQS-56. It was determined that the stranded beaked whales died from auditory structural damage related to bloody effusions and hemorrhaging around the ears. The undersea topography also written up in the Federal Register report as bathymetry along with intensive use of active sonar and constricted undersea space for the mammals to move about, caused the death of these animals. The Navy, states on page 15393 of this Federal Register report that it wants to conduct 17,172 non-impulsive multiple class category training and testing activities within MITT. If given 5 year authorization by NMFS to proceed, marine mammals will be injured, impaired or killed from auditory hemorrhaging and internal bleeding as well as possible vessel hits depending on the undersea area in which the testing and training activities are to take place. Recommend that the Navys request for a 5 year authorization to incidentally take marine mammals be denied.
Posted on: Sat, 03 May 2014 18:45:36 +0000
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