The government site appears dead, their offices are deserted and no one has responded to our comments from 2 days ago to extend the deadline due to faulty links. Assume it’s still due today.
Action: Because our Navy keeps wanting to. Deadline supposedly today (1/25)
We’ve been researching the best answers for the regulatory change request –“Taking and Importing Marine Mammals; Taking Marine Mammals Incidental to the U.S. Navy Training and Testing Activities in the Atlantic Fleet Training and Testing Study Area”. The Navy wants to be allowed to accidently kill or permanently maim dolphin and whales while they test out active acoustic sonar systems and other transducers, in-water detonations, air guns, construction activities involving pile removal and installation, and the operation of a fleet of vessels throughout the AFTT Study Area (boat strikes).
Unfortunately, the government website appears dead except for the countdown clock. Unlike “normal” regulatory actions, there’s not a link to an online comment post. Email your responses directly to ITP.Piniak@noaa.gov today (1/25).
After examining every link in this posting, we noticed a number of deficiencies and emailed NOAA as well as called all listed names in the posting. Wendy Piniak, Office of Protected Resources, cannot be reached through the listed number (301) 427-8401, and Jolie Harrison, Chief, Permits and Conservation Division, Office of Protected Resources, National Marine Fisheries Service is off for the duration of the shutdown.
Here is that email, sent 1/23. (Note – two broken links have been repaired since yesterday):
Jolie Harrison, Chief
Permits and Conservation Division
Office of Protected Resources
Nation Marine Fisheries Service
Its comment period ends in 2 days (1/25/19). I would like to review previous comments, so as not to be repetitive. However, the public record site comes up as this (corrected as of today 1/25):
Something fishy is going on indeed…
The Navy assures us of negligible “taking”, however, deaths from sonar testing and explosives are far higher than originally estimated. According to Orcanetwork.org: “The Navy estimates its use of explosives and sonar may unintentionally cause more than 1,600 instances of hearing loss or other injury to marine mammals each year, according to a draft environmental impact statement that covers training and testing planned from 2014 to 2019. The Navy calculates the explosives could potentially kill more than 200 marine mammals a year.
The larger numbers are partially the result of the Navy’s use of new research on marine mammal behavior and updated computer models that predict how sonar affects animals.
The Navy also expanded the scope of its study to include things like in-port sonar testing — something sailors have long done but wasn’t analyzed in the Navy’s last environmental impact statement. The analysis covers training and testing in waters between Hawaii and California for the first time as well.”
Plus, the Navy is doing this a LOT (list here): These are the some of the search results when you put in “Taking and Importing Marine Mammals”… (Wait, why are we risking marine mammals for commercial fireworks displays?)
And don’t forget our “Energy Dominance” friends…and the Japanese who want to be whalers again.
- Incidental Take Authorizations for oil and gas activities (note: top two applications are from Hilcorp Energy, for their existing and proposed installations in Alaska)
- Incidental Take Authorizations for other energy (renewable and LNG) activities
- Incidental Take Authorizations for research and other activities
- Incidental Take Authorizations for construction activities
- Navy admits sonar killed whales (Sciencemag.org)
- “A deaf whale is a dead whale”: US nave sonars could be cause of strandings (guardian)
- Does military sonar kill marine wildlife (scientificamerican)
- Navy agrees to limit underwater assaults on whales and dolphins.(CA & Hawaii) (earth justice)
- Navy agrees to limit underwater assaults on whales and dolphins (Center for Biological Diversity)
- Protect marine mammals from ocean noise (NRDC)
- 2016 – Federal Court: Navy must limit long-range sonar use to protect marine mammals (NRDC)
- The sea will get a lot quieter without the Navy’s whale-killing sonar (around Hawaii – 2016) (wired)
- Ship Strikes: Responses include incorporating all suggestions to avoid ship strikes from the Benioff Ocean Initiative and NOAA’s own guidelines.
Use information from the articles above or use your own thoughts.
Comment: We have demonstrated over and over that adequate documentation of compliance with government rules is complicated and fraught with inconsistencies. The marine mammals animals have no defense regarding human interference. Climate conditions in the oceans (warming and pollution) are am additional and significant threat to the survival of many marine mammal species.
I therefore object to this proposed rule.
Comment: In 2015, the Navy lost two court cases involving their underestimating the damage their activities were wreaking on the marine mammals near Hawaii and California. Scientific studies have documented the connection between high-intensity mid-frequency sounds, including Navy sonar, and serious impacts to marine mammals ranging from strandings and deaths to cessation of feeding and habitat avoidance and abandonment. Nonetheless, until sued in court, the Navy had refused to set aside biologically important areas or limit their use of sonar and other deafening equipment to minimize such harm to vulnerable marine mammal populations.
The Navy, in partnership with independent environmental scientists and biologists, must enact a program of wildlife care with a minimum base as established in the lawsuits. In addition, an updated Environmental Impact Statement needs to be created to understand the true scope of marine mammal deaths, due to global warming, the congregate total of all naval exercises and other military activities, commercial activities like oil and gas, and straight-out whaling activities by Japan and others.
Comment: The Navy has lied about how many marine mammals have been damaged by their activities. In no way can they be trusted to maintain any guidelines set down for them on their own. There must be an independent entity along with them on all exercises to monitor their activities and enforce compliance.