ALERT! U.S. Navy Escalates Warfare Testing in the Pacific, Atlantic & Gulf of Mexico in 2014 — PUBLIC COMMENT DEADLINE APRIL 15, 2014 – Action Items from Rosalind Peterson…


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From ROSALIND PETERSON
Redwood Valley

Public Comment Due by April 15, 2014, on U.S. Navy NWTT Website for Northern California, Oregon, Washington, Idaho & Alaska.  Read the Northwest Training & Testing EIS/OEIS Draft EIS/OEIS on the U.S. Navy Website & Make Your Public Comments or Ask Questions:

U.S. Navy Website:    http://nwtteis.com/

“…In many regions, the Navy plans to increase the number of its exercises or expand the areas in which they may occur, and virtually every coastal state will be affected. Some exercises may occur in the nation’s most biologically sensitive marine habitats, including National Marine Sanctuaries and breeding habitat for the endangered North Atlantic right whale. In all, the Navy anticipates more than 2.3 million takes (significant disruptions in marine mammal foraging, breeding, and other essential behaviors) per year, or 11.7 million takes over the course of a five-year permit…” Senator Barbara Boxer

“Shock & Awe” Bomb Blasts, Sonar-Toxic Chemicals-Lasers-Electromagnetic & Other Experimental Weapons to be used and more…as the U.S. Navy destroysour oceans for war practice when they could protect our National Marine Sanctuaries, Marine Reserves, Biologically Sensitive Areas, Breeding & Feeding Habitats and Other Marine Life.Call Your Elected Officials Today in Washington D.C. Toll Free:  (1866) 220-0044

1)  Request a 30 to 60 Day Extension of Time for Public Comment (U.S. Navy NWTT Draft EIS/OEIS)

2)  Contact U.S. Senator Barbara Boxer Requesting Congressional Hearings to Protect Our National Marine Sanctuaries, Biologically Sensitive Areas, Marine Reserves, Coral Reefs & Other Coastal Regions from “Shock & Awe” Navy Warfare Testing.

3)  The U.S. Navy applied for two permits to “take” marine mammals in the NWTT Range Complex which includes Northern California, Oregon, Washington, Idaho & California.  The U.S. Navy applications to NOAA was issued on December 18, 2014, one month before the Navy NWTT Draft EIS/OEIS was available for public comment on January 18, 2014.

A.  The public comment period issued by NOAA on these two applications (300 pages in length), closed on February 28, 2014, and did not give time for public comment due to the length of the Navy applications to NOAA and the Navy Draft EIS (Approximately 2,000 Pages in Length).

B.  We formally request that the NOAA deadline for Public Comment be reopened and that the U.S. Navy Draft EIS/OEIS public comment period be extended for 30 to 60 days.  Both the Navy Applications to NOAA and the NWTT Draft EIS are based on the information in both documents.  Thus, the public comment periods should be open at the same time to give the public time to comment under the National Environmental Policy Act (NEPA).

C.  We are aware that the U.S. Navy granted a very brief extension of the public comment period on the NWTT Draft EIS/OEIS.  However, without the public comment being opened on the Navy applications to NOAA, public comment is restricted because the two applications are based on the NWTT Draft EIS/OEIS.  Both public comment periods should be open at the same time due to the extensive information in each these documents.

PLEASE REQUEST THIS INFORMATION FROM OUR ELECTED OFFICIALS:

Would you be able to obtain a map and list from the U.S. Navy showing all areas in the new expanded NWTT Range that includes designated areas where the U.S. Navy has agreed not to conduct warfare exercises, bombing missions, use sonar, or test new weapons system in National Marine Sanctuaries, Marine Reserves, Breeding, Birthing, and Feeding Habitats or other biologically sensitive areas, and during times of marine mammal migrations.  Since the Navy has been operating in our area since 2010, this information should be readily available from the Navy.  It is my understanding that the Navy does not stop their warfare practice in any of these areas or during times of whale and salmon migrations along our coast.

Visit this Website and Watch the Video about Warfare Testing in the Atlantic, Pacific and the Gulf of Mexico:
http://www.agriculturedefensecoalition.org/content/us-navy-new

The U.S. Navy Range Maps and links to Navy Maps are available on the above website.
U.S. Navy Requests for Letters of Authorization to “Take” marine mammals listed by application date and range location.

 U.S. Navy Application – December 18, 2013:  (This is what is going to happen to our marine mammals)

http://www.nmfs.noaa.gov/pr/pdfs/permits/navy_nwtt_loa_application2014.pdf

Public Comment Was Closed on February 28, 2014.  Please join us in working to reopen this public comment period.

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Here is some additional Navy information which may be of interest to you:

The U.S. Navy plans to expand its warfare testing range from Northern California all the way to Alaska.  Their NWTT Draft Environmental Impact Statement (EIS/OEIS), is online athttp://nwtteis.com   (Public comment due by April 15, 2014.)

We are requesting that everyone work toward protecting the biologically sensitive areas in the U.S. Navy NWTT range from unlimited use of Sonar, Weapons and Experimental Weapons testing, toxic chemicals, sonar, and other harmful activities. U.S. Congressman Mike Thompson has additional information with regard to past Navy activities here and efforts to protect our area (See Information Below).   We are engaged in working toward protecting our coastal region from Navy warfare activities that are going to increase in our area and which might be detrimental to our coastal region and its marine life.

Please note that the U.S. Navy Draft EIS/OEIS has several alternatives listed within their documents.  I found out from the Navy that “Alternative 2” is the only approved action that the Navy has ever approved for all range complexes since 2008, except for one small range (per U.S. Navy Public Affairs Officer:  Mr. Mark Matsunaga).  Thus, there is no reason to consider that the Navy would choose any Alternative, except #2, for the new NWTT Range expansion.

We are therefore addressing all public comments to the Navy with regard to “Alternative #2”.  We should make it clear that we would only accept the “No Action Alternative” as a choice for our coastal region in addition to adding certain protections.  We feel that the Navy has no intention of choosing any Alternative except #2 for our region and that this decision has already been made due to the Navy’s past and more recent history (See U.S. Navy Record of Decision links below for the Atlantic & Southern California Ranges expansions which were approve in November and December 2013.)

The U.S. Navy and NOAA/MNFS mitigation measures to protect marine life, visual sightings, are unacceptable since they are effective only 9% of the time, according to U.S. Congressman Thompson (See Excerpt below from his letter to NOAA dated May 28, 2009):

“…NOAA’s comprehensive review is particularly important given that the Navy has estimated shipboard visual monitoring for marine mammals – the most commonly employed sonar mitigation measure – to be effective only 9% of the time. It is important that NOAA take immediate steps to validate its comprehensive review of mitigation measures. Specifically, I request that you provide my office with an outline of the comprehensive review process and answers to the following questions:

1.    What mitigation measures will be reviewed during NOAA’s process?

2.    What data will NOAA use to identify those mitigation measures best able to protect marine species?

3.     How will your agency’s recommendations target specific species, habitats or training activities of concern?

4.    How will NOAA’s recommendations address sonar impacts to species other than marine mammals?

5.    How will NOAA or the Navy establish performance standards to ensure that

recommended mitigation measures are functioning as intended?…”  End of Press Release.

U.S. Congressman Thompson’s October 8, 2010, Letter to the Navy Reads in Part:

We have noted that the mitigation measure, most commonly employed by the Navy, in the Atlantic, Pacific, and Gulf of Mexico operating ranges (see Final EIS/OEIS documents for all twelve+ operating ranges), are visual sightings, when other technologies are readily available to the Navy.  The current NWTTEIS draft does not address the issue brought forward by Congressman Thompson.  The Navy and NOAA/NMFS do not consider protecting our National Marine Sanctuaries, marine reserves, or biologically sensitive areas in our range or using mitigation measures that would protect marine mammals more than 85% of the time.

Request Documents & this information from our elected officials:

Would you be able to obtain a map and list from the U.S. Navy showing all areas in the new expanded NWTT Range that includes designated areas where the U.S. Navy has agreed not to conduct warfare exercises, bombing missions, use sonar, or test new weapons system in National Marine Sanctuaries, Marine Reserves, Breeding, Birthing, and Feeding Habitats or other biologically sensitive areas, and during times of marine mammal migrations.  Since the Navy has been operating in our area since 2010, this information should be readily available from the Navy.  It is my understanding that the Navy does not stop their warfare practice in any of these areas or during times of whale and salmon migrations along our coast.

 Formal Request:     Due to the length of the application the Navy Draft EIS (Approximately 2,000 Pages in Length), we are formally requesting an extension of time to file public comments on both the Navy draft EIS and their application to NOAA/NMFS to harass marine mammals in our area (Almost 300 Pages in Length).

U.S. Navy Requests for Letters of Authorization to “Take” marine mammals listed by application date and range location.

U.S. Navy Application – December 18, 2013:

http://www.nmfs.noaa.gov/pr/pdfs/permits/navy_nwtt_loa_application2014.pdf

Public Comment Ended February 28, 2014, on the above Navy application.   Please help us to re-open and extend this deadline for another 30 to 60 days.

Definition of “Take”
http://www.nmfs.noaa.gov/pr/glossary.htm

  • Defined under the MMPA as “harass, hunt, capture, kill or collect, or attempt to harass, hunt, capture, kill or collect.”
  • Defined under the ESA as “to harass, harm, pursue, hunt, shoot, wound, kill, trap, capture, or collect, or to attempt to engage in any such conduct.”

Please feel free to contact me if you have additional questions.

Sincerely,

Rosalind Peterson

Agriculture Defense Coalition

P.O. Box 499

Redwood Valley, CA 95470

(707) 485-7520

E-Mail: info@californiaskywatch.com

My Website has six sections on the U.S. Navy divided by region:  (Atlantic, Pacific, & Gulf of Mexico along with the Navy Maps of Warfare Ranges)

http://www.agriculturedefensecoalition.org/content/categories

For Additional Information on all NOAA approved “Takes” from all activities 

Visit the NOAA “take” Website:

http://www.nmfs.noaa.gov/pr/permits/incidental.htm

NOAA/National Marine Fisheries Service        http://www.nmfs.noaa.gov/pr/glossary.htm

Definition of “Take”  – The U.S. Navy contractors, when they were last here in Fort Bragg, totally rejected the definitions of “take” from the MMPA and ESA shown below:

  • Defined under the MMPA as “harass, hunt, capture, kill or collect, or attempt to harass, hunt, capture, kill or collect.”
  • Defined under the ESA as “to harass, harm, pursue, hunt, shoot, wound, kill, trap, capture, or collect, or to attempt to engage in any such conduct.”

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  • Also note that NOAA/NMFS are “cooperating agencies” and NOAA receives funding from the U.S. Navy.  This is a conflict of interest when NOAA/NMFS generates LOAs for the Navy to “take” marine mammals.

Item of Interest and questions as to why no one mentions the Navy when questioned about marine mammal impacts like strandings, illnesses, etc., that could be caused by Navy warfare testing in the Pacific, Atlantic or the Gulf of Mexico: 

1.    Could it be that the Navy funding given to NOAA/NMFS (a Navy cooperation agency), and the others groups listed below, be a conflict of interest?

2.    Could those listed below lose their funding if they researched and reported to the public Navy impacts on all marine life, habitats, feeding, breeding areas, adverse marine mammal events like strandings, and other ocean problems?
U.S. Navy Conflict of Interest Quote:

            http://aftteis.com/NaturalResources/ProtectingMarineResources.aspx

“…Much remains to be learned about how marine mammals live, travel and respond to human activities in the ocean. The Navy is a world leader in marine mammal research, and currently provides over $20 million per year to universities, research institutions, federal laboratories, private companies, and independent researchers around the world to increase the understanding of marine mammal physiology and behavior. This research helps the Navy to better understand marine species distribution and important habitat areas, develop methods to detect and monitor marine species before and during training, understand the effects of sound on marine mammals, sea turtles, fish and birds, and develop tools to model and estimate potential effects of sound. The Navy also uses the results of these studies to develop new programs to protect marine mammals and other marine species while training at sea…”

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The NOAA Website:                       http://www.nmfs.noaa.gov/pr/pdfs/permits/hstt_loa_training.pdf

has information on the “taking” of Marine Mammals in the Southern California/Hawaii Range at this time until 2018, as approved by NOAA/National Marine Fisheries Service.  You may find this item of interest.  Many of these marine mammals migrate along our coastline and should be protected here.  (Note that Alternative 2 was chosen by the Navy for warfare training and testing in this region in 2013.)  Note that some marine mammals and fish allowed for “takes” in this range also migrate and, we believe, are counted multiple times as allowable “takes” in our range by the NMFS.

This NOAA Website:          http://www.nmfs.noaa.gov/pr/pdfs/permits/nwtrc_loa_issued2012.pdf

has information on the “taking” of Marine Mammals now allowing in the NWTRC at this time through 2015.  Note the sonar and detonations use and the numbers of impacted marine mammals.  When you combine the two ranges, and include Alaska, the numbers are stunning.  (Please note that there are no exclusions for either Humboldt or Mendocino Counties with regard to the “taking” of marine mammals or protecting biologically sensitive areas.) 

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The U.S. Navy HSTTEIS Website for the Hawaii-Southern California Range Complex:

            http://hstteis.com/

  • Please note the areas expanded when this new range was approved.  U.S Navy Map on their Home Page.  The U.S. Navy Record of Decision dated December 20, 2013, has selected “Alternative 2” for this entire area regions which appears to show allowable testing in international waters.

http://hstteis.com/Portals/0/hstteis/ROD/HSTT%20FINAL%20ROD_signed.pdf

NOAA/NMFS Letters of Authorization (LOA), for the “Taking of Marine Mammals” for Training & Testing (December 13, 2014), for this entire HSTTEIS range:

http://hstteis.com/Portals/0/hstteis/marinemammaldocs/HSTT_LOA_Testing_12.13.13.pdf

http://mitt-eis.com/Portals/MITTEIS/files/draft_eis/5%20Standard%20Operating%20Procedures,%20Mitigation,%20and%20Monitoring.pdf

  • (Note:  The NOAA/NMFS LOA counts marine mammals that migrate from one range to another including into our NWTT Range which now includes Alaska in various coastal range NMFS Letters of Authorizations to “Take: Marine Mammals – This raises the question about “take” numbers being duplicated throughout the entire Pacific Ocean area.  When you add the current Mariana Range Complex

(http://mitt-eis.com/DocumentsandReferences/EISDocuments/DraftEISOEIS.aspx)

and the current Alaska Range Complex to the Pacific Ocean NOAA/NMFS “take” numbers for migrating marine mammals it appears that there may be duplication species and “take” numbers in all ranges.)

This Navy HSTTEIS now includes the following smaller ranges which each have a NOAA/NMFS (LOA) Letters of Authorization for the Navy to “take” Marine Mammals:

1.    Hawaii-Southern California Training and Testing Study Area

2.    Hawaii Range Complex

3.    Navy Training Areas Around Kauai

4.    Oahu Training Locations

5.    Maui Training Locations

6.    Southern California Range Complex

7.    San Clemente Island Offshore Training Areas

8.    San Clemente Island Nearshore Training Areas

9.    Southern California Training Areas

10.  Silver Strand Training Complex

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U.S. Navy AFTTEIS Website Atlantic Range Expansion Website:

            http://aftteis.com/Home.aspx

  • Please note the areas expanded when this new range was approved and all of the smaller ranges it now encompasses in the Atlantic & the Gulf of Mexico-U.S. Navy Map on their Home Page.  The U.S. Navy Record of Decision dated November 25, 2013, has selected “Alternative 2” for this entire region:

http://aftteis.com/Portals/4/aftteis/record_of_decision/AFTT_ROD%20_lo_res.pdf

NOAA/NMFS Letters of Authorization for Training & Testing for this entire range for each individual range within this AFTT range complex boundaries:

http://aftteis.com/Portals/4/aftteis/LOA/AFTT%20testing%20LOA.pdf

http://aftteis.com/Portals/4/aftteis/LOA/AFTT%20training%20LOA.pdf

http://aftteis.com/Portals/4/aftteis/FEIS/Section/05_AFTT_FEIS_SOPs_Mitigation_Monitoring.pdf

The following seven Navy EIS/OEIS ranges are now located within the AFTT Range Complex.  It is alleged that “Alternative #2” was selected by the Navy in each Record of Decision. (Note:  It appears that the Navy might be conducting activities in International Waters in the Atlantic and the Pacific):

1.    Final Atlantic Fleet Active Sonar Training Environmental Impact Statement/Overseas Environmental Impact Statement (December 2008)

2.    Virginia Capes Range Complex Final Environmental Impact Statement/Overseas Environmental Impact Statement (March 2009)

3.    Navy Cherry Point Range Complex Environmental Impact Statement/Overseas Environmental Impact Statement (April 2009)

4.    Jacksonville Range Complex Final Environmental Impact Statement/Overseas Environmental Impact Statement (March 2009)

5.    Final Environmental Impact Statement/Overseas Environmental Impact Statement, Naval Surface Warfare Center Panama City Division Mission Activities (September 2009)

6.    Gulf of Mexico Range Complex Final Environmental Impact Statement/Overseas Environmental Impact Statement (December 2010)

7.    Final Overseas Environmental Impact Statement/Environmental Impact Statement, Undersea Warfare Training Range (June 2009)

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  • Formal Request:      Due to the length of the application their Draft EIS (Approximately 2,000 Pages in Length), we are formally requesting an extension of time to file public comments on both the Navy draft EIS and their application to NOAA/NMFS to harass marine mammals in our area (Almost 300 Pages in Length). 

 U.S. Navy Application Quotes:  “…The United States (U.S.) Department of the Navy (Navy) has prepared this consolidated request for two Letters of Authorization (LOAs) for the incidental taking, as defined in Chapter 5 (Take Authorization Requested), of marine mammals during the conduct of training and testing activities within the Northwest Training and Testing (NWTT) Study Area (hereafter referred to as the Study Area). The Navy activity to be authorized will occur from 2015 through 2020, and the Navy requests that each LOA cover the entire period…This request for LOAs is based on the proposed training and testing activities of the Navy’s Preferred Alternative (Alternative 1 in the EIS/OEIS)… In addition to these potential impacts from specific activities, the Navy will also request takes from ship strikes that may occur during training or testing activities. These takes, however, are not specific to any particular training or testing activity…”

The above information in the Navy application raises the following questions:

*The Navy application only covers “Alternative #1” in their EIS and not Alternative #2.  Why?

*Does this mean that the Navy has already ruled out using the “No Action Alternative”?

*Since the U.S. Navy almost always chooses “Alternative #2” in their Record of Decisions, what happens if the Navy choice is Alternative #2 in their NWTT Final Record of Decision?

*The Navy LOA application should be revised to include “Alternative #2″ since this alternative is part of the NWTT Draft EIS and could be the Navy choice in their NWTT Record of Decision.
We are currently addressing all public comments to the Navy with regard to Alternative #2.  And we are making it clear that we don’t accept Alternative 2 as a choice for our coastal region.  We feel that the Navy has no intention of choosing any Alternative except #2 for our region and that this decision has already been made due to the Navy’s past and more recent history. (See the recent Navy Record of Decisions), links below for the Atlantic & Southern California/Hawaii Ranges).

The U.S. Navy HSTTEIS Website for the Hawaii-Southern California Range Complex:

            http://hstteis.com/

  • Please note the areas expanded when this new range was approved.  U.S Navy Map on their Home Page.  The U.S. Navy Record of Decision dated December 20, 2013, has selected Alternative 2 for this entire area regions which appears to show allowable testing in international waters.      Record of Decision:    http://hstteis.com/Portals/0/hstteis/ROD/HSTT%20FINAL%20ROD_signed.pdf

U.S. Navy AFTTEIS Website Atlantic Range Expansion Website:

            http://aftteis.com/Home.aspx

  • Please note the areas expanded when this new range was approved and all of the smaller ranges it now encompasses in the Atlantic & the Gulf of Mexico-U.S. Navy Map on their Home Page.  The U.S. Navy Record of Decision dated November 25, 2013, has selected Alternative 2 for this entire region:

http://aftteis.com/Portals/4/aftteis/record_of_decision/AFTT_ROD%20_lo_res.pdf

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One Comment

One huge consideration seems lacking in the navy’s strategies; and there is no mention of it here, either. Seems like a lot of navy lip service is being given to understanding marine life. A lot of pentagon research went into all sorts of aspects about marine life based on decades of research. Any and all mitigation would appear to be based on that data pool, along with predictive patterns that serve as hypotheses and a basis for sampling studies, etc. But something new has been added to the mix. ahem, …
RADIATION, that gift from Fukushima.
Have any of the Navy’s plans taken the ‘glowing plumes’ into consideration, not only its effects on marine life, but on its own crews? Or do they just want a shitload more lawsuits on their hands?

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