See maps of the expansion areas below.

Below are directions to comment to NOAA about the Navy's expansion plans by August 19 2009. (The comment period was extended on August 10.)

Or, just go to the
NRDC (Natural Resources Defense Council) comment form to send your views to NOAA.
Simply put, the decision to proceed or not proceed with the Navy's whale destroying sonar and explosives training plans (see New Weapons Systems) now rests with the National Marine Fisheries Service (NMFS) - part of NOAA. This is because the Navy, having completed their environmental impact statement (EIS), must now apply with NMFS for the permit to proceed. NMFS can deny that permit. We hope they will.

Your input will affect the outcome. NMFS needs to hear from as many people as possible their sentiments (and facts) on the issue. Please comment now (cut off August 12 2009) at NMFS's comment page.

Directions to comment: Ignore the "Document Type" box, but in the "Keyword" box, enter (or copy/paste) 0648-AX88, then hit "Search." This should bring up: Taking and Importing Marine Mammals: Navy Training Activities Conducted within Northwest Training Range Complex. On the right of the page click "Submit a Comment" which should bring up the actual comment page. Just fill in the blanks and type or paste your comment. They only allow 2000 characters, including spaces, which isn't a lot of room, but it is possible to attach documents also.

Orca Network's comments:
Due to the decline in numerous bird, fish and marine mammal species that inhabit the proposed training range, and the lack of information available to assess the impacts of the Navy's proposed expansion on those species, especially with proposed testing of new systems and the impossibility of achieving adequate marine mammal monitoring, the least disturbance possible while maintaining national defense, is the preferred option.

The Navy's analysis fails to account for cumulative impacts for the years of activity. According to the Acoustic Institute: "Behavioral impacts clearly replaced strandings and deaths as the key issue for marine mammals encountering human noise. Several studies released during 2008 all suggest that whales of many species may stop or reduce their feeding when loud human sounds enter their habitat, and this particular impact is likely to become a central focus of future research and regulatory consideration." AEI further states: "All parties seem to be accepting that gross injury is rare to the point of being difficult to use as a lever to shift the balance of interests with the Navy's national security imperative, but NGOs, many field researchers, and agency staff are all looking more closely at the behavioral impacts that take place at much longer ranges (up to several or even tens of kilometers)."

In our judgment the mitigation measures detailed in this EIS are not sufficient to reliably identify the presence of cetaceans in most instances, in part because the marine mammals themselves often attempt to avoid detection by other marine mammals. Recognition of marine mammals at sea either by sight or by sound is often highly problematic even for experienced personnel in calm conditions. Marine mammals can travel in a manner intended to be undetectable. Transient orcas, for example, are adept at evading detection by their wary prey or other orcas, or humans. Other marine mammals often attempt to avoid being noticed by transient killer whales.
Read the comment letter from Fred Felleman of Friends of the Earth HERE

If you've previously commented on the Navy's EIS, please reiterate to NMFS. If this is new to you please comment also. Great background info is available HERE

and see this great New York Times Magazine article about Navy sonars and friendly gray whales, "Watching Whales Watching Us"

It is hoped that with a marine ecologist appointed by Obama at the helm of NOAA, they will look at this issue with more intelligence and science than did the Bush administration. Also, in that vein, your input may help reverse some harmful rules that were pushed through at the last minute by Bush affecting the same issues in the Atlantic, Hawaii and S. California fleets. NRDC has set up a quick action page on this HERE.

Please spread this info. to your circle of influence. Please also contact as many policy makers on the following list as possible and ask them to stop the Navy's misdirected plans.

Congressman Rick Larsen's aide on military affairs Mark Middaugh, mark.middaugh@mail.house.gov - 202-225-2605
Senator Cantwell's contact: charlie_balter@cantwell.senate.gov - 888-648-7328 & (202) 224-3441
Senator Murray sits on the Defense Subcommittee and the Military Construction and Veterans Affairs Subcommittee of the Senate Committee on Appropriations. Her contact person is: Caroline E Paulsen NOAA Sea Grant Fellow caroline_paulsen@murray.senate.gov 202.224.2621
Congressman Norm Dicks, Contact: Sara Crumb Deputy District Director Toll Free Number: 1-800-947-6676 & 253-593-6536 Sara.Crumb@mail.house.gov
Dr. Jane Lubchenco, Marine Ecologist and newly appointed NOAA ADMINISTRATOR (NOAA oversees Nat. Marine Fisheries Service) jane.lubchenco@noaa.gov ...has appointed someone to "whale affairs", Kelly Denit - 202-482-0955
Sec. Gary Locke, newly appointed Secretary of Commerce which oversees NOAA. TheSec@doc.gov - (202) 482-2000
More info on commenting process: Jolie Harrison Office of Protected Resources NMFS Marine Mammal Permits Depts. - 301-713-2289 X 166

and thanks to John Hurd for prompting and prodding this notice to comment on the Navy's dangerous training expansion proposal.

For a pdf version of this poster, click HERE.

The Navy has completed a Draft Environmental Impact Statement (EIS) to describe the potential effects of its planned training activities in the Northwest Training Range Complex. The draft EIS is open to public scrutiny and comment until April 13th. You can download all or part of it HERE.
A paper copy of the Executive Summary or a single CD with the Draft EIS/OEIS will be made available upon written request by contacting Mrs. Kimberly Kler at the below address
Naval Facilities Engineering Command Northwest,
Attention: Mrs. Kimberly Kler-NWTRC EIS/OEIS,
1101 Tautog Circle, Suite 203,
Silverdale, WA 98315-1101.

Anti-submarine Warfare Training Kills Marine Life
Op-ed by Howard Garrett

See Orca Network's comments to the Navy HERE.

Feb. 6 Letter from Oregon Congressional delegation
requesting extension of comment period.

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."

Back to top.

Back to top.