VERY URGENT, PUBLIC HEARING ON DEADLY LFA SONAR !

[Guest guest]

DEADLY LFA PUBLIC COMMENTS DEADLINE:

MAY 3rd, 2001

 

DEADLY LFA PUBLIC HEARING DATES :

April 26, 2001

April 28, 2001 (Saturday)

May 3rd, 2001 (Thursday)

 

The detail follows :

 

-

" Andrew Christie " <Andrew

Wednesday, April 25, 2001 8:49 PM

Attend a public hearing on LFA sonar: CA, HI, MD

 

 

SEA SHEPHERD ACTION ALERT

 

The National Marine Fisheries Service, under extreme pressure from both

Congress and the public, has agreed to hold hearings on the U.S. Navy's

Low Frequency Active Sonar program before deciding on whether to

issue the Navy a permit to operate this extremely controversial

technology.

 

A NMFS permit would allow the Navy to " take " (harrass, injure or kill)

marine mammals as a consequence of delploying the system.

 

This is the only chance the public will have to weigh in on the

efforts to halt the deployment of LFAS.

 

MAIL OR FAX your comments to NMFS by May 3, 2001.

 

IMPORTANT HEARINGS :

 

But if you will be in L.A., Hawaii, or Maryland on the dates below, please

show up in person to let NMFS know the level of public concern over the

Navy's intention to introduce this disastrous technology into every ocean

in the world. Your attendance in crucial.

 

Dates and locations:

 

April 26, Los Angeles, California

protest 4:00 pm to 6:00 pm

hearing 6:00 pm to 9:00 pm

the Renaissance Hotel

9620 Airport Boulevard (near LAX)

 

April 28, Honolulu, Hawaii

hearing 1:00 pm to 5:00 pm

the Marriott Waikiki Beach Hotel

2552 Kalakaua Avenue

 

May 3, Silver Spring, Maryland

hearing 9:00 am to 12:00 noon

the Auditorium of Silver Spring Metro Center Building 4

1301 East-West Highway

 

California attendees are invited to contact Mark Palmer of Earth Island

Institute by 3:00 on April 26 (Just ask for his room number when you get

to the Renaissance Hotel.) Protest starts at 4:00. Make signs if you can.

 

Maryland hearing attendees are invited to contact Marsha Green,

President, Ocean Mammal Institute, at the Days Inn at 8040 13th Street,

Silver Spring, MD (Reservation phone # 1-800-329-7466) and join

with the OMI contingent and show your support.

 

 

WHAT NMFS NEEDS TO BE TOLD:

 

The following comments are submitted by the Sea Shepherd Conservation

Society regarding the proposed rule granting the U.S. Navy's request for a

small take exemption under section 101(a)(5)(A) of the MMPA in the

deployment of Surveillance Towed Array Sensor System Low Frequency

Active Sonar.

 

The Navy should not be issue a small take permit for deployment of LFA

sonar, as it cannot say with any degree of reliability what the size of

the take from use of LFAS is likely to be, nor determine a specified area

in which a potential take would occur.

 

The Navy's data on potential take of sea turtles and fish by LFAS

transmissions is virtually nonexistent. The data the Navy has amassed on

potential effects of LFAS on cetaceans is severely deficient.

 

This is due primarily to the phenomenon of sound channels and surface

ducts which have the potential to transmit high sound levels over long

distances or down into deep ocean. The Navy has documented RL of

140 db at a distance of 300 nautical miles from a single LFAS source.

The Navy cannot detect all the animals within the declared RL 180 db

zone one kilometer from the sound source, and the Navy's plan to

detect whales within the 1 km radius using binoculars and hydrophones

is deficient as whales are only at the surface for brief time periods and

often cease vocalizing as soon as they hear any noise, such as a ship's

engines. High-frequency " fish finders " cannot guarantee any better than

a 70-percent detection rate.

 

The Navy has attempted to dismiss the relevance of the stranding of beaked

whales in Greece during NATO LFAS exercises in 1996.

Faced with a research report's conclusion that there was a less than

one percent probability that the cause of the stranding could have been

anything other than LFAS, the Navy has attacked the methodology of the

researcher who studied the incident and attempted to affirm that the

timing of the LFAS transmissions and the unprecedented stranding event

could have been a coincidence. The applicant is evidently unaware of the

precautionary principle, sufficient grounds to deny the applicant a small

take permit.

 

The Navy has further denied the relevance of the sonar-incriminating

necropsy results from the stranding of beaked whales in the Bahamas in

March 2000 during an LWAD sonar exercise on the grounds that LWAD

deploys a mid-range, not a low-frequency, sonar. In this arbitrary focus

on frequency range, the applicant further demonstrates the unacceptably

narrow scope of its testing to determine levels of take. The Navy has

given insufficient consideration to the phenomenon of resonance,

produced at varying frequencies, causing tissue shear in whales' cranial

air spaces. The insufficient consideration of resonance is sufficient

cause to the deny the applicant a permit on the grounds that it has

not evaluated a likely cause of lethal take of marine mammals in the

deployment of high-intensity active sonar systems.

 

Were the Navy to admit that the Greece and Bahamas strandings were likely

to have been caused by high-intensity sonar and revise its requested take

numbers upward accordingly, the resulting estimate of take would still be

likely to be too low, as only a small number of cetaceans that are injured

or die at sea strand or wash up on a shoreline. The majority of marine

mammals that die as a result of LFAS deployment thus could not be known.

 

The Navy dismissed as insignificant the exodus of humpback whales from

their accustomed breeding grounds in the LFAS test area off Hawaii,

clustering on the opposite side of the island; the cessation of vocalizing

among several species; and the observation of abandoned calves

in the area during the Phase III test period. While the Service should

note in this an obvious predisposition to find test results that would

favor deployment, it is equally noteworthy that the Navy has defined

" harm " as a phenomenon that can be determined by immediate

observation.

 

Though the observed take of humpback whales during Phase III should

have been sufficient cause to abandon both the test and the LFAS program

and begin serious evaluation of safe alternatives, the Navy also has given

no consideration to the probability of long-term harm done to whales that

do not leave the areas of LFAS deployment. This deficient definition of

harm is sufficient cause to deny the Navy's application for a small take

permit, as the applicant on this basis essentially cannot define what

would constitute a take by deployment of LFAS.

 

The Navy has asserted that the LFAS testing program was not designed to

evaluate " worst-case scenarios " and thereby justifies its extrapolation

from harassment effects at RL 140 db to effects at RL 180 db. However,

the Navy's definition of " employment " of the system does not include the

actual use of the system for the purpose for which it was created. Outside

of war games, at any time of declared " heightened threat conditions " the

Navy will claim exemption from environmental laws for reasons of national

security and all proposed mitigations will be abandoned, meaning LFAS

is likely to be operated in near-shore areas, at full 230 db source

levels, and whether or not cetaceans are sighted within 1 km of the

deployment vessel. As the Navy intends to exempt itself from NEPA

whenever it deems it necessary -- inevitably creating thereby the

" worst-case scenario " for which they admit they have not conducted tests

-- all the more reason for the Navy to seriously pursue an alternative

that has not already proven to generate high levels of harassment at low

levels of deployment, as has LFAS. Passive submarine detection systems

developed since the introduction of the 1980s-era technology on which

LFAS is based include TB-29 towed array with Acoustic Rapid Insertion

Sonar (ARCI) and the Advanced Deployable System (ADS)

 

We concur with the U.S. House of Representatives Committee on Resources

in their expression of concern to the Secretary of Defense in October 2000

and its request that the Navy " postpone proceeding with the NMFS to obtain

a Letter of Authorization for incidental take under the Marine Mammal

Protection Act to operate LFA sonar worldwide until such time that NMFS

can properly establish scientifically-based noise standards for marine

animals. "

 

We also concur with the Staff of the California Coastal Commission, which,

in its Nov. 8, 2000, " no " vote recommendation on the determination of

the consistency of the operation of LFAS with the policies of the

California Coastal Management Program, noted that the Navy and NMFS

are a long way from establishing such standards.

 

 

To make your voice heard on this subject, you can get more information at

http://www.seashepherd.org/issues/habitat/may3tostop.html

http://www.seashepherd.org/issues/habitat/cnnnoise.html

and http://www.nytimes.com/2001/04/10/science/10WHAL.html

 

 

 

Sea Shepherd International

P.O. Box 2616

Friday Harbor, WA 98250

(360) 370-5500

http://www.seashepherd.org

seashepherd (@seashepherd.org )

 

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THANKS SO MUCH FOR YOUR KINDNESS,

COMPASSION AND HELP.