July’s Court Decision on Navy Sonar: What Does it Mean?


August 4, 2016 – First: the 9th Circuit Court’s does not mean the Navy is stopping its use of sonar. The Navy has publicly said the ruling has “no impact” on its current activities. It means the case, argued on fairly narrow but powerful terms, is going back to trial in the lower court. However significant this decision is for the protection of marine mammals, it is not a done deal yet and we will cautiously wait to celebrate until after the trial. WCAA has no information on the new trial. But we applaud the Natural Resources Defense Council’s astuteness and unwillingness to back down.

SURTASS towed sonar array2

Towed sonar array schematic.

Here’s what happened: On July 15, 2016, the 9th Circuit Court granted an appeal filed by the Natural Resources Defense Council that reversed a lower court decision upholding NOAA’s 2012 approval for the Navy to use low-frequency sonar for training, testing and routine operations. Specifically, this case was about the Navy’s towed low-frequency sonar array, which is so powerful that there are only 4 ships doing it, in 4 separate oceans. It’s for surveillance, and each sonar blast is at least 215 decibels and lasts for sixty seconds. It’s low-frequency so the noise travels for thousands of miles. Guess what animals are low-frequency hearers? Whales. The court did not address the Navy’s other sonar use in this decision, but it did make a distinction between peacetime and wartime use, in effect saying to NMFS, the law says you have to mitigate in peacetime, and you didn’t.

The effect of blasting so many of Earth’s oceans with this much surveillance sonar all the time would be like blindfolding every one of you and saying ‘Now go find food, avoid getting hit by cars, try to stay with your family, and by the way, here’s a big headache for you that will last forever.’

SURTASS towed sonar array

The Navy’s low-frequency towed sonar can reach every corner of the ocean.

The Court found that NOAA’s National Marine Fisheries Service (NMFS) had acted in an “arbitrary and capricious” manner by ignoring habitat requirements for mitigation under the law. In other words, they were supposed to have done a lot more than they did to help the animals whose welfare they oversee. By their actions (or lack thereof) NMFS and the Navy were in effect saying an animal that needs to hear to find food can survive just fine with impaired hearing and without a protected place in which to find it. This has been proven wrong again and again in the courts over decades. You would think NMFS might do everything it can for whales, given the other stresses they are under (climate change, ship strikes, pollution, etc.)

Dead whale on beach

The Court found that NMFS violated the Marine Mammal Protection Act’s “least practicable adverse impact” standard when they eliminated 70 percent of candidate Offshore Biologically Important Areas from consideration. It’s well known that not enough data exist for these offshore areas, so NOAA scientists wrote a white paper saying that specific areas of the ocean should be protected anyway, even if we don’t have the data, because what we do have shows they are important. NMFS could have listened to its scientists, but instead it chose to eliminate the potential Offshore Biologically Important Areas that didn’t have enough data, from consideration. This was of course to the Navy’s benefit. NMFS used the rationale that “no data means it’s unimportant.” They ignored their own scientists, and in fact the white paper was never factored into NMFS’ decision to grant the Navy its permit until after the fact, when someone “discovered” it.

Finally, the Court found that there is a bias toward establishing Offshore Biologically Protected Areas in the US over other countries, and that “unless an area is within 12 miles of the coast or designated as an Offshore Biologically Important Area, there is minimal mitigation of Level B harassment.” Meaning, too many places where marine mammals migrate are not protected and the Navy can blast away at will.

The case has been remanded back to the lower court for trial. In the meantime, the Navy has responded that this decision will have no impact on its current activities.

But it’s not just whales being harmed. According to a 2012 complaint filed by Earthjustice and the Natural Resources Defense Council, “High-intensity sound has been shown to reduce the viability of fish eggs and to cause developmental damage in young fish. Intense sound can kill eggs, larvae, and fry outright or retard their growth in ways that may hinder their survival later. It has also been shown to injure the ears and lateral lines necessary for hearing in adult fish. Intense sound may also have harmful resonance impacts on fish with swim bladders, particularly larger pelagic fish such as tuna. Because fish rely on hearing to locate prey and avoid predators, affects to their hearing both impair their ability to find food and increase their vulnerability to predation.”

We will post more on this subject. In the meantime, we should all consider this a big, but conditional, win for the whales.

2 orca breach

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When millions of acres aren’t enough

Burning money

July 5, 2016 – According to a 2014 report from the US Congressional Research Service, there are more than 4,800 US Department of Defense (DOD) sites worldwide that range in size from small parcels (less than an acre) to the 3.1 million acres of the Nellis Air Force Range in Nevada. A 2012 report from the same source said that 4,127 of these sites are within the 50 states and US territories. Recent news and research reports peg the number of US bases on foreign soil as of 2015 at around 800, in approximately 80 countries. These numbers don’t quite add up because no one really knows the exact figures.


Military bases worldwide

13 DoD bases & ranges in US

Military bases in US lower 48 states

According to the 2014 Congressional Research Service report, the DOD owns 14,477,496 acres of land in the United States and its Territories, or 22,621 square miles. Much of that acreage is in the West. Interestingly, the 2012 report shows DOD having 5 million more acres in 2012 than it did in 2014. Reasons are not immediately evident, and this writer could find no news stories of DOD divesting itself of that much land. Figures from 2014 DOD land ownership include:

438,938 acres in Washington,

31,510 acres in Oregon, and

1,897,978 acres in California.

This totals 2.4 million acres, or about 3,700 square miles in these three states alone. This does not include the hundreds of thousands of square miles of airspace, or the millions of square miles of ocean they also utilize in or adjacent to these three states.

Screen Shot Low Flying Navy jets

Low-flying Navy jets over the Olympic Mountains disturb wildlife and quiet.

The purpose of DOD-owned lands is “…to guarantee DOD continued access to its land, air, and water resources for realistic military training and testing and to sustain the long-term ecological integrity of the resource base and the ecosystem it provides.” The use of the phrase “realistic military training” is odd, since the military defines it (RMT) as taking place “off federally owned property.”

So with all that available space, why does the Navy insist it also needs our national forests, national parks, state parks, and even private lands, too?

A 1988 agreement states that the DOD must prove that military-owned lands are unavailable or unsuitable before they can be allowed to take over a national forest. Nowhere in any public documents relating to our region have they ever done that. And they are not managing the lands they already own, either.

Back in 2005, the US Government Accountability Office (GAO) published a report that was critical of the military’s management and utilization of its training ranges. Some ranges were overscheduled, and others were not utilized at all. Of 8 management actions for improving training range conditions analyzed by the GAO, the Navy was the only branch of the armed services to not complete a single one. Nearly ten years later, GAO’s most recent report (2014) concludes that the Secretary of Defense “…does not have a strategic plan, with goals and metrics, to manage DOD’s real property efficiently and facilitate identifying opportunities for consolidating unutilized or underutilized facilities.” Really? No plan? For 14 million acres?

Sometime this summer, the Forest Service will likely announce that it is adopting wholesale the Navy’s flawed 2014 Environmental Assessment on using its mobile emitters in Olympic National Forest. The Forest Service will then open a 45-day “objection period.” As if the public hasn’t already made their objections known—4,000 written public comments and thousands more expressions of public outrage back in autumn 2014 earned a 2-year stay from the Forest Service, but we will all have to again object en masse. Why? Because if the Forest Service and Navy think they can ignore the public, they can’t ignore the courts, and your comments will count heavily for the weight of public opinion when they are taken to court. You will be notified when the objection period opens.

It’s also worth noting that the Pentagon, whose spending continues to balloon despite claims to the contrary, is the only department of the government to have never passed an audit, despite a 1994 federal law saying it must. In fact, the Pentagon has never accounted for $8.5 trillion dollars doled out by taxpayers since 1996.


Think about it. If not even the Government Accountability Office can make the military fiscally accountable or manage its own ranges so that they don’t have to take over our precious public lands, then maybe there’s only one real force that can stop them: Citizens. Armed with facts, votes, raised voices, political savvy and the determination to stop this runaway war train that spends two dollars on defense contractors for every dollar it spends on troops, and either cannot or will not manage the resources given to it by taxpayers. The DOD has millions of acres for combat training. Let’s not allow our public parks, wildernesses and neighborhoods to be used that way, too.

ONP hiker

The notion that people who exercise critical thinking about their government are unpatriotic radicals who hate their country is naive and idiotic. These people are more likely the ones who love their country more than most, are thus more disturbed than the rest when they see it debauched, and are more willing to step up and act against their despair.

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Updates – underwater pile-driving, ocean noise, comments


A massive amount of pile driving is about to take place in Port Angeles harbor as the Navy gives us a tenfold construction increase. Pile driving noise carries 18 miles underwater. Wildlife, fisheries and the tourism economy will be adversely affected.

June 28, 2016 –  A lot is happening.

1. The US Forest Service has again delayed their decision on use of Navy mobile electronic warfare emitters in Olympic National Forest. Kim Crider, USFS Environmental Planner/Coordinator, said, “Our schedule has been delayed and the draft Decision Notice is not likely to be released until mid to late July at the soonest. You will be notified by email when the draft document is released for the 45-day Objection Period.”

2. 18 months of massive Navy pile-driving in Port Angeles harbor: The US Navy has quietly added 144 new pilings to its request for construction of facilities in Port Angeles harbor. These were not covered in the  January 2015 Environmental Assessment many of us commented on. It represents a tenfold increase in pile-driving, which can be heard for 18 miles underwater and is certain to drive marine mammals from the area. An application was filed late this month with the State and the US Army Corps of Engineers, and a comment period on that application is now open. Email your comments to brian.d.hooper@usace.army.mil and ecyrefedpermits@ecy.wa.gov. Tell them that when taken together, these projects rise to the impact level of a full Environmental Impact Statement (EIS) and thus the certification or concurrence  from the two agencies should not be given until the Navy has complied with its legal obligations to the public. Separation of functionally and geographically connected projects for the purpose of avoiding a full public examination of the cumulative impacts is illegal, and National Environmental Policy Act (NEPA) case law has proven this again and again. Comment period closes July 23. To see a spreadsheet of upcoming Navy construction activity that was provided to a veterans organization by a Navy employee, click here. The 144 extra pilings are item #14.

3. NOAA’s Ocean Noise Strategy Roadmap comment period closes July 1. If you aren’t familiar with it, this news article from the Washington Post will help. You still have time to comment, and you can email them to Comment.ONS@noaa.gov. Be sure to put “ONS Roadmap Comments” in the subject line. Here are three comment letters from which you can borrow language:

West Coast Action Alliance joint comment letter with 14 organizations and individuals;

Olympic Park Associates comment letter; and

A joint comment letter from a group that formed after the showing of the movie “Sonic Sea.”

4. Resolutions are being passed from Alaska to the Pacific Northwest. The City of Cordova, Alaska, passed a resolution asking the Navy to locate its war games further offshore, to do them in the fall after peak animal migration and feeding times are over, and to refrain from using live ordnance or sonar in any Marine Protected Area, including NOAA Fisheries Marine Protected Areas, State Marine Protected Areas and Habitat Areas of Particular Concern. These are reasonable requests, but the Navy continues to ignore Alaskans as it does Washingtonians. In fact, the Navy has actually scheduled its next Alaskan war games during prime peak time for the Copper River salmon run. That’s akin to a stick in the eye. This 4-minute video shows what’s at stake.

Another resolution objecting to Navy noise was recently passed in Skagit County, Washington. Add this to recent resolutions passed in San Juan, Clallam and Jefferson County  — in fact, a whole slew of them from California to Alaska — and it’s becoming clear that public antipathy for the unwarranted and unnecessary expansion of war games into public lands, waters and the skies over our once-quiet communities is rising. Maybe one or two or five resolutions get ignored by the Navy, but there comes a point where they can no longer be ignored. Resolutions also serve as a tool to alert and educate people to what is happening. If you think a resolution ought to be passed by your local governing body, read the resolutions that have been passed so far, and help get more passed. A local citizens group is working on this for the Olympic Peninsula; if you want to help, contact us and we will put you in touch with them.

Orcas breaching

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Analysis of Navy EIS – Northwest Training and Testing

Freelan_SalishSea_125 From WWU

June 16, 2016 – The West Coast Action Alliance is publishing its Analysis and Notes on the Navy’s Northwest Training and Testing EIS along with other documents:

The Navy’s Incidental Take of Marine Mammals and Endangered Species in Pacific Northwest Waters: An Analysis

and a chart adding up the numbers in four corners of the North Pacific Ocean: Takes by Species of Marine Mammal

To read the Navy’s EIS (Environmental Impact Statement) in sections, click here.

Can anything be done about noise and marine mammals? Yes. Read about NOAA’s “Ocean Noise Strategy Roadmap” summarized in this New York Times article and show your concern by sending comments to: Comment.ONS@noaa.gov Your subject line should say “ONS Roadmap Comments” and email your comments until July 1, 2016. Include any citations to scientific literature you know of, as this is a search for information, too.

2 orca breach

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A plan to give whales some peace and quiet


Unfortunately, this is not the “peace and quiet” we were hoping for; the Navy has evidently claimed another whale. Photo credit: Cascadia Research

June 6, 2016 – Another dead whale has been found in Puget Sound. This one was a young humpback that died after becoming trapped under the Navy’s docks at Bremerton (see photo below.) According to a report from Cascadia Research, “There was bruising at multiple locations consistent with it struggling after become trapped but these did not seem extensive enough to kill the animal. The exam could not rule out drowning related to becoming trapped under the dock. While not all tissues could be accessed and collected, additional tests will be conducted on some of the tissues that could be collected and these could provide additional insight into the cause of death.” This is the second whale death in little more than a month.


Young humpback whale trapped under Navy’s docks at Bremerton. She died there. How could this happen? Photo credit: Cascadia Research

Starvation is not a likely factor in this whale’s death, because Cascadia’s report said, “There were food remains in the intestines and colon indicating the whale had been feeding recently on fish as well as possibly krill and these suggest the cause of death was more sudden and acute.”

This post explains the enormous increases in Navy activities in our waters.


The Navy is disavowing culpability in this whale’s death; in fact, a Kitsap Sun news story reported that the “40-foot beast floated late Wednesday morning beneath a Puget Sound Naval Shipyard dock. A Navy boat towed it out of the way, into the bay.” It did not report that the whale had become trapped under the docks while still alive. Why? Did the Navy not notice a live 40-foot whale under its docks? Did they omit this or the fact that the whale was known to have been alive under there, when talking to news reporters? Does the Navy plan to retrofit its docks so this won’t happen again?

While shipping noise in general is a major factor in the silencing of whales’ ability to find food and each other, it is also a published fact that Navy underwater drones used in inland waters will increase from 140 to 161, that unmanned surface vehicles (which the Navy admits has trouble seeing sailboats) in inland waters are increasing from 2 to 25, that torpedoes used in inland waters will see huge increases, and worst of all, that acoustic testing and “life cycle” activity for sonar will increase at the Navy’s docks to 284 events per year.

Did the Navy run one of these acoustic tests while the whale was nearby?

Consider the fact that because of these increases the Navy is being allowed to “take” nearly 12 million whales, dolphins, porpoises and other marine mammals in the North Pacific, and that the takes breakdown for our waters covered by their Northwest Training and Testing EIS is as follows:

Coastal waters of California, Oregon and Washington:                575,258

Washington inland waters (Puget Sound, Hood Canal):              343,310

Southeast Alaska:                                                                              10,950

Eastern North Pacific (offshore)                                                     21,996

Consider also that because some of the Navy’s increases in activity are more than a thousand percent, it should be obvious that their contributions to the increasing levels of noise in the ocean are significant. Ocean noise has been doubling every decade. That’s from the Navy’s own figures.

The upshot? Maybe we should learn to expect more dead whales.

Or maybe there’s a better way. Natural Resource Defense Council Director of Marine Mammal protection Michael Jasny put it best. He said, “Unlike other ocean pollutants, this problem can be solved. Once you stop making noise, it goes away.”

An Ocean Noise Strategy Roadmap summarized in this New York Times article proposes to summarize the current status of noise in the oceans and the science that documents it; it will help NOAA to recommend cross-agency actions that will reduce this noise, and NOAA is asking for public comments. Please send your comments to Comment.ONS@noaa.gov, and make sure you put “ONS Roadmap Comments” in the subject line and any supporting data or literature citations with your comments, as appropriate. Even if you are not a scientist and don’t have data or scientific literature to reference, your comments are important because NOAA needs to know how much public concern there is.

The health of whales is an indicator of the health of our oceans. The health of our oceans is an indicator of the health of our planet. Even the most jaded person cannot ignore the fact that our oceans are worth $24 trillion dollars, and that if the ocean was a country it’d be the seventh largest economy on the planet.

Finance aside, the way we treat these intelligent cetaceans will be a measure of our collective humanity.

Sonic Sea - sperm whale

Sperm whale. Photo credit: Sonic Sea

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How the Navy gets its way, part 5: Forcible Evacuation


Tinian Island after the military took it over for war games.

May 30, 2016 – While the country celebrates Memorial Day and thanks veterans and serving military for their service to our nation, American citizens are about to be forcibly evacuated from an island they’ve inhabited for 3,000 years.


Pagan Island (pronounced pa-GAHN) as it looks now, before the Navy claims it for bombing practice.

The people of the Northern Mariana Islands in the western Pacific  decided in the 1970s to not seek independence, but instead to forge closer ties with the United States. They established a commonwealth in political union with the United States in 1975. Like other U.S. territories, the islands do not have representation in the U.S. Senate, but, since 2009, are represented in the U.S. House of Representatives by a delegate who may vote in committee, but not on the House floor.


The Northern Marianas are a US Commonwealth.

In 2013 the US Navy and Marine Corps announced their intention to turn all of Pagan Island (pronounced “pa-GAHN”) in the Commonwealth of the Northern Mariana Islands into a live-fire bombing range and training area. The military requested “unfettered and uninterrupted access” to the island, which means the people are to be forcibly removed. Pagan is called “the jewel of the Pacific” because it’s pristine and biologically rich but also fragile. It has been the ancestral and spiritual home of the Chamorro and Carolinian peoples for more than 3,000 years, with recorded history dating back to the 1300s, and is being proposed as an ecotourism resort.


Pagan Island. The Navy has refused to communicate with indigenous peoples in their own languages, thus denying them the right to know what the plans are.

Because of a 1981 volcanic eruption that caused temporary relocation of many but not all residents, families who had to leave the island have been wanting to return ever since. Some residents never left and still live there. “It is one of the most habitable islands in the Mariana chain,” said Dr. Michael Hadfield, a biologist at the University of Hawaii who has studied the island’s unique flora and fauna. Unfortunately, the government has for decades denied resettlement to most of the island’s former residents who have applied, and now the Navy and Marines claim the island is “uninhabited,” which is not true. Because of the volcano they say it’s “too hazardous” for resettlement. And they intend to forcibly evacuate the island’s remaining residents so bombing can commence in 2017.

According to the Los Angeles Times, massive, “guns-blazing war games on Pagan at least 16 weeks a year” would allow aerial, naval, field artillery, grenade, mortar, laser, and rocket bombardment. The Navy says it’ll be a good steward of the island, but with more than 700,000 live rounds to be fired yearly, that’s hard to imagine. And with fewer than 600 of the island’s 11,680 acres officially surveyed for cultural resources, how would the military know where not to bomb? More than 180 historic sites are known on the island, 110 of which are eligible for the National Register of Historic Places. Contractors working for the Navy identified six of those sites, after which the Navy discontinued the survey. That is the military equivalent of shoot, shovel and shut up.

A disturbing chain of events and manipulation has led to this crisis: READ THE REST OF THE ARTICLE


Opposition to forcible evacuation and seizing their ancestral home is universal in the western Pacific.

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The unbearable noise

Water texture

May 16, 2016 – Noise in the sea is killing and injuring wildlife.

“The Navy merely received a slap on the wrist and the public was never aware of the true nature of the Take or the violations.” -anonymous Navy source to Truthout reporter Dahr Jamail

The numbers are shocking. The online news organization Truthout published their top story this morning, on the excessively high numbers of marine mammals the US Navy is allowed to “take” as a result of exploding mines and bombs and using sonar in sensitive habitats during testing and training exercises. Truthout senior investigative reporter Dahr Jamail researched and wrote it after noticing this post from the West Coast Action Alliance.

Coincidentally, the New York Times wrote last week that Navy sonar “cannot be ruled out as cause of death” for dolphins in Southern California.

Which brings us to this: 23 organizations are sponsoring a showing of the movie “Sonic Sea” on Monday, May 23 from 7-9 PM at the Quimper Unitarian Universalist Fellowship (QUUF) in Port Townsend, Washington, 2333 San Juan Avenue. The eye-opening film reveals how noise from Navy sonar, drilling operations and everyday vessel traffic adversely impacts whales and other sea life. (Watch trailer here.) A donation of $10 is suggested at the door.

Two world renowned experts and cast members will be at the screening – Ken Balcomb of the Center for Whale Research and Michael Jasny of the National Resources Defense Council. They will speak and, after the film, lead a Q&A session. (Press release here.) If you are not in the area, check this site for more screenings, or to host one in your area. To learn more, download the Ocean Noise Report. See you there.

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Low oxygen delivery endangers pilots, civilians

May 14, 2016 – “Nothing scares a Hornet/Growler pilot more that losing oxygen – and it happens all the time.” This article in the Navy Times details the problem, which pilots have identified as their top concern. But read the comments, some are from pilots who add perspective, including the fact that the problem is decades old and the new, less reliable oxygen delivery system replaced the old reliable one because it made maintenance cheaper.

Here’s the issue as we see it: While the West Coast Action Alliance maintains our vigorous objections to the Navy’s encroachment on public lands, waters and airspaces over civilian communities, we also vigorously object to the fact that when the Pentagon’s focus becomes “How much money can we spend on defense contractors making new weapons” instead of “How can we take care of the people who serve and who’ve served,” then they put lives in danger unnecessarily, both in the air and on the ground. This is a fixable problem and the Navy is not fixing it. Do they not have the money? Not when you look at this list that shows at least 2/3 of the Pentagon’s budget goes to defense contractors. Of the top 37 US contractors, all but 4 are defense, and development of new weaponry takes priority. Humanity already knows ways to kill itself a thousand times over, but preventable jet crashes should not be one of them.

If a Navy jet ever crashes and hypoxia is found to be the cause, it will likely be a matter of criminal negligence.


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Leaked Navy emails show intent to violate law

USFWS Marbled_murrelet

Marbled murrelet-gate?

May 9, 2016 – A series of internal emails leaked by an anonymous Navy source to Truthout investigative reporter Dahr Jamail reveal a deliberate willingness by the US Navy to flout federal law; the story was published today.

The gist? Navy personnel have been “working to manipulate the US Fish and Wildlife Service (FWS) biologists into bending the law, then proceeded to break the law, whilst the consultations between the two entities are ongoing.”

A quick reading of the emails also reveals an unprecedented level of intimidation by Pentagon-level officials, of FWS field biologists.

According to the article, Navy sonar and explosive activities are a double whammy for marbled murrelets, “… secretive diving seabirds that nest in old-growth forests, which makes them vulnerable to both jet noise and sonar.” The Navy’s John Mosher frankly admits in one email, “We are conducting these activities without coverage.” Meaning, a valid permit to “take” (harm) threatened and endangered species does not exist, which is illegal.
The emails show the Navy trying to force the FWS to shrink its definition of harm by eliminating both temporary hearing loss caused by explosives, and behavior changes of all kinds, from the standards for measuring harm. This too would be illegal if the FWS complied with that request. It is possibly the reason for concern that has caused an unprecedented delay in completing the Biological Opinion (and the take permit that accompanies it) that the Navy wanted last September. According to the FWS, neither is complete and the consultation is still open. Which raises big questions about the legality of the Navy’s ongoing activities.

West Coast Action Alliance spokesperson Karen Sullivan, who was asked to analyze the emails, said, “If an evaluation of harm to a species rules out standard definitions of harm, encourages use of data more than 40 years old and prohibits the presence of adequately trained observers, then it neither gives the benefit of the doubt to the species nor uses the best available information — and thus does not contribute to legally defensible solutions.”
What will it take to make the Navy follow the law? Must the citizens who already pay for the Pentagon’s $600 billion dollar budget also have to sue them to keep them honest?

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Facts about increased Navy ocean activity in the Pacific Northwest

Update May 12, 2016: Navy sonar not ruled out in dolphin deaths off Southern California.

April 26, 2016 – Analysis of increases and some impacts as shown in the Navy’s Northwest Training and Testing EIS.

Orcas breaching

Orcas breaching

It’s obvious even to tourists that the increase in Navy activity in our Northwest waters, public lands, and skies is huge. But how big? The West Coast Action Alliance examined the Navy’s Northwest Training and Testing EIS (Environmental Impact Statement) and the Letters of Authorization  for incidental takes of marine mammals issued by NOAA’s National Marine Fisheries Service. We found some startling numbers. These numbers apply only to the coastal waters of Northern California, Oregon, Washington and Southeast Alaska, as well as inland waters including the San Juan Islands, Puget Sound, Hood Canal, and the Strait of Juan de Fuca. Click on any image to enlarge it.

Screen shot NWTT EIS map

Map from the Navy’s EIS showing the Northwest Training and Testing Range. This does not include any other ranges such as the Electronic Warfare Range on Washington’s Olympic Peninsula.

The NWTT EIS is still open because the Navy has not been able to sign a final Record of Decision (ROD) due to the fact that the US Fish and Wildlife Service’s endangered species consultation is still not finished, seven months after publication of the EIS. This is unprecedented.

First, a comparison of baseline to proposed numbers of activities listed in the October 2015 EIS revealed the following:

72% increase in electronic warfare operations,

50% increase in explosive ordance disposal in Crescent Harbor and Hood Canal,

244% increase in air combat maneuvers (dogfighting)

400% increase in air-to-surface missile exercises (including Olympic National Marine Sanctuary),

400% increase in helicopter tracking exercises,

778% increase in number of torpedoes in inland waters,

3,500% increase in number of sonobuoys,

From none to 284 sonar testing events in inland waters,

From none to 286 “Maritime Security Operations” using 1,320 small-caliber rounds (blanks) in Hood Canal, Dabob Bay, Puget Sound & Strait of Juan de Fuca,

72% increase in chaff dropped from aircraft (contains tiny glass fibers and more than a dozen metals,)

1,150% increase in drone aircraft,

1,150% increase in drone surface vehicles,

1,450% increase in expendable devices. These are just a few.

140915-N-UN259-006 PACIFIC OCEAN (Sept. 15, 2014) The Arleigh Burke-class guided-missile destroyer USS Stethem (DDG 63) fires a Harpoon missile during a sinking exercise as part of Valiant Shield 2014. Air and sea units from the U.S. Navy, Marine Corps and Air Force participated in the sinking exercise of the ex-USS Fresno to gain proficiency in tactics, targeting and live-firing against a surface target at sea. (U.S. Navy photo by Mass Communication Specialist Seaman Alonzo M. Archer/Released)

PACIFIC OCEAN (Sept. 15, 2014) The Arleigh Burke-class guided-missile destroyer USS Stethem (DDG 63) fires a Harpoon missile during a sinking exercise as part of Valiant Shield 2014. Air and sea units from the U.S. Navy, Marine Corps and Air Force participated in the sinking exercise of the ex-USS Fresno.

There are no changes to the following:

2 ship sinking exercises each year with 24 bombs, 22 missiles, 80 large caliber rounds and 2 heavyweight high explosive torpedoes,

30 air-to-surface bombing exercises, including in the Olympic Coast National Marine Sanctuary,

160 gunnery exercises with small, medium & large caliber rounds, missiles, and high explosive warheads offshore, includes Olympic Coast National Marine Sanctuary,

An active-duty Navy pilot confided that fuel dumping incidents occur more often than the public realizes; they happen about once a month.

And there are more.


Olympic Coast National Marine Sanctuary extends well into to offshore waters; the Navy is exempted from many prohibitions that protect marine species.

Now let’s look at the figures for “takes” to marine mammals. A “take” is a form of harm ranging from disturbance to injury to death. Under the Marine Mammal Protection Act  there are two classifications, called Level A and Level B.  Level B is mostly harassment, and Level A is injury (or death.) Most takes allowed are in the harassment category, but harassment causes behavior changes such as abandonment of feeding, nursing, and migration habitat. If a marine mammal that relies on echolocation to find food can’t hear, it has to work harder to feed itself. If it can’t take in extra food, it loses weight. A study on the increases in metabolism in bottlenose dolphins showed that after the animals had to work harder to find food or be heard, it took another 7 minutes per episode for oxygen consumption to return to normal levels. That translates eventually to starvation if they cannot find enough food to make up the difference.

Sperm whale

Sperm whale

The problem with Level A harassment is in documenting injuries or deaths; frequent mass strandings have occurred days after naval activity in an area, but in nearly every case the Navy disavows being the cause. They do not allow federal wildlife agency experts aboard their ships because of security concerns about civilians; however, civilian fitness instructors are found on many Navy ships. None of the mitigation measures require the Navy to tow hydrophones to listen for marine mammals before commencing exercises; the Navy’s technology for observing whether marine mammals are present is the same that has been used since the 17th century: two lookouts at the bow of the ship.

A recent study found that climate change can affect fur seal pups in their first few months of life. Wetter and windier conditions are predicted for Antarctica in the coming years. Young fur seals will expend more energy keeping warm and, thus, less energy growing and developing. (Photo Credit: Jordan Spielman)

Seal pups. Younger animals are more vulnerable to harassment, and less able to recover from it.

The noise threshold for hearing damage in humans is 85 decibels. For every 10-decibel increase, the intensity of the noise increases by a factor of ten; therefore, a 115-decibel noise, which is roughly what a Growler jet makes when passing overhead at altitude of 1000 feet, is a thousand times louder than the 85-decibel threshold for human hearing damage. Navy sonar is capable of at least 235 decibels at the source. This is over 10 trillion times more intense than the 85-decibel threshold. At a distance of 300 miles away from the source, underwater noise can still be 140 decibels. 140 decibels is sufficient to vibrate and rupture internal organs, and has been assessed by the French government as “a weapon to kill people.”

splashdatamap Hawaiian Humpback feeding-migration areas

Humpback feeding and migration areas

What does this mean? Since the Navy is positioning its ships in whale migration routes and feeding areas without regard to peak times of use for the animals, it means the animals will continue to work harder and to lose weight if they can’t find enough to eat, which is already exacerbated by climate change and decreasing abundance of their food. Since 30 large whales washed up on Alaskan beaches last summer in what NOAA called an “Unusual Mortality Event,” and since it was during the time Navy ships were up there conducting “Operation Northern Edge” sonar and bombing exercises, and since every single dead whale was also emaciated, one has to wonder who in their right mind wouldn’t take steps to reduce harassment of already-stressed animals.


Here are take numbers from the Northwest Training and Testing EIS, for just the waters from Northern California to Southeast Alaska, including Puget Sound and other inland waters, for a 5-year period:

Whales (toothed and baleen)         18,921

Dolphins and porpoises                   843,465

Seals and sea lions                            364,538

Totals:                                               1,226,924

Here are those numbers broken down by NWTT area:

Coastal waters of California, Oregon and Washington:                575,258

Washington inland waters (Puget Sound, Hood Canal):              343,310

Southeast Alaska:                                                                              10,950

Eastern North Pacific (offshore)                                                     21,996

Remember, these numbers do not include takes to endangered and threatened seabirds, fish, sea turtles or terrestrial species impacted by Navy activities, using sonar, explosives, underwater and surface drones, sonobuoys, ships, submarines, aircraft, or troops training on 68 beaches and state parks in western Washington. The numbers also do not include takes for smaller projects such as underwater detonation exercises and/or pile-driving and construction at Port Angeles, Bremerton, Everett, Kitsap, or Whidbey Island, nor does it include impacts from sonar and other acoustic devices at the Keyport Range Complex Expansion, or any impacts brushed over in dozens of Environmental Assessments that split the projects into smaller pieces so they don’t rise to the threshold of a full-blown EIS.


Migration routes for endangered Leatherback Sea Turtles

With regard to the 72% increase in chaff, the EIS says it is “…typically packaged in cylinders approximately 6 in. by 1.5 in. (15.2 cm by 3.8 cm), weighing about 5 oz. (140 g), and containing a few million fibers. Chaff may be deployed from an aircraft or may be launched from a surface vessel. The chaff fibers are approximately the thickness of a human hair (generally 25.4 microns in diameter) and range in length from 0.3 to 2 in. (0.8 to 5.1 cm). The major components of the chaff glass fibers and the aluminum coating are alumina, boron oxide, sodium oxide, potassium oxide, copper, manganese, silicon, iron, zinc,vanadium, titanium, and other metals.”

A 1997 Air Force study reviewed the potential impacts of chaff inhalation on humans, livestock, and other animals and concluded that the fibers are “…too large to be inhaled into the lungs.” Whose lungs? A fiber the thickness of a human hair is certainly inhalable by human beings, even children. And what about marine mammals with upturned and very large breathing holes? The fibers, said the study, were predicted to be deposited in the nose, mouth, or trachea and either swallowed or expelled. Has the public been made aware of the effects of chaff ingestion? Is chaff inhalation or ingestion by marine mammals considered a taking? Not that we could see.

chemring_co chaff UK

Chaff being dropped from a fighter jet. Chaff is often accompanied by flares.

The West Coast Action Alliance noticed some discrepancies among the Letters of Authorization (LOA) issued by NOAA to the Navy for takes; for example, more than 133,000 takes for bottlenose dolphins off the Northern California-Oregon-Washington coast were not listed in the LOA for the Northwest Training and Testing EIS – they were in the LOA for Hawaii-Southern California. Why? We don’t know, but the omission certainly helped to reduce the appearance of large numbers of marine mammal takes in the NWTT area. Curious, we looked at the LOAs for four EISs done in four regions of the North Pacific: the Gulf of Alaska, the Pacific Northwest coast, Hawaii-Southern California, and the Marianas Islands. What we found was shocking.

gray whale breaching

Gray whale

When you consider, for example, that the best estimate for the number of gray whales in the eastern North Pacific is 21,000, and that they migrate up and down the West Coast from Alaska to Mexico, but that the numbers of takes allowed to the Navy in the areas of the Pacific where gray whales might be found is 62,550, it becomes clear that multiple harassment incidents to the same animals throughout their range are not only anticipated but allowed.

Gray whale global distribution

Where gray whales are found

The WCAA also found it interesting and disturbing that neither sonar, bombing, explosives, nor any military activity whatsoever is included on NOAA’s list of threats caused by human impacts. Why, when this this much harm is being done on such a scale?

Takes by species: If you add up all the Navy’s takes of whales, dolphins, porpoises, seals and sea lions for these four regions of the North Pacific for a 5-year period, it is nearly 12 million.

Click here to see the take numbers broken down by individual species and regions, but you might want to be sitting down, it’s a horrifying picture. And remember, it only includes marine mammals.

The Navy prides itself on a concept it calls “Distributed Lethality,” the definition of which is “ …the condition gained by increasing the offensive power of individual components of the surface force (cruisers, destroyers, littoral combat ships [LCSs], amphibious ships, and logistics ships) and then employing them in dispersed offensive formations known as “hunter-killer SAGs.” SAG stands for “Surface Action Group.” The Navy has already sent a “hunter-killer pack of ships” into the Pacific toward Asia, in a clear sign that war games across the globe evidently know no limits to civilians.

It’s also clear that when it comes to wildlife, the Navy distributes lethality very, very well.


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