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Gulf of Alaska Bombing Range

The U.S. Navy is planning to expand military training exercises across 42,000 square miles of the Gulf of Alaska, which would involve a massive armada with live fire munitions, hazardous waste dumping and underwater sonar known to harm marine mammals. Now, the Navy wants a permission from the National Marine Fisheries Service (NMFS) under the federal Marine Mammal Protection Act to “take” over 425,000 marine mammals each year for five years.

The U.S. Navy is planning to expand military training exercises across 42,000 square miles of the Gulf of Alaska, which would involve a massive armada with live fire munitions, hazardous waste dumping and underwater sonar known to harm marine mammals. Now, the Navy wants a permission from the National Marine Fisheries Service (NMFS) under the federal Marine Mammal Protection Act to “take” over 425,000 marine mammals each year for five years. See www.nmfs.noaa.gov/pr/permits/incidental.htm

Background

The U.S. Navy released a Draft Environmental Impact Statement (DEIS) in late 2009 covering various alternatives for continuing to use the Gulf of Alaska (GOA) and its rich fisheries as a military bombing range and training area.  The Navy plans to introduce – for the first time – extensive sonar training in the GOA; its preferred alternative would use many different sources of active sonar, totaling over 1,160 hours of sonar use every year. The Navy also plans to abandon at least 352,000 pounds of spent material (both hazardous and non hazardous) in the GOA every year; over 10,300 pounds of this expended material is hazardous waste.  These proposed sonar training activities would pose significant risk to whales, fish, and other wildlife that depend on sound for breeding, feeding, navigating, and avoiding predators—in short, for their survival.  The GOA training activities would also affect fisheries and essential fish habitat by releasing large amounts of hazardous and expended materials into the waters.

SEND COMMENTS TO:

Michael Payne, Office of Protected Resources, National Marine Fisheries Service, 1315 East-West Highway, Silver Spring, MD 20910-3225. Email: PR1.0648-XU14@noaa.gov

Talking Points:

(Adapted from information provided by the Natural Resources Defense Council)

  • Military readiness is vital to our national security, but it need not come at the expense of degraded water quality, fisheries and marine mammal populations.

  • The Navy estimates that its sonar training exercises in the GOA from its Preferred Alternative (Alternative 2) will result in more than 425,000 marine mammal "takes" (behavioral impacts, harassment, injury, death) every year - that's over 2.125 million takes during the course of the Marine Mammal Protection Act permit it must seek from NOAA.  In all, the Navy expects to "take" more than 20 different species of marine  mammals, including 7 endangered species, in the GOA.  Nearly all of the mitigation measures that the Navy has proposed for the GOA concern the operation of a small "safety zone" around the sonar ship. Yet it is widely agreed in the scientific community that this measure is inadequate given the far-reaching effects of Navy sonar and the difficulty of spotting marine mammals from fast-moving vessels.  The Navy has not proposed to establish any protection areas in the GOA, despite the broad recognition that geographic protection zones are the most effective available means to mitigate sonar's impacts on marine wildlife.  For example, no protection areas are proposed for harbor porpoises, which are acutely sensitive to sound; for endangered gray whales, which migrate directly through the TMAA; for endangered humpback whales and blue whales, which gather to feed in the TMAA; for the critically endangered North Pacific right whale, who's critical habitat is directly adjacent to the TMAA; or for any other species or habitat.

  • The Navy does not properly analyze environmental impacts. For instance, it completely disregards the serious impacts its sonar training will have on the critically endangered North Pacific right whales, whose critical habitat is only 12 nautical miles from the training area or the endangered gray whales, which migrate through the training area.  Furthermore, it fails to discuss and analyze the cumulative effects its activities may have in conjunction with other projects and activities in the area.

  • The Navy underestimates the number of marine mammals (and fish) that will be harassed, injured and killed because it simply does not have the density estimates needed in order to accurately make this determination. The National Environmental Policy Act (NEPA) specifically requires federal agencies to obtain the data necessary to their analysis. The simple assertion that "no information exists" will not suffice; unless the costs of obtaining the information are exorbitant, NEPA requires that it be obtained. See 40 C.F.R. § 1502.22(a).

  • The Navy's acoustics impact analysis ignores scientific studies contrary to its interests and uses methodologies not supported by the scientific community. Thus, the thresholds it sets for permanent injury, temporary injury (hearing loss) and behavioral change (which we would argue are too high and thus completely underestimate the actual number of wildlife that will be impacted) are invalid as a matter of science.

  • The Navy's alternative analysis is inadequate. The Navy only presents three options - maintain the status quo, add more training, or add even more training. It does not consider - or blithely dismisses - any other alternatives, some employed by the Navy itself in other training exercises and ranges.

  • Most critically, the Navy does not set forth adequate measures to mitigate the harmful effects of sonar. Its proposed mitigation measures basically boil down to "safety zones" (1,000 yard power-down and 200 yard shut down) around the sonar maintained primarily by on-board visual  monitors. These are the same measures that federal courts have found to be "woefully inadequate and ineffectual." (For instance, studies show that visual monitoring only spots about 5% of marine mammals. Statistically, a 5% "success" rate clearly does not cut it.) The Navy's refusal to employ better mitigation measures is astounding, because it has used more protective measures during previous training.

Information on the Impacts of these Proposed Activities

Comments from Natural Resources Defense Council

Comments from Trustees for Alaska

Comments from Ocean Conservation Research

 

For more information:

Bob Shavelson
Cook Inletkeeper
907.235.4068 x22
keeper@inletkeeper.org