Monday, February 18, 2013

Navy sonar and explosions comments

Video of abnormal dolphin behavior off San Diego in the vicinity of Navy sonar.

NOAA seeks comment on regulations to protect marine mammals during Navy training and testing in waters off California and Hawaii

Connie  Barclay
 (301) 427-8003 
 (202) 441-2398  (Cell)
January 25, 2013
NOAA’s Fisheries Service is seeking comments for a proposed rule requiring the United States Navy to implement protective measures during training and testing activities off the coasts of California and Hawaii and on the high seas of the Pacific Ocean to reduce the chances of harming marine mammals.
The Navy has requested an authorization under the Marine Mammal Protection Act, because the mid-frequency sound generated by active sonar, the sound and pressure generated by detonating explosives, and other associated activities may affect the behavior of some marine mammals, cause a temporary loss of their hearing sensitivity or other injury.
NOAA’s Fisheries Service recently made a preliminary determination that these effects would have a negligible effect on the species or stocks involved.  Based on that preliminary determination, it does not necessarily expect the exercises to result in serious injury or death to marine mammals, and proposes that the Navy use mitigation measures to avoid injury or death.
However, exposure to sonar in certain circumstances has been associated with the stranding of some marine mammals, and some injury or death may occur despite the best efforts of the Navy. Therefore, the proposed authorization allows for a small number of incidental mortalities to marine mammals from sonar, as well as vessel strikes and explosions.
Under the authorization, the Navy would have to follow mitigation measures to minimize effects on marine mammals, including:
  1. establishing marine mammal mitigation zones around each vessel using sonar;
  2. using Navy observers to shut down sonar operations if marine mammals are seen within designated mitigation zones;
  3. using mitigation zones to ensure that explosives are not detonated when animals are detected within a certain distance;
  4. implementing a stranding response plan that includes a training shutdown provision in certain circumstances, and allows for the Navy to contribute in-kind services to NOAA’s Fisheries Service if the agency has to conduct a stranding response and investigation; and,
  5. designating a Humpback Whale Cautionary Area to protect high concentrations of humpback whales around Hawaii during winter months.
These measures should minimize the potential for injury or death and significantly reduce the number of marine mammals exposed to levels of sound likely to cause temporary loss of hearing. Additionally, the proposed rule includes an adaptive management component that requires that the Navy and NOAA’s Fisheries Service meet yearly to discuss new science, Navy research and development, and Navy monitoring results to determine if modifications to mitigation or monitoring measures are appropriate.  
NOAA’s Fisheries Service and the Navy have worked to develop a robust monitoring plan to use independent, experienced vessel-based marine mammal observers (as well as Navy observers), and passive acoustic monitoring to help better understand how marine mammals respond to various levels of sound and to assess the effectiveness of mitigation  measures. Additionally, an Integrated Comprehensive Monitoring Plan being developed by the Navy (with input from NOAA’s Fisheries Service) will better prioritize monitoring goals and standardize data collection methods across all U.S. range complexes.  
The proposed rule is posted on our website:
NOAA Fisheries will accept comments through March 11, 2013. Comments should be addressed to:
P. Michael Payne, Chief, Permits and Conservation Division
Office of Protected Resources
National Marine Fisheries Service
1315 East-West Highway
Silver Spring MD 20910-3225
Electronic comments can be sent via the Federal eRulemaking Portal:, using the identifier 0648-BC52.
NOAA’s mission is to understand and predict changes in the Earth's environment, from the depths of the ocean to the surface of the sun, and to conserve and manage our coastal and marine resources. Join us on Facebook, Twitter and our other social media channels at

These are the comments I submitted. You are welcome to excerpt from them in writing your own. I was unable to get the eRulemaking portal to work, so I sent a hard copy via regular mail.

18 February, 2013

P. Michael Payne, Chief, Permits and Conservation Division
Office of Protected Resources
National Marine Fisheries Service
1315 East-West Highway
Silver Spring MD 20910-3225

Electronic comments can be sent via the Federal eRulemaking Portal:, using the identifier 0648-BC52.

Dr. Payne:

Regarding the proposed rule requiring the United States Navy to implement protective measures during training and testing activities off the coasts of California and Hawaii and on the high seas of the Pacific Ocean to reduce the chances of harming marine mammals, 2014-2019:

Thank you for giving the public an opportunity to comment on this proposed rule. The amount of noise in the oceans is already making it difficult for the animals that live there and depend on sound for communication to engage in their normal and necessary life activities. Several of the areas in question are especially biologically sensitive. Please impose limits and conditions that will protect these animals and their habitat.

Sonar and the blasts from detonations create pressure waves that can of themselves affect marine life. The cumulative effects of adding more noise to an already increasingly noisy environment  is making the ocean habitat of marine mammals, fish and invertebrates in hospitable to them. Many ocean inhabitants rely on sound for navigation and social interactions. If they can’t hear each other, they can’t find each other, their food resources and other necessities of life.

NOAA’s Underwater Sound Field Mapping Working Group,,  has produced graphic maps that reveal the extent of disruptive noise in the oceans. Dr. Leila Hatch, co-chair of the Working Group, said too many areas of the ocean surface (where sea mammals and whales spend most of their time) are orange in coloration, denoting high average levels. 
National Geographic documented the problem in an article in its Big Idea column in 2011, The article points out that many areas of the ocean have experienced a hundredfold increase in noise since 1960. “The problem is getting steadily worse for another reason. As we’re making more noise, we’re also making the ocean better at transmitting it. Seawater is absorbing less sound as carbon dioxide from fossil-fuel burning seeps into the ocean and acidifies it,” the article states.
Noise affects behavior: “Noise drives many species of whales, dolphins, and other marine animals to change their behavior markedly—their calling, foraging, and migration patterns—even when it’s not enough to drive them onto a beach. Cod and haddock in the Barents Sea have been found to flee the area when air guns start firing, drastically reducing fish catches for days. Large baleen whales are of special concern. They communicate over vast distances in the same frequencies, around the lowest C on a piano, that ship propel­lers and engines generate. On most days, says Christopher W. Clark, director of the bioacoustics research program at Cornell University, the area over which whales in coastal waters can hear one another shrinks to only 10 to 20 percent of its natural extent. “
Acoustician Michael Stocker writes:
Marine animals have figured out ways to cut through this noise. One strategy used is by inhabiting “acoustical niches” – communicating in frequency bands that are not otherwise used by other critters.
But the broadband noise from ship traffic, or seismic airgun surveys (or the roar of crashing waves) does not lend well to the frequency-band selection implied in an “acoustical niche.”
Dr. Colleen Reichmuth and her shoal of grads and undergrads at the UCSC Pinneped Cognition and Sensory System Lab is working with Arctic seals to determine the effects of masking signals on their hearing acuity. Buy running unmasked auditory threshold tests on the seals, and then testing their thresholds in the presence of a masking signal they can determine how the masker affects their hearing. Her lab environment demonstrates the seals’ sensitivity to noise that can interfere with their behavior.
Dr. Clark was quoted in a CNN interview:
“In the ocean's very quietest moments, blue whales singing off the Grand Banks of Canada can sometimes be heard more than 1,500 miles away off the coast of Puerto Rico. But on most days, that distance is a mere 50 to 100 miles.
“Ocean noise is a global problem, but the U.S. should step up and lead the way.
“Finally, federal regulation on ocean noise must be changed. For decades, regulators have focused entirely on the short-term effects of one action at a time. A more holistic and biologically relevant risk assessment system, centered on the concepts of ocean acoustic habitats and ecosystems, is sorely needed. Emerging trends in marine spatial planning are encouraging signs, as is NOAA's support of two groups that are developing geospatial tools for mapping underwater noise and marine mammal distributions in U.S. waters.
“The loss of acoustic habitats for marine species that rely on sound to live and prosper is increasing. Solutions are available. The question is whether we humans value and will invest in a healthy ocean ecosystem that supports life, and in doing so, sustain our own health and future.”
We appreciate the Navy’s need to prepare for military conflict. However, this addition to ocean noise and destruction is excessive and unjustified when weighed against the damage to ocean life. We ask NMFS to deny this authorization.
Points 1, 2, and 3: Mitigation zones are inadequate to protect marine mammals from noise that can be heard over hundreds or thousands of miles. Noise that does not kill or deafen outright adds to the cumulative noise burden that plagues the marine environment, making it ever more difficult for animals to communicate. Detonating bombs under water cannot be tolerated. It’s bad enough that it happens during war. Shall peace be just as damaging? The shock waves are deafening and the destruction damages the marine environment.
4. Stranding responses after the fact do not compensate for the loss of life and habitat. No.
5. Making special provisions for Humpback Whales cannot protect them adequately from masking noise or from bomb blasts. No.
Thank you for giving the public the information and opportunity to comment.

Christine Heinrichs
1800 Downing Ave.
Cambria, CA 93428

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