Time to review Navy’s NW neighborliness

NOAA recently released an incidental take authorization associated with the Navy’s proposed expansion of the Northwest Range Training Complex.  The authorization and associated Navy documents are Complex, indeed!  Unfortunately, NOAA has allocated too little time for public comment on the .

Below I’ve quoted an inspirational letter from Fred Felleman.  Please emulate him and join me this weekend in requesting more time to review and comment.  Also, here are links to a recent story and blog by Chris Dunagan about the situation which provide useful links and background information:

30 July 2009

By Electronic Mail

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

Re: Request for Extension of Comment Deadline for Navy Marine Mammal Take Permits

Taking and Importing Marine Mammals;

U.S. Navy’s Research, Development, Test, and Evaluation Activities Within the Naval Sea Systems Command Naval Undersea Warfare Center NW Training Range;

RIN: # mailto:nbkehweis@ssp.navy.mil0648-AX88” ##0648-AX88# (74 Fed. Reg.) & Keyport Range Complex; RIN:0648-AX11 (74 Fed. Reg. 32264 (July 7, 2009))

Dear Mr. Payne:

On behalf of Friends of the Earth and numerous other organizations and individuals who are deeply concerned about recovery of the endangered population of Southern Resident Killer Whales and the marine environment that supports them, we urgently request that you extend the public comment period and hold public hearings to solicit comments on the two take permits referenced above you are proposing to grant the U.S. Navy in the Northwest.  Friends of the Earth requests a minimum 30-day extension of time for the comment deadline for both proposals.

The National Marine Fisheries Service (NMFS) should be well aware of the fact that most North American marine mammal biologists are in the field at this time and that the general public is engaged in recreational activities that make commenting on these voluminous documents difficult at best.

Furthermore, unlike the public notices you sent out touting your proposed rules for regulating whale-watching activities this week for hearings that will not be held until the fall, nothing more than a Federal Register notice was made for these far more impactful activities.  In addition you have afforded only one month on which to comment and no public hearings.  The comment deadlines for these proposals are also overlapping (August 6th and August 12th) adding to the unreasonable public burden.

While we are encouraged that the Navy has committed to no longer using the inshore waters of Puget Sound for sonar training activities, as part of the expansion of the NW Training Range Complex (Kitsap Sun July 30, 2009), the Navy intends to expand their operations off the coast significantly (i.e. Antisubmarine warfare 10%, Gunnery Exercises 100%, Bombing Exercises 25%, and Sinking Exercises 100%; 74 Fed. Reg. 33829).  It is also hard to understand why NMFS would not require the Navy to have a take permit for explosive ordinance testing in the inshore region?

In addition, the takings associated with the proposed expansion of the Keyport Range (link, 74 Fed. Reg.), which actually includes three sites both inshore and offshore, need to be reviewed by NMFS in context to those being proposed for the expansion of the NW Training Range Complex (www.NWTRangeComplexEIS.com) as well as the various other Navy Environmental Impact Statement’s (EIS) that are likely to impact marine mammals and their prey.  Those EISs include: Swimmer Interdiction Security System EIS (www.nbkeis.gcsaic.com), Kinetic Hydropower Systems Puget Sound Demonstration (www.nps-khps.net), Gulf of Alaska Training Range Activities EIS (www.gulfofalaskanavyeis.com), Multi-mission Aircraft Deployment out of Whidbey NAS (www.MMAEIS.com), and the proposed construction and operation of a second Trident Support Facilities explosives handling wharf at Naval Base Kitsap on Hood Canal (74 Fed. Reg. 22900 (May 15, 2009)). Furthermore the Navy’s other activities that can include the use sonar need to be considered in any environmental analysis.

The existence of so many concurrent projects is not only burdensome to the public to review and comment on, but also highlights the need for the production of a Programmatic EIS covering all of these projects by Navy Region NW, and for NMFS to review the proposed take permits to address the cumulative effects of these interlinked efforts.

Friends of the Earth requests this extension of time for these two comment periods not only to afford us the ability to thoroughly review the materials but to also use the time to meet with the Navy for an exchange of information and ideas regarding the scope of the proposed projects and the adequacy of the proposed mitigation.  We hope to construct a clear and constructive path to follow allowing the Navy to maintain our nation’s military readiness while minimizing its impact to the marine environment as well as to make contributions that will further our understanding and ability to protect it.

Thank you for considering our request for a minimum 30-day extension of the comment periods for the take permits at issue.


Fred Felleman, NW Consultant
Friends of the Earth
3004 NW 93rd St.
Seattle, Washington 98117

cc: Vice Admiral Richard Hunt, Commander U.S. Navy 3rd Fleet, Senator Patty Murray, Senator Maria Cantwell, Congressman Norm Dicks, Congressman Jay Inslee

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