Protect orcas from harmful Navy testing

Imagine hearing a constant, loud, and piercing noise that you cannot escape from. That is what marine mammals, especially the Southern Resident orcas, will experience for the next seven years if the U.S. Navy under the Trump administration is allowed to increase training, underwater explosions, and sonar testing in Washington waters.

The Navy’s increased training and testing would negatively impact Southern Resident orcas for the next seven years. Orcas need quieter waters in an increasingly noisy world to effectively communicate with one another, to forage for food, to nurse their young, to breed, and to migrate.

Send a comment to the National Marine Fisheries Service today to protect orcas from harmful Navy training and testing.

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Subject:

Takes of Marine Mammals Incidental to Specified Activities: U.S. Navy Training and Testing Activities in the Northwest Training and Testing Study Area

Dear U.S. Navy,

Thank you for the opportunity to comment on the National Oceanic and Atmospheric Administration (NOAA) Proposed Rule: Takes of Marine Mammals Incidental to Specified Activities: U.S. Navy Training and Testing Activities in the Northwest Training and Testing Study Area (Docket ID: NOAA-NMFS-2020-0055).

I am specifically concerned about impacts on the Southern Resident orcas, which are at serious risk of extinction. I urge NMFS to change its preliminary determination of “negligible impact” and require additional mitigation measures to significantly reduce the incidental take of Southern Resident orcas so that it does in fact warrant a “negligible impact” determination.

The NMFS proposed rule on incidental take from Navy activities would increase training and testing that will negatively impact orcas for the next seven years without sufficient protections. Activities like at-sea sonar testing can mask vocalizations and social interactions of marine mammals. The Navy amended its application to increase numbers of level B harassment from 2 to 51 orcas to reflect new offshore Southern Resident orca density data since the Navy’s initial density date were outdated. Level B harassment means it interferes with breeding, nursing, foraging, use of core critical habitat, etc. However, the Navy did not add any additional mitigation measures after massively increasing its impact estimates, a concern flagged in public comments.

Astonishingly, NMFS determined that this increased level B harassment of as much as 68% of the Southern resident orcas every year would have negligible impact on this critical population of only 72 individuals. This is not insignificant.

A March 2019 report by NOAA by Emmons, Hanson, and Lemmers (see citation below) records calls from both Southern Resident and Northern Resident Killer Whales (orcas) at the same locations and months as explosive noises from Navy activities. That means the Navy is already altering the soundscape in ways that are harmful to these endangered species. Any harm to orcas constitutes an illegal “take” under the Endangered Species Act.

There are documented cases in this region of U.S. and Canadian naval activities, including active sonar training and explosive testing, causing direct harm, death, or displacement to the Southern Resident orcas. Three incidents between 2003 and 2017 included harm to Southern Residents associated with military sonar exercises and detonations.

The Navy must consider the current crisis facing the endangered Southern Resident orcas and make new adjustments in its testing and training activities. Despite being listed under the Endangered Species Act for nearly 14 years, this unique population is not recovering and is continuing to decline. Given their highly endangered status and continuing decline, the NMFS should require the Navy to;

- Cease any active mid-frequency sonar testing and exercises if any orcas are sighted within .5 nautical miles, rather than the proposed 200-yard or 100 yard “shut-down mitigation zone” which is much closer than even the 300 yard and 400 yard approach distance for commercial whale watch operators and recreational boaters.

- Use real time whale alert system rather than relying exclusively on human observers on Navy vessels or communications with NMFS to determine location of orcas.

- Shift testing and training activities away from locations and seasonal windows that endangered species are present.

In conclusion, I urge NMFS to revise its proposed rule to significantly reduce the number of Southern Resident orcas authorized for incidental take.

* Citation: Emmons, C.K., M.B. Hanson, and M.O. Lammers. 2019. Monitoring the occurrence of Southern Resident killer whales, other marine mammals, and anthropogenic sound in the Pacific Northwest. Prepared for: U.S. Navy, U.S. Pacific Fleet, Pearl Harbor, HI. Prepared by: National Oceanic and Atmospheric Administration, Northwest Fisheries Science Center under MIPR N00070-17-MP-4C419. 25 February 2019. 23p.

Regards, Your Name

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