DRAFT MEC POSITION ON NWTR EIS

The following is a draft of a position that I was requested to prepare for approval by the MEC. It was never vetted by the MEC board. Feel free to adopt it or refer to it. The Navy has extended the public comment deadline to October 24. But it has also made it clear that any comments at this point will not alter the war training activities described in the EIS.
For a link to the EIS, as well as to the address to which comments may be sent, go to http://www.mendocinocountry.com/ Thank you.
Richard Johnson, publisher

8888888888888888888888888888888888888888888888

MENDOCINO ENVIRONMENTAL CENTER
106 West Standley Street, Ukiah CA 95482 • 707-468-1660

Naval Facilities Engineering Command Northwest,
1101 Tautog Circle, Suite 203,
Silverdale, WA 98315-1101,
Attn: Mrs. Kimberly Kler – NWTRC EIS
October 7, 2010

Dear Ms. Kler
Taking into account that the Northwest Training Range Final Environmental Impact Statement covers the same geographical area and substantially the same training activities as the Draft Environmental Impact Statement, the Mendocino Environmental Center finds the comments made on the DEIS by the Natural Resources Defense Council in March of 2009 to be most compelling.
According to NRDC,, the National Environmental Quality Act requires that decision makers obtain high quality information and conduct accurate scientific analysis, justify the need for the project, predict its possible environmental impacts and describe more benign alternatives.
Merely making general statements about possible effects and risks does not suffice absent a justification why more definitive information cannot be provided. NRDC concludes that the Navy document fails to meet the high standards of rigor and objectivity required by the NEPA “in nearly every respect.”
Consequently, the MEC recommends that NAVFAC withdraw the EIS and rewrite the entire document, and that the Navy postpone any of the described training activities in the Northwest Range complex until a scientifically acceptable EIS is approved.
Specifically, the NWTR EIS
Fails to establish any exclusion areas or even special management areas requiring greater mitigation or procedural checks anywhere in the 122,000nm2 range.
Fails to provide any specific analysis beyond generic statements of need of why certain sensitive areas cannot be subject to additional mitigation.
Fails to modify its activities in and around the Olympic Coast National Marine Sanctuary;
Fails to modify its activities in and around the habitat of the Southern Resident killer whales in Puget Sound;
Fails to identify its methodologies and evaluate indeterminate adverse impacts of acoustic emissions based on approaches generally accepted in the scientific community;
Fails to adquately assess the impact of noise induced stress on marine mammals;
Fails to consider the risk of ship collisions with large cetaceans exposed to acoustic induced stress;
Fails to adequately consider the the cumulative impact of toxic chemicals, hazardous materials and waste on wildlife over the life of the range.
ails to consider the potential for large scale oil spills from accidents and collisions involving military and oil cargo vessels.
Fails to consider indirect, delayed time impacts such as calf abandonment among mammals after repeated sonar exposures.
Failure to adopt specific Protection Zones in which all sonar activity would be banned. The NRDC recommended five specific zones, including the Olympic Coast National Marine Sanctuary.
Failure to adopt seasonal avoidance of marine mammal feeding grounds, calving grounds and migration corridors as well as federal and state marine protected areas, submarine canyons, the California Current.
Failure to provide for timely, regular reporting to NOAA, state coastal management authorities and the public to describe and verify use of mitigation measures during testing and training activities.
Failure to discuss alternative sites, specification of zones within the OPAREA according to the activities to be conducted, or seasonal, temporal or hourly restrictions on them;
Failure to consider impacts on whale watching and recreational fishing industries, potential loss of revenue from tourism both coastal and inland.
Failure to adequately describe specific activities in sufficient detail to permit the public to effectively comment.
Failure to release computer modeling systems it used to develop biological risk function or calculate acoustic harrassment or injury levels.
Failure to provide the Biological Evaluation it prepared to evaluate he effects of its proposed alternatives on species listed in the Endangered Species Act.
In addition to the above concerns raised by the NRDC, the MEC is concerned that live fire exercises will conflict with commercial and recreational fishing. The proposed mitigations leave it up to individual vessels captains to inquire daily by telephone or internet if their course and destination is to be the target of live naval fire.

On behalf of the board of directors,

LYNDA McCLURE, president