To: John Fiorentino, Permits conservation biologist and Jolie Harrison, Chief of Permits

Stop Sonar and underwater explosions in Gulf of Alaska

The US Navy says training and testing using sonar and explosives could potentially hurt whales and other marine mammals. We think NMFS should deny the Navy application for a permit that would allow them to use sonar and under water explosives during peak migration periods in Alaska waters.

Why is this important?

I am the Director of Eye of the Whale Research. We are a non-profit Research group studying humpback whales in the North Gulf Coast of Alaska. Humpback whales have had a great recovery in the North Pacific Ocean after commercial whaling was banned. Now thousands of whales come to feed in our coastal waters. I am deeply concerned about the Navy’s plans to use sonar and underwater explosives in this area where so many whales are feeding. The Navy’s supplemental Environmental Impact Statement (EIS/OEIS) was thorough and a very updated source of abundance data for marine mammals inhabiting the North Gulf coast of Alaska. In this draft it is stated many times that there is little known about the affects of sonar and loud noises on the inner soft auditory and organ tissue and brains of marine mammals. Most of the experimentation was done with terrestrial animals, ie small mammals or bovine tissue (which is cow meat) were submerged in cages and exposed to sounds and sonar. Marine mammals are different than terrestrial mammals. They have adapted to their marine environment in many delicate and refined ways.

Stranded marine mammals are difficult to study because either they are damaged by the time they are found or the tissue gets crushed during investigation. But by freezing the skulls and using cat scans it has been proven that some stranded whales have blood around their brains and have suffered from something similar to what we call “the bends”. There have been too many mass strandings that have been related to sonar activities in the vicinity to ignore the dangers it causes to marine mammals. Truly we do not have any way of knowing the whole story of the affects of Navy mid range sonar and large explosives on sea mammals. Quantifying the temporary or permanent damages caused to the animals by the Navy activities is guesswork. Many mammals affected could be dying at sea or abandoning their normal ranges. Thousands of hours of study and millions of our tax dollars have gone into it trying to prove that sonar is not damaging marine mammals and we all know it can and does.

In the North Gulf coast there are many species listed as “Endangered” under the Marine Mammal Protection Act: the western north pacific grey whales, the north pacific right whales (of which there are 31 remaining in the entire ocean), the Alaska North Pacific stock of sperm whales, the Stellar sea lion , and the heavily hunted sei, and minke whales. Though not listed, there are also three kinds of beaked whales, of the family Mesoplodon, of which we know very little about. They are rarely seen and regularly dive to depths of over 2000 feet. These odd and often solitary beaked whales can stay down for over an hour and feed in the deep dark trenches off our continental shelf. This alone makes them very difficult to study. We have had a few of these mysterious whales wash up on the shores of Kachemak Bay.

All these endangered whales communicate, navigate and hunt with sound. There is no arguing that both sonar and explosives affect their lives. In our remote North Gulf coast waters monitoring damages to the thousands of endangered marine mammals that feed on our food rich waters would be impossible. The next training is planned for June 2015. All the endangered whales will have just arrived from their migration to the North Gulf Coast from all over the North Pacific…bad timing.

As I understand the Navy is presenting three alternatives. The “no action alternative” would be to continue their normal practice off the North Gulf coast with no sonar or explosives. Alternatives 1 and 2 would add various degrees of sonar and explosives. In the conclusions of the EIS/OEIS both Alternatives 1 and 2, I quote:
• May affect, and is likely to adversely affect, the North Pacific right whale, humpback whale, blue whale, fin whale, sei whale, sperm whale, and the Western Distinct Population Segment of Steller sea lion
• May affect, and is not likely to adversely affect Western North Pacific gray whale, and the Southwest Alaska stock of Northern sea otter
I cannot live with these two alternatives. I suggest the “no action alternative”, which I understand would not allow the use of sonar or under water explosives.

This is the wrong time and the wrong place for this kind of war practice.