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Introduction
Currently the U.S. Navy is consulting with the Director of the
Office of National Marine Sanctuaries in order to deploy Surveillance
Towed Array Sensor System Low Frequency Active Sonar (SURTASS
LFA) within the Monterey Bay National Marine Sanctuary. The sonar
system is a long-range, low frequency sonar that has both active
and passive components. The purpose of the proposed action is
to meet U.S. need for improved capability to detect foreign submarines
at long range. The characteristics and operating features of the
active component (LFA) are:
- The source is a vertical line array of up to 18 source emitters
suspended below the vessel.
- LFA's transmitted beam is omnidirectional (360 degrees along
a horizontal plane (nominal depth of the center of the array
is 122m [400 ft]), with a narrow vertical beamwidth
that can be steered above or below the horizontal axis.
- The source frequency is between 100 and 500 Hz. A variety
of signal types can be used including continuous wave (CW) and
frequency-modulated signals.
It is possible that this deployment of acoustics will adversely
affect Sanctuary resources. Operation of the SURTASS LFA system
may constitute a violation of federal regulations at 15 CFR (922.132
(5)) which prohibit taking any marine mammal, sea turtle or seabird
in or above the Sanctuary, except as permitted by regulations,
under the Marine Mammal Protection Act, the Endangered Species
Act, and the Migratory Bird Treaty Act. NOAA Fisheries (NMFS)
will determine whether to grant the Department of Defense a small
take exemption under the Marine Mammal Protection Act.
The FEIS for SURTASS LFA Appendix A states: "Sanctuary regulations
require that military activities be carried out in a manner that
avoids to the maximum extent practicable adverse impacts on Sanctuary
resources and qualities. The Navy has determined that Alternative
1 of the Draft OEIS/EIS would meet this requirement".
Sanctuary regulations at 15 CFR 922.132 (c) except some Department
of Defense activities from the above prohibitions, but only military
activities specifically identified in the MBNMS Final Environmental
Impact Statement/ Management Plan (FEIS/MP) published in June
1992. Sanctuary regulations are very clear in stating that the
prohibitions in paragraphs (a) (2) through (9) do not apply to
existing military activities carried out by the Department of
Defense. SURTASS LFA was not identified as a pre-existing activity
in the 1992 FEIS/MP, and would therefore not be eligible for exception
from these prohibitions. However, new activities may be exempted
after consultation between the Director and the Department of
Defense.
We understand the intent of the Navy's proposal is to keep the
sound source outside the limits of the United States Territorial
Sea. This should reduce potential impacts to the migrating Gray
whales during the winter and spring. However, the Monterey Bay
National Marine Sanctuary has concerns regarding the variety and
distributions of deep diving whales throughout our boundaries,
in particular, offshore areas beyond the Territorial Sea during
spring, summer, and fall.
Deep
Diving Whales Range Distribution Charts
The Sanctuary has compiled charts of the range and
distribution of some of the deep-diving whale species present
within our region. All of these species are either threatened
or endangered, and all are sought by a growing number of whale
watching boats in central California. These data are summarized
below.
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 Chart
1 -- Deep Diving Whales Major Range
Distribution. The Blue Whale major adult area is
illustrated by green diagonals and is within Sanctuary boundaries
from May through December. The Right Whale adult area is
depicted by the light orange dots and ranges throughout
Sanctuary boundaries from October through March. The Humpback
Whale major adult area is illustrated by purple diagonals
and is within Sanctuary boundaries from May through October.
The Fin Whale major adult area is depicted by blue dots
and is within Sanctuary boundaries from April through September.
The Sperm Whale major adult area is illustrated by orange
verticals and is over Davidson Seamount on a year-round
basis.
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 Chart
2 -- Blue Whale Range Distribution.
Blue Whales are the largest animal to live on earth and
in the past decade its numbers have surged locally. The
Monterey Bay National Marine Sanctuary hosts several hundred
blue whales annually who come to the region to feed on krill.
These animals are highly mobile and it is thought that they
move regularly between the Monterey Bay region and other
feeding grounds near Cordell Bank and the Channel Islands.
Blue Whales within the MBNMS range throughout the Sanctuary
boundaries from May to December as depicted by the blue
dots. The area in green illustrates the major adult area
from May to September.
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 Chart
3 -- Northern Pacific Right Whale
Range Distribution. Marine Scientists consider the
Northern Pacific Right Whale the most rare mammal in the
world. It represents a separate subspecies from the Atlantic
Right Whale, which we understand the Navy has elected to
avoid on the eastern U.S. seaboard. The three most recent
sightings of the Northern Pacific Right Whale south of Alaska
have occurred in the Monterey Bay National Marine Sanctuary,
two of which occurred in the last four years. The entire
region is considered to be within the Right Whales' range.
Any disturbance to this extremely rare whale could be disastrous.
Right Whales within the MBNMS range throughout the Sanctuary
boundaries from October through March as depicted by the
orange dots.
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 Chart
4 -- Humpback Whale Range Distribution. Humpback
whales are highly acoustic animals known for their "songs".
Their songs are long and complex intertwining melodies,
which can sometimes last up to twenty minutes long. These
songs are repeated continuously for hours. The Humpbacks
in the North American Pacific populations all sing the same
song which progressively changes over the years. The bulk
of evidence thus far, points to the singing whales being
males; it is thought that these songs are a function of
mating behavior. Any device that has the potential to effect,
impede, or alter this behavior should be examined critically.
Humpback whales within the MBNMS range throughout the Sanctuary
boundaries from May through October. The area depicted in
red diagonals is the major adult concentration for feeding
and migration from May through October, as well as the recreational
viewing area from June through September. The area in blue
dots depicts the major adult area for feeding and migration
from May through October.
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 Chart
5 -- Fin Whale Range Distribution. Once one of the
most abundant of the large whales, the Fin whale was heavily
exploited by the whaling industry and its population has
been severely depleted. Current figures suggest that a mere
80,000 animals remain worldwide with between fifty and several
hundred in the MBNMS. Fin whales within the MBNMS range
throughout the Sanctuary boundaries from April through September
and commonly feed on krill associated with upwelling at
the boundaries of offshore currents. The area depicted by
small blue dots illustrates the major adult area whereas
the area depicted by the larger blue dots illustrates the
general adult area.
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 Chart
6 -- Sperm Whale Range Distribution. The Sperm whale
is the deepest diving whale and can swim to depths of 1000
m, and stay submerged for over an hour. At depth there is
very little light available and hence these whales have
developed a superior echolocation ability, which they use
to find their prey. As such, these animals are highly dependent
upon sound. It is unlikely that an observer on a ship would
be able to accurately interpret this animal's reaction to
LFA, or to even see a Sperm whale feeding in the Sanctuary.
Sperm whales within the MBNMS range throughout the Sanctuary
boundaries on a year round basis. The adult area within
Sanctuary boundaries is illustrated by blue dots. The major
adult area that should be noted, though it is outside of
Sanctuary boundaries, is the area around Davidson Seamount
as depicted by the orange lines.
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Beaked
Whales
The Monterey Bay National Marine Sanctuary has three species of
beaked whales that inhabit our waters – the Baird's, Cuvier's
and Hubbs beaked whale. Little is known about these cetaceans.
They may be rare or merely elusive, but generally they live in
deep offshore waters and have escaped live studies.
Studies of dead beaked whales from the March 2000 Bahamas strandings
by Kenneth Balcomb, indicate that a resonance phenomena in the
whales cranial airspaces may be responsible for tearing apart
the delicate tissue around the ears and brain. Kenneth Balcomb
further reiterated that the resonance frequency of airspaces in
Cuvier's beaked whales to be about 290 Hz at 500 meters depth,
which is precisely the middle frequency of LFA as described in
the OEIS/EIS.
Marine
Mammal Abundance Information
Table 1 was generated from data compiled
by the National Marine Fisheries Service and reports the estimated
Pacific populations as well as the estimated California populations
for the following species of whales: Blue, Humpback, Fin, Minke,
Gray, Northern Right, Sperm, Cuvier's Beaked, Baird's Beaked,
and Mesoplodont Beaked. Migrating species are indicated seasonally
on the right of the table.
From: Forney et al. 2000, U.S. Pacific Marine Mammal Stock Assessments:
2000.
NOAA Technical Memorandum NMFS/SWFSC 300
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Species
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Estimated Pacific Population
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CV
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CA Estimated Population*
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CV*
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Winter
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Spring
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Summer
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Fall
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Blue Whale
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1940
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0.15
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not calculated
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Migrating S
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Migrating N
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Present
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Present
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Humpback Whale
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905
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0.06
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319
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0.41
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Migrating S
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Migrating N
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Present
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Present
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Fin Whale
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1236
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0.2
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49
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1.0
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Lower #'s
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Lower #'s
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Present
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Present
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Minke Whale
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631
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0.45
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73
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0.62
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Present
|
Present
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Present
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Present
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Gray Whale
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26635
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0.1006
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not calculated
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Migrating S
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Migrating N
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Absent
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Absent
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Northern Right Whale
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Unknown
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not calculated
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Possible
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Unknown
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Unknown
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Unknown
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Sperm Whale
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1191
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0.22
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892
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0.99
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Present
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Peak
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Peak
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Present
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Cuvier's Beaked Whale
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5870
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0.38
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not calculated
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Possible
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Possible
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Possible
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Possible
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Baird's Beaked Whale
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379
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0.23
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not calculated
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Lower #'s
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Lower #'s
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Possible
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Possible
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Mesoplodont Beaked Whales
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4098
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0.5
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not calculated
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Possible
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Possible
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Possible
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Possible
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*Forney et al. 1995. (Not corrected for diving whales)
CV= Coefficient of Variation
Table 2 is taken from the Final EIS/EIR for the California
ATOC project and estimates the marine mammal stock of the following
species of whale: Blue Humpback, Fin, Minke, Gray, Sei, Northern
Right, Sperm and Beaked for the offshore central California area.
This table separates Winter/Spring populations from Summer/Fall
populations.
From: Final EIS/EIR for the California Acoustic Thermometry of
Ocean Climate Project, April 1995. Estimates of the stock of marine
mammal species offshore central California
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Species
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Winter/Spring
Population
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CV
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Summer/Fall
Population
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CV
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Blue Whale
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28
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1.03
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2198
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0.36
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Humpback Whale
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375
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0.36
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609
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0.41
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Fin Whale
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78
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0.8
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913
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0.59
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Minke Whale
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71
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0.61
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569
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1.1
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Gray Whale
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20869
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0.34
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not calculated
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Sei Whale
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not calculated
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61
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1.21
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Northern Right Whale
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16
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1.08
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not calculated
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Sperm Whale
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857(1286)*
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1.05
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725(1088)*
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0.47
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Beaked Whales (Cuvier's, Baird's, Mesoplodont)
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426(852)*
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0.38
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1430(2860)*
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0.91
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* Numbers in ( ) indicate estimates accounting for whales submerged
during entire survey evolution
CV= Coefficient of Variation
Sea
Turtle Abundance Information
Table 3 is taken from the Final EIS/EIR for the California ATOC
project and estimates the following sea turtle species: Leatherback,
Green, Olive and Loggerhead. The abundance of these species is
unknown.
From: Final EIS/EIR for the California Acoustic Thermometry of
Ocean Climate Project, April 1995
Estimates of the stock of sea turtle species offshore central
California
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Species
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Abundance
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Remarks
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Leatherback Sea Turtle
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Unknown
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Note 13
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Green Sea Turtle
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Unknown
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Note 11,12
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Olive Ridley Sea Turtle
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Unknown
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Note 11
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Loggerhead Sea Turtle
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Unknown
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Note 11
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Note 11: NOAA-TM-NMFS-F/SPO-2, Dec 1992 (for eastern
tropical Pacific [ETP])
Note 12: "Green turtles are the most commonly observed hard-shelled
sea turtle
on the western coast of the USA." (NOAA-TM-NMFS-SWFSC-186,
Sep 193)
Note 13: Predominant sea turtle in central California coastal
area (Eckert, pers. Comm., 1994)
Acoustic
impacts
The University of California at Santa Cruz, Marine Mammal and
Seabird Ecology Group has produced a technical report for LFA
EIS entitled Marine Vertebrates and Low Frequency Sound that states:
Richardson et al. (1991) found that belugas have an auditory
threshold of 40 dB. This suggests, by analogy, that belugas experience
discomfort at sounds of 140-160 dB (Gordon and Moscrop 1996).
If cetaceans such as baleen whales have similarly low auditory
thresholds for LFS, then sound levels of 195-210 dB could result
in immediate damage and permanent threshold shift (PTS).
Because all species of mysticete whale recorded to date produce
loud, species-specific signals in the low-frequency band, they
are particularly at risk from manmade LFS. It is unclear whether
low-frequency signals produced by most mysticetes are used for
communication, orientation, navigation, or detection of predators
and prey. However, disruption of any of these functions could
interfere with normal activities and behavior, and potentially
impact the reproductive success of individuals and eventually
the size of a population.
Furthermore, Whale Biologist Kenneth C. Balcomb, has stated in
a letter sent to Mr. J.S. Johnson, SURTASS LFA Sonar OEIS/EIS
Program Manager, dated February 23, 2001 that:
Based on two significant mass mortality events (Greece and the
Bahamas) the body of evidence indicates that not only is resonance
with LFA and sonar frequencies a problem for beaked whales, the
sound pressure level of 180 db RL is demonstrably not safe for
beaked whales and is probably not safe for other cetaceans.
NEPA
issues
The following is a list of public hearings held by the Department
of Defense regarding LFA: Norfolk, Virginia 1999, San Diego, California
1999, and Honolulu, Hawaii 1999. The National Environmental Policy
Act requires agencies to provide public notice to people and agencies
who may be interested or affected (40 CFR 1506.6[b]) and
to those who have requested it (40 CFR 1506.09(b)(1). The residents
of the communities adjacent to the Sanctuary boundaries were not
adequately informed of this proposed project.
Furthermore, it is the position of the MBNMS that the latest
research mentioned above presents a seriously different picture
of the likely environmental consequences of the proposed action
not adequately envisioned by the original EIS, such that the Navy's
failure to act on it may be arbitrary or capricious. A Supplemental
Environmental Impact Statement (SEIS) would assist in adequately
addressing potential ill effects of SURTASS LFA to species in
the marine environment offshore central California.
The Sanctuary recognizes that thus far the Department of Defense
has spent in excess of $350 million dollars developing the technology
for this project. We applaud their dedication to ensuring, as
stated in the FOEIS/EIS, "monies expended on the SURTASS LFA sonar
program do not bind the Navy to deploy the SURTASS LFA sonar as
proposed".
Observers
The Department of the Navy proposes in the Final Environmental
Impact statement (p.2-14) to use visual monitoring for marine
mammals and sea turtles from the SURTASS LFA sonar vessel during
daylight hours. Generally, cetaceans spend over 90% of their lives
below the water surface. This being stated, it is easy to comprehend
why ship-based observers may be unsuccessful in identifying potentially
impacted animals.
Research
Activities
The Monterey area is recognized nationally and internationally
for the extensive myriad research activities and organizations
that are active in the region. Annually $160 million is spent
on marine research at twenty-six facilities within the region.
This research is conducted on a year-round basis throughout Sanctuary
waters, but typically more effort is expended during the summer
months. Hundreds, if not thousands, of research projects are conducted
in Sanctuary waters each year. Obviously, underwater sound would
have undesirable ramifications on these on-going studies and projects.
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