We are especially concerned that the NW training area includes waters known to be traveled by endangered Southern Resident orcas, as well as their essential food source, endangered Chinook salmon, and 27 other cetacean species and uncountable other marine life. Of course there are many other insults and onslaughts killing the oceans, but Navy training is under direct government control in our democracy.
A major flaw in the Navy's EIS is that the mitigation measures described will not reliably detect cetaceans in most instances, in part because the mammals themselves often attempt to avoid detection by mammal-eating transient killer whales. Transient orcas, in turn, are adept at evading detection by their wary prey. We are well acquainted with the difficulty of finding orcas even when we know they must be nearby. Detection would be especially difficult in typical high seas weather during erratic vessel activities in the midst of simulated warfare.
Beaked whales and sperm whales often remain below the surface for more than an hour. Blue and fin whales can travel miles in silence beneath the surface. Thousands of gray whales travel the entire length of the training range twice yearly, and hundreds spend their summers there. Offshore orcas frequent the edge of the continental shelf and travel across the wide Pacific, and transiting humpbacks, minkes and dolphins may be found close to shore or far out at sea. All are often obscured by high winds and wave troughs when they surface to breathe.
Improved mitigations would help avoid harming whales and dolphins, but given that detection is highly problematic and there is no part of the marine environment that is devoid of marine mammals, fish, turtles and birds, any mitigations are only better by degrees. In addition, the Navy has back-pedaled from at least partial compliance with court-ordered mitigations in California, apparently concluding that such mitigations detract from realistic training. The Navy agreed to avoid using sonar in Washington's inland waters, but we saw on April 8th how those agreements can be ignored when the USS San Francisco tested sonars near Dungeness Spit at harmful levels, demonstrating that the Navy holds training and testing at a higher priority than safety of marine mammals.
We ask for more stringent mitigation measures in the short term, while global treaties to ban silent submarine warfare are implemented. The very concept may seem impossible and unthinkable, and the opposition to curtailing the US fleet is predictable, but the alternative to reaching international accords is an almost certain decimation of marine life worldwide. Decades ago the nuclear test ban was reached to avoid destroying our atmosphere. Treaties to ban at least silent submarine warfare would avoid destroying the marine environment.