The scientific reasoning behind the Navy's conclusions in their Environmental Impact Statement (EIS) that Low Frequency Active Sonar (LFAS) is safe are scientifically flawed for several reasons:
* The Navy's Scientific Research program never tested the full source level of LFAS on marine mammals. In the Hawaii Quicklook, written by the marine mammal scientists who conducted the testing, they say on page 5, "This research did not use the full source level of LFA." On page 6 they say, "The playback protocol used in this Phase III research was specifically designed to expose animals to LFA sounds at levels that are not harmful." In the Executive Summary on page vi they say, "
it will be difficult to extrapolate from these results to predict responses at higher exposure levels."
The Navy has not followed the advice of their own hired scientists and has inappropriately extrapolated to conclude that LFAS is safe to deploy at levels of at least 5,000 times more acoustic intensity and 70 times more pressure than test levels.
* Even at the lower LFAS test levels a number of negative effects were documented including inshore gray whales changing their migration route, blue and fin whales decreasing their vocalization by 50 and 30% respectively, humpback whales leaving the test area, humpback whales changing the length of their song and three abandoned cetacean calves appearing in the test area in Hawaii during and right after testing. According to the precautionary principle, these observations should have been heeded as warning signs. Instead they were ignored or dismissed as biologically insignificant.
* Published accounts of whale strandings correlated with Naval maneuvers (Nature 1991 and 1998) suggest that beaked whales are especially vulnerable to high intensity sonar. However, beaked whales were not included in LFAS testing. In fact every recorded multi species stranding involving beaked whales has been correlated with Naval maneuvers nearby.
* LFAS was tested at low levels on only four species of whales for about one month each. Consequently, we know virtually nothing about what impact the higher, deployment level sonar will have on marine life and humans over the long term.
* The Navy's research has focused on LFAS damaging hearing in cetaceans. However, evidence now indicates that the damage from high intensity sonar is due mainly to resonance phenomena in the whales' cranial air spaces that tear apart delicate tissues around their brains and ears. Necropsies show that this is what caused the death of the whales in the Bahamas stranding in March 2000 (sonar in use there was a mid-frequency system). The Navy has known the resonance frequency of airspaces in Cuvier's beaked whales since 1998. Therefore, based on two significant mass strandings and deaths (Greece in 1998 and the Bahamas in 2000) evidence indicates that not only is airspace resonance with LFAS and other sonar frequencies a problem for beaked whales, but also the sound pressure level of 180 dB received level is not safe, and is probably not safe for other cetaceans as well (two minke whales and a dolphin also stranded in the Bahamas).
* The Navy ignores widely accepted research showing that whales change their behavior and show avoidance at about 115-120 dB. (Marine Mammals and Noise, 1995) In fact, they have consistently attempted to increase the scientifically accepted level at which whales change their behavior in response to noise without research to substantiate the increase.
According to the Navy, LFAS will be used to detect enemy submarines. We now know that the Navy has developed passive sonar systems that can detect silent submarines and not harm marine life.
This was noted in a statement of RADM Malcolm I Fages, U.S. Navy Director, Submarine Warfare Division Office of the Chief Of Naval Operations (N87) and RADM J. P. Davis, U.S. Navy Program Executive Office for Submarines before the House Armed Services Committee Military Procurement Subcommittee on Submarine Force Structure and Modernization 27 June 2000:
Admiral Fages said in direct testimony that the Navy now has the ability to detect quiet submarines in littoral waters using passive listening systems, at considerable distances.
"Surveillance Towed Array Sensor System (SURTASS) Twin Line operations in 1998 and 1999 demonstrated the ability to detect advanced diesel submarines at substantial ranges in the littoral environment where contact was previously thought to be "unobtainable" by the operational commander
This use of COTS equipment has also resulted in substantially reduced costs with no reduction in fielded capability. Development of the new Advanced Deployable System (ADS) will provide a rapidly deployable acoustic array installed on the ocean floor that provides littoral undersea wide-area surveillance and real time cueing. ADS development is moving along smoothly with potential for accelerated capability development."
From an environmental standpoint, there is no conflict: by using the safe, passive detection systems, and shutting down the acoustically hazardous LFAS system, the Navy can fulfill its mission for national security and be stewards of the seas.
While stopping the deployment of LFAS will protect marine life, it will not address harmful impacts from conventional Navy sonar as witnessed in the whale stranding and deaths in the Bahamas in March, 2000. However, it would be environmentally and fiscally sound to halt production of acoustically hazardous and tactically questionable LFAS.
1. The scientific literature consistently states that whales move away from sounds at 115-120 dB:
* Richardson, W.J., Greene, C.R., Malme, C.I. and Thomson D.H., (1995) Marine Mammals and Noise. Academic Press.
2. Sperm whales stopped vocalizing in response to a seismic vessel hundreds of kilometers away:
* Bowles, A.E., Smultea, M.,Wursig, B., DeMaster, P. and Plaka, D. (1994) Abundance of marine mammals exposed to transmissions from Heard Island Feasibility Test. Journal of the Acoustical Society of America 96; 2469-2484.
3. Studied reactions of humpback whales in response to explosions and drilling off Newfoundland. Their data revealed only small changes in residency, movements and general behavior. However, two humpback whales trapped in fishing gear after the explosions were found to have severely damaged ear structures similar to blast injury in humans. They noted that the whales showed no dramatic behavioral reaction to these harmful sounds and cautioned that whales visible short-term reactions to loud sounds may not be a valid measure of the degree of impact of the sound on them:
* Lien, J., Todd S., Stevick, P., Marques, F. and Ketten, D. (1993) The reaction of humpback whales to explosives; Orientation, movements and behavior. 126th Meeting of the Acoustical Society of America. Journal of the Acoustical Society of America 94: 1849.
4. Bowhead whales react to a received level of 115 dB. Noted behavioral changes in bowhead whales more than 8 km from seismic vessels with received noise levels of 142-156 dB:
* Ljungblad, D.K., Wursig, B., Swartz,.S.L. and Keene, J.M. (1988) Observations on the behavioral responses of bowhead whales (Balacena mysticetus) to active geophysical vessels in the Alaskan Beaufort Sea. Artic 41: 183-194.
5. Several studies show that grey whales begin to avoid sounds at exposure levels of 110 dB and more than 80% of the whales showed avoidance to sounds at 130 dB. Ninety percent of the whales avoided airgun pulses at 180 dB. Typically whales slowed down and moved around the sound source. At times they moved into the shallow surf zone to avoid the noise, respiration rates increased and there were indications that mother-calf pairs were more sensitive to the noise than other whales:
* Malme, C.I., Miles, P.R., Clark, C.W., Tyak, P. and Bird, J.E.. (1983) Investigations of the potential effects of underwater noise from petroleum industry activities on migrating gray whale behavior. BBN Report 5366, Report from Bolt Beranek & Newman Inc., Cambridge, MA for US Minerals Management Service, Anchorage, AK, NTIS PB86-174174.
* Malme, C.I., Miles, P.R., Clark, C.W., Tyak, P. and Bird, J.E.. (1983) Investigations of the potential effects of underwater noise from petroleum industry activities on migrating gray whale behavior/Phase II: January 1984 migration. BBN Report 5851, Report from BBN Laboratories Inc., Cambridge, MA for US Minerals Management Service, Anchorage, AK, NTIS PB86-218385.
* Malme, C.I., Miles, Wursig, B., Bird, J.E. and Tyack, P. (1986) Behavioral responses of gray whales to industrial noise: Feeding observations and predictive modeling. BBN Report 6265, Report from BBN Laboratories Inc.. Cambridge, MA for US National Oceanic and Atmospheric Administration and US Minerals Management Service, Anchorage, AK.
* Malme, C.I., Miles, Wursig, B., Bird, J.E. and Tyack, P. (1988) Observations of feeding gray whale responses to controlled industrial noise exposure. In: Sackinger, W.M. et al. (Eds) Port and Ocean Engineering Under Arctic Conditions. Volumn II. University of Alaska, Fairbanks, AK, Geophys. Inst
* Malme, C.L Miles, P.R., Miller, G.W., Richardson, W.J., Roseneau, D.G., Thomson, K.H., and Green, C.R., (1989) Analysis and ranking of acoustic disturbance potential of petroleum industry activities and other sources of noise in the environment of marine mammals in Alaska. BBN Report 6945, OCS Study MMS 98-0006, Report from BBN Systems & Technological Corporation, Cambridge, MA, for US Minerals Management Service, Anchorage, AK, NTIS PB90-188673.
6. Humpback whales showed avoidance when sonar was played back to them:
* Maybaum, H.L., (1989) Effects of 3.3 kHz sonar system on humpback whales, Megaptera novaeangliae, in Hawaiian waters. Eos 71:92.
7. After WWII the Norwegians used sonar to hunt whales because they found the sonar frightened especially baleen whales and caused a predictable flight response making them easier to catch:
* Mitchell, E. Blaylock, G. and Kozicki, V.M., (1981) Modifers of effort in whaling operations: with a survey of anecdotal sources on searching tactics and the use of asdic in the chase. Center for Environmental Education Monograph Series, Center for Environmental Education, Inc., 1925 K Street NW, Washington, DC.
8. Loud underwater sounds also, of course, affect fish and other marine life. Studies show harmful effects of even moderate noise on hearing in fish and the viability of fish eggs exposed to noisy environments was significantly reduced:
* Myrberg, A.A..(1990) The effects of Man-Made Noise on the Behavior of Marine Animals. Environment International 16: 575-586.
9. While cetaceans show avoidance behavior to sounds starting around 115 dB, more intense sounds can cause physiological damage. Noise can mask biologically important signals. This article suggests that if baleen whales show low auditory thresholds for low frequency sounds, then sound levels of 195-210 dB might result in immediate damage to their auditory organs:
* Richardson, W.J., Green, C,R., Malme, C.I., Thompson, D. H., Moore, S.E. and Wurwig, B. (1991) Effects of noise on marine mammals. Report prepared by LGL Ecological Research Associates Inc., TX, for US Minerals Management Service, Atlantic OCS Region, Herndon, VA, MMS Study 90-0093, NTIS PB 91-168914, 462 pp.
10. In their chapter "Underwater Noise Pollution and its Significance for Whales and Dolphins", Jonathan Gordon and Anna Moscrop state that shock waves caused by intense underwater sound sources can cause direct tissue damage. Animals with air filled lungs and swim bladders are especially vulnerable because of the large difference in impedance between air in the lungs and their body tissues or sea water. Submerged animals exposed to explosions at short range showed hemorrhage in the lungs and ulceration of the gastro-intestinal tract.
* Simmonds, M.P. and Hutchinson, J.D. (1996) The Conservation of Whales and Dolphins. John Wiley & Sons.
11. Sperm whales became silent, stopped their activities and scattered in response to military sonar signals:
* Watkins, W.A., Moore, K.E., and Tyack, P. (1985) Sperm whale acoustic behaviors in the Southeast Caribbean. Cetology 19:1-15.
12. From Sounding the Depths by Michael Jasney, page 38, " The National Environmental Policy Act demands that the Navy 'rigorously explore and objectively evaluate all reasonable alternatives'--a duty that lies, in the words of the regulators, at 'the heart' of the entire assessment process. In this light, mere proclamations of national security do not suffice. It is necessary to establish that LFA, which was initially designed to face the deep-sea Soviet threat, actually meets the needs of the post-Cold War world. Doubts persist over the program's utility, and not merely among conservationists, but in such neutral quarters as the General Accounting Office and Jane's Defense Weekly. At least one military contractor has recommended that the Navy stick to passive sonar even in combat, since active sonar could serve as a beacon, attracting enemy fire. And indeed a less intrusive, passive sonar program that would deal expressly with the coastal threat - Advanced Deployable Systems - is ready for testing. Even as the Navy pushes forward on LFA, with NATO at its heels, the potential of this program (or others) to serve as the more 'reasonable alternative' contemplated by Congress has not, to our knowledge, been addressed. Under the circumstances, NRDC has opposed, and continues to oppose, the deployment of LFA."
* Jasney, M. (1999) Sounding the Depths; Supertankers, Sonar and the Rise of Undersea Noise. Natural Resources Defense Council. Los Angeles, CA.
13. Alexandros Frantzis linked a stranding of Cuviers beaked whales in the Mediterranean to military low frequency active (LFA) sonar trials the day before. Cuviers beaked whales rarely strand. A Bioacoustics Panel investigated this stranding and it is clear that the NATO vessel transmitting the LFA sonar came within 10 km of the beach where the whales stranded. The panel concluded these whales were exposed to LFA sonar at 150-160 dB.
* Frantzis, A. (1998) Does acoustic testing strand whales? Nature 392:29.
14. Noted the association between three other strandings of whales (including two pygmy sperm whales, a bottle-nosed whale and eighteen beaked whales) in the Canary Islands in 1985, 1988 and 1989 and the times at which naval fleets had been visibly operating in the area close to stranding sites:
* Simmonds, M.P. and Lopez-Jurado, L.F. (1991) Whales and the Military. Nature 351:448.
15. In their annual report to Congress (Jan.31, 1998) the Marine Mammal Commission stated, "If the LFA system were made available for worldwide use as proposed, all species and populations of marine mammals including those listed as endangered and threatened under the Endangered Species Act possibly could be affected."
This report continues to explain that the possible effects on marine mammals could include:
* death from trauma
* hearing loss
* disruption of feeding, nursing, sensing and communication
* abandonment of traditional feeding and breeding habitants
* stress (making animals more vulnerable to disease and predation)
* changes in distribution and abundance of important marine mammal prey species
* subsequent decreases in marine mammal survival and productivity
16. The Navy has funded much of the research done in large universities in the U.S. on the effects of sound on marine mammals. In 1995 Marine Mammal Science (published by the Society for Marine Mammalogy) published scientific correspondence entitled, "Marine Mammal Science, The US Navy and Academic Freedom." This correspondence discusses the reluctance of US marine mammal scientists to criticize two previous US Navy acoustic projects, Shipshock and ATOC. The authors state that, "Almost all prominent US marine mammal scientists with expertise in acoustics were involved in ATOC." (ATOC was transmitted at about 190 dB, LFAS will be transmitted at 235 dB). The authors go on to say, "the current structure of marine mammal science in the US, where Navy and other defense related agencies fund a large proportion of medium-large projects (especially those involving underwater acoustics) effectively restricts academic freedom.
it is disturbing when any agency with a principal mandate unrelated to science funds a large proportion of the research in any field."
* Whitehead, H.and Weilgart, L. (1995) Marine mammal science, the US Navy and academic freedom. Marine Mammal Science 11: 260-263.
17. In a report submitted to National Marine Fisheries Service in March, 1998 on the impact of engine noise on the Hawaiian humpback whale, researchers at the Ocean Mammal Institute found that whales swim 2 to 3 times faster away from engines of 120 dB than they do around quieter engines. Research by the Ocean Mammal Institute also shows that the presence of a boat up to _ mile away significantly changes the behavior of humpback whales.
18. Ken Balcomb, a marine mammal scientist doing research in the Bahamas, sent a letter to the LFAS Program Manager in February, 2001 stating that in the year following the Bahamas stranding, March 2001, he has not seen any of the photo-identified beaked whales he normally saw in the area. In fact, he has seen only two beaked whales since March and they were individuals he had never seen before. He believes they were new to the area. He concludes, "it is probable that all Cuvier's beaked whales in the region when the naval exercise commenced were killed by the sonar."
* Letter dated February 23, 2001 to Mr. J.S. Johnson [READ LETTER]