Update on LFA

By William Rossiter

Noise issues have been quieter than expected. The US Navy/Marine Acoustics Low Frequency Active Sonar (LFA) Final Environmental Impact Statement (FEIS) has not surfaced, and the Navy declined at the last minute to testify at December's California Coastal Commission (CCC) Determination Hearing. The CCC has asked all the right questions, while the Navy seems to have no new answers. If California's environmental concerns prove too demanding, the Navy may declare CCC's jurisdictional waters off limits for LFA "normal operations, test and training," probably as if that was their intent all along.

How can this be done, given the Navy's strong presence in California? According to the DEIS the LFA is already off limits along much of the east coast's continental shelf, another Navy backyard, because this is essential right whale habitat. Long ago the Navy recognized the public relations and environmental debacle of harming right whales, and went elsewhere for tests and training. However, LFA use "in armed conflict or direct combat support operations, [or] during periods of heightened threat conditions, as determined by the National Command Authority," is not mitigated or limited because such operations involve the potential for real submarines. The Navy's submarine war is always played as if the world was about to end, right up to the point of firing weapons. The LFA asset could be tasked to search for subs anywhere there was a suggested threat, probably by direct CNO authority, and perhaps without even a paper trail.

Meanwhile scuttlebutt has increasing numbers of Navy people declaring the LFA already obsolete, with the Navy creating a new class of submarines equipped with passive arrays that would do the job of the LFA, but without telltale noise, and a class of destroyer with an LFA derivative. The latter would multiply the noise problem several times. Other nations are developing LFA clones, and most importantly, the countermeasures to deter LFA effectiveness. We are left with a noisy boondoggle pushed by a contractor, a story similar to so many wasteful military programs.

The key to the LFA mitigations is the 180 decibel zone, within which they have a phantom chance to detect marine animals in time to limit impacts. As CSI and nearly everyone else has pointed out, 180 dB is a farcical point of initial mitigation measures, based on an assertion that only then is there significant potential for harm from loud noises. CSI has reported previously that the National Marine Fisheries Service (NMFS) is willing quietly to accept a received level of 180 dB, without any formal rule making. In our view, and that of many others, this decision is not based on facts, but perhaps a desire to cut paperwork. Another asserted farce is that the burden of proof is being shoved around so that we are supposed to prove 180 dB would do harm, rather than the noisemakers prove that it would not cause harm.

CSI supports non-harmful, humane scientific studies to determine noise levels of concern. One example is Dr. Ketten's laboratory analysis of acoustical damage to auditory structures, opportunistically using marine animals that die from stranding or entanglement. Another is a planned study in the Azores and Ligurian Sea of cetacean behavioral responses to specific sounds. Our faith in the caring expertise of the Principle Investigators, Drs. Tyack and Gordon, to not do harm, is not shared by some other organizations. A few oppose all noise making experiments. We all oppose projects that grab funding meant for noise research but do something else instead, as happened during ATOC's Marine Mammal Research Program.

Meanwhile other noise research is being done or planned. NMFS and the Office of Naval Research (ONR) in 2000 funded a National Research Council panel on the subject of ambient noise, which will continue in 2001. NMFS also funded research on the effects of explosions on turtle cadavers, a workshop and report on safety zone criteria for explosions, and scientific recommendations to the oil industry for research on airgun arrays versus marine mammals. In March NMFS will host a workshop on reducing ship noise through better design, and plans to produce a web-based acoustics clearing house. Next year NMFS proposes a five year, $25 million project to begin constructing what they hope will be a global network for measuring the rise and spread of noise from shipping, whale calls, earthquakes, volcanoes, and rainfall. One million dollars per year of this budget will research the effects of noise on marine mammal behavior, including a Navy study that envisions using loud noises and invasive wires on stranded and entangled whales. CSI is adamantly opposed to this last study. It is simply inhumane.