CSI has used Whales Alive! to comment on the U.S. Navy's SURTASS Low Frequency Active Sonar (LFA) since October, 1996. At last it's time for all of us to express our views on the LFA as a significant environmental problem. The LFA Draft Environmental Impact Statement (EIS) has been due for months; we expect it finally to be available this July for a 30 day public comment period. When the EIS process is complete the Navy will be ready to operate the LFA worldwide with four multipurpose vessels now under construction, and they may want four more. We implore you to order a copy of the LFA DEIS; don't miss your chance to comment. Please contact Mr. Joseph S. Johnson, SURTASS LFA EIS Action Manager, U.S. Department of the Navy, 2000 Pentagon N874, Washington, DC 20350-2000 or Johnson.Joseph@HQ.NAVY.MIL.
For a provocative and thorough background to the LFA and the broader issues of human noise in the oceans, or "anthropogenic acoustical impacts", CSI recommends "Sounding the Depths: Supertankers, Sonar and the Rise of Undersea Noise", by Michael Jasny of the Natural Resources Defense Council. "Sounding the Depths" is the most sophisticated yet readable explanation of underwater acoustics, human impacts, and potential solutions ever compiled. Available from the NRDC, <http://www.nrdc.org>, 40 West 20th Street, New York, NY 10011 USA, phone: 212-727-2700, or 1350 New York Avenue, N.W., Washington, DC 20005, phone: 202-783-7800. Other excellent resources we recommend are: (1) Silent Oceans Project, 24 Village Green Drive, Litchfield, Connecticut 06759, Ph: 860-567-1999, Fax: 860-567-3304; and (2) The Quiet Sea Coalition, http://www.maui.net/~mailbot/quietsea.html. If you know of others please tell us about them. Be aware that because of the technical and confusing nature of the science and politics of underwater sound, and the basic ignorance about acoustical impacts on marine life among experts much less the public, not everything that you find is true. There is a lot of guesswork and hyperbole out there, as with so much on the Internet. In another related issue the Office of Naval Research in June published a Federal Register notice that ONR would prepare an environmental impact statement for continued operation of the ATOC undersea sound source off Kauai, Hawaii, to measure ocean temperature changes. (The ATOC source off California is expected to be removed by the end of October.)
Why worry so much about the LFA, only one specific noise amidst all our increasing din? Because the LFA EIS may become the new standard from which every other noise polluter will start. The EIS is expected to conclude that "no significant impact" will occur during LFA operations, and that none was observed during the associated Scientific Research Program (SRP). What does significant mean? September's NMFS workshop on acoustical criteria decided that significant acoustical effects included interfering with predator or danger detection, separation of mothers and babies, abandonment of core habitat, "vigorous" errors in navigation and obstacle avoidance (e.g. strandings), major panic reactions, stimulated agonism (e.g. attacking objects), sleep disturbance, haul out disturbance of pregnant pinnipeds, and long term problems such as stress. Lesser effects not considered generally significant on smaller scales included migration, mate selection, feeding, and changes in dive or respiration patterns, and masking communications didn't make either list. But the experts could not come up with specific levels to regulate, and no one can deal with the worst offenders, commercial shipping.
The problem is that no one knows what whales and other marine life will consider significant. At what point will they react negatively to the LFA? The LFA has an estimated maximum source level near 235dB re 1 µPa @ 1m. It will kill creatures close by. Within a short distance the received level is down to 180dB, the very theoretical level for permanent physical damage. A few kilometers away the received level is 160dB, another theoretical level NMFS uses in a regulatory sense. A number of studies have shown behavioral responses such as avoidance at received levels of 120dB and less, but this occurs well over 100 kilometers from the LFA source. Not only is it very difficult to scientifically observe meaningful negative reactions at any time, much less over such an enormous area, but there is no way humans can mitigate the impacts of their noise so far from the source. If 120dB was everyone's level of concern the LFA and many other sources couldn't operate; the scale of impacts requiring official action would cover impossible areas. NMFS has a similar problem with commercial shipping, the major source of human noise pollution and also the most uncontrollable. NMFS doesn't mess with commercial shipping because it's hopeless. Ironic, isn't it? Humans hate to feel inadequate and love to rationalize. If 120dB creates problems that no one can deal with, doesn't it make sense to convince ourselves that 160dB is a more realistic level? There's nothing realistic about that at all, it is only a compromise with our limits. It must not be confused with the truth that we don't know what whales and other marine life will consider as significant.
CSI initially supported the SRP because it was the most ambitious and sophisticated research effort ever directed at the noise issue. We had hopes that it would define whales' perceptions of significant noise. It has produced volumes of data that will take years to analyze, but a quick conclusion was required to meet the contractual needs of the EIS. The SRP tried to observe target animals and groups, and a close mitigation area around the LFA ship. There was no budget available to observe much else, such as surveys or observations to quantify changes in behavior or distribution out to received levels of 120dB, or follow-ups for problems caused by the SRP transmissions after the particular phase ended. Like the impossible task of NMFS regulating at a scale too large to handle, the Navy budget could not cover our much needed understanding about what whales consider significant noise. Another criticism of the SRP is the unrealistic expectation that this one short experiment is suitable for defining long term effects. In the end the SRP will answer some questions, but perhaps not the biggest ones. Some critics point out that the Navy has invested tax dollars wisely; that the number of U.S. scientists funded by the Office of Naval Research or ATOC-associated Marine Mammal Research Program unfortunately correlates well to the whisper of objective scientific criticism by U.S. scientists of the LFA, ATOC and other acoustical sources. Do these folks truly believe that the LFA is no problem? The issue has surfaced in several ways, such as "The U.S. Navy and Academic Freedom" presented in the Society for Marine Mammalogy's Journal, "Marine Mammal Science", April 1995. The international scientific community hasn't been so quiet. As is customary in less politicized science the aptly named "Quicklook" reports on the three SRP phases and a small amount of additional available data will be assessed by independent, international scientists to verify the preliminary conclusion and comment on the DEIS.
To the Navy the SRP was purchased like a torpedo or any other product, to fulfill a mission, to satisfy EIS requirements. The LFA contractor writing the EIS is not expected to declare that the system they are selling the Navy is destructive. All they really need is the preliminary SRP conclusion that "no significant impact was observed". Although the higher levels of the Navy should be commended for their attention to "green" concerns, the operational elements that will use the LFA will be driven by the mission. Is the DEIS' description of operational Navy mitigation procedures realistic? Will the Navy implement an adequate science-based system of constraints on where and when the LFA should not be used? There are other military projects using very loud sounds and several nations are working on LFA equivalents. Commercial use of loud sound sources are becoming very innovative. Will this EIS let them make any sounds they wish?
The most frustrating failure in this chain of human impact and human limitations is the official silence on the Precautionary Principle. The LFA may be the loudest portable, controllable source of non-impulse sound humans have yet made for use in the water, as loud as technology and the laws of physics will permit. The LFA can cause physical effects in organisms miles away, and behavioral changes perhaps 100 miles away. No one knows the effect it will have on marine life. If we know something might do terrible damage but we don't know how to quantify or constrain the damage doesn't it make sense to be very cautious? Why isn't NMFS cautious enough? Why should anyone expect the Navy to be cautious enough? Is it alarmist to say that the LFA will kill in spite of mitigations? Or that it may cause significant impacts that won't be apparent for some time? Doesn't this beg for the Precautionary Principle?
The LFA is a necessary focus but on a larger scale CSI and a growing consortium of organizations representing public concerns are concerned with the enormous growth of the sounds humans make collectively in the oceans, their cumulative effect over time, and the inability of science to tell us what effect we are causing to specific creatures, populations, habitats, and our own future. Intuitively everyone seems to agree that today's damage will be worse tomorrow. But scientists rely on empirical data to draw conclusions, and regulators rely on science to counter the powerful forces of economics and political power. So while we get noisier no one seems to have a clue about empowering significant solutions. So what are we to do, ignore the inevitable? Please don't ignore your short opportunity to comment on the LFA DEIS.
For additional information on this issue, read the three-part series from CNN called "Making Waves":
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