Is anyone listening out there?

We are closing in on a public comment period for the proposed Northwest Warfare Training Range Complex Environmental Impact Statement (NWTRC – EIS) The comment deadlines are October 24 for the US Navy, and October 31 for NOAA.

The NWTRC is a consolidation of a set (or “complex”) of training areas under the rubric of one regime. It includes marine sanctuaries, national forest areas, and a large section of ocean off of the Oregon and Washington coast.

It seems as if the Navy would like the entire ocean be a warfare training range, as this is just another training range in a long string of them – four in as many years: the Atlantic UnderSea Warfare Training Range (USWTR), the Southern California Range Complex (SOCAL), the Hawaii Range Complex, and the Gulf of Alaska “Temporary Maritime Activities Area” (GOA – TMAA).

Despite our comments on USWTR, GOA, and SOCAL (along with the comments of NRDC and other groups to these and the Hawaii range) the same elements keep showing up in the Navy proposals – chemical dumping, disregard for critical habitats of endangered species, and of course exposure to extremely loud sonar signals – the subject of their request for “incidental take” permits.

So it appears that despite all of the work we do to read through these cumbersome Environmental Impact Statements (the NWTRC EIS is 2700 pages long!) the Navy is not reading our comments or incorporating our recommendations into their operating protocol.

This was made even more evident in a proposed ruling in yesterday’s Federal Register permitting “incidental takes” in the Gulf of Alaska “Temporary Maritime Activities Area.”

Many of us commented on the GOA EIS this past January. One point that was repeatedly made in everybody’s comments was that the animal population surveys for the take estimates were based on a ten day set of transects across a 42,000 square mile area that the survey contractor admitted were deficient because they were constrained by bad weather for three out of the ten days.

The GOA transects also occurred only in part of April, and as such they were not representative of the year-round populations of marine mammals. But from the scant information provided by the survey the Navy heaped together a 990 page draft EIS for comment.

And from this document – which we all decried as inadequate, NOAA has nonetheless drafted up a “take permit” for public comment. It makes one wonder if anyone is reading the comments, or if the process is just used as a carminative for public ire.