Letter to NOAA on Ocean Noise

PPF, along with eleven other area organizations, recently signed on to the following letter to NOAA regarding NOAA’s new strategy to reduce adverse ocean noise:

June 25, 2016
SUBJECT: ONS ROADMAP COMMENT
TO: Dr. Kathryn D. Sullivan, Administrator, NOAA, comment.ONS@noaa.gov

Dear Dr. Sullivan:

We represent a group of citizens affiliated with environmental, tribal, religious, social and other organizations from the greater Olympic Peninsula in Washington. What draws us together from Jefferson, Clallam and Kitsap counties is our interest in reducing harmful ocean noise arising from vessel traffic, Navy sonar and seismic exploration.

We are pleased to see NOAA’s new strategy to reduce adverse ocean noise. Ocean noise pollution is a rising problem that now is more fully recognized, thanks to research and science-based studies. Its damaging effects on cetaceans and other marine life are substantial, requiring immediate attention.

OVERARCHING COMMENT
A Strategy requires an Implementation Plan in order to transform high-level objectives into concrete Action Plans that may be acted upon, measured, evaluated and regulated on a timely basis. An Implementation Plan identifies immediate priorities as well as intermediate and long-term goals. Every Action Plan has a quantifiable deliverable and timeline, as well as estimates for staffing, resources and budgets.

The NOAA Ocean Noise Strategy Roadmap lacks such an Implementation Plan, or detailed “Roadmap.” A true “Roadmap” is comprised of Action Plans, which will mobilize time, talents, resources and monies toward achieving quiet, healthy oceans.

For every day in which NOAA delays in developing Action Plans, increasing harm occurs to the largest whales down to the smallest invertebrates.

We recommend that NOAA develop an Implementation Plan over the next six months, with a completion date of December 31, 2016.

COMMENTS CONCERNING THE SALISH SEA
We request that NOAA accelerate Action Plans relative to the Salish Sea because it is a significant hub for rising acute and chronic ocean noise. Two primary reasons serve as catalysts.

First, the three major ports of Vancouver, Seattle and Tacoma and the busy ports of Port Angeles, Victoria and Bellingham have plans for expansion to enhance economic activity or new or existing military infrastructure. (Source: Port Authority Websites)

For example, here on the Olympic Peninsula, the U.S. Navy has formal plans to construct a large pier on Ediz Hook in Port Angeles. It will have support facilities, including a 10,000-gallon fuel tank and full hotel services for 20-30 crewmembers. The pier will berth seven submarine-escort vessels, some up to 250 feet. Ediz Hook is a long narrow spit, teeming with sea mammals, eelgrass and other marine life. Recently, there have been numerous reports by whale watch companies of humpback whales nearby in the Strait. The U.S. Navy filed a request with the National Marine Fisheries Service to “take” marine mammals incidental to its construction activities. A “take” is an acknowledgement of significant behavioral disruption or injury to animals.   Moreover, the Navy indicates that 80 temporary and 144 permanent pilings will be necessary to build one potential pier site, affecting eelgrass, seals, birds and resident fish, including injury to endangered Chinook salmon. Loud, vibrating pile driving will occur for 75 days over seven months. This information comes from the Navy’s Environmental Assessment for Port Angeles dated November 2015.

In addition, the Port of Port Angeles reports that it is poised to handle bulk and containerized cargoes inbound and outbound. (http://www.portofpa.com/index.aspx?NID=211)

How do we measure such disruptive human-induced ocean noise? How much noise is too much? Will the enforcement of the Marine Mammal Protection Act be compromised? Who is measuring the cumulative effects of noise from port construction, restoration and modernization projects, and military sonar and explosive activity? We believe NOAA to be responsible for these questions.

The second catalyst pertains to characteristics of the Salish Sea. Its channel depth and hard bottom create a kind of acoustic echo chamber. Thus, noises from shipping, naval training exercises, seismic blasting and other activities are very disruptive because of this amplification effect. Recent analyses have shown that average ambient noise in some parts of the Salish Sea regularly exceed the standard for “take” from continuous noise under the Marine Mammal Protection Act. (Bassett, C., Polagye, B., Holt, M., and Thomson, J., 2012, “A vessel noise budget for Admiralty Inlet, Puget Sound, Washington USA,” Journal of the Acoustical Society of America 132: 3706-3719) Another study indicates that the communications space of killer whales is reduced by as much as 97% for much of the time. (Williams, R., Clark, C.W., Ponirakis, D., and Ashe, E., 2014, “Acoustic quality of critical habitats for three threatened whale populations,” Animal Conservation 17: 174-185)

The documentary, Sonic Sea, states that at any one time, 60,000 ships are on our oceans. In the Pacific Northwest, the number of cruise ships, coal transporters, tankers, container ships, ferries and tour boats are rising. In late February, a 1,300-foot container ship longer than four football fields docked in Seattle with much fanfare. It represents the next generation of megaships. Commercial vessel traffic and its noise are predicted to double every decade. (Sonic Sea film)

Noise from the U.S. Navy in our region is also intensifying. There are double and triple-digit increases in proposed air-to-surface missile exercises, use of torpedoes, helicopter-tracking trainings using towed sonar, sonar-testing events in inland waters, and explosives testing and training. (http://westcoastactionalliance.org/facts-about-increased-navy-activity-in-the-pacific)

Fortunately at this time seismic testing related to the oil and gas industry is not a major factor contributing to the sonic din in the Salish Sea. Such seismic tests create injurious loud blasts that carry for hundreds of miles.

The Salish Sea is home to 83 Southern Resident Killer Whales, an endangered population that is struggling to survive amidst substantially increased ocean noise, growing toxins and greatly reduced Chinook salmon stocks. These whales and many other marine creatures depend on acoustics to locate food, find mates, navigate in dark waters, protect themselves, and communicate. The migratory corridor of the Southern Resident Killer Whales extends from British Columbia to Monterey Bay.

The plight of endangered species in tandem with uniquely amplifying ocean terrain, growing vessel traffic and Navy sonar exercises call for aggressive regulation of harmful noise by:

1. Extending and maintaining National Marine Sanctuaries so that they truly protect sea life and restore quiet;

2. Designating shipping and sonar-free lanes that are away from seasonal and migratory patterns of endangered and threatened marine life;

3. Establishing voluntary and required measures for business and industry to adopt quieter technologies, and slowing down the speed of ships;

4. Quantifying the cumulative impact of port and military expansions, and saying no to expansions that require regulatory exceptions;

5. Enforcing existing laws to prevent disruptions to important habitats for marine mammals and endangered species. This action means increasing enforcement budgets; and

6. Completing a detailed Implementation Plan by December 31, 2016.

We urge NOAA to seriously consider these comments and priorities with a sense of urgency. We welcome further dialogue.

If you have any questions, please contact Barb Laski at (360) 301-1855 or flashlaski@gmail.com.

Sincerely,
Rev. Barb Laski
Liaison, Advocacy Group on Ocean Noise Greater Olympic Peninsula
206 Pierce St.
Port Townsend WA 98368