The US National Marine Fisheries Service has recently issued its proposed rule under which the US Navy would be given free reign over 70% of the world ocean to test and use its very loud, low frequency sonar (SURTASS LFA) for the next five years. The US Navy says it needs this permission for national security and because the low frequency sonar is the Pacific Fleet Commander's top anti-submarine warfare priority. But is there a real threat of submarine warfare against the US, NATO and Allied forces?

 

NATO and US Navy sonar in the mid-frequency range has already killed whales in a number of highly publicized events in the Bahamas (16 killed in 2000); North Carolina (2005); Washington State (2003); the Canary Islands (1985, 1986, 1989, 2002, 2004); Madeira (2000); the U.S. Virgin Islands (1998, 1999); and Greece (1996). In most cases, the whales were tens of kilometers away from the sources of the loud sounds (at 145 dB, as loud as rifle blasts in air) and were driven to shore, some with bleeding in the brain and other signs of sudden death, but otherwise were healthy animals.

 

Low frequency sonar can travel much, much further than the mid-frequency sonar that caused the above strandings – hundreds or even thousands of kilometers. An unknown number of cetaceans are at risk and the research has NOT been done to determine the impact and how it might be controlled. Many conservation agencies around the world are writing letters to oppose this disastrous plan. Here is the letter I wrote:

 

                            21st July 2007

 

Dr. William Hogarth

National Marine Fisheries Service

1315 East-West Highway

Silver Springs, MD 20910 USA

 

Re: Fed. Register V.72 #130, 50 CFR pt. 216

ID # 062206A

 

Dear Dr. Hogarth,

 

I am deeply disturbed about the new proposal to deploy SURTASS-LFA (Surveillance Towed Array Sensor System – Low Frequency Active) and, unbelievably, through as much as 70% of the world ocean. How can NMFS be willing to issue global take permits in view of the known sensitivity of whales and dolphins, fish and other marine animals, to this LF sonar ensonification as well as in light of the fragile state of world fishing (including the collapse of ocean predators, reported in Nature in 2003)?

 

I am particularly surprised and upset about the agency's proposal to shrink the Navy's coastal exclusion zone and its failure to consider offshore exclusion zones, with the only three exceptions outside the US being the Costa Rica Dome, the Gully off Nova Scotia, and an area around Antarctica.

 

For the past decade, I have worked on Marine Protected Areas (MPAs) worldwide, focusing on marine mammals. My book Marine Protected Areas for Whales, Dolphins & Porpoises (2005, Earthscan, London, 516pp) details more than 350 existing MPAs for cetaceans and a further 175 areas proposed for protection. There are also 20 countries and territories that have declared their 200 nautical mile exclusive economic zones (EEZs) as marine mammal protection zones. My chapter on Marine Protected Areas for Marine Mammals for the Encyclopedia of Marine Mammals (in-press for 2009) will report that there are now more than 375 MPAs existing and 200 proposed for all marine mammals and that a key mostly unplanned-for threat to the species in these MPAs comes from the growing ensonification of the world ocean.

 

If 70% of the world ocean is now to be opened to LF sonar ensonification, I can say that it is possible that marine mammals in many of these 575+ proposed and existing MPAs, specifically reserved to protect marine mammal habitat, will be impacted, albeit to an unknown extent. I think it is appalling that the extensive (in many cases 10-15 years) work that has gone into research, public process, management plans, review, monitoring, etc for EACH of these MPAs is to be put at risk now by this deployment. These MPAs include the National Marine Sanctuaries in the US (some of which, like the Channel Islands NMS, have not been excluded) as well as many others, under many other names and protection regimes, in more than 100 countries around the world.

 

The problem is that we do not yet have even a modest understanding of the consequences of the impact on marine species from LF sonar. I believe that it is completely irresponsible to allow the global deployment of the SURTASS-LFA system until we know more – a lot more.

 

I would like to add that I could have provided more detailed comments but the minimal 15-day comment period precludes that. I hope that you will consider extending the comment period – I suspect that the timing for this will mean that many marine mammal researchers will be in the field, and those who work in offices, on holiday.

 

Sincerely,

 

Erich Hoyt