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May 30, 2001
Re: US Navy's SURTASS LFA Sonar FEIS & the NMFS Intent to Rule
Dear Chief Wieting,
The Low Frequency sounds used in the Navy's LFA sonar (SURTASS towed array sonar) constitute only a portion of the loud sounds (140+ dbs) the Navy is introducing into the oceans in warfare maneuvers. Asking permission from NMFS to take marine mammals in conjunction with the use of LFAS technology constitutes SEGMENTATION of their use of underwater sounds in warfare. The use of mid-frequency sounds has been verified by the Navy to cause cetacean deaths, while low frequency use has not been deemed harmful by the Navy. The Navy has SEGMENTED their technology and projects involving Very Loud Sounds introduced into the living seas. SEGMENTATION is clearly against the law! The Navy's use of LFAS, with possible takes of marine mammals, is not a complete picture of the Navy's involvement with loud sounds in the seas which have harmful effects on marine mammals. Following the letter of the law, NMFS has an obligation to justice to deny the Navy's request for taking marine mammals using LFAS as only one segment of the frequency bands and technologies the Navy uses which potentially impact marine mammals. The Navy has not addressed Calibration time in its estimation of the impact of LFAS. Departing from Pearl Harbor en route to the testing grounds off Kona, The Cory Choest calibrated the LFAS equipment, possibly causing at least one death and beaching of a whale. Multiple and long term exposure is not addressed in the FEIS, although nearby seas of the home ports for the vessels equiped with LFAS technology may be subjected to such repeated exposure during such calibrations. At the least, please request an addendum to the FEIS addressing multiple exposures of high intensity low frequency sounds to marine mammals over the long term. Taking into account reflection of sound from land, and the trap the land barrier presents to marine mammals possibly fleeing the Navy's use of deafening noise, permitting 140 dbs. in nearshore waters is too high to be "safe" and acceptable. Please reconsider this application for holding unforseen damages over the long term to populations of marine mammals it is your responsibility to protect. The Navy's longterm use of Very Loud Sounds in the seas is an intrusion which will detrimentally impact populations of marine mammals. I urge you to withdraw your proposed rule and to deny the Navy's application to deploy LFA sonar. Thank you for your reconsideration of this permit request.
Roberta Goodman Hilo, Hawaii
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