Tag Archives: marine mammals

The Navy and the Blob 2.0 will impact the lives of whales, dolphins, and seals. Here’s what you can do about it.

We need the military to keep us safe,  most of us get that. We also understand that the Navy has vitally important activities that – however unfortunately – can lead to injury and death of marine mammals. The government goes to some length to insure that those Navy activities have a minimum impact by requiring them to submit fairly complex documents every five years, based in part on what impact they had in the previous five-year period.
At issue here is that although the Navy and NOAA Fisheries have already established allowable “takes” (marine mammals that can be killed or displaced) for 2019 through 2023, they now want to extend the period an additional two years without having to reassess the effect they are having on marine mammal populations. 
In other words, the Navy won’t have to take into account how much changing ocean conditions will alter the statistics – we have already seen that population distributions are changing for many whale and dolphin species as they follow their prey. For instance, gray whales appear to be starving in some cases, humpback entanglements have risen as they come in closer to shore and encounter crab pots, and diseases such as the morbillivirus decimate cetaceans in parts of their range. Young California sea lions are stranding in unprecedented numbers.
Complicating everything is that Blob 2.0 is forming off the West Coast which is expected to further alter marine mammal health and distribution (graphic and original NOAA data are below).

Comments to NOAA can be made here by October 15th:
Taking and Importing Marine Mammals; Taking Marine Mammals Incidental to the U.S. Navy Training and Testing Activities in the Hawaii-Southern California Training and Testing Study Area
Please take a few minutes to submit your comment to NOAA, the process is simple but be aware that NOAA will only consider well-grounded comments in their decision making. There’s no harm in venting your feelings though, and NOAA needs to know how the public feels so any comment you care to make will be read.

Data from NOAA documents

“NMFS has reviewed the Navy’s data and analysis and determined that it is complete and accurate, and NMFS agrees that the following stressors have the potential to result in takes of marine mammals from the Navy’s planned activities:

Acoustics (sonar and other transducers; air guns; pile driving/extraction);

Explosives (explosive shock wave and sound, assumed to encompass the risk due to fragmentation); and

Physical Disturbance and Strike (vessel strike).”

Photo Credit: Alaska Magazine

(Level A takes are possibly lethal, Level B takes disturb or disrupt):

3,162 potentially lethal  10,775,414 disturbed/displaced during TESTING

1,598 potentially lethal   7,187,158 disturbed/displaced during TRAINING

The following is a list of species that can possibly be killed in BOTH Navy training and Navy testing activities; alarming because some species (such as dwarf sperm whales) are impacted out of scale to what is known about them:

Comments to NOAA can be made here by October 15th:
Taking and Importing Marine Mammals; Taking Marine Mammals Incidental to the U.S. Navy Training and Testing Activities in the Hawaii-Southern California Training and Testing Study Area

The following shows the both Level A and Level B “takes” for each species in Navy testing, followed by the list of “takes” in  Navy training activities:

Expected takes during Testing Exercises:

Level A  Level B  Species  Stock

0             205        Blue whale *      Central North Pacific
6             7,116     Blue whale *      Eastern North Pacific
0             167        Bryde’s whale † Eastern Tropical Pacific
0             631        Bryde’s whale † Hawaiian †
0             7,731     Fin whale *         California, Oregon, & Washington
0             197        Fin whale *         Hawaiian
7             7,962     Humpback whale †          California, Oregon, & Washington †
12           34,437   Humpback whale †          Central North Pacific
7             4,119     Minke whale      California, Oregon, & Washington
6             20,237   Minke whale      Hawaiian
0             333        Sei whale *         Eastern North Pacific
0             677        Sei whale *         Hawaiian
27           16,703   Gray whale †      Eastern North Pacific
0             19           Gray whale †      Western North Pacific †
0             8,834     Sperm whale *  California, Oregon, & Washington
0             10,341   Sperm whale *  Hawaiian
215        84,232   Dwarf sperm whale         Hawaiian
94           33,431   Pygmy sperm whale        Hawaiian
149        38,609   Kogia whales      California, Oregon, & Washington
0             8,524     Baird’s beaked whale      California, Oregon, & Washington
0             23,491   Blainville’s beaked whale              Hawaiian
0             47,178   Cuvier’s beaked whale    California, Oregon, & Washington
0             7,898     Cuvier’s beaked whale    Hawaiian
0             82,293   Longman’s beaked whale             Hawaiian
0             25,404   Mesoplodon spp (beaked whale guild)    California, Oregon, & Washington
0             1,295     Bottlenose dolphin          California Coastal
13           201,619               Bottlenose dolphin          California, Oregon, & Washington Offshore
0             13,080   Bottlenose dolphin          Hawaiian Pelagic
0             500        Bottlenose dolphin          Kauai & Niihau
10           57,288   Bottlenose dolphin          Oahu
0             1,052     Bottlenose dolphin          4-Island
0             291        Bottlenose dolphin          Hawaii
0             4,353     False killer whale †          Hawaii Pelagic
0             2,710     False killer whale †          Main Hawaiian Islands Insular †
0             1,585     False killer whale †          Northwestern Hawaiian Islands
4             177,198               Fraser’s dolphin Hawaiian
0             460        Killer whale         Eastern North Pacific Offshore
0             855        Killer whale         Eastern North Pacific Transient/West Coast Transient
0             513        Killer whale         Hawaiian
99           784,965               Long-beaked common dolphin    California
0             14,137   Melon-headed whale      Hawaiian Islands
0             1,278     Melon-headed whale      Kohala Resident
57           357,001               Northern right whale dolphin      California, Oregon, & Washington
19           274,892               Pacific white-sided dolphin           California, Oregon, & Washington
0             17,739   Pantropical spotted dolphin         Hawaii Island
0             42,318   Pantropical spotted dolphin         Hawaii Pelagic
0             28,860   Pantropical spotted dolphin         Oahu
0             1,816     Pantropical spotted dolphin         4-Island
0             35,531   Pygmy killer whale          Hawaiian
0             2,977     Pygmy killer whale          Tropical
45           477,389               Risso’s dolphin   California, Oregon, & Washington
0             40,800   Risso’s dolphin   Hawaiian
0             26,769   Rough-toothed dolphin  Hawaiian
0             0             Rough-toothed dolphin  NSD
307        5,875,431            Short-beaked common dolphin   California, Oregon, & Washington
6             6,341     Short-finned pilot whale               California, Oregon, & Washington
0             53,627   Short-finned pilot whale               Hawaiian
0             609        Spinner dolphin Hawaii Island
0             18,870   Spinner dolphin Hawaii Pelagic
0             1,961     Spinner dolphin Kauai & Niihau
8             10,424   Spinner dolphin Oahu & 4-Island
5             777,001               Striped dolphin  California, Oregon, & Washington
0             32,806   Striped dolphin  Hawaiian
894        171,250               Dall’s porpoise   California, Oregon, & Washington
629        460,145               California sea lion            U.S
0             3,342     Guadalupe fur seal *       Mexico
0             62,138   Northern fur seal             California
48           19,214   Harbor seal         California
5             938        Hawaiian monk seal *     Hawaiian
490        241,277               Northern elephant seal  California
Totals: 3,162 potentially lethal   10,775,414 disturbed/displaced during Testing Exercises
* ESA-listed species (all stocks) within the             HSTT Study Area.
† Only designated stocks are ESA-listed.

Expected takes during Training Exercises: 

Level A  Level B  Species  Stock

0             93           Blue whale *      Central North Pacific
0             5,679     Blue whale *      Eastern North Pacific
0             97           Bryde’s whale † Eastern Tropical Pacific
0             278        Bryde’s whale † Hawaiian †
7             6,662     Fin whale *         California, Oregon, & Washington
0             108        Fin whale *         Hawaiian
0             4,961     Humpback whale †          California, Oregon, & Washington †
19           23,750   Humpback whale †          Central North Pacific
0             1,855     Minke whale      California, Oregon, & Washington
0             9,822     Minke whale      Hawaiian
0             178        Sei whale *         Eastern North Pacific
0             329        Sei whale *         Hawaiian
0             13,077   Gray whale †      Eastern North Pacific
0             15           Gray whale †      Western North Pacific †
0             7,409     Sperm whale *  California, Oregon, & Washington
0             5,269     Sperm whale *  Hawaiian
197        43,374   Dwarf sperm whale         Hawaiian
83           17,396   Pygmy sperm whale        Hawaiian
94           20,766   Kogia whales      California, Oregon, & Washington
0             4,841     Baird’s beaked whale      California, Oregon, & Washington
0             11,455   Blainville’s beaked whale              Hawaiian
28           30,180   Cuvier’s beaked whale    California, Oregon, & Washington
0             3,784     Cuvier’s beaked whale    Hawaiian
0             41,965   Longman’s beaked whale             Hawaiian
15           16,383   Mesoplodon spp (beaked whale guild)    California, Oregon, & Washington
0             11,158   Bottlenose dolphin          California Coastal
8             158,700               Bottlenose dolphin          California, Oregon, & Washington Offshore
0             8,469     Bottlenose dolphin          Hawaiian Pelagic
0             3,091     Bottlenose dolphin          Kauai & Niihau
0             3,230     Bottlenose dolphin          Oahu
0             1,129     Bottlenose dolphin          4-Island
0             260        Bottlenose dolphin          Hawaii
0             2,287     False killer whale †          Hawaii Pelagic
0             1,256     False killer whale †          Main Hawaiian Islands Insular †
0             837        False killer whale †          Northwestern Hawaiian Islands
9             85,193   Fraser’s dolphin Hawaiian
0             236        Killer whale         Eastern North Pacific Offshore
0             438        Killer whale         Eastern North Pacific Transient/West Coast Transient
0             279        Killer whale         Hawaiian
34           805,063               Long-beaked common dolphin    California
0             7,678     Melon-headed whale      Hawaiian Islands
0             1,119     Melon-headed whale      Kohala Resident
22           280,066               Northern right whale dolphin      California, Oregon, & Washington
14           213,380               Pacific white-sided dolphin           California, Oregon, & Washington
0             9,568     Pantropical spotted dolphin         Hawaii Island
0             24,805   Pantropical spotted dolphin         Hawaii Pelagic
0             1,349     Pantropical spotted dolphin         Oahu
0             2,513     Pantropical spotted dolphin         4-Island
0             18,347   Pygmy killer whale          Hawaiian
0             1,928     Pygmy killer whale          Tropical
24           339,334               Risso’s dolphin   California, Oregon, & Washington
0             19,027   Risso’s dolphin   Hawaiian
0             14,851   Rough-toothed dolphin  Hawaiian
0             0             Rough-toothed dolphin  NSD
304        3,795,732            Short-beaked common dolphin   California, Oregon, & Washington
0             6,253     Short-finned pilot whale               California, Oregon, & Washington
0             29,269   Short-finned pilot whale               Hawaiian
0             1,394     Spinner dolphin Hawaii Island
0             9,534     Spinner dolphin Hawaii Pelagic
0             9,277     Spinner dolphin Kauai & Niihau
0             1,987     Spinner dolphin Oahu & 4-Island
20           371,328               Striped dolphin  California, Oregon, & Washington
0             16,270   Striped dolphin  Hawaiian
478        115,353               Dall’s porpoise   California, Oregon, & Washington
36           334,332               California sea lion            U.S
0             6,167     Guadalupe fur seal          Mexico
7             36,921   Northern fur seal             California
12           15,898   Harbor seal         California
0             372        Hawaiian monk seal        Hawaiian
187        151,754               Northern elephant seal  California
1,598 potentially lethal   7,187,158 disturbed/displaced during Training Exercises                       

Changing ocean conditions are impacting everything in the Navy permit area (and beyond)

from plankton to blue whales (the graphic is from NOAA).

The Blob 2.0


How a few minutes of your time can save a lot of whales [and keep seafood on your table]

Pilot whale stranding in New Zealand Credit: Reuters

The Problem

It’s game-on for offshore drilling in the Atlantic, and it will wreak havoc

Once big oil gets its hooks into the Atlantic seabed there will be no turning back, no way to unwind that clock. Even if they never cause a spill or erect a rig, untold damage will happen to marine life, from the tiniest organisms (see Seismic surveys now proven to kill zooplankton…there goes your crab dinner) to the great whales. And they can’t wait to get started.
The following stranding event caused by ExxonMobil in 2008 is a prime example of the deadly impact of oil exploration.
The story started on a typically breezy and hot day near the mouth of a lagoon on the island nation of Madagascar. Two small whales had beached and died, their gleaming bodies still fresh enough to be eaten by the astonished villagers who carried them off.
But that was just the beginning – the brackish and turbid water of the the Loza Lagoon began to fill with panicked whales swimming desperately away from the ocean world they knew. By the afternoon the deep ocean dwelling melon-headed whales had traveled 65 kilometers (40 miles) inland.

Slowly the lost and confused whales began to die. Amid the tangled mangroves, mudflats and on narrow beaches their skin blistered and their body temperature rose until death came as a reprieve. Impoverished villagers caught and ate an unknown number. Of the estimated 100 -200 melon-headed whales that entered the lagoon only a handful were known to survive, despite a dedicated rescue attempt.
Finally, after nearly a month, four whales were seen leaving the lagoon and heading out to sea.
What had caused the mayhem? After years of meticulous study scientists concluded that the culprit could be summed up in one word: Sonar.
Earsplitting, terrifyingly loud and relentless, the sound had bounced off the underwater cliffs and canyons in the deep ocean. It drove the whales out of their familiar habitat with nowhere to escape until they sought refuge in the lagoon death trap.
It turned out that ExxonMobil and partners were mapping the ocean floor along the coast prior to doing seismic surveys for oil when the stranding occurred, using the type of sonar employed by the navy that had caused the deaths of whales in the Bahamas in 2000. In War of the Whales, author Joshua Horwitz carefully documents the Bahamas strandings but until the sad event in Madagascar no one had be able to document that the private sector – big oil – similarly destroyed marine life.

There is no way to know how many other species were affected and/or died in the ocean or at other remote locations during this one sonar mapping fiasco. And it was expensive – the investments by the scientific community, local officials, and rescue organizations were deep, and because the local population of Madagascar feasted on the toxic meat of the freakishly out of place whales they may experience health consequences.
In the end the whale deaths were for nothing: ExxonMobil and its partners just didn’t find a significant enough puddle of oil hidden under the seafloor to be worthwhile.
And now big oil is poised to repeat their activities off the Atlantic coast of the US. Marine life will have to endure various seismic challenges, from the sonar that drove the melon-headed whales to seek safety where the noise couldn’t penetrate (but for which they were not adapted to survive), to the repeated nearly year long pounding of seismic noise.


These steps will guide you through the commenting process

NOAA Fisheries wants the public to weigh in on this – the oil companies can’t operate seismic surveys unless they get permits from the energy bureau, and the energy bureau won’t issue permits unless NOAA is satisfied that existing restrictions are met.

  1. Go to the Federal Register website and familiarize yourself with the process.
  2. Choose current research to support your comments.  (The links below are studies published in 2017 and either were done in the region specified or include species known in the specified area.)
  3. Email your comments to:  ITP.Laws@noaa.gov by July 6th.

But remember, NOAA will NOT consider comments other than as specified. “We will only consider comments that are relevant to marine mammal species that occur in U.S. waters of the Mid- and South Atlantic and the potential effects of geophysical survey activities on those species and their habitat.”
Suggested links:
Natural and anthropogenic ocean noise recorded at long-term and temporary observatories
High suckling rates and acoustic crypsis of humpback whale neonates maximise potential for mother–calf energy transfer
Cetacean sightings and acoustic detections during a seismic survey off Nicaragua and Costa Rica, November-December 2004
Nowhere to go: noise impact assessments for marine mammal populations with high site fidelity

Background information:

Having removed the protections against drilling along the Atlantic Coast put in place by then President Obama, the Trump administration is trying to push NOAA Fisheries to use the old, lower standards for sound levels rather than the new standards that were set to start this year. And they want the permits to be expedited so that the oil companies can start the seismic surveys as soon as possible.
From Trump’s executive orderImplementing an America-First Offshore Energy Strategy

Sec. 9. Expedited Consideration of Incidental Harassment Authorizations, Incidental-Take, and Seismic Survey Permits. The Secretary of the Interior and the Secretary of Commerce shall, to the maximum extent permitted by law, expedite all stages of consideration of Incidental Take Authorization requests, including Incidental Harassment Authorizations and Letters of Authorization, and Seismic Survey permit applications under the Outer Continental Shelf Lands Act, 43 U.S.C. 1331 et seq., and the Marine Mammal Protection Act, 16 U.S.C. 1361 et seq.
Sec. 10Review of National Oceanic and Atmospheric Administration (NOAA) Technical Memorandum NMFS-OPR-55. The Secretary of Commerce shall review NOAA’s Technical Memorandum NMFS-OPR-55 of July 2016 (Technical Guidance for Assessing the Effects of Anthropogenic Sound on Marine Mammal Hearing)… take all steps permitted by law to rescind or revise that guidance, if appropriate.


References and further reading:

SeaWorld’s Tank Size Questioned by Congress, Thanks to the Little Film That Could, “Blackfish”

(Courtesy Orca Network)
(Courtesy Orca Network)

According to (CNN), “Over three dozen members of Congress want the government to ensure the humane treatment of orca whales and other marine animals in captivity, following an outcry sparked by the documentary “Blackfish.””
“The letter, released Thursday and signed by 37 Democrats and one Republican to Agriculture Secretary Tom Vilsack, cites outdated regulations protecting those sea mammals and asserts that the current rules don’t reflect “updated science.””

“Our letter is asking USDA to update regulations for captive marine mammals under the Animal Welfare Act (AWA), which have not been revised since 2001. In May 2002, USDA proposed to update captive marine mammal standards for indoor facilities, outdoor facilities, water quality, space requirements, and swim-with-the-dolphin (SWLD) programs. During the comment period, USDA received numerous comments recommending changes to tank sizes and otherwise improving facilities for marine mammals. Yet twelve years after the public comment closed, USDA still has not finalized these regulations. Given the public interest in humane treatment of orcas and other marine mammals, especially in light of the death in 2010 of SeaWorld trainer Dawn Brancheau by the orca Tilikum and the film Blackfish, it is incumbent on USDA to finalize this long-overdue process.”
(The entire letter can be viewed here.)


Protesters in Seattle seeking the freedom of "Namu", who died in captivity.
Protesters in Seattle seeking the freedom of “Namu”, who died in captivity.

After nearly a lifetime of watching the captive display industry exert power over and muffle the voices of anyone who tried to bring change to the orcas and other whales and dolphins suffering for entertainment I have been stunned by the changes that are on the horizon for these precious and sentient animals.
The documentary Blackfish, and the dedicated people who have worked tirelessly through the years to support the message that captivity is not viable for these animals, along with the reach of social media have come together to  reach the eyes, ears, and hearts of people the world over.
Among those who have come to understand the nature of marine mammal captivity are those who have the power to do something about it, and they are.
But most important of all are those of you the world over who stand up and speak up, and who refuse to support the amusement parks and aquariums that have shown indifference in the past. Because of you, aquariums are questioning the keeping of whales and dolphins in tanks of any size and are giving serious consideration to moving the animals that can’t be released into sea pens and lagoons, our Congress in the U.S. are stepping up to the plate, and countries such as India have banned the captivity of whales and dolphins entirely.

“Nothing is stronger than an idea whose time has come.”
       Victor Hugo (1802-1885)
French poet, novelist, and playwright

Argentina Empty the Tanks
Argentina Empty the Tanks

Below is a reprint of a post I wrote in 2010 a,  a week and a half before Dawn Brancheau was killed. I fills in background on this issue and explains Congress’s role in protecting the whales and dolphins entrusted to government oversight.
I could write for days about how difficult, frustrating, annoying, and depressing it has been for those who have worked so hard on this issue, but I won’t.  I’m in a celebratory mood, and feeling deeply grateful to all who have worked to bring this to the attention of Congress, and to all those Congresspersons who are now stepping up to the plate.

Captive L-pod Orca Is Caught In A Legal Quagmire

Posted on February 12, 2010 | By 

One of the Southern Resident orcas captured in 1971 continues to reside in captivity at the old and tired Miami Seaquarium. This lonely whale was given the unfortunate name “Lolita” and lives in a sub-standard pool without companions of her species. She is getting old, has to perform tricks for her dinner, and has no other orcas for company. There is nothing for her to do but to circle her pool or lie on the bottom when she is not being forced to perform.

Lolita performs for sparse audiences in a sad theme park.

This confinement is cruel for an animal species which has been shown to be bright and highly social – orcas have one of the strongest family bonds in the animal kingdom. They rarely sleep and they swim hundreds of miles a day.
Day after day, month after month, year after year…Lolita’s life never changes.

Creative Commons Photo

Gone are the days when we enjoyed seeing large animals in small cages, or marveled at the sight of an elephant chained to a post on a concrete pad…yet magnificent whales and dolphins are allowed to be kept like giant fish in small tanks and are trained to do dumb tricks for our amusement. If they are allowed to breed, the families are separated, sold, or traded.
Caring people have been trying to help Lolita (a member of L-pod) for decades – writing letters, protesting, raising awareness – but Lolita’s captors are indifferent and uncaring, and they hide behind loopholes in the laws designed to protect our rare and valuable wild animals.
I have talked to people in Senator Murray’s office, at NOAA, and the Washington State Department of Fish and Wildlife (Governor Gregoire’s office directed my information request to them). Senator Cantwell’s office has never responded to emails or phone calls, on any of the orca issues (salmon, vessel regulations, or captivity).
What it boils down to is that Lolita needs a lawyer, and a good one. Here is why:
First, Lolita was captured right before the Marine Mammal Protection Act was implemented.
Second, because she was caught ‘pre-act’, the powers-that-be decided she should be directly excluded from the status of endangered that protects the rest of her family (the document reads ‘any member of J, K, or L pods’ in captivity).
Third, Animal Welfare is under the jurisdiction of the Department of Agriculture. When it came to determining what standards a dolphin or whale should have in captivity, they asked the theme parks and aquaria to set the standards, not biologists.
Fourth, the Animal and Plant Inspection Service (known as APHIS) is required to inspect and enforce compliance with the pathetic standards set by the theme parks. It is up to them to interpret the measurements, and they consistently measure Lolita’s pool incorrectly.
And fifth… no one in any of these organizations with whom I spoke feels they can do anything to change the standards set for captive cetaceans. But people made the decisions that allow a handful of individuals get very wealthy in the mistreatment of these gentle (and in the case of Lolita; endangered) animals. So it would seem that people can also change those laws and remedy the situation.
Meanwhile, individuals and groups continue their efforts to improve Lolita’s life. In 2009 Shelby Proie and SaveLolita.com used the Freedom of Information Act to obtain inspection records and to have their complaints addressed. As far as I can tell by looking at the documents, it looks like APHIS denied some of the information on the basis that “it’s release would cause a clearly unwarrented invasion of personal privacy”. The results that they did provide were not remarkable, other than to state that Lolita has the company of Pacific white-sided dolphins, and they are “biologically related” to orcas. That is like saying locking a human up with a monkey for company is equivalent to a human companion. That may be true for the owners of the theme park, but it certainly isn’t true for most of humanity.
It may take an Act of Congress to make it right – but given the fact that Lolita is one of only 89 whales like her in the world, shouldn’t that effort be made?

NBC News Reports 27 Million Marine Mammals May Be Impacted By Navy Practice – Comment Period Extended

NAVY EXTENDS PUBLIC COMMENT PERIOD FOR NORTHWEST TRAINING AND TESTING. Please take a minute to express your opinion to the navy on their planned activities, using logical and factual arguments.

The Navy estimates that its activities could inadvertently kill 186 whales and dolphins off the East Coast and 155 off Hawaii and Southern California, mostly from explosives. 

It calculates more than 11,000 serious injuries off the East Coast and 2,000 off Hawaii and Southern California, along with nearly 2 million minor injuries, such as temporary hearing loss, off each coast. It also predicts marine mammals might change their behavior — such as swimming in a different direction — in 27 million instances.  (NBCnews)


SILVERDALE, Wash. – The U.S. Navy is extending the public comment period for the Northwest Training and Testing (NWTT) Draft Environmental Impact Statement/Overseas Environmental Impact Statement (EIS/OEIS) until April 15, 2014, to allow the public more time to submit comments.
The Navy prepared the Draft EIS/OEIS to evaluate the potential environmental impacts associated with military readiness training and testing activities conducted primarily within existing range complexes, operating areas and testing ranges in the NWTT Study Area. The Navy invites the public to submit comments on the Proposed Action and alternatives, and the accuracy and adequacy of the Draft EIS/OEIS analysis. The Draft EIS/OEIS is available for public review online at www.NWTTEIS.com.
The Navy is accepting comments throughout the extended public comment period, which began Jan. 24, 2014, and now runs until April 15, 2014. All comments must be postmarked or received online by April 15, 2014, for consideration in the Final EIS/OEIS. Written comments may be submitted via the project website at www.NWTTEIS.com or by mail to:
Naval Facilities Engineering Command Northwest
Attention: Ms. Kimberly Kler – NWTT EIS/OEIS Project Manager
1101 Tautog Circle, Suite 203
Silverdale, WA 98315-1101

Eight public meetings were recently held in Washington, Oregon, Northern California and Southeastern Alaska to inform the public about the Navy’s Proposed Action and findings in the Draft EIS/OEIS. Public comments on the environmental analysis were accepted during the public meetings. All comments received by April 15, 2014, will be considered in the development of the Final EIS/OEIS.
The Navy’s Proposed Action is to conduct training and testing activities, to include the use of active sonar and explosives, within the NWTT Study Area. The Proposed Action also includes pierside sonar maintenance and testing within the NWTT Study Area.
The purpose of the Proposed Action is to ensure that the Navy accomplishes its mission to maintain, train and equip combat-ready naval forces capable of winning wars, deterring aggression and maintaining freedom of the seas. This mission is achieved in part by training and testing within the NWTT Study Area. The NWTT EIS/OEIS also supports the renewal of federal regulatory permits and authorizations for current training and testing activities and future activities requiring environmental analysis.
The NWTT Study Area is composed of Navy training and testing range complexes, operating areas, testing facilities, and select Navy pierside locations in the Pacific Northwest. Aircraft training and testing activities that take place on or within established Navy airfields at Naval Air Station Whidbey Island, Wash., or Naval Weapons Systems Training Facility Boardman, Ore., are not included in this NWTT EIS/OEIS.
Visit the project website at www.NWTTEIS.com to download the Draft EIS/OEIS, view a map of the NWTT Study Area, learn more about the project and submit comments online.

So, the question is…HAS BEING PREPARED FOR WAR EVER PREVENTED WAR? World War I was to be the war that ended all wars – one hundred years and many wars later here we are.  It is time for a new world strategy, but until we figure that out please take action to help minimize our impact on the environment.

The war to end war” (sometimes called “The war to end all wars“) was a term for World War I. Originally idealistic, it is now used mainly in a disparaging way.In later years, the term became associated with Woodrow Wilson, despite the fact that Wilson used the phrase only once. Along with the phrase “make the world safe for democracy,” it embodied Wilson’s conviction that America’s entry into the war was necessary to preserve human freedom. (Wikipedia)

“Strange game. The only way to win is not to play.”.

Whales, Dolphins, and Ocean Noise: ‘Absence of Evidence is not Evidence of Absence’

Whales and dolphins are known to strand due to sonar and seismic exploration.
Whales and dolphins are known to strand due to sonar and seismic exploration.

Your input is needed to balance that of the oil industry and special interests on the issue of ocean noise – March 13, 2014 is the deadline to make comments on the government’s proposed guidelines on ocean acoustics and marine mammals.
Because this is a complex issue involving a lot of science and technical language, reading all of the documents can be off-putting and discouraging but it is worth the effort to skim through them.  However, if you are short on time the information below will give you a great start and can be checked back through the links provided.


Your input is vital! The oil industry would like a proposed 24 hour time period for measuring the sound levels their activities generate reduced significantly to as little as three hours – which means they would only have to measure a portion of the recommended time.
NOAA has repeatedly requested more input on this point (please scroll to the bottom to the section on the public meeting), and it is important to share your thoughts as counter-point to industry input such as this statement by a researcher contracted by the oil industry. (See full remark below).

This leads me to ask “what problem is NOAA trying to solve by this aggressive  approach?” Is there any evidence at all that the present guidelines leave whales with hearing loss from shipping, low-frequency active sonar, seismic arrays, and others? Have whale populations declined in areas where these sources are used? Unless there is evidence of either effect, then it is best to discard this graph and continue to use the present guidelines until empirical data become available on hearing in low-frequency cetaceans. (Gentry)

Fortunately, when dealing with wildlife the government has taken the stance that the benefit of doubt should go to the animals, particularly if there are threatened or endangered species involved (which sadly is true in all the oceans). You can use this point as an argument in your comment to the government.
Background on the Endangered Species Act:

5. Assess species responses to exposure.
Actions potentially resulting in habitat modification or destruction are indirect effects – as these effects may ultimately cause demographic effects on individuals or populations of a listed species. In this case the assessment must determine if a species habitat is likely to change in response to action-related changes in the quantity, quality, or availability of one or more of the resources that comprise its habitat.
To meet the statutory requirement to insure a proposed action is not likely to cause JAM, the agency conducts its analysis to avoid concluding that the action had no effect on listed species or its habitat when, in fact, there was an effect. This approach minimizes the likelihood of making a false negative conclusion (absence of evidence is not evidence of absence). In doing so, the agency must use the “best scientific and commercial data available,” and in cases where information is incomplete, clearly articulate the rationale for reaching a conclusion (thus avoiding being found to have made an arbitrary or capricious conclusion). At times, this approach to error may lead to different conclusions than would a more traditional scientific approach to hypothesis testing, but it is in compliance with direction from the ESA and the courts to provide the benefit of the doubt to the species.
6. Assess risk: to individuals, populations, and to species.
a. Would the response of the individuals exposed to the action be sufficient to reduce the fitness of those individuals?
b. Would changes in the fitness of these individuals be sufficient to increase the extinction risk (or reduce the probability of persistence and recovery) of the populations, given what is known about the species?
c. Would changes in the extinction risk (or persistence) of those populations be sufficient to increase the extinction risk of the species, given its status?

Below are excerpts from the relevant documents, but you can stop reading here and just use the information on endangered species above since it is applicable.

One additional point – walruses, polar bears, otters, and manatees are NOT included in NOAA’s document and so your comments on these species will not be included for consideration.  They will only consider arguments that address points covered in the document.

Please go here to enter your comment, the full draft can be found here. Reference comments from the documents are below, you might them helpful in writing your comments.


 NOAA’s remarks taken from the Peer Review Report:
(“Thresholds” refers to the sound levels that cause temporary hearing impairment (‘TTS  is Temporary Threshold Shift’) or permanent hearing loss (PTS is ‘Permanent Threshold Shift’)).

  • There will not be implementing regulations in association with this document.
  • These thresholds are to be used more before the activity occurs. So when applicants come and they have to estimate how many marine mammals are going to be harassed…this more of a tool to be used beforehand rather than out in the field.
  • So whatever process applicants are undergoing now in order to estimate the distribution or presence of marine mammals when they come in for authorizations under the MMPA would be the same using these thresholds. It is just that the science used in calculating these  thresholds is different.
  • So on a case-by-case basis, I would assume that applicants are doing the best  they can to estimate the distribution and presence of marine mammals, but there is no guidance additional within this document for that kind of estimation.

NOAA is continuing our examination of the effects of noise on marine mammal behavior and will focus our work over the next year on developing guidance regarding the effects of anthropogenic sound on marine mammal behavior. Behavioral response is a complex question, and additional time is needed to research and appropriately address the issue.
This guidance on behavior, when available, will also be subject to future peer review.

Input  was made by these four peer reviewers:

Klaus Lucke, Ph.D., Wageningen University and Research (The Netherlands)  “Results of masking modelling indicate that airgun sounds can lead to a reduction in communication range for blue and fin whales 2000 km from the source depending strongly on the frequency content of the vocalization.” Conference abstract, page 180
Paul Nachtigall, Ph.D., University of Hawaii Loud anthropogenic sounds have been associated with whale strandings. Loud impulsive sounds may contribute to behavioral disruption and hearing deficits.” Conference abstract, page 113  {This preliminary study showed that some cetaceans may be able to mute the effects of noise when given a warning noise.}
Doug Nowacek, Ph.D., Duke University “The critical elements of a robust mitigation and monitoring plan for responsibly conducting marine seismic surveys include obtaining baseline ecological data; substantial advance planning, communication, and critical review; integrated acoustic and visual monitoring during operations; and systematic analysis of results to inform future planning and mitigation.” Abstract
Aaron Thode, Ph.D., Scripps Institution of Oceanography  “Call localization rates (CLRs) were compared before, during, and after periods of airgun use between sites near seismic activities (median distance 41-45km) and sites relatively distant from seismic activities (median distance >104km). At the onset of airgun use, CLRs dropped significantly at sites near the airguns, where median received levels from airgun pulses (SPL) were 116-129 dB re 1 Pa (10-450 Hz). Abstract   {This study was done on bowhead whales.}

The bulleted points below were taken from the Peer Review document – they are not in order since the remarks were not identified by reviewer (but are by one of the individuals above, or by a NOAA representative, so are somewhat anonymous).
These remarks were selected to represent the issue that seems to be most important for the public to comment upon, the 24 hour recovery period. (cSEL is ‘cumulative Sound Exposure Level’). NOAA repeatedly requested that this issue be addressed during the comment period.

  • I feel the report has so many caveats on this subject as to render this definition worthless:
    “The 24-h baseline accumulation period is generally considered a conservative baseline for accumulation time under most situations. However, flexibility may be required. For example, if specific information on residence time of individuals, likely swim speeds for transient species, more specific details on the sound-producing activity (e.g., specific times when activity temporarily ceases),”
  • Just about every oil and gas industry survey is going to try to reduce this period of time to the time it takes for a migrating animal to swim past a spatially compact activity.
  • I think a sentence should be added that if the primary behavior of marine mammals in the area is migration, the cSEL duration can be restricted to three hours. Areas that cover feeding and mating should remain at 24 hours. This is much simpler than requiring an applicant to estimate swimming speed, swimming depth, whether animals is assumed to deviate or avoid course, etc. Restricting duration to 3 hours also makes the behavioral and TTS criteria more consistent.
  • → Response: NOAA appreciates your input on this particular topic and anticipate there will be additional comments provided during the public comment period. The proposed 24-h accumulation period may not be appropriate for certain sound sources or species. We are planning to call particular attention to this topic during the public comment period.
  • Additionally, your comments seem to focus strictly on seismic activities. However, the proposed accumulation period is for all PTS onset acoustic threshold levels for various sources (e.g., sonar, pile driving, drilling, etc.). Thus, there are multiple considerations needed based on whether a source is stationary or mobile and based on the species and specific context of exposure.
  • Proposed solution: Provide specific guidelines whether cSEL covers only proposed activities or whether it covers all independent activities (including shipping) during that time. State whether NOAA will reduce the cSEL threshold if multiple permits working in the same area are received.
  • Another issue with defining cSEL duration to be 24 hours is what to do when multiple uncoordinated activities are present. For example, multiple seismic surveys? Shipping vessel transits? NOAA should also state intentions what it plans to do if multiple organizations submit requests to operate in the same region, with each showing individual cSELs below TTS, but cumulative cSEL from all operations exceed TTS.
  • Response: Currently, the PTS onset acoustic threshold levels are being proposed for discrete activities and not multiple activities occurring in a single area. This will be clarified in the text (footnote #15).


Input from those attending the public meeting:
JESSICA LEFEVRE [Jessica S. Lefevre is an attorney in private practice specializing in natural resource issues, including the mitigation of local impacts resulting from resource development. She has served ascounsel to the Alaska Eskimo Whaling Commission since 1985]:

I think we might encourage you to do that, if it is possible, and we also will  put in a request for an extension. This is pretty important and a lot of information to get on top of. Those are procedural questions. My substantive question is: Could you talk a little bit how the cumulative SEL can be used to account for multiple, repeated exposures, where you’ve got an animal going past one site and then moving along encountering a second site? It just we have not had a lot of time to spend with this and that is one of the questions we’re trying to wrap our heads around. Thanks.
[MODERATOR]: I think terms of the nature of that comment, what I would suggest is that you provide information that you think it is not clear how we are proceeding in accumulating sound from multiple exposures, and we will make sure we clarify that in the final document. Thank you.

SCOTT SLAUGHTER: I am Scott Slaughter, and I am commenting today on behalf of The Center for Regulatory Effectiveness  [“CRE was formed by former career officials of the White House Office of Management and Budget. The head of the firm is Jim Tozzi.It has been criticised as a front organisation for industries which seek to undermine the regulatory process, notably by Chris C. Mooney in his book The Republican War on Science.[1]  Wikipedia].

…Given this absence of harm in the real world, the government should carefully consider the benefits and costs of regulating oil and gas  seismic. In particular, the government should consider the requirements of Executive Orders 12866 and 13563 when regulating oil and gas seismic. Under Executive Order 12866, the Guidance should go to OMB to review standards that require a benefit-cost analysis be performed. Suggest that the government solicit public input performing cost-benefit analysis. We thank you for the opportunity to present these comments, and we look forward to the government’s response.

ROGER GENTRY: I’m Roger Gentry..G-E-N-T-R-Y. I’m with ProScience Consulting and the Joint Industry Program. [“The JIP is a cooperative effort, established in 1991, by a number of petroleum and chemical companies to consolidate independent construction cost surveys soliciting similar information from contractors”.]

I’m going to read my statement.
My written comments covers three pages, but I’ll just here discuss the guidelines for low-frequency cetaceans. The frequency weighting function shown in Figure 2 [page 16 of NOAA’s draft acoustic Guidance ] are basically invented because there are no empirical data to support them.
It is probably invalid to use mid-frequency cetacean equal loudness contours to set points “a” and “b” on that graph. The overall effect of this weighting function is much more  aggressive than the approach presently in place, especially in the Arctic guidelines. It implies that low-frequency cetaceans are much more sensitive to acoustic exposure than is formally believed, and it does so with supporting data.
This leads me to ask “what problem is NOAA trying to solve by this aggressive  approach?” Is there any evidence at all that the present guidelines leave whales with hearing loss from shipping, low-frequency active sonar, seismic arrays, and others? Have whale populations declined in areas where these sources are used? Unless there is evidence of either effect, then it is best to discard this graph and continue to use the present guidelines until empirical data become available on hearing in low-frequency cetaceans.
Several funding groups are interested in obtaining these data, and current development suggests they will be available in five to six years when the next version of these guidelines should appear. NOAA wisely declined to set guidelines for behavioral effects due to poor data and should make an equally wise decision to not to set guidelines for low-frequency cetaceans in total absence of data. Thank you.

DAVID ZEDDIES: Hi. David Zeddies. Last name Z-E-D-D-I-E-S. I’m at JASCO Applied Sciences. [JASCO Research is an international company with over 25 years experience providing consulting services to the Marine Industrial, Oceanographic, Oil & Gas, Fisheries, Defense and IT sectors.] 

I want to make a quick technical comment on the 24-hour integration period, and it starts with..we have a pretty good idea why you want to do that. There are natural breaks in the operations or you want to give some sort of method for allowing recovery to occur, but 24 hours is an arbitrary number that is really not based in any type of biology that I am aware of. There is some scant studies on that, but basically thereare better ways of doing it. Agent-based models we have will give you a natural indication of how long the animals..you expect the animals to be in that area. So instead of setting a guideline that strictly writes down the number ..in a 24-hour period, you could ask people to estimate the time the animals would be in that area, and there are also better ways of allowing for recovery periods. That would be as part of the cumulative SEL measurement. You could integrate..you could use a function that would allow for some recovery period.

ROBERT SUYDAM  [Senior Wildlife Biologist, Department of Wildlife Management, North Slope Borough] :

Thank you. My name is Robert Suydam. My last name is spelled S-U-Y-D-A- M. First, I would like to kinda re-emphasize what Dr. Ketten and Dr. Gentry mentioned about a section on needed research I think would be helpful in the document and then a couple of other points. One that Jessica LeFevre mentioned, the cumulative impacts issue of multiple operations that I know that frequently in the past NOAA has not ..dealt with each operation separately and not really addressed cumulative impacts from multiple operations on individual animals. So adopting new guidance criteria, I think needs to figure out how to address that issue of multiple operations that are occurring in one location. So, I think additional guidance is needed there. I would also like to comment on the guy from JASCO, sorry I didn’t catch his name that the 24 hour integration period for cumulative SEL seems a bit arbitrary and some additional support is needed for..in the document for why the 24 hour integration period is the appropriate one and not either a greater period or shorter period. So that would be helpful.
Another issue that really wasn’t addressed in the Guidance is the issue of impulsive sound versus non- impulsive sound. Of course with seismic sound, they are impulsive when they are close, when an animal is close to the seismic source, but they become more non-impulsive the farther you are away from an airgun. Of course, the loudness of the sounds changes, as well, but maybe trying to figure out if having  this dichotomy of impulsive vs. non-impulsive is really the best way to go or whether there needs to be some other category in between there? And then, I guess a question that I had: I understand that the  Guidance is really about assessing what the effects are on the marine mammals prior to the operations that I am at a loss to figure out at least how cumulative SEL is going to be actually monitored for what animals are actually taken. So I think the Guidance, the new Guidance would really benefit by having a section on how monitoring would occur to actually figure out if the projections of exposures to marine mammals are realistic.
[MODERATOR]: Thank you very much. I would just like to reiterate that any input that anyone may have on the accumulation duration, we would much appreciate that. Thank you.


NOAA’s New Noise Guidelines for Marine Mammals – What You Need to Know

In order to make comments on this draft during the next 30 days, you can view the document here (note: there is a list of acronyms on page VII, and a glossary of terms on page 61 – both very helpful!) then place your comment here (which is document  NOAA-NMFS-2013-0177). You have until January 26th, 2013.
Please remember, NOAA will only take seriously comments that address the specific document, which in this case is the science behind the numbers but is also the lack of a broader scope.  NOAA promises to release the peer reviewer reports and NOAA’s response to those reports, but they are not up at the present time.
article-2449077-18956B9700000578-858_634x430 pilots in spain
By the title “Draft Guidance for Assessing the Effects of Anthropogenic Sound on Marine Mammals“, you might think that NOAA is establishing guidelines for assessing the effects of anthropogenic (manmade) sound on marine mammals.  Guess again.
The promise:

 This guidance is intended to be used by NOAA analysts and managers and other relevant user groups and stakeholders, including other federal agencies, when seeking to determine whether and how  their activities are expected to result in particular types of impacts to marine mammals via  acoustic exposure.

What they deliver:

This document outlines NOAA’s updated acoustic threshold levels and  describes in detail how the thresholds were developed and how they will be revised and updated in the future.

Not included:

NOAA currently is in the process of developing  new thresholds for onset of behavioral effects. When that process is completed, TTS [Temporary Threshold Shift, which are temporary hearing losses] will be  addressed for purposes of take quantification. In the meantime, the TTS thresholds presented represent the best available science and will be used in the comprehensive effects analyses under the MMPA [Marine Mammal Protection Act} and the ESA [Endangered Species Act] and may inform the development of mitigation and monitoring.

In other words,the draft does not cover behavior in any new way, and disregards any science that correlates certain types of sound with strandings and deaths, nor does it address the compounding effect of so many sources of noise invading the marine environment for lengthy time periods.
It is a myopic look through the lens of hard science on how sound effects different species of marine mammals, and although it is based on solid science the data points are few, and NOAA set clear guidelines for updating as new research is published.
Having so little data available, NOAA basically relies heavily on Marine Mammal Noise Exposure Criteria:  Initial Scientific Recommendations in setting the guidelines for PTS (Permanent Threshold Shift, which is permanent hearing loss):

Thus, NOAA accepts the recommendation made by Southall et al. (2007) as guidance for determining PTS onset for impulsive signals for all cetacean [dolphin, porpoise, whale] and underwater pinniped [seals, sea lions, walruses) species, resulting in an approximate 15 dB difference between TTS [temportary] and PTS [permanent] onset.

That study was published in the journal Aquatic Mammals, which is “Supported through Joint Sponsorship by the European Association for Aquatic Mammals, the Alliance of Marine Mammal Parks and Aquariums,
and the International Marine Animal Trainer’s Association.”
From a technical standpoint  NOAA’ draft is a huge step forward in delineating more species-specific guidelines, yet there are no teeth in the document to force compliance with the new standards.

 NOAA recommends that Federal agencies and prospective  applicants evaluating these types of impacts for the purposes of engaging in the aforementioned statutory processes also use these thresholds in the manner described here. However, this guidance does not create or confer any rights for or on any person, or operate to bind the public. An alternative approach may be proposed (by Federal agencies or prospective applicants) and used if case-specific information/data indicate that the alternative approach is likely to produce a more accurate estimate of Level A Harassment, harm, or auditory injury for the project being evaluated and if NOAA determines the approach satisfies the requirements of the applicable statutes and regulations.
The National Research Council (NRC 2004) provided basic guidelines on National Standard  (NS2) under the Magnuson-Stevens Fishery Conservation and Management Act, section 301, which stated “Conservation and management measures shall be based upon the best scientific information available.” They recommended that data underlying the decision-making and/or  policy-setting process be: 1) relevant, 2) inclusive, 3) objective, 4) transparent and open, 5) timely, 6) verified and validated, and 7) peer reviewed.

Of the ten candidates for peer review, NOAA selected four, all specialists in the ability of marine mammals to hear. None of the behavior experts were included, and no one addressed the effect of sound on the animals outside of the hearing structures themselves – so tissue damage resulting directly from noise, or from rapid decompression during escape from sound sources are included.

The following website contains updated information on the peer review process including: the  charge to peer reviewers, peer reviewers’ names, peer reviewers’ individual reports, and NOAA’s response to peer reviewer reports http://www.nmfs.noaa.gov/pr/acoustics/guidelines.htm.

Below are some samples from the document – which, while long, is logically laid out and easy to navigate (but very science dense).

NOAA has compiled, interpreted and synthesized the best available science to produce new thresholds for the onset of both temporary and permanent hearing threshold shift (“TTS” and  “PTS”, respectively) in marine mammals from underwater sound. In the regulatory context, NOAA uses this information to help quantify “take” and to conduct more comprehensive effects analyses under several statutes.
For applicants/users that have the ability to model moving animals and/or  sources and the accumulating sound at each receiver, NOAA proposes that 24-hours or the length of activity, whichever is less, be used as the accumulation time. 24 hours has been used in other noise assessment planning applications (e.g., community noise planning for aircraft, vehicular traffic, and railway noise) and provides a reasonable outer bound in situations where the model will be able reflect realistic changes in relative distance between the source and likely exposed marine mammals over the course of a day.
However, for models that do not incorporate animal movement, it is not appropriate to make the assumption that animals will remain at a constant distance from the source accumulating acoustic energy for 24 hours. Additionally, if sound accumulation cannot be modeled, an alternative method must be used. For situations where modelling of movement and sound accumulation are not possible, an alternate method that is intended to address the accumulation of sound energy over time, but instead provides a distance from the source (“SEL threshold distance”) that is  simpler to apply in exposure modeling (i.e., would be used in calculations in the same way distance is used to calculate exposures above previous NOAA sound pressure level thresholds) should be used. Based on what we know about typical animal movement and avoidance, we propose a 1-hour accumulation period be used to calculate the “SEL threshold distance”. This “SEL threshold distance” is calculated by determining the distance from the source at which an animal would have to remain for 1 hour in order to accumulate sound to the designated threshold.  While, animals may move closer and farther from the source, this distance is considered a reasonable and conservative approximation.
The 24-hour (for models able to account for movement and sound accumulation) and 1-hour (for models not able to account for movement and sound accumulation) accumulation periods are considered a conservative baseline for accumulation time under most situations. The use ofmodels able to account for movement and sound accumulation may also allow for the inclusion of additional details to provide a more realistic results based on the accumulation of sound (e.g. information on residence time of individuals, swim speeds for transient species, or specific times when activity temporarily ceases). Alternatively, there may be case-specific circumstances where the 1-hour accumulation time should be modified to account for situations where animals are expected to be in closer proximity to the source over a notably longer amount of time, based on activity, site, and species-specific information (e.g., where there is a resident population in a small and/or confined area and a long-duration activity with a large sound source, or a continuous stationery activity nearby a pinniped pupping beach).
NOAA’s previous acoustic threshold levels are expressed as root-mean-square (dBrms), which  uses a different metric from peak sound pressure levels (dBpeak) and SELcum that are being recommended for our TTS and PTS onset acoustic threshold levels. Thus, we recommend caution when comparing past acoustic threshold levels to the acoustic threshold levels presented in this document as because they are based on different metrics, they are not directly comparable. For example, a 180 dBrms level is not equal to a 180 dBpeak level. Furthermore, theSELcum metric incorporates time and is an energy level with a different reference value (re: 1μPa2-13 s), thus it is not directly comparable to other metrics that describe sound pressure levels (re: 1 14 μPa).


NOAA is Changing its Guidelines on Permissible Sound Levels and Marine Mammals – You Are Important!


Navy sound levels measured in Hawaii.

This may be one of the most important issues you participate in for marine mammals and ocean life in 2014.  The outcome of NOAA’s guidelines will affect how much noise marine animals will have to face at the hands of industry and the military – without strong guidelines species we have yet to fully understand may be driven from their habitats, or worse, may suffer irreversible declines in population levels.
Naval sonar and oil exploration seismic surveys are known to cause the death and stranding of hundreds to thousands of marine mammals worldwide every year. (More information can be found here and here).
risso's dolphin strand philippines
The guideline “provides noise exposure levels for onset of permanent threshold shift (PTS) and temporary threshold shifts (TTS) for all sound sources and behavioral response zones for seismic surveys (e.g., primary sound source is airguns). It is intended to be used by NOAA analysts/managers and other relevant user groups/stakeholders, including other federal agencies to better predict a marine mammal’s response to sound exposure in a manner that has the potential to trigger certain requirements under one or more of NOAA’s statutes (e.g., MMPA, ESA, and National Marine Sanctuaries Act).” (NOAA)
Please mark these dates on your calendar if you wish to express your concerns to NOAA. December 27th is the first day of the comment period, which will extend for 30 days. A public meeting will be held in Silver Spring, Maryland on January 14th, also available through a webinar for those of us who can’t attend.

We are pleased to announce that a 30-day public comment period for this document will begin on December 27, 2013. In conjunction with this public comment period, we will host a public meeting on January 14, 2014 in Silver Spring, Maryland. For those unable to attend in person, webinar access will be provided. Please consult the following web site for more detailed information and updates after the New Year: http://www.nmfs.noaa.gov/pr/acoustics/guidelines.htm
On December 27th electronic copies of the document can be found at the Federal eRulemaking Portal http://www.regulations.gov and via http://www.nmfs.noaa.gov/pr/acoustics/guidelines.htm. Comments may be submitted via the Federal eRulemaking Portal (http://www.regulations.gov, search for NOAA-NMFS-2013-0177).

NOAA’s Guidelines for Assessing Impacts of Anthropogenic Sound on Marine Mammals
The National Oceanic and Atmospheric Administration (NOAA) is developing acoustic guidelines for assessing the effects of anthropogenic sound on marine mammal species under our jurisdiction.
The document provides guidance for assessing the effects of anthropogenic sound on marine mammal species under NOAA’s jurisdiction. Specifically, it provides noise exposure levels for onset of permanent threshold shift (PTS) and temporary threshold shifts (TTS) for all sound sources and behavioral response zones for seismic surveys (e.g., primary sound source is airguns). It is intended to be used by NOAA analysts/managers and other relevant user groups/stakeholders, including other federal agencies to better predict a marine mammal’s response to sound exposure in a manner that has the potential to trigger certain requirements under one or more of NOAA’s statutes (e.g., MMPA, ESA, and National Marine Sanctuaries Act).
To develop these noise exposure levels, NOAA evaluated currently available information on the effects of anthropogenic sound on marine mammals, as well as developed a method for updating these levels through a systematic, transparent process. This document is intended to outline noise exposure levels, how they were developed, and how they will be reviewed and assessed as additional science becomes available.
Where are we in the Process?
The process to finalize the guidelines includes the following steps:
NOAA internal review
External peer review
Public comment
Finalize and release guidelines
NOAA’s draft Acoustic Guidelines has undergone an internal review within NOAA on the scientific/technical aspects of the document. NOAA is still working through issues relating to the implementation of the science under our various statutes.
The external peer review, which began in July 2013, focuses on the scientific and technical studies that have been applied. The reviewers will not focus on the implementation aspects of the document (e.g., the amount of uncertainty that is acceptable, the amount of precaution that should be embedded in the analysis).
After peer review, NOAA will seek public comment on the scientific and implementation aspects of the document. Once the peer review and public comments are addressed, NOAA will finalize and release the acoustic guidelines.

Marine Mammal Observer Jobs Available in Alaska

As I hear about jobs and promising internships I’ll try to pass them along.
Being a marine mammal observer on a fishing boat requires the ability to witness the incidental death and injury of marine mammals of all types  – from otters to whales – in the nets of commercial fisheries.
If you have the constitution to handle it though, you would be providing a service that ultimately reduces the mortality of marine mammals because your presence will help to control the loss.

Posted January 2012
Alaska Marine Mammal Observer Positions (AMMOP)

Saltwater Inc is currently recruiting applicants for the marine mammal

observer program in Southeast Alaska.

The National Marine Fisheries Service (NMFS) is mandated by the Marine

Mammal Protection Act to monitor the level and nature of interactions
between commercial fisheries and marine mammal stocks. Monitoring will begin
for the Southeast Alaska salmon drift gillnet fishery in Alaska Department
of Fish and Game management districts 6 and 8 during 2012 and 2013.
Saltwater Inc was awarded the contract to implement the program together
with NMFS.
The Alaska marine mammal observer program (AMMOP) is focused on providing

statistically reliable information to measure and report on injury and
mortality of marine mammals. AMMOP will rely on marine mammal observers to
collect this information and support scientific studies. While on assignment
observers will collect and record data relating to commercial fishing
operations, gear types, and marine mammal and seabird interactions.
Observers will estimate quantity and species harvested, in addition to
conduct standardized surveys, observations, and sample collection for marine
mammals and seabirds.

We are currently seeking experience observers with a background in marine

mammal or fisheries observer research. Ideal candidates will be proven
self-starters, have excellent communications skills, and the ability to work
independently while following direction from a supervisor.
Observers must meet the following requirements:

* Prior fisheries or marine mammal observer experience with successful

* At least 90 days prior at-sea observer experience
* Bachelor’s degree or higher in the natural sciences with a minimum of 30
semester hours or equivalent in biological sciences, and at least one
undergraduate course in math or statistics
* Experience in systematic observations and making clear, concise scientific
* Possess excellent inter-personal skills, and demonstrate responsibility,
maturity, and self-motivation
* Able to live in close quarters with others for extended periods in a
professional setting
* Have physical ability to carry out the duties of an observer, and work at
sea for extended periods without medical restrictions
* Have current first aid and CPR certifications
* Experience in outdoor living skills and etiquette
* United States citizen or non-citizen legally residing in the U.S. for at
least 3 years and have legal Immigration and Naturalization Service (INS)
visa status
Observer logistics

Observers will conduct field observations for each day the commercial

fishery is open. Observations may occur during the nighttime hours.
Commercial periods typically run for 3 to 4 days weekly. An additional day
of work will be required weekly for data debriefing in the office. Observers
will be paid for each day worked. The daily pay rate for observation is $256
and $176 for debriefing.
Observers will be primarily based in the towns of Petersburg and Wrangell,

Alaska. Observers will travel to the fishing grounds and work from
independent work boats operated by experienced, licensed boat operators.
During commercial fishing periods observers may stage for two to three
nights weekly in remote locations, with accommodations including shared
bunkhouses or floating cabins. All housing and meals will be provided while
on duty.
All observers must successfully complete a two week training prior to

deployment. Training will begin May 29 in Anchorage, Alaska. A
transportation stipend will be provided for travel to Anchorage, and travel
to the duty location in Southeast Alaska will be covered. Housing and meal
reimbursement will be provided during training. Training will end on June 8.
Employment will begin immediately following on approximately June 10, and
will run through mid to late September depending on the duration of the
drift gillnet fishery.
How to apply

For additional information about the program and to submit an application

please visit our website:  <http://www.saltwaterinc.com>. Applications
will be accepted through February 3, 2012.
Stacey Buckelew

Saltwater Inc.
733 N Street
Anchorage, AK 99501

(907) 276-3241