CARE

Camano Action for a Rural Environment

March 11, 2009

To:       Mrs. Kimberly Kler – NWTRC EIS/OEIS

            Naval Facilities Engineering Command Northwest

1101 Tautog Circle, Suite 203

Silverdale, WA 98315

From:   Camano Action for a Rural Environment

RE:       Northwest Training Range Complex Draft Environmental Impact Statement

Camano Action for a Rural Environment herein submits its comments to the US Navy on the proposed Northwest Training Range Complex EIS. We appreciate the extension provided for the comment period.

Camano Action for a Rural Environment is a broad-based citizen group serving Camano Island.  We provide a voice for citizens of Camano regarding proposed land use actions, and provide education to Camano citizens regarding water quality, wildlife protection, and sustainable living.  Camano Island citizens are very involved through Beach Watchers, Shore Stewards, Backyard Wildlife Stewards, and Friends of Camano Island Parks, in protecting and stewarding Camano Island’s natural resources. Camano citizens are involved in or have participated in shoreline surveys, non-point pollution planning, salmonid habitat planning, trail maintenance and construction, the Snow Goose birding festival, and have an active Watershed Resource Advisory Committee. C.A.R.E. for its part monitors and comments on land use proposals that may affect this Island we all care deeply about.

Because of the involvement of Camano’s citizenry in shoreline surveys and Beach Watcher programs we are deeply aware of the use of the waters between Camano and Whidbey and along Camano’s shorelines by marine mammals such as the grey whales which feed on the shallow sands in our bays, and endangered species such Chinook salmon juveniles which rear in the eelgrass beds along the shoreline. The potential to deleteriously affect gray whales, a listed state sensitive species, which feed on Camano beaches is a serious effect whose ramifications are not explored in any meaningful way in the EIS.

The relatively pristine waters along Whidbey and Camano’s coastline harbor a vast web of marine wildlife and birds, from Great Blue Heron to bald eagles, and a large number of pelagic birds, waterfowl, and shorebird species. In addition to its importance to the web of life intrinsically connected to Federally listed salmonid species, the natural bounty of this area is also connected to the economic prosperity and quality of life of its residents. This a world class birding area, and its wildlife and marine species populations bring a source of revenue to the communities of Stanwood, Camano Island, and Whidbey Island, including fisheries, shellfish production, and tourism dollars.  Camano citizens crab in these waters, kayak, boat, swim, and enjoy the tranquility and inevitable interactions we have with marine wildlife along the coastline, whether it be nesting bald eagles, the smelt and sand lance spawning, or watching kingfishers at work along the shore. The waters between Whidbey and Camano are linked by tides and tidal flow and the free movement of species and migration of species. The notion that these waters should be turned into training grounds for use of explosive devices that may leave exploded fragments , inert ordinance, chemicals and other debris listed in the EIS (Section 4.2.6), as well as sonar that may injure marine mammals utilizing these waters, is an affront not only to the our environment and these marine wildlife species, but to our sense of place and security as members of this community.  This latter effect of the proposed action has no mitigation for it. 

The detonation of explosive devices and sonar will have effects on species that utilize Camano waters. The Navy admits that it will injure marine mammals by producing an EIS asking for incidental take of marine mammals based on the sound effects of its proposed actions. Given the decline of Orca whales in recent years, and the known problems for Orca whales of chemical contamination in their cellular tissues, adding “take” in the form of disorientation of the animals such that it could impede their breeding or rearing of young, we feel does not meet the standard of “incidental take” of individual animals but rather could more deleteriously affect the species as a whole.  The “No Action Alternative” is the only acceptable Alternative.

We do not feel that the EIS sufficiently documents a lack of effect on numerous other marine species by the proposed action. Due to the decline in numerous marine species, including Orca whale, Chinook salmon and steelhead, several listed state sensitive species of rockfish, as well as the marbled murrelet; and lack of information available to assess the impacts of the Navy’s proposed expansion upon those species, especially with proposed testing of new systems and inadequate marine mammal monitoring, the “No action Alternative” is the preferred option.

The avoidance mitigation proposed in the EIS is inadequate. Prior to expanding training activities, the Navy needs to fund independent research on seasonal presence of marine fish, birds and mammals found within their training ranges rather than rely on outdated surveys.

The EIS does not demonstrate a means to respond to environmental consequences of a maritime incident in all of the operating areas, including interactions between Navy ships and commercial vessels. These are relatively intensely used waters by the general public and using them for a military training ground seems a completely incompatible use.

According to the Orca network, which has been involved in observing and researching several species of cetaceans for 28 years, the difficulty of recognizing marine mammals at sea by sight or sound is highly problematic even for experienced personnel. The mitigation measures detailed in the EIS are insufficient to reliably identify the presence of cetaceans to meet the standard of avoidance in mitigation sequencing. The “whale protection” wheel device for use by monitoring personnel is woefully inadequate for use in normal sea-state conditions.  Mitigation measures should include training of monitoring personnel by experienced whale biologists to improve recognition of marine mammals by visual and acoustic monitoring.  However, it is the opinion of these trained Orca network researchers that even with mitigation measures in place, training vessels would fail to detect marine mammals in most cases, particularly in rough weather. Due to the density of marine mammal use in this area, injuring or killing marine mammals would be routine during these exercises.  Due to the decline in marine mammal species, this would be an unacceptable impact to listed species. The “No Action Alternative” should be selected as the preferred alternative.

Respectfully submitted

Allison Warner

C.A.R.E. President