Navy data omissions and data inadequacies regarding the MITT

In response to the well-written May 22, 2015, article by Dennis B. Chan, titled “MITT findings vulnerable to lawsuit,” it is also noteworthy and important to convey the fact that the Navy, in its request to seek a letter of authorization seeking waiver from the National Oceanic and Atmospheric Administration to increase incidental takings of marine mammals, is replete with omissions of historical data to directly support just how likely the over 17,000 hours of active sonar training each year and the over 12,000 underwater explosion events to be performed each year will devastate marine mammal and undersea ecosystems through the Marianas Islands region. This is unacceptable and constitutes one of several reasons why NOAA should deny the Navy’s request for waiver.

Instead, the Navy in its request to NOAA last year, piled on reams of theoretical examples of how this military service branch guesses marine mammals may or may not become injured or killed. There is no scientific data contained in the report to draw conclusions that Navy claims for additional training are reasonable, justifiable, or safe to the undersea environment nor does the Navy provide any information on how they have effectively self-enforced their undersea training iterations in the past to in fact protect or prevent marine mammal harm, injury or death. There is not one example to reference as direct evidence to support Navy claims.

The Navy fails to spell out for the American general public how many kinds and levels of contingency training will be performed throughout the undersea domain and omits any mention of how Mariana Islands residents feel about these undersea training activities that will damage or kill marine mammals, some of which are Endangered Species Act listed. The recent court ruling in Hawaii related to the Hawaii – Southern California Training and Testing Training Study Area, will open up the floodgates to future litigation against the Navy. All these developments signal that our nation’s Navy may not have the appropriate anti-submarine warfare capabilities to successfully detect and track Chinese or Russian subs, which are known to be relatively quieter because they are diesel powered. If our nation had the right kinds of anti-submarine capabilities, why would we need so much active sonar and undersea explosion training and testing to be performed throughout the Pacific?

Rick Perez
Hanover, NH