SAMPLE LETTER - get rid of everything in red before
sending
PUT DATE HERE
Naval Facilities Engineering Command Northwest
Attention: Ms. Kimberly Kler – NWTT EIS/OEIS Project Manager
1101 Tautog Circle, Suite 203
Silverdale, WA 98315-1101
Please first mention whether or not you have commented on any of the previous Navy
proposals of the last year. This is a significant component of our new response to the
NWTT. If you did not comment on previous proposals talk about how you now feel
compelled at this time to comment as it is an opportunity to look at a whole suite of
Navy impacts that should not be divided.
I wish to take this opportunity to comment on the Supplement (December 2014) to
the Navy’s Draft Environmental Impact Statement/ Overseas Environmental Impact
Statement (DEIS), dated January 2014, for its continued training and testing activities
in the Pacific Northwest (NWTT). Please include these comments in the administrative
record.
Effect on wildlife
The proposed increases in this Supplement of marine exercises and additional use of
sonar and explosives will only increase the damage done to marine mammals, sea
turtles, fish and birds. Of particular concern to me is the Supplement and the EIS’s
lack of protections for the Southern Resident Killer Whale's dwindling population.
These animals need a protected home in accord with their endangered status. In
public sessions and in a radio interview the Navy’s public relations personnel have
been heard to say that the (MSO) and TRACKEX marine exercises save gas and allow
personnel to be closer to their homes for these maneuvers. These considerations
should not allow one single injury to this endangered Killer Whale population.
Though this supplement admits increased sonar and explosive testing (TRACKEX) and
finally addresses the MSO maneuvers there is no additional mitigation mentioned.
Nowhere is it outlined whether visual patrols will increase as a result of this new
activity, nor does the Supplement address real concerns over whether or not visual
patrol is adequate at times of night or rough seas. No acoustic monitoring or
avoidance strategies are included. This is a serious omission to a document that
intended to address the inadequate science and mitigation plans of the original draft
and is unacceptable.
Lack of Science
There is little consideration of exclusion zones, geographic alternatives to the southern
Puget Sound and seasonal restrictions of exercises. All of the Alternatives propose
year-round, unrestricted use without regard to seasonal variations in marine mammal
and fish abundance. This is true despite the well-documented seasonal migrations of
numerous endangered species and the identification of biologically important areas.
The Navy should put critical marine habitats off-limits to sonar and explosives testing
and schedule training to avoid times of the year when sensitive species are present in
places like the Olympic Coast National Marine Sanctuary.
Climate Change and Cumulative Impacts
The Supplement document responds to calls to address these two big issues but it is
very unclear that anything more than lip service was expended by deeming Navy
activities to be of little significance.
Public Process
What most concerns me is this. There has been an overwhelming number of proposals
since late in 2013 rolled out to the public in a piecemeal fashion. Five calls for
comments on clearly-linked documents have been spread out in their introduction to
the public over the last year and a half. Ground-based, (Electronic warfare range), airbased (Two growler scoping documents) and sea-based naval activities (these two
NWTT documents) have been dropped onto the region as if they were not linked.
The separate comment periods and the separate documents minimize the larger
picture of impacts on the area. In my opinion this is misleading. Is it even legal in
regards to Federal Law, specifically NEPA?
Please redo this chopped-up public process with a comprehensive Environmental
Impact Statement that includes all of the activities in the region. These huge changes
that affect wildlife, real estate values, allow precedent-setting incursions into the
peace of our national parks, national forest, wilderness, state parks and state lands,
should be discussed as a whole, not split into so many fractured pieces that the
residents of this region cannot know what they are actually facing.
.
Sincerely,
YOUR NAME, ADDRESS HERE.