This week’s environmental review and public input session at Hatfield Marine Science Center on U.S. Navy Testing EIS for weapons testing project off the Washington and Oregon coasts

A number of national and regional environmental protection organizations have sent a letter to the Administrator of NOAA and to the Project Manager of the U.S. Naval Facilities Engineering Command, claiming that a still underway series of public meetings on receiving public input on an Environmental Impact Statement dealing with upcoming weapons testing operations off the Washington and Oregon Coasts, violates federal environmental protection rules that require meaningful public input before those operations can be properly considered, evaluated and a decision made as to how those operations may be properly managed. Those environmental groups contend such options are necessary so that U.S. Navy tests don’t pose a major danger to marine mammals and other marine and on shore wildlife.

Despite frequent statements by U.S. Navy officials and contractors that U.S. Navy weapons testing managers would ensure that their sonar and weapons testing would be conducted in a manner that would minimize their impact on whales, seals, sea lions and fish, when asked about proof that such management techniques would be effective by truly minimizing their effects on aquatic wildlife, the response was “we’d like to tell you that, but a lot of that information is not available other than to say we do everything we can to minimize impacts. Other aspects are classified.” Navy representatives also said “Such testing is required to test technologically advanced detection systems under ‘real live’ conditions or we won’t know if they really work.” Some residents asked why it’s important that they test so close to some of the most biologically rich and, in some cases, environmentally sensitive areas of the U.S. coastline, especially with regard to whale migrations and permanent populations of killer whales, seals and sea lions? Answers that were offered centered around the idea that enemy submarines are getting more and more quiet and harder to detect so that it’s important to test newer, high tech detection systems in areas where those subs might attempt to lie in wait and then attack the U.S.

Several Hatfield Marine Science Center Oceanographic scientists engaged the presenters in detailed dialog about other aspects of the Navy’s sonar and weapons testing programs, but they showed obvious signs that they felt they weren’t getting answers in sufficient detail.

Perhaps anticipating such frustrations, a number of major environmental protection groups boycotted the public meetings altogether. Instead of attending, they sent the following letter to to the head of NOAA and to the Navy’s testing program about their concerns that the Navy’s entire EIS review process is sorely lacking. Here’s their letter.

March 13, 2012
Dr. Jane Lubchenco, Administrator
National Oceanic and Atmospheric Administration
1401 Constitution Avenue, N.W., Room 5128
Washington, DC 20230

Mrs. Kimberly Kler, NWTT Project Manager
Naval Facilities Engineering Command, Northwest
1101 Tautog Circle
Silverdale, WA 98315-1100

Re: Scoping Meetings for the Navy’s Northwest Training and Testing EIS

Dear Dr. Lubchenco and Mrs. Kler:

On behalf of the Natural Resources Defense Council, Center for Biological Diversity, Friends of the Earth, Friends of the San Juans, InterTribal Sinkyone Wilderness Council, Olympic Environmental Council, Orca Network, People For Puget Sound, Puget Soundkeeper Alliance, Seattle Audubon, Washington State Chapter of the Sierra Club, Wild Fish Conservancy, and our millions of members and activists, many thousands of whom reside in Washington, Oregon, and California, we are writing to express our disappointment with the scoping process the Navy has initiated for the Northwest Training and Testing (“NWTT”) Environmental Impact Statement (“EIS”).

Because this process fails to provide an opportunity for meaningful public participation as required by the National Environmental Policy Act (“NEPA”), we have made a deliberate decision to not attend any of the Navy’s scoping meetings or to encourage our members to do so.

The Navy published its Notice of Intent to prepare an EIS for the NWTT Study Area on February 27, 2012. The Notice provided dates and addresses for nine public scoping meetings (none of which are located in Washington or Oregon’s major population centers), a brief description of pre-determined alternatives (none of which identify means of achieving the agencies’ purposes and needs in ways that will result in different environmental impacts), and information on submitting written comments. The Notice specifically noted that no formal oral comments will be allowed at the scoping meetings, yet inexplicably assured the public that all comments provided orally or in writing would receive the same consideration. See 77 Fed. Reg. 11497.

As you know, the scoping process is the best time to identify issues and provide recommendations to agencies on what should be analyzed in the EIS. However, a process developed for activities with controversial impacts, like those at issue here, that does not provide opportunity for the public to testify or speak to a broader audience, or to hear answers to questions raised by others, and that fails to engage major population centers is not designed to help citizens and organization effectively participate in agencies’ environmental reviews.

Additionally, although organizations have repeatedly raised our concerns with both the Navy and NOAA on numerous occasions – calling, for instances, for greater protections for the Olympic Coast National Marine Sanctuary and other biologically important areas – neither agency has taken the steps required by law to adequately protect marine wildlife and the marine environment. Nothing in the scoping notice suggests any change in the Navy’s approach.

Under these circumstances we do not believe these scoping meetings have been designed to help our organizations and members effectively participate in this phase of the NEPA process. We do not believe our mere attendance will contribute to moving either agency to seriously address our concerns.

We would like to meet with you or your staff to discuss our concerns about how this scoping process was developed. We look forward to more substantive opportunities to participate in a manner that fulfills the purposes of NEPA.

Thank you for your consideration.

Sincerely,
Zak Smith
Staff Attorney
Natural Resources Defense Council
310-434-2300
zsmith@nrdc.org

Peter Galvin
Conservation Director
Center for Biological Diversity

Marcie Keever
Oceans & Vessels Project Director
Friends of the Earth

Kyle Loring
Staff Attorney
Friends of the San Juans

Priscilla Hunter
Chairwoman
InterTribal Sinkyone Wilderness Council,

A consortium of ten federally recognized
Northern California Indian Tribes

Darlene Schanfald
Executive Director
Olympic Environmental Council

Howard Garrett
Executive Director
Orca Network

Heather Trim
Director of Policy
People For Puget Sound

Chris Wilke
Executive Director and Soundkeeper
Puget Soundkeeper Alliance

Jerry Joyce
Advisor on Marine Issues
Seattle Audubon

Tristin Brown
Conservation Chair
Washington State Chapter of the Sierra Club

Kurt Beardslee
Executive Director
Wild Fish Conservancy

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