CAFO Emissions and Ocean Noise Poses Threats
Your Comments are Needed Urgently

Dear Humanitarian:

We are contacting you about two important animal protection issues, as the respective government bodies are giving the public a chance to submit comments on their proposals.  The first proposal, submitted by the Environmental Protection Agency (EPA), aims to remove the requirement that Concentrated Animal Feeding Operations (CAFOs) report their hazardous air emissions.  The second proposal is by the US Navy, which plans to expand its training exercises in an area on the Eastern Seaboard – a move that would expose countless marine animals to ocean noise.  Your immediate action on these issues is much appreciated.

Factory Farms to be Exempt from Reporting Toxic Air Emissions

Though federal law currently requires all industries to report the toxic substances they emit into the air, the EPA has never put restrictions on emission limits; it has only requested that facilities disclose if they discharge toxins in the air beyond certain levels.  It argues that the already weak requirement should be dropped because it is difficult for CAFOs to comply with the monitoring, and since there are no legal restrictions, the government would never take action against an operation anyway.  The proposal is also in response to a number of lawsuits brought by communities actually wanting to strengthen emissions controls.

CAFOs are torturous places for animals.  Confined to cramped quarters, there is no regard given to their most basic needs for space, bedding, fresh air, and wholesome feed without hormones or antibiotics.  It is not a pleasant place for people, either. Studies show numerous negative health impacts on factory farm workers and people living close to these facilities.

Removing the reporting requirement would deny local, state and federal public health and environmental agencies the critical data they need to ensure communities are safe.  Without this information, local public health officials will not be able to identify pollution sources and take immediate action when people develop health problems.

Not only should EPA require toxic emissions to be measured, but steps must also be taken to decrease the polluting impact factory farms have on rural communities in the first place – such as reducing the number of animals kept at these facilities, prohibiting open-air manure lagoons, and banning the aerial spraying of animal waste.

YOU CAN MAKE A DIFFERENCE:

Please tell the EPA that you strongly oppose its proposal to allow large industrial operations to release millions of pounds of toxic substances in the air without having to report them.  Sustainable farming methods that do not harm animals, people or the environment should be encouraged and promoted instead.

Send comments on Docket ID No. EPA-HQ-SFUND-2007-0469 before March 27, 2008 by writing to:

Superfund Docket, Environmental Protection Agency
Code: [2822T]
1200 Pennsylvania Ave., N.W.
Washington, DC 20460
Fax: (202) 566–9744
E-mail: superfund.docket@epa.gov

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Marine Life Threatened by Deadly Navy Action

Marine life on the Eastern Seaboard may be at risk. On the heels of several successful lawsuits challenging the US Navy’s use of mid-frequency active (MFA) sonar because of its harmful effects on marine animals, plans are still underway to formalize and increase training exercises into the massive Atlantic Fleet Active Sonar Training (AFAST) Study Area.

The Navy conducts training exercises out of its myriad installations dotted along the East Coast and Gulf of Mexico; some of these and similar exercises have resulted in mass strandings of marine mammals.  Fortunately, the public is able to provide comments to the Navy on its most recent plans, and now we need you to speak up.  Additional information about the dire situation follows at the end of this alert to assist you in taking action.

WHAT YOU CAN DO:

Please respectfully submit comments on the Draft Environmental Impact Statement for the AFAST Study Area by March 31, 2008.  In addition to the information provided on the following page, here are some suggestions about what to include in your comment letter:

- As a resident of an area adjacent to the AFAST Study Area, you enjoy its marine environment and have an obligation and right to speak up for its animals;

- The Navy’s operational requirements should not supersede its marine stewardship obligations;

- Exercises should not be conducted at night or during other periods when visibility is poor;

- Areas where marine animals are known to congregate, such as feeding and breeding areas, should be completely avoided;

- Areas close to the migration path of the endangered North Atlantic right whale should be off-limits to Navy traffic during the migration season;

- The Navy should have at least three trained and dedicated marine mammal observers on all ships equipped with MFA sonar and employ dedicated marine mammal aerial surveillance to look for marine animals an hour before and an hour after an exercise;

- When an animal (including dolphins, who typically bow ride) is observed within 2,000 yards of the sonar dome, the sonar should be shut down until the animal has left the area.

- An after action report for each exercise documenting ship positions and sonar use should be prepared and made publically available at no charge.

Write to:

Naval Facilities Engineering Command, LANTDIV
Attn: Code EV22 (Atlantic Fleet Sonar Project Manager)
6506 Hampton Blvd.
Norfolk, VA 23508-1278
Fax: (888) 875-6781.
www.afasteis.gcsaic.com (visitors may post comments on this site)

Please share our “Dear Humanitarian” letter with family, friends and co-workers, and encourage them to submit comments on these proposals as well.  Again, thank you very much for your assistance.

Sincerely,
Cathy Liss
President

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FACTS ABOUT MARINE ANIMALS, NAVY SONAR AND AFAST

US Atlantic Coast Rich in Marine Life

The Eastern Seaboard is rich in marine animal diversity. There is a rapid change in sea temperature off the East Coast because of the Gulf Stream, so both tropical and temperate species overlap ranges in the region. Dolphin species found in the areas include bottlenose, common, striped, spinner, Risso’s and Atlantic white-sided dolphins. Whale species include pilot, fin, minke, pygmy and dwarf sperm, humpback, sei and sperm whales. This area is also home to beaked whale species and the highly endangered North Atlantic right whale, of whom only 300 individuals remain.

The Navy has Chosen the Alternative that Could Impart the Most Harm

The Navy considered four alternatives when selecting training sites within the Study Area: a) sites that would enable the Navy to fulfill its operational requirements while avoiding areas of biological significance, such as whale feeding areas, year-round; b) sites that would avoid such areas on a seasonal basis; c) sites based solely on areas of biological significance and avoiding those areas completely by training elsewhere; and d) sites based on the Navy’s operational requirements only, and disregarding any biologically sensitive areas.  The Navy chose the fourth, citing operational impedance as the reason for not choosing a more protective and precautionary alternative.

Ocean Noise Impacts to Marine Animals

A growing body of research confirms that human-generated noise – especially the type of MFA sonar to be used at the AFAST Study Area – can disturb, harm and kill marine life. The Scientific Committee of the International Whaling Commission has found that the evidence linking military sonar to whale strandings is “very convincing, and appears overwhelming.” Other bodies acknowledging and addressing the issue include the United Nations, the European Parliament and the World Conservation Union.

Sonar-related strandings have occurred in the Canary Islands, Greece, Bahamas, Madeira, Washington State, Hawaii, North Carolina, and Southern Spain, amongst other locations.  The 2000 Bahamas incident involved 16 whales of three species stranded along 150 miles of shoreline as naval ships used MFA sonar in the area. The Navy has acknowledged that its sonar use resulted in the deaths of the whales.  Similarly, in the report of the Hanalei Bay, Hawaii live-stranding of up to 200 melon headed whales, the DoC said the Navy’s MFA sonar use was a “plausible, if not likely contributing factor” in the event, which resulted in the death of a calf.

Intense ocean noise also can injure and kill fish, with studies showing that commercial catch rates can decrease up to 80 percent when loud sound is in the area.  As the science on the impacts of ocean noise grows, so do the findings relating to its impacts on marine life.  Without comprehensive knowledge of its impacts on all marine life, precaution must prevail.

The Marine Mammal Protection Act prohibits the “taking” of marine mammals without DoC permission.  The Navy disingenuously states that since “most animals” will not be impacted by its preferred action, it will have no significant impact and cause no significant harm to populations of marine mammals, turtles, fish, fish habitat, invertebrates or sea birds.

The Navy admits that its MFA sonar levels, calculated using the Navy’s own questionable numbers, will cause an estimated 120 animals to become deaf – a death sentence since marine mammals use sound for essential life functions.  Further, it expects over 20,000 animals to suffer temporary deafness (which can also lead to death) and tens of thousands to be behaviorally impacted.  The Navy is asking the DoC for permission to kill or injure up to 10 beaked whales – those known to strand most often as a result of MFA sonar use.  It also admits wanting to avoid investigation should a beaked whale be found “dead coincident with Navy activities” because it would “unnecessarily interfere with Navy training exercises.”

Inadequate Precautions

The source level of the Navy’s sonar is 235 decibels – about a billion times more intense than the sonar that caused whales to strand and die in the Bahamas incident.  The Navy says it will use non-dedicated trained observers to look out for animals and passive acoustic monitoring to listen for vocalizing marine mammals.  If an animal is detected within 1,000 yards of the sonar dome, the Navy claims it will turn down the sonar by 6 decibels, at 500 yards by 10 decibels, and that it will shut it down if an animal encroaches undetected within 200 yards of the sonar dome.  The Navy will not shut down at all when dolphins ride the bow wave.  However, whales and dolphins are diving animals, some staying at depth for over an hour.  The chance of seeing beaked whales has been calculated by DoC at a mere 2 percent during good conditions.  Human observers cannot possibly see every animal in the vicinity at all times, and their chances approach zero at night.  Passive acoustic detection can only detect vocalizing animals, which many whales do not do.