Some excellent further reading on the issue if you are still on the fence about sending your thoughts to the Navy:
Bottom line: Navy: Clinging to exceedingly hard line as it embraces stewardship
The Navy seems truly mystified at the uproar being made over sonar training, given the very few incidents over the past decades of mid-frequency active sonar deployment. Many seem to feel that judges who imposed additional safety measures did not really understand the modeling of impacts and scientific minutia used by the Navy and NMFS in designing current safetey measures. There really is a sense within the Navy that this is not a huge problem, thought it clearly deserves attention, and that their famous "29 Measures" are sufficient to minimize future risk. Whether the adoption of these formal standards emerged from within after the Bahamas and later incidents, or was triggered by the outside scrutiny spurred by NRDC and others, there appears to be an authentic desire to do what needs to be done to protect whales. We can assume additional mitigation measures suggested by others, and even those adopted by allies, are truly considered to be excessive and of little practical value in protecting whales from harm.
Even if all this is true, there remain a few areas in which the Navy's approach to the issue leaves much to be desired.
First is the focus on being satisfied with avoiding physical injury, which leads inevitably to discounting behavioral disruption as a cause for concern.
Second is the seeming deaf ear the Navy turns to any suggestion that it put some areas off-limits to sonar training. Look again at the map near the beginning of this report; can it really be true that every square mile of all those ranges off the US east coast contains crucially unique training opportunities, and that putting biologically rich or seasonally important areas off-limits would cripple our training abilities? This attitude cannot help but undermine the public's faith in the Navy to make balanced, prudent decisions on its own.
Third is the vagueness contained in the 29 Protective Measures concerning changes in procedure when the Bahamas-like "contributing factors" are encountered. As noted above, the language here does not inspire confidence that the Navy is taking the threat of injury seriously even in the one very specific set of circumstances that it is convinced is the only situation in which sonar can kill whales. The lack of extended aerial surveys prior to powering up sonar is especially troubling, since beaked whales are so difficult to spot at the surface. Most likely, the Navy simply feels that the likelihood that whales will be present is so low that it does not justify exerting the effort to look for them, or it trusts that in nearly all cases, the whales will hear and avoid the sonar without injury. Even if they are correct in these assumptions, this is a key place where going the extra mile would indicate a level of good faith that is sorely needed to build confidence in their commitment to safe practices.
Related to this is the small size of the US Navy's safety zones, compared to those used by other Navies. As noted above, the 9th Circuit Court of Appeals, in deferring to the lower court's increase of the shut-down zone from 500 yards to 2000 meters, noted that "NATO imposes a 2,000 meter shutdown zone when a marine mammal is detected–the same zone that the district court’s preliminary injunction requires. The Australian Navy goes farther, mandating a shutdown of activities if a marine mammal is detected within 4,000 yards of a sonar-emitting vessel," and further calculated that the 2000 meter zone would only lead to one or two shut-downs per week of training, hardly crippling training preparedness.
Finally, the Navy's reluctance to encourage more investigation—or even acknowledge enduring ambiguity—of stranding events that do not fit the current clear-cut model of sonar-induced stranding is short-sighted, also undermining pubic confidence in its commitment to do its best. While it is difficult to ever really know what caused many—perhaps most—strandings, the Navy seems too eager to brush aside questions about events that don't fit its simple, specific picture. Acknowledging our uncertainty about the ways that animals may react to sonar, and so treating some of the ambiguous events as possibly sonar-induced, would certainly complicate things for the Navy, but it would not tie them to making operational changes based on these uncertain events. It would, however, show that the Navy is authentically considering the full spectrum of possible impacts that its activities may be having, and would allow the Navy to engage more honestly with scientists and environmental advocates as we slowly unravel some of the mysteries and uncertainties that currently limit our understanding.
This last point was starkly highlighted during a June 2008 press event in which the Navy took reporters and several scientists on a sonar training exercise off Virginia. In its briefings, the Navy repeated its well-known mantra: Only five stranding events have been "linked scientifically" with sonar since its inception in 1939....No strandings have been "linked scientifically" to the U.S. Navy since 2000....And, finally, "No scientific evidence exists proving mid-frequency active sonar has ever killed any marine mammals as a direct and sole cause of death." (i.e., they are injured by the changes in their dive patterns, and/or by being tossed about on the beach after stranding, rather than by direct acoustic impact/trauma). Even the scientists that were hand-picked by the Navy to participate in this PR exercise could not abide the stridency of the Navy's message: Nina Young, of the Consortium for Ocean Leadership (a multi-agency coordinating group) said the Navy uses uncertain cause of death rulings to downplay possible links between sonar and mammals. "It's unfortunate that the threshold for the Navy seems so absolute, and the burden of proof so high, that it undermines efforts to engage in a productive discussion," she said, while Andrew Wright, a marine mammal scientist who has worked for the Marine Mammal Commission and NOAA, said definitive proof of sonar's effect on whales didn't exist until recently. "We've only really known about the problem since 2000, 2002. We don't have long-term information, even on humans. There's so much uncertainty around this, and it all depends on where you place the burden of proof."
Remembering the crucial point that routine use of active sonar far exceeds the use of sonar in training situations, the Navy could dramatically advance its own cause by being less adament in all these ways as it conducts its training missions. Of course, that would require a long-term institutional commitment to minimize potential harm; and indeed, there are many within the military with authentic desires to work constructively with scientists, regulators, and other civilians, as well as in balance with Congressional and judicial oversight. So far, however, the decision-making apparatus, appears to remain in the hands of those more commited to maintaining the Pentagon's autonomy in the face of public or judicial opinion.
For more information, see AEI Special Report: Active Sonars - Includes continually updated news items, tracking of range-specific EIS releases, technology descriptions, current deployment, and links to military, agency, and NGO websites. [GO THERE]
You can read the Proposed EIS Plan or go directly to the comment page here.