Download Olympic Park Associates comment letter

Dear Dr. Sullivan,
Subject: NOAA Ocean Noise Strategy Roadmap
Olympic Park Associates (OPA) appreciates this opportunity to comment on the
Draft NOAA Ocean Noise Strategy Roadmap. OPA is a citizen non-profit organization,
begun in 1948, with the mission “To protect the wilderness and ecological integrity
of Olympic National Park".
Because Olympic National Park’s (ONP) boundary extends into the off-shore islands
and because the interactions of the ocean and land affect the biology of both, OPA is
especially concerned about the ecological health of the ocean environment adjacent
to the park. Marbled murrelets and salmon are prime examples of this ecological
interaction requiring the good health of sea, land, water, and air.
OPA is very concerned about the effectiveness of ocean management that will
sustain the natural ecosystems and allow for growth of food resources. The
complexity of ecosystems requires knowledge before making decisions that allow
takings, incidental or otherwise. The complexity of ecosystems, in many instances, is
matched by a complexity of management of ocean systems in the United States and
around the world.
For example, the management of the Washington State coastal area of ONP is
complex but the legislative direction from 1907 forward recognizes the importance
of this area for marine wildlife. It began with theWashington Islands National
Wildlife Refuges which were established by President Theodore Roosevelt in 1907.
The refuges include 125-acre Flattery Rocks, 300-acre Quillayute Needles, and 60acre Copalis, stretching off-shore from Cape Flattery all the way south to Copalis,
Washington.
“Vision Statement for the Washington Islands National Wildlife Refuges: Since
1907, critical resting and breeding grounds for marine wildlife off the outer Olympic
coast have been protected and preserved by the National Wildlife Refuge System. The
more than 600 rocks, reefs, and islands known as Flattery Rocks, Copalis, and
Quillayute Needles National Wildlife Refuges are designated wilderness (except
Destruction Island), and all will continue to be preserved in a natural condition with
minimal human intrusion. Management activities will focus on monitoring Refuge
wildlife and on protection and maintenance of a natural functioning ecosystem. The
U.S. Fish and Wildlife Service will coordinate with other agencies and tribes
to ensure the long-term health and viability of native seabird and marine wildlife
populations…
“The Service’s goals for the Washington Islands NWRs are to minimize or eliminate
disturbance to wildlife. Island trespassing from boats is rare. Disturbance is a larger
issue from the air, with helicopters and other aircraft flying low over seabirds and
marine mammal areas. Biologists, NPS staff, and conservation groups have all
brought attention to the incidences of overflight disturbances to wildlife on refuge
islands. Overflight disturbances disrupt seabird and marine mammal breeding and
resting activities. Currently, there is a Federal Aviation Administration (FAA)
advisory and Sanctuary regulation that requires a 2,000-foot (610 m) minimum
flight altitude for aircraft flying over the islands. However, this regulation is difficult
to enforce due to the remote nature of the region and is often violated. For the CCP
[Comprehensive Conservation Plan], this issue will overlap with interagency
cooperation, as work with NOAA and the FAA will be needed to address this
concern.”[Comprehensive Conservation Plan and Environmental
Assessment, Washington Islands National Wildlife Refuges, 6-14-2007]
Together these refuges provide nesting habitat for over 70% of Washington’s
seabirds. They are important haul-out and breeding grounds for a variety of marine
mammals and the ecosystem that supports them all.
The Washington Island Wilderness was created in 1970, very soon after the passage
of the Wilderness Act of 1964. This wilderness is mandated by Congress to be offlimits to most boats and low-flying aircraft in order to protect the sea life that uses
these islands and the sea surrounding them.
The Olympic Coast National Marine Sanctuary was established in 1994 because this
marine environment was considered to be of special national significance. It
is managed by NOAA with its mission:
“SCIENCE, SERVICE, AND STEWARDSHIP To understand and predict changes in
climate, weather, oceans, and coasts;
To share that knowledge and information with
others; and To conserve and manage coastal and marine ecosystems and resources”
It is OPA’s contention that not all noise in the ocean comes from activities under or
on the water. Many marine creatures must surface, if only to breathe. Is noise in the
air transmitted into the ocean? Will noise above the surface affect animals beneath
the surface? OPA asks that airplane noise also be included in the research. Research
should include: low flight, answering the question what is low flight?; aircraft
landings on water, etc. These activities should also be included in NOAA’s activity
list requiring permits.
OPA argues that ocean noise is an increasing contributor to the problem of
maintaining a healthy marine environment. Along with other assaults on the marine
environment, it is one more reason to spend more time and money doing scientific
studies of this environment and the various intrusions into it. We are also troubled
about the fragmentation of projects that studied and judged on their own could
overwhelm the environment when taken as a whole.
OPA’s equal concern is: with the legislative protection and the missions of the
various agencies involved, is the wildlife, marine mammals, and their ecosystem
being protected sufficiently to prevent the reduction in number of species and their
populations? The whole ecosystem must be studied and understood. The loss of the
smallest organisms can result in the death of sea mammals. i.e. krill reduction effects
whale health. There may be many more such relationships we don’t yet understand.
Ocean resources are as important to us and future generations as our freedom and
the freedom of our grandchildren. A reduction of resources will cause conflict and
strife as human population grows. Food resources must grow. Reduction to just
above extinction or even remaining the same will not serve our future.
It is the responsibility of all who use the ocean to use it in a sustainable manner.
Sustainability requires maintenance and recovery of species. No user organization
can absolve itself of this responsibility. To determine sustainability requires
research, coordination of projects and overseers.
Is the knowledge of marine ecosystems sufficient to allow “taking” that will not
change, to its determent, valuable marine ecosystems? In short, do we know enough
to issue permits to any organization allowing incidental, or otherwise, takings or
changes to the marine environment used by these animals and birds?
Because of the overlapping management responsibilities, particularly on the
Washington State coast, OPA is concerned that despite the mission statements and
various planning documents, are the environmental results matching the goals and
missions?
Olympic Park Associates contends it is imperative that NOAA exercise its mission as
stated on its website.
“NOAA Fisheries is responsible for the stewardship of the nation's ocean resources
and their habitat. We provide vital services for the nation: productive and
sustainable fisheries, safe sources of seafood, the recovery and conservation of
protected resources, and healthy ecosystems—all backed by sound science and an
ecosystem-based approach to management.”
To do this, OPA implores NOAA to use its scientific mandate and resources to
develop the data needed to achieve its mission.
Sincerely,
Donna Osseward, President,
Olympic Park Associates
13245 40th Ave NE
Seattle, WA 98125