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Old 05-02-2006, 04:13 PM   #7
brian eiland
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Join Date: Jul 2004
Location: Washington DC, Annapolis MD, Thailand
Posts: 646
Testing, Varification, Deployment

The Navy has stated in testimony before a Congressional subcommittee that it has passive listening systems that can detect quiet submarines in littoral waters where previously they were thought to be undetectable. Evidence concerning the present and future availability of new and advanced passive sonar technologies (such as Advanced Deployable Systems tested off California, Robust Passive Sonar (RPS) and towed arrays equipped with Acoustic Rapid Commercial-off-the-shelf Insertion (ARCI) processing) which have the potential to locate quiet submarines without harm to marine life are not discussed in the FEIS. (See RADM Malcolm I. Fages and RADM J.P. Davis, Statement before the House Armed Services Committee, Military Procurement Subcommittee (June 27, 2000) and Presentation of Dr. Thomas J. Green, Defense Advanced Research Projects Agency (DARPA), to Department of Defense (Sept. 6-8, 2000) noting the potential effectiveness of a "Robust Passive Sonar" system apparently in development at DARPA). Why authorize highly dangerous LFA sonar when safe alternatives exist?

The precautionary principle should be adopted here as well as in the fishery management arena - deployment of LFA sonar should be approved only if the Navy can demonstrate that there will be no significant adverse effects on marine life over broad areas of the ocean at full deployment intensity levels. We do not believe NMFS should approve the Navy's deployment or even additional potentially lethal testing in marine environments until NMFS and the Navy can answer the question "what will likely be the lethal and sublethal effects of LFA sonar at full deployment intensity levels on marine life for which NMFS is the federal steward, including fish as well as marine mammals and other protected species?" Specifically for fish, we need to know

"at what decibel level does LFA sonar no longer cause direct mortality and at what lower decibel level is there no longer any debilitating injury?"
Only then will we know how large an area of ocean and how much marine life could be seriously affected.
Sincerely,
James R. Chambers
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