A proposed increase in the level of U.S. military bombings on Farallon de Medinilla and amphibious vehicle landing exercises on Tinian beaches, among other things, pose “significant impacts” on local resources but many of these effects were absent in a draft environmental impact statement, according to CNMI government biologists and officials.
The U.S. Navy’s draft EIS on the Mariana Islands Training and Testing, or MITT, study area lacks basic information required to assess ecological, socioeconomic and cultural risks, they added.
For example, bombs up to 200 lbs are and will be allowed to be dropped on FDM and such explosives would significantly disrupt soil and reefs.
But the draft EIS “failed to provide this as a potential impact of increased bombing of FDM,” said CNMI Department of Lands and Natural Resources Secretary Arnold I. Palacios, acting Division of Fish and Wildlife director Manuel M. Pangelinan, and DLNR marine and wildlife biologists.
Rather, the EIS focused on the in-water impacts of explosives and potential contamination from ordnance, “which were found to have local and short-term negative impacts,” they said.
FDM is the only area in the CNMI that the U.S. military uses for live fire training since 1976.
An entirely separate proposal seeks to use Tinian and Pagan, also for live-fire training.
“Proposed activities will have significant impacts on ecological, cultural, and socioeconomic resources of the Marianas archipelago and surrounding waters,” DLNR officials said in a Nov. 25 joint comment on a draft EIS for the Mariana Islands Training and Testing area.
The public has only until Dec. 12, Thursday, to comment on the EIS on the MITT area.
Impossible to monitor
Palacios and Pangelinan said social impacts—such as the degradation of landscapes, the effects of limited access to resource users, and the diminishment of cultural value—are impossible to monitor, measure, mitigate, and recover.
This comes a few months after Palacios sent a memo to the governor stating that the U.S. Navy’s proposal to increase restricted areas surrounding FDM can only be an indication of significant increase in bombings “that will destroy the island and its surrounding reefs.”
In the latest comment to the draft EIS on the MITT study area, DLNR said U.S. military activities are presented in “number of activities per year,” not specific durations or seasonality of the activities.
DLNR said the EIS ignores the environmental impacts of increased bombing activities in waters surrounding FDM, specifically within the 3-nautical mile permanent restricted area.
“There is a strong likelihood that aberrant ordnance will adversely affect the surrounding coral reef and associated fauna (fish, sea turtles and marine mammals). The EIS should provide an ordnance-specific probability estimation of land versus sea detonation based on known target success of the specific weapons applied,” the DLNR officials and experts said.
The draft EIS proposes to increase the number of grenades and mortars from 100 to 600.
It proposes to increase the number of large-caliber projectiles from 1,000 to 1,200, as well as the number of bombs up to 2,000 lbs in size from 2,150 to 6,241 bombs.
It also says that an “Mk 84” 2,000-lb bomb can kill or injure wildlife and disturb vegetation across a 60-acre area.
DLNR said there are a few detailed maps showing coral habitat for FDM.
Military-funded surveys were performed on FDM in the past, and data from these surveys should be incorporated in the standard series of maps.
“Overall, the Draft EIS simply ignores some of the most apparent activities that impose risk to surrounding fauna; some examples include the impact of amphibious landings on turtles and corals, and the increasing bombing activity of FDM,” DLNR said.
DLNR also pointed out that the real ecological impact of proposed activities will be observed and described by U.S. Department of Defense observers who have the “potential to underreport or report with bias the impact of activities.”
“The proposal does not provide for independent assessment of the impact of proposed military activities,” they said.
The level of access that non-military personnel have to FDM in the 3-mile exclusion zone is also not well-described, they added.
They added that subsurface activities—including anti-submarine warfare, electronic warfare, sonar use and ordnance detonation, and on or near seamounts—will have significantly larger impacts on populations of marine habitats and animals.
DLNR officials said there is significant risk in military activities having an adverse impact on local sea turtle populations, whereas the draft EIS states a limited impact.
They said the draft EIS “largely ignored important factors that involve the increasing level of ordnance on FDM and amphibious assault on Tinian’s beaches.”
The DLNR comment to the U.S. military says the use of sonar, underwater explosives, and other acoustic devices will have an adverse impact on whales and dolphins in the CNMI.
They said aberrant bombing on FDM would likely increase mortality of species that are closely related to near-shore habitats such as sperm whales, humpback whales, false killer whales, and spinner dolphins.
As far as corals are concerned, the greatest effects will be on FDM and Tinian.
The DLNR officials said the draft EIS is “speculative” regarding impacts on fish from FDM and Tinian when it stated that “most activities will be in deeper waters and therefore will have a low risk to fish.”
For example, the ordnance size limit of 2,000 lbs on FDM, according to DLNR, further increases the potential for significant impact on surrounding reef fish.
On Tinian, the use of tracked landing craft will crush delicate coral habitat and decrease essential fish habitat, DLNR said.
DLNR is also wary of the draft EIS’ claim that the likelihood of introducing invasive species is negligible to low.
The department also said proposed activities in the Marpi maneuver area on Saipan, North Field on Tinian, in and around Rota International Airport, and in forested and well-vegetated areas on Rota have the potential to negatively affect the population integrity and breeding of forest birds.
Besides birds, the proposed activities are likely to directly impact the Mariana fruit bats, which are endemic to the CNMI, and other animals.
As for socioeconomic aspects, increased military activities in the archipelago will significantly alter lifestyles and attitudes of and perceptions toward people in the archipelago.
Inadequate information provided in the draft EIS on the duration of activities precludes any meaningful assessment on socioeconomic impact.
The sheer quantity of military activities in FDM’s vicinity suggests a more protracted closure of the surrounding productive reef area to commercial and sport fishing.
An analysis of the total area taken by the 3-nautical mile restricted zone, and the 10- and 12-nm danger zones also shows the real extent and impact of the closure would have on fishing.
“A total of the reef area exclusion would constitute 29, 93, and 98 percent of FDM’s fishable reef area. Thus, it seems more likely the activities on FDM will impose a significant take of the CNMI’s most productive fishing grounds,” DLNR said.
In a separate Nov. 25 memo to Gov. Eloy S. Inos and Lt. Gov. Jude U. Hofschneider, Palacios and Pangelinan said DLNR marine and wildlife biologists conducted a comprehensive review of the MITT EIS and their report entails specific concerns on the effects of proposed MITT activities.
The CNMI government as a whole is expected to submit comments to the draft EIS.
In October, Inos and Hofschneider urged the public to review the draft EIS.
The proposed MITT activities include increasing the size of the current military range of operations area to the north and west boundaries of the existing Mariana Islands Range Complex.
Sea-based activities in and around the CNMI include sonar, torpedo, and missile testing.
Land-based activities in the CNMI include amphibious vehicle landing exercises at Unai Chulu, Unai Babui, and Unai Dankulo beaches on Tinian, training activities at the Saipan Marpi Maneuver Area, and the Rota International Airport.
The draft EIS is available for download at http://mitt-eis.com.