EPA wants Navy commitment to dive surveys on health of marine life

The U.S. Environmental Protection Agency wants the U.S. Navy to commit to annual dive surveys on the health of marine life around Farallon De Medinilla, as the Navy eyes a three-fold increase to explosive ordnance used on the island, a routine bombing area leased to the U.S. military.

EPA also wants the Navy to commit to an evaluation of how munitions are consumed and transported by affected fish around the island, since humans can be exposed to these contaminants through consumption.

The agency’s requests are supported in their comments on the final draft environmental impact statement for the Marianas Islands Training and Testing area, or MITT. Among other sonar, vessel, and on-land training, the U.S. Navy has offered three training alternatives, two of which sees explosive ordnance use rise well-over 6,000 for FDM. The other alternative sees current use at the same level, or at 2,150 explosives.

EPA’s final comments on June 18, follows their comments on the Navy’s “draft” impact statement in 2013, where EPA had rated Navy findings as “insufficient.” This, over the lack of information provided on potential erosion from increased bombing and the effects of sediment runoff on corals around the island.

Since that time, the Navy has added a map covering the distribution and percent cover of corals surrounding FDM, as EPA requested. They also included results from dive surveys the Navy has conducted since 1999.

In EPA’s letter, Environmental Review Section manager Kathleen Martyn Goforth notes that the final impact documents attribute impacts to FDM’s physical environment in 2007, 2008, 2010, and 2012, but that the Navy found that coral fauna were observed to be “healthy and robust.”

Goforth goes on to say, though, that this appears to be contradicted in the Navy’s 2012 dive report, which documents “several coral barnacle infestation” identified as a “significant adverse change.”

“The dive report concludes that this is not a result of military training,” she said. “However, this conclusion is based solely on the fact that these barnacles were also found on a reef of north of FDM.”

The Navy’s survey explains that the presence of high densities of barnacles means the corals are “highly impacted by other stressors.” The Navy said, “Coral barnacles can be likened to an ‘opportunistic infection’ that are merely indicative of a ‘weakened immune system.”

The Navy also states, “It’s these unknown stressors that are causing the [coral species] to die.”

Goforth writes though, that, “The presence of these barnacles on a reef north of FDM does not preclude the possibility that increased sedimentation and/or the presence of munitions constituents are contributing to the weakened immune system of the corals at FDM.”

“Observations of existing coral health do not demonstrate that a training increase magnitude proposed would have less than significant effect on corals surrounding FDM,” she goes on to say.

According to the EPA, the Navy is proposing “a substantial increase in the use of explosive munitions on FDM.” The annual number of bombs dropped on land targets annually at FDM would increase three-fold—from 2,150 to 6,242, EPA said.

In EPA’s estimation, the Navy is also proposing to increase explosive missile use annually by 42 percent, from 60 to 85. They also want to introduce 2,000 explosive rockets not currently used on the island, and increase explosive grenades and mortars by 500 percent, from 100 to 600. They also want an increase of small-caliber rounds by 1,348 percent (from 2,900 to 42,000).

“These actions have the potential to greatly increase erosion and sedimentation,” Goforth writes. “We recommend that the Record of Decision [which finalizes the Navy’s request] commit to annual dive surveys to continue to monitor the marine resources and the coral barnacle infestation at FDM, and that results from these surveys be made available to government agencies and the public,” she said.

Exposure to fish, humans

In 2013, the EPA found that the Navy’s 208 condition assessment for the Marianas Island range “did not asses the fate and transport of sediment, including munitions constituents, from FDM.”

EPA had requested that the Navy discuss the results for their five-year reassessment in the final MITT documents if possible. However, according to Goforth, the Navy has not indicated whether an update to the range condition assessment occurred.

Citing the 2008 assessment, EPA said the Navy acknowledged “source loading of residual munitions constituents” in the Marianas range, but concluded that no further analysis was warranted since FDM poses “no risk to human receptors.”

However, as they have commented on earlier impact documents, EPA says ecological and human receptors should be considered in range condition assessments, since, there is a potential for human receptors via the “fish consumption pathway,” which the Navy fails to recognize in their range assessments, EPA says.

Goforth said the Navy’s final impact documents recognize FDM has been and continues to be an important area for local fishers. She said the Navy’s 2008 study already notes that aerial bombing and ship bombardment at FDM as “significant source of munitions constituents.” She said the Navy is proposing to introduce 2,000 rockets per year at FDM with a 4-percent failure rate— “which leaves unconsumed explosives in the environment,” Goforth says.

“We recommend that future range condition assessments evaluate the fish consumption pathway, including potential sampling of fished species for munitions constituents, and that a commitment to this evaluation be included in the Record of Decision,” she said.