United States Department of the Navy September 2018

Volume V

Atlantic Fleet Training and Testing 

Final Environmental Impact Statement/

Overseas Environmental Impact Statement
Atlantic Fleet Training and Testing 

Final Environmental Impact Statement/

Overseas Environmental Impact Statement

Volume V

United States Department of the Navy

September 2018
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Appendix G Federal Register Notices

APPENDIX G

Federal Register Notices
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APPENDIX G FEDERAL REGISTER NOTICES___________________________________G-1

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Appendix G Federal Register Notices

APPENDIX G FEDERAL REGISTER NOTICES

Appendix G contains the following Federal Register Notices:

1. Notice of Intent to Prepare an Environmental Impact Statement/Overseas Environmental Impact 

Statement for Navy Atlantic Fleet Training and Testing 

2. Corrected Notice of Intent to Prepare an Environmental Impact Statement/Overseas 

Environmental Impact Statement for Navy Atlantic Fleet Training and Testing

3. Notice of Availability of the Draft Environmental Impact Statement/Overseas Environmental 

Impact Statement for Navy Atlantic Fleet Training and Testing 

4. Notice of Public Meetings for the Draft Environmental Impact Statement/Overseas Environmental 

Impact Statement for Navy Atlantic Fleet Training and Testing

5. Amended Notice of Availability of the Draft Environmental Impact Statement/Overseas 

Environmental Impact Statement for Navy Atlantic Fleet Training and Testing 

6. Notice of Receipt of Application for Letter of Authorization for Taking and Importing Marine 

Mammals Incidental to the U.S. Navy Training and Testing Activities in the Atlantic Fleet Training 

and Testing Study Area

7. Proposed Rule for Takes of Marine Mammals incidental to the U.S. Navy Training and Testing 

Activities in the Atlantic Fleet Training and Testing Study Area

8. Correction Proposed Rule for Takes of Marine Mammals incidental to the U.S. Navy Training and 

Testing Activities in the Atlantic Fleet Training and Testing Study Area
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APPENDIX H PUBLIC COMMENT RESPONSES ________________________________H-1

H.1 Introduction ...................................................................................................H-1

H.2 Public Comment Period for the Draft Environmental 

Statement/Overseas Environmental Impact Statement...................................H-1

H.2.1 Commenters, Comments and Responses............................................................. H-1

H.2.1.1 Comment Response Process................................................................. H-2

H.2.1.2 Agency, Organization and Private Individual Comment 

Coding................................................................................................... H-2

H.2.1.3 Agency and Organization Comment Coding......................................... H-2

H.2.1.4 Private Citizen Comment Coding .......................................................... H-5

H.3 Comment Responses.......................................................................................H-6

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Table H.2-1. Agencies and Organizations Who Commented on the Draft Environmental 

Impact Statement/Overseas Environmental Impact Statement ......................................... H-2

Table H.2-2. Private Individual Comment Response Index....................................................................... H-6

Table H.3-1. Comment Response Matrix .................................................................................................. H-8
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Appendix H Public Comment Responses

APPENDIX H PUBLIC COMMENT RESPONSES

This appendix includes information about the public’s participation in the development of the Atlantic 

Fleet Training and Testing (AFTT) Environmental Impact Statement/Overseas Environmental Impact 

Statement (EIS/OEIS).

H.1 INTRODUCTION

The Navy would like to thank the elected officials, Native American tribes and nations, federal regulatory 

and state resource agencies, business and community leaders, organizations, and individuals for taking 

the time to review the AFTT Draft EIS/OEIS, attend the public meetings, and submit comments on the 

AFTT Draft EIS/OEIS. Public informational meetings and public participation are an essential aspect of 

the environmental review process. This appendix contains a summary of the comments received on the 

Draft AFTT EIS/OEIS and the Navy’s responses.

H.2 PUBLIC COMMENT PERIOD FOR THE DRAFT ENVIRONMENTAL

STATEMENT/OVERSEAS ENVIRONMENTAL IMPACT STATEMENT

The public comment period on the AFTT Draft EIS/OEIS began with the issuance of the Notice of 

Availability and a Notice of Public Meetings in the Federal Register on 30 June 2017. A correction of the 

Notice of Availability was issued on 7 July 2017 (Appendix G, Federal Register Notices). The public 

comment period began on 30 June 2017 and concluded on 29 August 2017. The Navy made significant 

efforts to notify the public to ensure maximum participation during the public comment period using 

signed letters, post cards, press releases and newspaper daily advertisements (Chapter 8, Public 

Involvement and Distribution). An email announcement was sent to the project website email 

distribution list announcing the availability of the Draft EIS/OEIS for public review and the public 

meetings. 

The Notice of Public Meetings included a project description and dates and locations of the five public 

meetings. The public comment period allowed a variety of opportunities for the public to comment on

the Draft EIS/OEIS (Appendix G, Federal Register Notices). Copies of the Draft EIS/OEIS were originally 

provided to 27 libraries along the east and Gulf coasts (see Chapter 8.0, Public Involvement and 

Distribution). After the Notice of Public Meetings was published in the Federal Register, the Navy 

submitted a copy of the Draft EIS/OEIS to two additional libraries, one in Key West, Florida per the 

request of the Naval Air Station Key West Public Affairs Officer and the other in Cape Cod, 

Massachusetts per request by a private citizen. The Draft EIS/OEIS was also available on the project 

website for review. Navy representatives were available during the open house public meetings to 

provide information and answer questions one-on-one. Comment sheets and a voice recorder were 

available to attendees. Commenters provided their input on the Draft EIS/OEIS in letters submitted 

through mail, written comments received at the public meetings, and via the project website.

H.2.1 COMMENTERS, COMMENTS AND RESPONSES

This appendix contains a list of the agencies (Table H.2-1) and private entities (Table H.3-1) that 

commented on the Draft EIS/OEIS and a comment matrix with Navy responses associated with the 

comments received (Table H.3-2). Scanned copies of comment letters (with the Commenter 

Identification Number assigned) are available on the project website (http://aftteis.com).
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Appendix H Public Comment Responses

H.2.1.1 Comment Response Process

The Navy considered and responded to all comments received on the Draft EIS/OEIS, as detailed in this 

Final EIS/OEIS. The Navy’s responses to comments received during the public comment period are 

included in this Appendix. In accordance with 40 Code of Federal Regulations (CFR) 1503.4, comments 

were assessed and responded to as follows:

 The Navy project team read and carefully reviewed all comments received. Each comment 

was assigned to a resource-specific specialist from the Navy’s interdisciplinary team.

 Within each comment submittal, substantive comments were identified for consideration of 

possible updates to the EIS/OEIS analysis. Generally, substantive comments included items 

such as questions related to the alternatives analysis and components of the Proposed 

Action; resource-specific methodology, analysis, or impact conclusions; or the use, 

adequacy, or accuracy of data used to support the analysis. 

 The EIS/OEIS analysis was updated as warranted based on comment review.

 Comment responses were developed for every comment based on the above-described 

comment review and Final EIS/OEIS update process. Responses identify, as appropriate, 

sections of the Final EIS/OEIS where revisions were made or details on where additional 

information is provided within the Final EIS/OEIS.

H.2.1.2 Agency, Organization and Private Individual Comment Coding

Comments were received from 7 federal agencies, 31 state agencies, 7 local/regional government 

agencies, 5 non-governmental organizations, 2 tribal governments, 1 commercial group, and 63 private 

individuals.

H.2.1.3 Agency and Organization Comment Coding

Table H.2-1 lists the agencies and organizations that submitted comments during the comment period. 

This table lists each comment by the Commenter Identification Number and where in the Comment 

Response Matrix (Table H.3-2) their comment and response can be found using a comment reference 

number. For example, a comment letter from a federal agency could have 10 comments within it. To 

organize responses, each commenter received a Commenter Identification Number and each comment 

within the letter was numbered (e.g., F01-01) is the first comment in the letter from the Army Corps of 

Engineers A list of all of the Commenter Identification Numbers assigned and the corresponding 

comments can be found on the project website (http://aftteis.com).

Table H.2-1. Agencies and Organizations Who Commented on the Draft Environmental 

Impact Statement/Overseas Environmental Impact Statement

Commenter 

ID Commenting Agency/Organization Table H.3-2 Comment Reference Number

Federal Agencies (F)

F01 Army Corps of Engineers 141, 186

F02 Department of the Interior 51, 73, 74, 75, 76, 77, 141, 

150, 151, 152

F03 Environmental Protection Agency 141

F04 Federal Aviation Administration 7, 14, 141
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Table H.2-1. Agencies and Organizations Who Commented on the Draft Environmental 

Impact Statement/Overseas Environmental Impact Statement (continued)

Commenter 

ID Commenting Agency/Organization Table H.3-2 Comment Reference Number

F05 Marine Mammal Commission 52, 53, 54, 55, 56, 57, 58, 

59, 60, 61, 78, 79, 80

F06 NASA Kennedy Space Center 2

F07 National Oceanic and Atmospheric Administration – Office of 

Coastal Survey 62

State Agencies (S)

S01 Alabama Historical Commission 8, 141

S02 Delaware Coastal Management Program 81, 82, 83, 177, 192, 193

S03 Florida Division of Historical Resources

& State Historic Preservation Officer 15, 142

S04 Florida Fish and Wildlife Conservation Commission 16, 17, 84, 85

S053 Georgia Department of Natural Resources

5, 18, 19, 20, 63, 85, 86, 87, 

88, 143, 144, 154, 155, 

156, 157, 158, 159, 160, 

191, 192, 194, 195, 196, 

197, 198, 199, 213, 214

S06 Georgia State Historic Preservation Office 142

S07 Louisiana Department of Natural Resources 144, 161

S08 Maine Historic Preservation Commission 141

S09 Maryland Department of Natural Resources 21, 22, 23

S10 Maryland Environmental Service 141

S11 Maryland State Clearinghouse 1, 141

S12 Massachusetts Port Authority 2

S13 Mississippi Department of Archives and History; Historic 

Preservation Division 141

S14 Mississippi Department of Marine Resources 2, 5, 24, 168, 177

S15 New Hampshire Department of Environmental Services 13, 25, 26, 27

S16 New Jersey Department of Environmental Protection 142, 145

S17 New York State Department of Environmental Conservation 6, 28, 89, 90, 91, 162, 192, 

200, 201

S18 New York State Military and Naval Affairs 1

S19 North Carolina Department of Environmental Quality 5, 92, 103, 163, 164, 182, 

183, 186, 202

S20 North Carolina Division of Parks and Recreation 165

S21 North Carolina Military Affairs Commission 2, 141

S22 North Carolina State Environmental Review Clearinghouse 1

S23 North Carolina Wildlife Resources Commission 1, 93, 94

S24 South Carolina Department of Health and Environmental Control 64, 176, 177, 203

S25 South Carolina Department of Natural Resources 95, 96, 141, 208

S26 Texas Commission on Environmental Quality 13, 141, 184

S27 Texas Historical Commission 142

S28 Texas Parks and Wildlife Department 97, 98, 99, 185

S29 Virginia Department of Environmental Quality 13, 100, 141, 144, 146, 147,

148, 166, 175

S30 Virginia Department of Military Affairs 141

S31 Virginia Port Authority 2
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Appendix H Public Comment Responses

Table H.2-1. Agencies and Organizations Who Commented on the Draft Environmental 

Impact Statement/Overseas Environmental Impact Statement (continued)

Commenter 

ID Commenting Agency/Organization Table H.3-2 Comment Reference Number

Local/Regional Government Agencies, Officials and Representatives (L)

L01 City of Cape Canaveral 1

L02 City of St. Mary’s, Georgia 2

L03 Representative Diana Urban – 43rd Assembly District of 

Connecticut 5, 65, 177

L04 Town of Barnstable, Hyannis, MA 2, 208

L05 Town of Nags Head, NC 5, 101, 215

L06 Town of Pine Knoll Shores, NC 1

L07 Town of South Kingston, RI 2

Organizations (O) 1

O01 American Friends Service Committee, South East New England 3, 5, 13, 175, 177, 186, 209, 

211

O02 Mid-Atlantic Fishery Management Council 2, 35, 81, 104, 105, 106, 

181, 210

O032 Natural Resources Defense Council

36, 37, 38, 39, 40, 41, 42, 

43, 44, 55, 66, 67, 68, 69, 

70, 71, 107, 108, 109, 110, 

111, 112, 113, 114, 115, 

116, 117, 118, 119, 120, 

121, 122, 123, 124, 125, 

126, 127, 128, 129, 130, 

131, 132, 153, 173, 174, 

187, 188, 189, 190, 204

O04 New England Fishery Management Council

45, 46, 47, 103, 133, 134, 

135, 136, 175, 177, 180, 

186, 205, 212

O05 Save The Bay 48, 49, 50, 137, 138, 139, 

140, 206, 207

Native American Tribes (N)

N01 Delaware Nation 2, 149

N02 Seminole Tribe of Florida 2, 149

Commercial Business

C01 Seafreeze Ltd 2, 72, 177, 178, 179, 211, 

212

1 These private individuals submitted comments that referenced an organization that is not listed here: OTOCY (350.org), 

CURWH (Honor the Earth), FOWOR (Savannah Navy League), DIAJO (Zero Geo Engineering), EDDJU (Berkshire 

Environmental Action Team), ELLDA (Maine VFP), and TIPRE (Center for Cultural Evolution). These individuals’ comments 

are addressed in table H.3-2. See table H.3-1 for the location of the response.

2 Natural Resources Defense Council submitted comments on behalf of the following organizations: Animal Welfare 

Institute, Humane Society of the United States, Cetacean Society International, Ocean Mammal Institute, and Citizens 

Opposing Active Sonar Threats.

3

In addition to two letters received from the Georgia Department of Natural Resources in response to the request for 

comment on the current AFTT EIS/OEIS, the Georgia Department of Natural Resources also provided past letters from 

2013. Issues raised in the 2013 letters were incorporated into the previous AFTT EIS/OEIS and are also addressed in the 

current document. We are only responding to issues raised from the 2017 letters in this Final EIS/OEIS.
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Appendix H Public Comment Responses

H.2.1.4 Private Citizen Comment Coding

In order to keep personally identifiable information private and to allow commenters to find their 

comments in this appendix, the Navy assigned each comment a code based on components of the 

commenter’s name. Personally identifiable information include an individual’s name, physical address, 

email address, or place of employment. Table H.2-2 lists the Commenter Identification Number for 

private individuals who submitted comments during the comment period. This table lists each comment 

by the Commenter Identification Number and where in the Comment Response Matrix (Table H.3-2) 

their comment and response can be found using a comment reference number. Individuals who 

commented on the Draft EIS/OEIS during the public comment period may find their comments using the 

following method: 

 Each individual commenter was assigned a five-digit code (AAABB) that corresponds with 

their first and last name. “AAA” is the first three letters of the commenter’s last name; “BB” 

is the first two letters of their first name. If more than one person has the same code then a 

number was added to the end of the five-digit code to designate multiple commenters 

(AAABB1 and AAABB2). If the commenter submits multiple comments within a letter, then a 

sequential number was assigned to each comment in the letter beginning with 01 and 

increases with each comment received from that individual. For example, the first comment 

received from an individual named John Doe would have the comment code DOEJO-01.

 Special cases: 

o For instances where limited information is provided, a lower case “x” is used in 

place of letters or numbers. Examples include instances in which only a last name is 

provided, such as “Doe,” and the resulting comment code would be DOExx. 

Similarly, if only the first name “John” is provided, the comment code would be 

xxxJO. If a first or last name is too short to fill in the code (i.e., three letters for the 

last name or two letters for the first name), a lower case “x” is also used. For 

example, if the commenter is J Doe, the comment code would be DOEJx.

o When a comment is submitted with no name or the commenter wrote 

“anonymous,” the comment is coded ANONY and the single-digit numbers increase 

sequentially. For example, if multiple individuals submit comments without proving 

a name then the comment codes would be ANONY1, ANONY2, and ANONY3. 
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Appendix H Public Comment Responses

Table H.2-2. Private Individual Comment Response Index

Commenter 

Identification 

Number

Table H.3-2 

Comment 

Reference 

Number

Commenter 

Identification 

Number

Table H.3-2 

Comment 

Reference 

Number

Commenter 

Identification 

Number

Table H.3-2 

Comment 

Reference 

Number

ANONY1 3 FOLMA 3, 5 MCGKA 3, 5

ANONY2 3 FOWOR 2 MCGSA 3, 5, 34, 

170, 175

ANONY3 3, 5 FRISU 3, 5, 186 NAPSA 3, 5, 211

ANONY4 2, 5, 9 GAGBR 3, 5, 186, 

199, 211 ODENA 3, 5

ANONY5 2 GALEV 3, 5, 170 OTOCY 3, 5

ARRRI 200 GERGR 3, 5 PATEL 3, 5

AUBMA 3, 186, 211 GOLDO 3 PETJU 2

BEHLA 3 GRACR 3, 5 RAYSU 3, 5, 13, 177

BENST 5 HAISA 3, 5 SCHRI 2

BREWE 3, 5 HANDA 3, 5 SMICH 2

BUCBE 3, 10 HARAM 3, 5 SNOBA 3, 211

BYRRU 2 HOPCH 3, 5, 169, 

211 SPEJA 3, 5, 171

COEPH

4, 5, 175, 

177, 186, 

211

HUBWI 2 STATE 2

CURWH 3, 5 JEWSU 3, 5 STEHE 3, 5

DEERO 2 KAPJO 3 TIPRE 5

DIAJO 5, 11, 186 KUNJE 3, 5, 103, 

168

TUCLI 3, 5

DOWDA

2, 12, 28, 

29, 30, 31, 

32, 33

LAMRE 3, 5 UTTRI 3, 5

DREJA 3 LEPSH 3, 5, 186 VENPA 3, 5, 211

EDDJU 3, 5 LLOGA 3, 5, 13 WATAN 3

ELLDA 5 LOVST 5 WRITH 2

FARLA 3, 5 MAREU 103, 167 xxxJO 13, 172, 

211

1 See section 2.1.2.2, Private Citizen Comment Coding, for an explanation of the commenter identification numbers 

methodology. 

H.3 COMMENT RESPONSES

Responses to all comments received on the Draft EIS/OEIS are included in this section. Comment 

responses are organized by topic category. Tables H.2-1 and H.2-2 provides commenters the location in 

Table H.3-1 where their comments are addressed. Many of the comments received during the Draft 

EIS/OEIS public comment period can be grouped into larger categories. In these instances, the 

comments are summarized and a response is provided for the entire category. A copy of all of the 

comments received during the Draft EIS/OEIS public comment period is provided on the project website 
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Appendix H Public Comment Responses

(http://aftteis.com). Some comments require a more detailed response. In these cases, the entire 

comment is provided in Table H.3-1 with a response specific to that comment. Many of the comment 

responses refer to sections of the Final EIS/OEIS or the associated technical reports. The Final EIS/OEIS 

and the technical reports are located on the project website.
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Appendix H Public Comment Responses

Table H.3-1. Comment Response Matrix

Reference 

Number Commenters Comment Response

No comment

1 Local/Regional:

L01-01, L06-01

State:

S11-02, S18-01, S22-01, S23-03

Six comments explained that they did not have 

a comment on the Proposed Action.

Thank you for your review.

Support of the Navy/Proposed Action

2 Federal:

F06-01

State:

S12-01, S14-01, S21-02, S21-04, 

S21-07, S31-01

Local/Regional:

L02-01, L04-01, L07-01

Organization:

O02-01

Native American Tribes:

N01-01, N02-01

Commercial:

C01-01

Individuals:

ANONY4-01, ANONY5-01, 

BYRRU-01, DEERO-01, 

DOWDA- 08, FOWOR-01, 

HUBWI-01, PETJU-01, SCHRI-01,

SMICH-01, STATE-01, 

WRITH-01

26 comments expressed support for the Navy 

and/or the Proposed Action.

Thank you for your participation in the National Environmental 

Policy Act process. Your comment is part of the official project 

record.
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Appendix H Public Comment Responses

Table H.3-1. Comment Response Matrix (continued)

Reference 

Number Commenters Comment Response

Against Navy/Proposed Action

3 Organization:

O01-01, O01-02a, O01-

05, O01-06a, O01-10a

Individuals:

ANONY1-01, ANONY2-

02, ANONY3-01, 

ANONY3-02b, AUBMA01, BEHLA-01, BREWE02, BUCBE-02, CURWH01, DREJA-01, EDDJU01, FARLA-01b, FOLMA02, FOLMA-03, FRISU01, GAGBR-02, GALEV01, GERGR-01a, GERGR02, GOLDO-01, GRACR01, HAISA-01a, HANDA01, HARAM-01a, 

HARAM-02b, HOPCH01b, HOPCH-02, JEWSU01a, KAPJO-01, LAMRE01b, KUNJE-03a, LEPSH03, LLOGA-03, MCGKA01b, MCGSA-04, NAPSA02b, ODENA-01b, 

OTOCY-01, PATEL-01b, 

RAYSU-01, SNOBA-01, 

SPEJA-02a, SPEJA-04, 

STEHE -01a, TUCLI-02, 

UTTRI-01, VENPA-01a, 

WATAN-01

53 comments expressed opposition to the Navy 

and/or the Proposed Action.

Thank you for your participation in the National Environmental 

Policy Act process. Your comment is part of the official project 

record. The proposed training and testing activities are generally 

consistent with training and testing that the Navy has been 

conducting in the AFTT Study Area for decades.
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Appendix H Public Comment Responses

Table H.3-1. Comment Response Matrix (continued)

Reference 

Number Commenters Comment Response

4 Individuals:

COEPH-01, COEPH-06

Two comments expressed concern that the Navy was 

conducting “war games”.

Thank you for your participation in the National Environmental 

Policy Act process. The Navy developed the alternatives 

considered in this Final EIS/OEIS after careful assessment by 

subject matter experts, including military units and commands 

that utilize the ranges, military range management professionals, 

and Navy environmental managers and scientists. These 

alternatives were approved by senior Navy leadership. The 

alternatives carried forward meet the Navy's purpose and need 

(Section 1.4, Purpose and Need) to ensure that it can fulfill its 

obligation under Title 10. See Section 2.4 (Action Alternative 

Development) for more detailed information on the development 

of alternatives. The proposed training and testing activities are 

generally consistent with training and testing that the Navy has 

been conducting in the AFTT Study Area for decades.

Potential impact to marine life

5 State:

S05-37, S14-02a,

S19-01, 

Local:

L03-03, L05-01

Organization:

O01-06b

Individuals:

ANONY3-02a, ANONY4-

03, BENST-01, BREWE01, BREWE-03, COEPH04a, CURWH-02, DIAJO02, EDDJU-02,

ELLDA-01, FARLA-01a,

FOLMA-01, FRISU-02a, 

GAGBR-01a, GALEV-02, 

GERGR-01b, GRACR-02,

48 comments expressed concerns regarding 

potential impact to marine species and environment 

from the proposed activities. These include both 

generalized concern as well as concerns regarding 

specific species and activities.

The Navy is concerned for marine life. All of the potential effects 

from Navy training and testing activities were analyzed in Chapter 

3 (Affected Environment and Environmental Consequences) of the

Final EIS/OEIS. Also, as described in Chapter 5 (Mitigation) of the

Final EIS/OEIS, the Navy implements mitigation measures during 

its training and testing activities. The Navy has conducted active 

sonar training and testing for decades in the sea space depicted in 

the Study Area with no long-term consequences or populationlevel impacts to marine species. The Navy consulted with the 

appropriate federal and state regulators regarding applicable 

environmental statutes.
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Appendix H Public Comment Responses

Table H.3-1. Comment Response Matrix (continued)

Reference 

Number Commenters Comment Response

5 (cont.) HAISA-01b, HANDA-02, 

HARAM-01b, HARAM02a, HOPCH-01a, 

JEWSU-01b, KUNJE-03b,

LAMRE-01a, LEPSH-01a, 

LLOGA-02, LOVST-01, 

MCGKA-01a, MCGSA01a, NAPSA-02a, 

ODENA-01a, OTOCY-02,

PATEL-01a, RAYSU-03a, 

SPEJA-01, SPEJA-02b, 

STEHE -1b, TIPRE-01,

TUCLI-01, UTTRI-02, 

VENPA-01b

6 State:

S17-01

The Department's primary concerns regarding effects 

of training and testing in the 2.6 million square 

nautical mile AFTT Study Area are that the impacts 

are broad and wide- ranging, and include New York 

waters. The large scope has many significant direct 

and indirect effects on the marine environment and 

species, and covers a wide spectrum of impacts 

including ship strike, multiple acoustic impacts, 

entanglement, and ingestion. In recent years, New 

York State has seen an increased number of dead or 

dying whales along our shoreline. The primary cause 

of death of beached and washed-ashore marine 

mammals has been blunt trauma as a result of ship 

strike and/or entanglement by marine debris. 

There is potential that training and testing activities 

may drive marine mammal and sea turtle species 

into the New York Bight, increasing the risk for 

serious injury and mortality from interaction with 

human activity.

Thank you for your concern. There is no evidence that Navy 

training and testing activities drive marine mammals and sea 

turtle species into the New York Bight. The analysis and 

conclusions for the potential impacts to marine mammals from 

each of the individual stressors are discussed in Sections 3.7.3.1 

(Acoustic Stressors) through 3.7.3.6 (Ingestion Stressors) and the 

potential impacts to turtles from each of the individual stressors 

are discussed in Sections 3.8.3.1 (Acoustic Stressors) through 

3.8.3.6 (Ingestion Stressors). As stated in these sections potential 

impacts to marine mammals or turtles from the proposed testing 

and training activities is not expected to lead to long-term 

consequences for populations.
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Appendix H Public Comment Responses

Table H.3-1. Comment Response Matrix (continued)

Reference 

Number Commenters Comment Response

Concerns about activities/areas that are outside of the proposed action

7 Federal:

F04-10

The Federal Aviation Administration expressed 

concern over any potential impacts to airspace.

Thank you for your response. The Navy is not proposing any 

construction or changes to airspace in support of the training 

covered in this document. Any pertinent Obstruction 

Evaluation/Airport Airspace Analysis (OE/AAA) matters will be 

handled separately through the appropriate coordination 

channels in a timely manner.

8 State:

S01-02

Should artifacts or archaeological features be 

encountered during project activities, work shall 

cease and our office shall be consulted immediately. 

Artifacts are objects made, used or modified by 

humans. They include but are not excluded to 

arrowheads, broken pieces of pottery or glass, stone 

implements, metal fasteners or tools, etc. 

Archaeological features are stains in the soil that 

indicate disturbance by human activity. Some 

examples are post holes, building foundations, trash 

pits and even human burials. This stipulation shall be 

placed on the construction plans to insure 

contractors are aware of it.

Thank you for your participation in the National Environmental 

Policy Act process. The Proposed Action does not include 

activities, such as construction, that would impact archaeological 

features. Please see Chapter 2 (Description of Proposed Action 

and Alternatives) of the Final EIS/OEIS for a definition of the scope 

of the project.

9 Individual: 

ANONY4-02

If I was a terrorist I'd be following the path of the 

whales sonar isn't being blasted that way. I hope that 

the navy is able to immediately "stand down" if 

something horrible is revealed while testing new 

technology and the xxxxx is not bogged down in 

paperwork. I wish the results of some of these tests 

were not classified. If they are classified I hope there 

is a reasonable wait period to declassify; like within 

my lifetime.

Thank you for your participation in the National Environmental 

Policy Act process. The Navy developed the alternatives 

considered in this Final EIS/OEIS after careful assessment by 

subject matter experts, including military units and commands 

that utilize the ranges, military range management professionals, 

and Navy environmental managers and scientists. The alternatives 

carried forward meet the Navy's purpose and need (Section 1.4, 

Purpose and Need) to ensure that it can fulfill its obligation under 

Title 10. See Section 2.4 (Action Alternative Development) for 

more detailed information on the development of alternatives.
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Appendix H Public Comment Responses

Table H.3-1. Comment Response Matrix (continued)

Reference 

Number Commenters Comment Response

10 Individual: 

BUCBE-01

Seismic testing and the drilling which is sure to 

follow, if anything is found, would be terrible. Marine 

life and the local tourist industry, which accounts for 

most of Charleston's and South Carolina's economy, 

could be devastated.

The Navy is not proposing any seismic activities as part of the 

proposed action. Please see Chapter 2 (Description of Proposed 

Action and Alternatives) of the Final EIS/OEIS for a definition of 

the scope of the project. The Navy strives to conduct training and 

testing activities in a manner compatible with commercial and 

recreational ocean users by minimizing temporary access 

restrictions (Section 3.11, Socioeconomics). Because the proposed 

activities would not lead to a noticeable change in Navy presence, 

and because the proposed locations for these activities do not 

differ much from historical use, it is unlikely that commercial and 

recreational activities would be noticeably affected by Navy 

activities requiring area restrictions.

11 Individual:

DIAJO-01

Are these exercises exclusively American, or is the 

UN and NATO also involved? If not, who is leading?

Thank you for your participation in the National Environmental 

Policy Act process. All exercises associated with the Proposed

Action are led by the U.S. Navy. Some activities will involve 

partner nations and allies.

12 Individual: 

DOWDA-07

The cumulative impacts section would be improved if 

it included a worst case scenario example and this 

would carry over into the socioeconomic 

consequences. I don't know what the worst case 

scenario might be, but it could include ship board 

explosions or ship collisions and release of fuels/toxic 

chemicals.

Thank you for your participation in the National Environmental 

Policy Act process. The National Environmental Policy Act does not 

require an agency to analyze speculative worst case scenarios. 

Rather, the focus of this EIS/OEIS is analysis of the reasonably 

foreseeable impacts of the Navy's proposed activities. This 

includes analyzing public health and safety, which are discussed in 

Section 3.12, including the standard operating procedures that the 

Navy implements to ensure the safety of its training and testing 

activities, as well as the reasonably foreseeable impacts from 

discharges associated with training and testing. Additional 

information is included in Section 3.1 Air Quality, and Section 3.2 

Sediments and Water Quality. 
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Appendix H Public Comment Responses

Table H.3-1. Comment Response Matrix (continued)

Reference 

Number Commenters Comment Response

13 Individual:

LLOGA-01, RAYSU-02, 

xxxJO-03

Organization:

O01-04, O01-11b, 

State:

S15-03, S15-04, 

S26-02, S29-15

Nine of the comments submitted discussed activities 

outside of the scope of the Proposed Action. These 

comments discuss concerns about terrorism, Navy 

facilities and training at locations not covered in this 

document and a wide variety of other concerns.

Thank you for your participation in the National Environmental 

Policy Act process. The Proposed Action does not include these 

activities. The proposed training and testing activities are 

generally consistent with training and testing that the Navy has 

been conducting in the AFTT Study Area for decades. Please see 

Chapter 2 (Description of Proposed Action and Alternatives) of the 

Final EIS/OEIS for a definition of the scope of the project.

Corrections/Typos/other errors in document

14 Federal: 

F04-01, F04-02, F04-03, 

F04-04, F04-05, F04-06, 

F04-07

The Federal Aviation Administration provided 

revisions to the text in the EIS/OEIS.

Thank you for your participation in the National Environmental 

Policy Act process. The Navy has revised the Final EIS/OEIS per 

your request.

15 State:

S03-02

The Florida Division of Historical Resources

& State Historic Preservation Officer provided a 

correction to section 3.10.

Thank you for your review. The Final EIS/OEIS has been revised to 

include the correct reference number Section 5.4.1 (Mitigation 

Areas for Seafloor Resources) instead of Section 5.4.5.

Inclusion of Additional Science

16 State:

S04-01

The DEIS cites a “minimum number alive population 

index” for North Atlantic right whales during 1990-

2010 that suggests a mean annual population growth 

rate of 2.8 percent. More recent information 

suggests that the population growth rate, 

reproductive rates, and health indices have declined 

for right whales in recent years, and may be below 

the rate identified in the DEIS (Kraus et al. 2016, 

Pettis and Hamilton 2016, Rolland et al. 2016). 

Section 3.7.2.2.2.3 (Population Trends) of the Draft EIS/OEIS 

presented data from the most recent National Oceanic and 

Atmospheric Administration (NOAA)'s National Marine Fisheries 

Service (NMFS) Stock Assessment Report available at the time of 

Draft EIS/OEIS publication on North Atlantic right whale 

population trends, citing a mean growth rate of 2.6 percent. The 

information presented in the Draft EIS/OEIS is consistent with the 

information included in the NMFS 2015 Proposed Rule to expand 

critical habitat (80 FR 9314). The Navy updated the Final EIS/OEIS 

with new information on population trends if new NMFS Stock 

Assessment Reports became available. The Navy reviewed the 

literature suggested by Florida Fish and Wildlife Conservation 

(FWC) and incorporated into the Final EIS/OEIS as appropriate.
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Appendix H Public Comment Responses

Table H.3-1. Comment Response Matrix (continued)

Reference 

Number Commenters Comment Response

17 State:

S04-02

Additionally, human-caused mortality and serious 

injuries for right whales exceed Potential Biological 

Removal (Waring et al. 2016). Year-to-date, at least 

thirteen mortalities and four new entanglement 

cases have been observed for right whales.

As discussed in Section 3.7.3 (Environmental Consequences), the 

Navy does not anticipate any serious injuries or mortalities to 

North Atlantic right whales; therefore the Navy will not contribute 

to the exceedance of Potential Biological Removal. In addition to 

procedural mitigation, the Navy also developed mitigation areas 

(see Section 5.4, Mitigation Areas to be Implemented) to further 

avoid potential interactions between training and testing activities 

and North Atlantic right whales.

18 State:

S05-01

In 2009 the Navy implemented a Right Whale 

Distribution Study. However, results of this study 

have not been provided, either in the AFTT 

DEIS/DOEIS or associated appendices or through 

other direct submission to GaDNR. Results of this 

work are needed in order to assess the potential 

impacts of AFTT activities on right whales.

Long-term passive acoustic monitoring has been occurring in the 

JAX OPAREA, and the results of the monitoring are presented on 

the NMFS Office of Protected Resources web site and the Navy’s 

Marine Species Monitoring web site 

(http://www.navymarinespeciesmonitoring.us/). Information from 

the AFTT monitoring program has been incorporated into the Final 

EIS/OEIS.

19 State:

S05-43

We appreciate the Navy's use of revised marine 

mammal density maps in AFTT Phase III. Accurate 

density maps should improve the accuracy of take 

estimates and enhance mitigation efforts. 

Unfortunately, the current NARW model (Roberts et 

al. 2016) did not include Early Warning System (EWS) 

aerial survey data, which are the primary NARW data 

source for the Southeast U.S. Therefore, the NARW 

density estimates and resulting take estimates may 

be inaccurate. For example, the current model shows 

higher densities of NARWs in the Southeast U.S. in 

April than in December, which is inconsistent with 

decades of field observations.

The North Atlantic Right Whale model that predicted higher 

density in the species' core habitat area (e.g. Southeast U.S.) was 

selected as a precautionary measure to ensure take estimates 

would err on the high side until models are improved. The current 

North Atlantic Right Whale model did not produce higher density 

predictions in April compared to December for the Southeast U.S. 

Based on the mode,; density is higher in December, with 

predictions reaching up to 46 animals/100 km2 off the Southeast 

coast compared to April, which had predictions reaching up to 3.2 

animals/100 km2 off the Southeast coast. Please refer to the 2017 

technical report titled U.S. Navy Marine Species Density Database 

Phase III for the Atlantic Fleet Training and Testing Study Area

(http://aftteis.com/Current-Documents) or the website, 

http://seamap.env.duke.edu/models/Duke-EC-GOM-2015/, for 

further information on the North Atlantic Right Whale model.

20 State:

S05-44

Unfortunately, the current NARW model (Roberts et 

al. 2016) did not include EWS aerial survey data, 

The best available science and data was used to prepare both the 

Draft and Final EIS/OEIS and will be used in Endangered Species
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Appendix H Public Comment Responses

Table H.3-1. Comment Response Matrix (continued)

Reference 

Number Commenters Comment Response

20 (cont.) which are the primary NARW data source for the 

Southeast U.S. Therefore, the NARW density 

estimates and resulting take estimates may be 

inaccurate. For example, the current model shows 

higher densities of NARWs in the Southeast

U.S. in April than in December, which is inconsistent 

with decades of field observations. Roberts et al. are 

revising the model to include EWS aerial survey data 

which will increase the number of NARW sightings in 

the Southeast U.S. portion of the model 100-fold. 

The revised model should be complete by September 

201 7 (T. Gowan and J. Roberts, pers. comm.) We

recommend that the Navy recalculate NARW take 

estimates with the revised model and provide 

updated results in the Final EIS.

Act and Marine Mammal Protection Act consultations with NMFS.

21 State:

S09-01

Maryland has and is funding the following three 

surveys and we encourage the U.S. Navy to consider 

this new data and information in its AFTT Draft 

EIS/OEIS:

1. Aerial surveys to collect data on presence, density 

and seasonality of large whale species were 

conducted along the coastal waters of Maryland 

from July 2013 to June 2015. There were twentyfour surveys over 16,579 km of track- line. Here 

are a few highlights:

a. 23 large whale groups sighted (9 fin whale, 2 

humpback, 1 minke whale, 8 right whale and 3 

unidentified whales);

b. 417 bottlenose dolphin groups sighted and 36 

groups of other dolphin species (25 common 

dolphin groups, 1 spotted dolphin group, 10 

unidentified dolphin groups); and

Data from multiple surveys, including aerial surveys from the 

Northeast Fisheries Science Center (NEFSC) and the Southeast 

Fisheries Science Center (SEFSC), and a shipboard survey from 

SEFSC, were used for the Phase III models and these surveys 

included track lines that covered most of, if not all of, the 

Maryland (MD) Wind Energy Area (WEA) survey area. . However, 

the Maryland MD WEA 2013-2015 aerial survey effort data was 

not used for the density models included in the AFTT Draft 

EIS/OEIS for several reasons. The MD WEA aerial data for the 

entire 2013-2015 period was received by Duke University 

(contractors for the Navy density modelling effort) as a single 

batch from Virginia Aquarium on 21 October 2015. The end of 

September 2014was the last possible deadline the Duke University 

density modelling team could accept new data for density models 

that would be used for analysis in the AFTT Draft EIS/OEIS. Due to 

the late receipt of the data, refitting the models to include these 

MD aerial survey data was not feasible without incurring months 

of work that would also then have
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Appendix H Public Comment Responses

Table H.3-1. Comment Response Matrix (continued)

Reference 

Number Commenters Comment Response

21 (cont.)

c. 809 loggerhead turtle sightings and 142 sightings 

of other turtle species (45 green, 14 leatherback, 

1 Kemp's and 82 unidentified). The study was 

conducted by the Virginia Aquarium and Marine 

Science Center and the Riverhead Foundation for 

Marine Research and Preservation.

affected the acoustic modelling timeframe. Because, the MD WEA 

project survey area was included in other surveys conducted by 

NEFSC and SEFSC, the inclusion of this data would not result in an 

appreciable change to the density model. The Duke University 

density modelling team has incorporated MD WEA 2013-2015 

aerial survey data in the updated density models for the East 

Coast species that are currently under development and will be 

used in later Navy environmental compliance documents on the 

East Coast of the U.S.

22 State:

S09-02

2. Maryland is cost-sharing a study with the Bureau 

of Ocean Energy Management (BOEM) to collect 

acoustic data to:

a. characterize patterns of temporal and spatial 

occurrence of vocalizing marine mammal species 

(including right whales, fin whales, humpback 

whales, minke whale and any small cetacean 

species); and

b. characterize the existing ambient noise 

environment in and around the Maryland WEA. 

The project is being undertaken by the University 

of Maryland Center for Environmental Science 

and the Bioacoustics Research Program at Cornell 

University and is still ongoing with preliminary 

information and data available upon request.

The Navy has corresponded with the study’s principal investigator 

and has reviewed the available data. The Navy will continue to 

stay apprised of the study as it progresses.

23 State:

S09-03

3. Maryland provided funds to the Biodiversity 

Research Institute to expand their ongoing work 

with the U.S. Department of Energy (DOE) to:

a. assess wildlife distribution and abundance 

patterns and examine temporal variation in these 

patterns;

During the development of the Draft EIS/OEIS, the Navy reviewed 

the information presented on http://www.briloon.org/mabs 

(based on a public scoping comment received from Delaware 

Natural Resources and Environmental Control). Following a review 

of the documents it was decided that the information provided in 

the reports did not add more relevant species-specific information 

than was already included in the relevant species sections. The 

Navy re-evaluated the referenced information and that
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Appendix H Public Comment Responses

Table H.3-1. Comment Response Matrix (continued)

Reference 

Number Commenters Comment Response

23 (cont.) b. development of statistical models to identify 

ecological drivers of these patterns and predict 

important habitat and aggregation areas; and

c. identification of species likely to be exposed to 

offshore wind energy development or other 

anthropogenic activities. 

applicable relevant information has been incorporated in the Final 

EIS/OEIS. The Navy incorporated the information presented on 

http://www.briloon.org/mabs into the Final EIS/OEIS Sections 

3.6.2.1.5 (Fishes), 3.7.2.1.5 (Marine Mammals), 3.8.2.1.5 

(Reptiles), and 3.9.2.1.5 (Birds and Bats).

Maryland funded an extension of the DOE-funded 

surveys that included the expansion of existing boat 

surveys into Maryland state waters, the extension of 

video aerial surveys into areas west and south of the 

Maryland Wind Energy Area; and an extra aerial 

survey in Maryland waters. Key findings can be found 

in the Figures section at the end of this document. A 

copy of the final published reports and this work may 

be found online at: http://www.briloon.org/mabs. 

There are both Mid-Atlantic- and Maryland-scale 

data and reports on this website.

24 State:

S14-04

More information about the proposed activities and 

locations would allow the MDMR to properly 

evaluate the risks to our marine resources. We 

believe that successful management is measured by 

sustainability as well as by accessibility though 

understanding and communication. Feel free to 

contact me with any additional information.

Appendix A (Navy Activity Descriptions) provides the activities that 

may occur within the AFTT Study Area. All of the potential effects 

from Navy training and testing activities were analyzed in Chapter 

3 (Affected Environment and Environmental Consequences) of the

Final EIS/OEIS. Also, as described in Chapter 5 (Mitigation) of the

Final EIS/OEIS, the Navy implements mitigation measures during 

its training and testing activities. The Navy has conducted active 

sonar training and testing for decades in the sea space depicted in 

the Study Area. Regarding impacts to Mississippi coastal 

resources, the Navy has consulted with the state of Mississippi 

through the Coastal Zone Management Act and received 

concurrence, see Appendix J (Agency Correspondence).
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Appendix H Public Comment Responses

Table H.3-1. Comment Response Matrix (continued)

Reference 

Number Commenters Comment Response

25 State:

S15-01

As suggested in November 2015, NHDES 

recommends that the Department of the Navy 

review the ocean use and resource data available at 

the Northeast Ocean Data Portal 

(www.northeastoceandata.org) during the 

development of the Atlantic Fleet Training and 

Testing Environmental Impact Statement/Overseas 

Environmental Impact Statement (DEIS/OEIS). The 

Northeast Ocean Data Portal is an information 

resource and decision support tool that provides 

access to maps, data, tools, and information for 

ocean planning from the Gulf of Maine to Long Island 

Sound.

Within the AFTT Study Area, the Northeast and Mid-Atlantic 

Regional Planning Bodies developed Plans that were certified by 

the National Ocean Council in December 2016. In those Plans, the 

Department of Defense committed to using the Plans and 

Regional Data Portals to inform pertinent environmental 

programs, initiatives, and planning documents. The Regional 

Ocean Plans and Data Portals were used as a resource throughout 

the development of this Final EIS/OEIS.

26 State:

S15-02

The comments formerly submitted by the NHDES Air 

Resources Division in response to the January 2016 

Preliminary Request noted that the analysis should 

be expanded to consider the impacts of: 1) emissions 

from ships included in training and testing while at 

port and near shore;

Emissions from ships operating nearshore have been included in 

the analysis, to cover 0-3 nautical miles from shore. They have 

been identified by the Range Complex. Emissions off the coast of 

New Hampshire would fall under the Northeast Range Complex, 

which includes three OPAREAS that encompass some or all of the 

offshore state waters of Maine, New Hampshire, Massachusetts, 

Rhode Island, Connecticut, New York, and New Jersey. Vessel 

Steaming Hours by State vs International Waters is quite small for 

the Northeast Range Complex, as can be seen in the Appendix C 

(Air Quality Emissions Calculations and Record of NonApplicability), Tab D (Ship Emissions). 

While it is impossible to estimate what percentage of vessel 

transits could possibly occur in the state waters of New 

Hampshire, it is reasonable and conservative to consider all vessel 

transits in state waters in the Northeast Range Complex to occur 

in New Hampshire state waters in order to assess whether or not 

there would be any impact.
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Appendix H Public Comment Responses

Table H.3-1. Comment Response Matrix (continued)

Reference 

Number Commenters Comment Response

27 State:

S15-03, S15-04

Two comments expressed concern over emissions 

from on-road and in-port activities. 

Thank you for your participation in the National Environmental 

Policy Act process. The Proposed Action does not include these 

activities. The proposed training and testing activities are 

generally consistent with training and testing that the Navy has 

been conducting in the AFTT Study Area for decades. Please see 

Chapter 2 (Description of Proposed Action and Alternatives) of the 

Final EIS/OEIS for a definition of the scope of the project.

28 Individual:

DOWDA-01

State:

S17-08

Two comments expressed concern that the Navy 

does not take into account the ongoing changes to 

the resources being impacted and the “shifting 

baseline”. New and significant noise impacts

combined with an observed global shift in species 

regimes may cause changes in the distribution, 

abundance, and activities of marine life that are not 

fully understood.

The Final EIS/OEIS contains discussions within each biological 

resource section regarding climate change and how physical and 

biological components of the marine environment are changing.

The Navy has used the best available science in its analysis of 

resources and cumulative impacts. The proposed training and 

testing activities are generally consistent with training and testing 

that the Navy has been conducting in the AFTT Study Area for 

decades. As a result, any substantial increases in noise within the 

oceans would be due to commercial shipping and other 

anthropogenic sources. With respect to more localized or regional 

concerns, the Navy has consulted with all coastal states in the 

Study Area on effects to their resources.

29 Individual:

DOWDA-02

The NE ROP data portal includes much information 

that could add to the U.S. Navy EIS/OEIS which tends 

to be data, rich but information poor from my 

perspective as a retired scientist.

The best available science and applicable data relevant to the 

Draft EIS/OEIS were used in the analysis. Within the AFTT Study 

Area, the Northeast and Mid-Atlantic Regional Planning Bodies 

developed Plans that were certified by the National Ocean Council 

in December 2016. In those Plans, the Department of Defense 

committed to using the Plans and Regional Data Portals to inform 

pertinent environmental programs, initiatives, and planning 

documents. The Regional Ocean Plans and Data Portals were used 

as a resource throughout the development of this Final EIS/OEIS.

30 Individual:

DOWDA-03

The U.S. Navy needs to adopt a more dynamic 

conceptual model for the EIS/OEIS to replace the 

Large Marine Ecosystem (LME) approach. 

The LME concept was used in the Final EIS/OEIS to describe the 

current distribution of species and training/testing areas. The LME

concept is recognized by NMFS, and other leading scientific 

organizations, and represents the best available science. 
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Appendix H Public Comment Responses

Table H.3-1. Comment Response Matrix (continued)

Reference 

Number Commenters Comment Response

31 Individual:

DOWDA-04

Fisheries population dynamics models which include 

Essential Fish Habitat and variations in human 

environmental stressors could provide a way forward 

to evaluate the site-specific consequences of U.S.

Navy Training and Testing events and the required 

monitoring programs of effects on wild places, wild 

things.

Habitat-based models of fisheries population dynamics require 

knowing age- and habitat- specific mortality rates from various 

sources and generally when/where they are occurring in terms of 

Essential Fish Habitat/Habitat Areas of Particular Concern. The 

sort of data needed to conduct a habitat-based fishery population 

model is not currently available for the AFTT study area. Even if 

the data were available, the primary sources of mortality for 

fishery populations are (by enormous measure) commercial and 

recreational fishing. The AFTT EIS/OEIS concludes that the

proposed action (e.g., explosions, MEM, seafloor devices) would 

not result in population-level level impacts. The Navy also 

consulted with NMFS regarding impacts to Essential Fish Habitat 

from the Proposed Action. The resulting conservation measures 

were mostly a continuation of existing mitigation measures, with 

the addition of new mitigation for submerged aquatic vegetation

and Habitat Areas of Particular Concern for sandbar sharks. The 

new mitigation measures are presented in Section 5.4.1 

(Mitigation Areas for Seafloor Resources) and Section 5.4.3 

(Mitigation Areas off the Mid-Atlantic and Southeastern United 

States), respectively.

32 Individual:

DOWDA-05

The EIS/OEIS document focuses on marine mammals; 

sea turtles and sea birds. While ignoring the 

important role of forage species/filter feeders.

The Final EIS/OEIS analyzes all physical and biological components 

of the Study Area that could be impacted by the Proposed Action. 

The individual resource sections include: Section 3.2 (Sediments 

and Water Quality), 3.3 (Vegetation), 3.4 (Invertebrates), 3.5 

(Habitats), 3.6 (Fishes), 3.7 (Marine Mammals), 3.8 (Reptiles), 3.9 

(Birds and Bats).
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Appendix H Public Comment Responses

Table H.3-1. Comment Response Matrix (continued)

Reference 

Number Commenters Comment Response

33 Individual:

DOWDA-06

This document would benefit from describing some 

worse case scenarios and how they might be 

mitigated.

The National Environmental Policy Act does not impose a duty on 

an agency to make a "worst case scenario analysis" if it can make a 

reasoned assessment of a proposed project's environmental 

impact. The Navy focused on reasonably foreseeable impacts that 

generate information and discussion on those consequences of 

greatest concern to the public and of greatest relevance to the 

agency's decision, rather than distorting the decision-making 

process by overemphasizing highly speculative or conjectural

harms.

34 Individual:

MCGSA-03

Not enough scientific data has been provided to 

coastal residents to provide an educated opinion on 

the testing. Please allow for further study to educate 

the public. Please complete further studies or 

consider other options.

The Navy complied with the Coastal Zone Management Act 

regarding its impact on coastal resources. All of the potential 

effects from Navy training and testing activities were analyzed in 

Chapter 3 (Affected Environment and Environmental 

Consequences) of the EIS/OEIS. Also, as described in Chapter 5 

(Mitigation) of the Final EIS/OEIS, the Navy implements mitigation 

measures during its training and testing activities.

35 Organization:

O02-05

The Mid-Atlantic Ocean Data Portal 

(http://portal.midatlanticocean.org /data-catalog 

/fishing/) has developed maps from Federallyrequired Vessel Trip Reports (VTRs) and Vessel 

Monitoring Systems (VMS) that represent the 

locations and intensity of commercial fishing during 

2011-2014. These maps could provide additional 

information to support site-specific training plans. 

However, important fishing areas may not be fully 

represented as locations frequently shift annually 

due to factors including market dynamics, regulatory 

changes, and rotational fishing strategies.

As a matter of practice, the Navy typically does not conduct 

certain activities in coastal areas due to specific mission 

requirements (see Section 2.3.3.16, Coastal Zone). For activities 

that could potentially be conducted in a coastal zone, the Navy 

implements procedural mitigation (see Section 5.3, Procedural 

Mitigation to be Implemented) and mitigation areas (see Section 

5.4, Mitigation Areas to be Implemented). The Navy completed a 

full biological assessment and operational analysis of potential 

mitigation areas throughout the entire Study Area. Developing 

additional mitigation areas beyond what is described in Section 

5.4 (Mitigation Areas to be Implemented) would be impractical 

due to implications for safety, sustainability, and the Navy’s ability 

to continue meeting its mission requirements to successfully 

accomplish military readiness objectives. 

Additionally, as discussed in Section 3.11.3.1 (Impacts on
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Appendix H Public Comment Responses

Table H.3-1. Comment Response Matrix (continued)

Reference 

Number Commenters Comment Response

35 (cont.) In addition, staff at NOAA Fisheries Greater Atlantic 

Regional Office and the Fishery Management Council

can be consulted for specific information about the 

location of fishing activities throughout the year as 

specific training exercises are contemplated.

Accessibility), Navy training and testing activities have the 

potential to temporarily change access to ocean areas for safety 

reasons. These areas are relatively limited in size and time, and 

will typically be announced by U.S. Coast Guard and Federal 

Aviation Administration issued Notices to Mariners and Notices to 

Airmen, respectively. The Navy is not proposing to add any new 

restricted areas and proposes to continue the same type of 

temporary area closures that have occurred for decades. 

Therefore, Navy does not foresee there will be any measurable 

impacts to the commercial or recreational fishing industry.

36 Organization:

O03-26

It seems likely that the DEIS does not consider the 

Cul de Sac for geospatial mitigation because the AFTT 

Study Area excludes the OPAREA. Putting aside 

questions of territoriality and statutory jurisdiction, 

the Navy has previously made commitments to 

restrict its training activities in foreign locations, 

including in the Bahamas (where sonar use in the 

Providence Channels has been prohibited since the 

2000 mass stranding event), for the protection of

beaked whales.61 We believe the AFTT EIS/ OEIS 

process is an appropriate vehicle. But regardless of 

whether it uses that process or, as in the case of 

certain other prior commitments, acts independently 

of NEPA and Executive Order 12114, we urge the 

Navy to expeditiously consider the Cul de Sac for 

year-round time-area management to benefit the 

TOTO population of Blainville’s beaked whales.

The Proposed Action does not include these activities. Please see 

Chapter 2 (Description of Proposed Action and Alternatives) of the

Final EIS/OEIS for a definition of the scope of the project.
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Appendix H Public Comment Responses

Table H.3-1. Comment Response Matrix (continued)

Reference 

Number Commenters Comment Response

37 Organization:

O03-28

While the Navy considered establishing Mitigation 

Areas for coastal bottlenose dolphins within a 

portion of the Mississippi Sound, and while the AFTT 

Study Area and the Navy’s Gulf of Mexico Operating 

Areas exclude many of the Gulf’s bays and inlet, it 

did not consider designating a Mitigation Area 

(outside the Mississippi Sound area it did consider) 

to capture waters out to the 20 m isobath, which 

marks the limit of the dolphins’ range. 

Certain populations exhibit seasonal movements 

between the coastal waters of the Gulf and inshore 

bay, sound, and estuary habitat; and some near

coastal bottlenose dolphin populations have been 

observed leaving the Mississippi Sound during the 

winter to temporarily reside outside of the barrier 

islands. The Navy should undertake a more thorough 

analysis of bottlenose dolphin habitat within the 

AFTT Study Area, particularly within those waters 

from Louisiana to western Florida that are still 

recovering from the Deepwater Horizon spill.

In its assessment of potential mitigation, the Navy considered 

implementing additional restrictions on active sonar and 

explosives in the Gulf of Mexico, including within the areas 

affected by the Deepwater Horizon spill. Navy operators 

determined that implementing additional mitigation beyond what 

is described in Section 5.4.4 (Mitigation Areas in the Gulf of 

Mexico) would be impractical due to implications for safety, 

sustainability, and the Navy’s ability to continue meeting its 

mission requirements to successfully accomplish military 

readiness objectives. Some of the considerations regarding why it 

would be impractical to implement additional mitigation in the 

Gulf of Mexico are provided below.

The mitigation identified in Section 5.4 (Mitigation Areas to be 

Implemented) represents the maximum mitigation within the 

identified mitigation areas that is practical to implement under the 

Proposed Action. Operational input indicates that designating 

additional mitigation areas (including dolphin habitat within the 

Deepwater Horizon spill area) would have a significant impact on 

the ability for units to meet their individual training and 

certification requirements (preventing them from deploying with 

the required level of readiness necessary to accomplish their 

missions), to meet national security tasking (limiting the flexibility 

of Combatant Commanders and warfighters to project power, 

engage in multi-national operations, and conduct the full range of 

naval warfighting capability in support of national security 

interests), on the ability of program managers and weapons 

system acquisition programs to meet testing requirements and 

required acquisition milestones; on operational costs (due to 

extending distance offshore, which would increase fuel 

consumption, maintenance, and time on station to complete 

required training and testing activities), on the safety risk 

associated with conducting training and testing at extended 
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Appendix H Public Comment Responses

Table H.3-1. Comment Response Matrix (continued)

Reference 

Number Commenters Comment Response

37 (cont.) distances offshore (farther away from critical medical and search 

and rescue capabilities), on accelerated fatigue-life of aircraft and 

ships (leading to increased safety risk and higher maintenance 

costs), on training and testing realism (due to reduced access to 

necessary environmental or oceanographic conditions that 

replicate potential real world areas in which combat may occur), 

and/or on the ability for Navy Sailors to train and become 

proficient in using the sensors and weapons systems as would be 

required in a real world combat situation.

Furthermore, the iterative and cumulative impact of all 

commenter-proposed mitigation areas and seasonal or temporal 

restrictions would deny national command authorities the 

flexibility to respond to national security challenges as required 

training necessary for deployment would entail movements to 

multiple operational areas along the Eastern seaboard and the 

Gulf of Mexico to conduct training within set time frames. 

Likewise, this iterative and cumulative impact would deny 

weapons system program managers and research, testing, and 

development program managers the flexibility to rapidly field or 

develop necessary systems due to the required use of multiple 

areas within limited timeframes. Additional information regarding 

the operational importance, significant negative impacts on Navy 

training and testing operations, and impracticality of 

implementing the mitigation area proposed by commenter in each 

geographic region mentioned is provided in the responses to 

Commenter Reference numbers 111, 116 through 119, and 121

through 123, as well as in Chapter 5 (Mitigation) of the Final

EIS/OEIS.

38 Organization:

O03-31

Thus there is a need for the Navy to collect more 

information regarding the number, nature, and 

timing of testing and training events that take place 

within, or within close proximity to, important 

The Navy does consider historic use (number and nature of 

training and testing activities) and locational information of 

training and testing activities when developing modelling boxes. 

The timing of training cycles and testing needs varies based on 
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Appendix H Public Comment Responses

Table H.3-1. Comment Response Matrix (continued)

Reference 

Number Commenters Comment Response

38 (cont.) habitat areas, essentially refining the scale of the 

analysis of operations to match the scale of the 

habitat areas considered to be important.

deployment requirements to meet current and emerging threats. 

Due to the variability, the Final EIS/OEIS is structured to provide 

flexibility in training and testing locations, timing, and number. In 

addition, information regarding the exact location of sonar usage 

is classified. Due to the variety of factors, many of which influence 

locations that cannot be predicted in advance (e.g., weather), the 

analysis is completed at a scale that is necessary to allow for 

flexibility.

The purpose of the quantitative acoustic analysis is to provide the 

best estimate of impact/take to marine mammals and Endangered 

Species Act (ESA) listed species for the Final EIS/OEIS and the 

regulator. Specifically, the analysis must take into account 

multiple Navy training and testing activities over large areas of the 

ocean for a five year period; therefore, analyzing activities in 

multiple locations over multiple seasons produces the best 

estimate of impacts/take to inform the Final EIS/OEIS and 

regulators. The scale at which spatially-explicit density models are 

structured is determined by the data collection method and the 

environmental variables that are used to build the model. A 

number of variables that are meaningful to marine mammal 

species, such as sea surface temperature, do not vary or affect 

species on a fine scale. Expecting fine scale resolution from the 

Navy's density database may force artificial granularity on species 

for which it is not biologically meaningful at the population-level. 

Therefore, given the variables that determine when and where 

the Navy trains and tests and the resolution of the density data, 

the analysis of potential impacts is scaled to the level that the data 

fidelity will support. This data is provided in the Final EIS/OEIS and 

to the regulator to determine potential impacts/take on a 

population of animals.

39 Organization:

O03-32, O03-33

Two comments urged the Navy to further investigate 

and research sonar signal modification as a potential 

mitigation measure.

Sonar signals are designed explicitly to provide optimum 

performance at detecting underwater objects (e.g., submarines) in 

a variety of acoustic environments. Although the Navy
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Appendix H Public Comment Responses

Table H.3-1. Comment Response Matrix (continued)

Reference 

Number Commenters Comment Response

39 (cont.) acknowledges that this very limited data set suggests up or down 

sweeps of the sonar signal may result in different animal 

reactions, this is a very small data sample and this science requires 

further development. If future studies indicate this could be an 

effective approach, then Navy will investigate the feasibility and 

practicality of modifying signals, based on tactical considerations 

and cost, to determine how it will affect the sonar's performance.

40 Organization:

O03-37

In addition to continuing to make funds available to 

support long-term monitoring studies, we 

recommend that, in the future, the Navy’s Marine 

Species Monitoring Program expand funding for 

projects that aim to quantify the impact of Navy 

activities at the individual, and ultimately, 

population-level. 

The Navy established the Strategic Planning Process under the 

marine species monitoring program to help structure the 

evaluation and prioritization of projects for funding. Section 

5.1.1.1.3 of the Final EIS/OEIS provides a brief overview of the 

Strategic Planning Process. More detail, including the current 

intermediate scientific objectives, is available on the monitoring 

portal as well as in the Strategic Planning Process report. The 

Navy's evaluation and prioritization process is driven largely by a 

standard set of criteria that help the steering committee evaluate 

how well a potential project addresses the primary objectives of 

the monitoring program. NMFS has opportunities to provide input 

regarding the Navy's intermediate scientific objectives as well as 

providing feedback on individual projects through the annual 

program review meeting and annual report. For additional 

information, please visit: 

https://www.navymarinespeciesmonitoring.us/about/strategicplanning-process/ 

Details on the Navy's involvement with future research will 

continue to be developed and refined by Navy and NMFS through 

the consultation and adaptive management processes, which 

regularly considers and evaluates the development and use of 

new science and technologies for Navy applications. The Navy will 

continue to be a leader in funding of research to better 

understand the potential impacts of Navy training and testing 

activities and to operate with the least possible impacts while 

meeting training and testing requirements.
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Appendix H Public Comment Responses

Table H.3-1. Comment Response Matrix (continued)

Reference 

Number Commenters Comment Response

41 Organization:

O03-38

First, detailed, individual-level behavioral response 

studies, such as focal follows and tagging using 

DTAGs, carried out before, during, and after Navy 

operations, can provide important insights for these 

species and stocks and we encourage the Navy to 

expand funding for certain of these projects. 

In addition to the Navy's marine species monitoring program 

investments in the topic of individual-level behavioral response 

studies, the Office of Naval Research Marine Mammals and 

Biology program and the Navy’s Living Marine Resources program 

continue to heavily invest in this topic. 

For example, the following studies are currently being funded:

 The Southern California Behavioral Response Study 

(Principal Investigators: John Calambokidis and Brandon 

Southall)

 Cuvier's Beaked Whale and Fin Whale Behavior During 

Military Sonar Operations: Using Medium-term Tag 

Technology to Develop Empirical Risk Functions (Principal 

Investigators: Greg Schorr and Erin Falcone)

 3S3- Behavioral responses of sperm whales to naval sonar 

(Principal Investigators: Petter Kvadsheim and FransPeter Lam)

 Measuring the effect of range on the behavioral response 

of marine mammals through the use of Navy sonar 

(Principal Investigators: Stephanie Watwood and Greg 

Schorr)

 Behavioral response evaluations employing robust 

baselines and actual Navy training (BREVE) (Principal 

Investigators: Steve Martin, Tyler Helble, Len Thomas)

 Integrating remote sensing methods to measure baseline 

behavior and responses of social delphinids to Navy sonar 

(Principal Investigators: Brandon Southall, John 

Calambokidis, John Durban). 

Please visit http://greenfleet.dodlive.mil/environment/ and 

https://www.onr.navy.mil/ScienceTechnology/Departments/Code-32/All-Programs/AtmosphereResearch-322/Marine-Mammals-Biology for further information

regarding these projects.
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Appendix H Public Comment Responses

Table H.3-1. Comment Response Matrix (continued)

Reference 

Number Commenters Comment Response

42 Organization:

O03-39

Recent studies using DTAGs have also been used to 

characterize social communications between 

individuals of a species or stock, including between 

mothers and calves; we recommend that the Navy 

prioritize funding studies that further characterize 

the suite of vocalizations related to social

interactions.

The Navy has funded a variety of projects that are collecting data 

that can be used to study social interactions amongst individuals. 

Examples of these projects include: 

 Southern California Behavioral Response Study (Principal 

Investigators: John Calambokidis and Brandon Southall) 

 Tagging and Tracking of Endangered North Atlantic Right 

Whales in Florida Waters (Principal Investigators: Doug 

Nowacek and Susan Parks). This project involves the use 

of DTAGs, and data regarding the tagged individual and 

group are collected in association with the tagging event. 

In addition to the vocalization data that is being collected 

on the DTAGs, data is collected on individual and group 

behaviors that are observed, including between 

mother/calf pairs when applicable. The Navy will 

continue to collect this type of data when possible.

 Integrating remote sensing methods to measure baseline 

behavior and responses of social delphinids to Navy sonar 

(Principal Investigators: Brandon Southall, John 

Calambokidis, John Durban.)

 Acoustic Behavior of North Atlantic Right Whale 

(Eubalaena glacialis) Mother-Calf Pairs (Principal 

Investigators: Susan E. Parks and Sofie Van Parijs). The 

long-term goal of this project is to quantify the behavior 

of mother-calf pairs from the North Atlantic right whale 

to determine a) why mothers and calves are more 

susceptible to collisions with vessels and, b) determine 

the vocal behavior of this critical life stage to assess the 

effectiveness of passive acoustic monitoring to detect 

mother-calf pairs in important habitat areas (see

https://www.onr.navy.mil/reports/FY15/mbparks.pdf.)

Social Ecology and Group Cohesion in Pilot Whales and their 

Responses to Playback of Anthropogenic and Natural Sounds
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Appendix H Public Comment Responses

Table H.3-1. Comment Response Matrix (continued)

Reference 

Number Commenters Comment Response

42 (cont.) (Principal Investigator: Frants H. Jensen). This project investigates

the social ecology and cohesion of long-finned pilot whales as part 

of a broad multi-investigator research program that seeks to 

understand how cetaceans are affected by mid frequency sonar 

and other sources of anthropogenic noise (see 

https://www.onr.navy.mil/reports/FY15/mbjensen.pdf).

43 Organization:

O03-40

We recommend that the Navy make funds available 

to use these technologies for assessing marine 

mammal behavior before, during, and after Navy 

operations (e.g. swim speed and direction, group 

cohesion). In addition, studies into how these 

technologies can be used to assess body condition 

should be supported as this can provide an 

important indication of energy budget and health, 

which can inform the assessment of population-level 

impacts.

Studies that use unmanned aerial vehicles to assess marine 

mammal behaviors and body condition are being funded by the 

Office of Naval Research Marine Mammals and Biology program. 

Although the technology shows promise, the field limitations 

associated with the use of this technology has hindered the useful 

application in behavioral response studies in association with Navy 

training and testing events. For safety reasons, research vessels 

cannot remain in close proximity to Navy vessels during Navy 

training or testing events, so battery life of the unmanned aerial 

vehicles has been an issue. In addition to researching unmanned 

platforms, the Navy plans to continue researching thermal 

detection systems to determine their effectiveness and 

compatibility with Navy applications. If thermal detection 

technology matures to the state where it is determined to be an 

effective mitigation tool during training and testing, the Navy will 

assess the practicality of using the technology during training and 

testing events and retrofitting its observation platforms with 

thermal detection devices. The Navy will provide information to 

NMFS about the status and findings of Navy funded studies and 

any associated practicality assessments at the annual adaptive 

management meetings.

However, as the technology improves, the Navy will continue to 

assess the applicability of this technology for the Navy’s research 

and monitoring programs. An example project is Integrating 

Remote Sensing Methods to Measure Baseline Behavior and 

Responses of Social Delphinids to Navy sonar (Principal 
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Appendix H Public Comment Responses

Table H.3-1. Comment Response Matrix (continued)

Reference 

Number Commenters Comment Response

43 (cont.) Investigators: Brandon Southall, John Calambokidis, and John 

Durban).

44 Organization:

O03-41

We therefore recommend the Navy expand funding 

to explore the utility of other, simpler modeling 

methods that could provide at least an indication of 

population-level effects, even if each of the 

behavioral and physiological mechanisms are not 

fully characterized. Additionally, we encourage the 

Navy to contribute increased funds to studies aimed 

at exploring other potential proxy measures of 

changes in population-level abundance in order to 

develop an early-detection system for populations 

that may be experiencing a decline as a result of 

Navy activities.

The Office of Naval Research Marine Mammals and Biology 

program has invested in the Population Consequences of 

Disturbance (PCoD) model, which provides a theoretical 

framework and the types of data that would be needed to assess 

population-level impacts. Although the process is complicated and 

many species are data poor, this work has provided a foundation 

for the type of data that is needed. Therefore, in the future, 

relevant data that is needed for improving the analytical 

approaches for population-level consequences resulting from 

disturbances will be collected during projects funded by the 

Navy’s marine species monitoring program. General populationlevel trend analysis is conducted by NMFS through their stock 

assessment reports and regulatory determinations. The Navy’s 

analysis of effects to populations (species and stocks) of all 

potentially exposed marine species, including marine mammals 

and sea turtles, is based on the best available science as discussed 

in Section’s 3.7 (Marine Mammals) and 3.8 (Reptiles). PCoD 

models, similar to many fisheries stock assessment models, once 

developed will be powerful analytical tools when mature. 

However, currently they are dependent on too many unknown 

factors for these types of models to produce a reliable answer.

45 Organization:

O04-01

The Atlantic sea scallop is notably absent from the 

list of species on page 3.4-4, but can be quite 

abundant in certain habitat types, namely areas with 

sand and gravel sediments and depths of 18-110 

meters. 

Page 3.4-4 does not provide a comprehensive list of species, only 

sample lists of taxonomic groups including scallops. The intent of 

this section was not to provide a comprehensive list of 

invertebrate species tied to any particular location, but rather 

taxonomic/morphologic/behavioral groups that were the subject 

of analysis regarding sparse impacts spread across a vast study 

area. 
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Appendix H Public Comment Responses

Table H.3-1. Comment Response Matrix (continued)

Reference 

Number Commenters Comment Response

46 Organization:

O04-06

Coral distributions in the New England and MidAtlantic regions are well documented in the recent 

plan amendments/environmental assessments 

developed by the Mid-Atlantic and New England 

Fishery Management Councils, and we would be 

happy to provide the Navy with specific information 

based on our recent work. NMFS, a collaborating 

agency on the EIS, has substantial expertise in this 

area and is the source of most of our coral data.

Thank you for offering the data. The Navy did consider and use the 

data, as appropriate, in the analysis.

47 Organization:

O04-12a

With respect to fishing activity, the summary 

provided in section 3.11.2.4 is a good overview of 

commercial and recreational fishing in the Atlantic 

and Gulf regions, but would benefit from additional 

specifics. It would be helpful to include an 

assessment of the likely spatial overlap between 

specific types of fishing activities with the locations 

where training and testing activities are likely to be 

concentrated. Fishing activities could be grouped by 

target species, fishery management plan, or gear 

type. Such an analysis would not need to be overly 

specific to be useful; as both fishing activities and 

Naval testing and training are somewhat difficult to 

forecast precisely, this would be challenging in any 

case. 

Fishing effort maps are available on regional ocean 

data portals such as http://www. 

northeastoceandata .org/ and

http://portal .midatlanticocean .org/.

Within the AFTT Study Area, the Northeast and Mid-Atlantic 

Regional Planning Bodies developed Plans that were certified by 

the National Ocean Council in December 2016. In those Plans, the 

Department of Defense committed to using the Plans and 

Regional Data Portals to inform pertinent environmental 

programs, initiatives, and planning documents. The Regional 

Ocean Plans and Data Portals were used as a resource throughout 

the development of this EIS/OEIS. Additionally, because the 

proposed activities would not lead to a noticeable change in Navy 

presence, and because the proposed locations for these activities 

do not differ much from historical use, it is unlikely that 

commercial and recreational fishing activities would be noticeably 

affected by Navy activities requiring area restrictions.
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Appendix H Public Comment Responses

Table H.3-1. Comment Response Matrix (continued)

Reference 

Number Commenters Comment Response

48 Organization:

O05-02, O05-04

Two comments were specific to concerns over 

potential impacts to the Narragansett Bay from the 

Proposed Action.

Appendix A (Navy Activity Descriptions) provides the activities that 

may occur within inland waters and pierside locations. For 

example, the only training events identified as occurring within 

Narragansett Bay are Maritime Security Operations (section 

A.2.9.13) and Waterborne Training (section A.2.10.9). The timing 

of training cycles and testing needs varies based on deployment 

requirements to meet current and emerging threats. As such, the 

AFTT EIS/OEIS is structured to provide flexibility in training and 

testing locations, timing, and number of events. Due to the variety 

of factors, many of which influence locations that cannot be 

predicted in advance (e.g., weather), the information and analysis 

provided is at a geographic scale necessary to allow for flexibility. 

Additionally, the activities occurring within and near Narragansett 

Bay are consistent with activities that have been occurring in the 

area for decades, to which no effects to the Bay or watershed 

have been identified.

49 Organization:

O05-03, O05-11

Two comments expressed that the Navy did not 

adequately address or inform the public of the 

potential direct, indirect, or cumulative impacts 

resulting from the proposed activities. 

The Navy’s analysis of direct and indirect effects is described in 

Chapter 3.0.3 (Overall Approach to Analysis). Generally for each 

resource analyzed in Chapter 3 (Affected Environment and 

Environmental Consequences), the direct impacts from individual 

stressors are analyzed first, followed by, where applicable, the 

secondary stressors, and then concludes with a summary of the 

potential impacts of combined stressors (all direct and indirect). 

The analysis of cumulative impacts is provided in Chapter 4 

(Cumulative Impacts). Further, the U.S. EPA has reviewed the 

Draft EIS/OEIS and rated the Draft EIS/OEIS as LO-Lack of 

Objections-which means, it has not identified any environmental 

impacts requiring substantive changes to the proposal.

50 Organization:

O05-09

Despite the critical importance of SAV to 

Narragansett Bay and the close proximity of SAV to 

training and testing grounds, most graphics depicting 

Narragansett Bay make it impossible to discern any 

detail due to their scale.

The Phase III Essential Fish Habitat Assessment can be found on 

the project website (www.aftteis.com) and has a full page map of 

Narragansett Bay including up-to-date mapping of seagrass beds, 

seaweed beds, rocky shorelines, rocky bottoms, shipwrecks, etc.
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Appendix H Public Comment Responses

Table H.3-1. Comment Response Matrix (continued)

Reference 

Number Commenters Comment Response

Acoustics and Explosives

51 Federal:

F02-04

Acknowledge all the park units in the study area and 

include an analysis of all noise generating activities 

(airborne and marine) that could impact national 

park resources and values even when not occurring 

within park boundaries. In particular, the NPS 

requests that the Final EIS include a more thorough 

analysis of potential impacts that airborne noise 

sources may have on wilderness values, recreational 

activities and visitor experience in and around NPS 

units. Certain site-specific noise sources may warrant 

inclusion and potential mitigation in the document 

due to their specific location and potential severity of 

impacts.

The Navy added several parks to Chapter 6 Table 6.1-2 that had 

not been previously identified in the Draft EIS/OEIS. These include: 

Fort Carolina National Memorial; Gulf Islands National Seashore; 

Fort Sumter National Monument; Acadia National Park; Boston 

Harbor Islands National Recreation Area; Christiansted National 

Historic Site; Fort Monroe National Monument; Colonial National 

Historic Park; and Sandy Point National Wildlife Refuge. All these 

locations are either within the Study Area or are directly adjacent 

to the Study Area. The rest of the areas provided in Attachment A 

to the comment letter were in close proximity to the Study Area, 

but generally, noise producing activities conducted by the Navy 

near coastal National Parks, Historic Sites or Monuments would 

occur greater than 12 NM from the coast. Aircraft noise would be 

intermittent due to transits from airfields to the operating areas at 

sea. Any activities occurring on the coast, would generally occur 

on Department of Defense controlled beaches. These operating 

parameters will prevent or reduce any noise impacts to park 

resources. The Final EIS/OEIS includes more information regarding 

potential impacts of wilderness values, recreational activities and 

visitor experience from airborne noise to Section 3.11 

(Socioeconomics) with regard to park units.

52 Federal:

F05-01

The Commission notes that 30 iterations or Monte 

Carlo simulations is low for general bootstrapping 

methods but understands that increasing the 

number of iterations in turn increases the 

computational time needed to run the models.

Accordingly, the Commission suggests that, if the 

computation time is not overly burdensome, the 

Navy consider increasing the iterations from 30 to at 

least 200 for activities that have yet to be modeled 

for Phase III and for all activities in Phase IV.

The 30 iterations used in Navy Acoustic Effects Model (NAEMO)

represent the number of iterations run for each of the four 

seasons analyzed in AFTT Phase III which results in a total of 120 

iterations per year for each event analyzed. For other areas where 

only warm and cold seasons are analyzed, the number of 

iterations per season is increased to 60 so that the same 120 

iterations per year are maintained. Navy reached this number of 

iterations by running two iterations of a scenario and calculating 

the mean of exposures, then running a third iteration and 

calculating the running mean of exposures, then a fourth iteration 

and so on. This is done until the running mean becomes stable.
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Appendix H Public Comment Responses

Table H.3-1. Comment Response Matrix (continued)

Reference 

Number Commenters Comment Response

52 (cont.) Through this approach, it was determined 120 iterations was 

sufficient to converge to a statistically valid answer and provides a 

reasonable uniformity of exposure predictions for most species 

and areas. There are a few exceptions for species with sparsely 

populated distributions or highly variable distributions. In these 

cases, the running mean may not flatten out (or become stable); 

however, there were so few exposures in these cases that while 

the mean may fluctuate; the overall number of exposures did not 

result in significant differences in the totals. In total, the number 

of simulations conducted for AFTT Phase III exceeded six million 

simulations and produced hundreds of terabytes of data. 

Increasing the number of iterations, based on the discussion 

above, would not result in a significant change in the results, but 

would incur a significant increase in resources (e.g., computational 

and storage requirements). This would divert these resources 

from conducting other more consequential analysis without 

providing for meaningfully improved data. The Navy is continually 

looking at ways to improve NAEMO and reduce data and 

computational requirements. As technologies and computational 

efficiencies improve, Navy will evaluate these advances and 

incorporate them where appropriate. 

53 Federal:

F05-02

Therefore, the Commission again recommends that 

the Navy use its spatially and temporally dynamic 

simulation models (e.g., randomly-generated 

munition trajectories and animat simulations) rather 

than simple probability calculations to estimate 

strike probabilities and number of takes from 

expended munitions and non- explosive materials.

The recommendation of the Marine Mammal Commission to use a 

dynamic simulation model to estimate expended munitions and 

non- explosive materials strike probability was considered, but the 

Navy found that the current analysis used in the Final EIS/OEIS is 

more conservative and over estimates the potential impacts to 

marine mammals. An analysis of direct strike resulting from 

expended materials conducted in a dynamic simulation model 

such as NAEMO would also be a probability analysis, however it 

would be conducted in a different manner.

The current analysis provides an overestimation of the probability 

of a strike for the following reasons: (1) calculates the probability 

of a single military item (of all the items expended over the course
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Appendix H Public Comment Responses

Table H.3-1. Comment Response Matrix (continued)

Reference 

Number Commenters Comment Response

53 (cont.) of the year) hitting a single animal at its species' highest seasonal 

density, (2) does not take into account the possibility that an 

animal may avoid military activities, (3) does not take into account 

the possibility that an animal may not be at the water surface, (4) 

does not take into account that most projectiles fired during 

training and testing activities are fired at targets, and not all 

projectiles would hit the water with their maximum velocity and 

force, and (5) does not quantitatively take into account the Navy 

avoiding animals that are sighted through the implementation of 

mitigation measures. In order to be more conservative, the Navy 

will continue using this method.

54 Federal:

F05-03

As such, the Commission recommends that the Navy 

review Branstetter et al. (2017) and determine 

whether inclusion of the killer whale audiogram data 

would alter the composite audiograms, weighting 

functions, and/or weighted thresholds for the 

various functional hearing groups and if so, whether 

those modifications are sufficient to warrant 

revisions in the current weighting functions and 

associated thresholds as stipulated in Department of 

Navy (2017).

The Navy developed the current Phase III temporary and 

permanent threshold shift (TTS) thresholds and weighting

functions in coordination with NMFS and in turn NMFS adopted 

these criteria for species under their regulatory purview. Navy

reviewed Branstetter et. al. 2017 and is cited in Section 3.7.2.1.4, 

Hearing and Vocalization. We will continue to review and evaluate 

new relevant data as it becomes available. Since the methodology 

for deriving composite audiograms and associated marine 

mammal auditory weighting functions, as well as TTS thresholds is 

data driven, any new information that becomes available has the 

potential to cause some amount of change for that specific 

hearing group but also other hearing groups, if they rely on 

surrogate data. It may not be feasible to make changes every time 

a new data point becomes available. Instead, Navy will periodically 

examine new data to date and consider the impacts of those 

studies on the Technical Guidance to determine what 

revisions/updates may be appropriate. Thus far, no new 

information has been published or otherwise conveyed that would 

fundamentally change the assessment of impacts or conclusions 

of this Final EIS/OEIS.

55 Federal:

F05-04

Two comments expressed concern over the use of 

cut-off distances in the analysis estimating the 

The consideration of proximity (cut-off distances) was part of the 

criteria developed in consultation with NMFS and was applied 
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Appendix H Public Comment Responses

Table H.3-1. Comment Response Matrix (continued)

Reference 

Number Commenters Comment Response

55 (cont.) Organization:

O03-50

numbers of marine mammal takes. within the Navy's acoustic effects model. Cut-off distances were 

used to better reflect the take potential for military readiness 

activities as defined in the MMPA. As stated in Draft EIS/OEIS 

Section 3.7.3.1.2.1, the derivation of the behavioral response 

functions and associated cut-off distances is provided in the 2017 

technical report titled Criteria and Thresholds for U.S. Navy 

Acoustic and Explosive Effects Analysis (Phase III). Briefly, much of 

the data used to derive the behavioral response functions was 

from nearby, scaled sources, thereby potentially confounding 

results since it is difficult to tell whether the focal marine mammal 

is reacting to the sound level or the proximity of the source and/or 

vessel amongst other potentially confounding contextual factors 

that are unlike actual Navy events for which the behavioral 

response functions (BRF’s) are being derived. To account for these 

non-applicable contextual factors, all available data on marine 

mammal reactions to actual Navy activities and sound sources (or 

other large scale activities such as seismic surveys when 

information on proximity to sonar sources is not available for a 

given species group, i.e. harbor porpoises) were reviewed to find 

the farthest distance to which significant behavioral reactions 

were observed. These distances were rounded up to the nearest 5 

or 10 km interval, and for moderate to large scale activities using 

multiple or louder sonar sources, these distances were greatly 

increased --- doubled in most cases. The Navy’s BRF’s applied 

within these distance is currently the best know method for 

providing the public and regulators with a more realistic (but still 

conservative where some uncertainties exist) estimate of impact 

and potential take under military readiness for the proposed 

actions within this Final EIS/OEIS. 

56 Federal:

F05-05

Therefore, the Commission recommends that the 

Navy include behavior takes of marine mammals 

during all explosive activities, including those that 

involve single detonations. 

As stated in Final EIS/OEIS Section 3.7.3.2.2.1 (Methods for 

Analyzing Impacts from Explosives), the derivation of the explosive 

injury criteria is provided in the 2017 technical report titled 

Criteria and Thresholds for U.S. Navy Acoustic and Explosive Effects 
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Appendix H Public Comment Responses

Table H.3-1. Comment Response Matrix (continued)

Reference 

Number Commenters Comment Response

56 (cont.) Analysis (Phase III). This report was provided as supporting 

documentation to the AFTT EIS/OEIS.

There is no evidence to support that animals have significant 

behavioral reactions to temporally and spatially isolated 

explosions. The Navy has been monitoring detonations since the 

1990's and has not observed these types of reactions.

TTS and all other higher order impacts are assessed for all training 

and testing events that involve the use of explosives or explosive 

ordnance. All Navy’s monitoring projects, reports and publications 

are available on the marine species monitoring webpage 

(https://www.navymarinespeciesmonitoring.us/).

57 Federal:

F05-06

The Commission recommends that the Navy (1) 

specify why the constants and exponents for onset 

mortality and onset slight lung injury thresholds for 

Phase III have been amended, (2) ensure that the 

modified equations are correct, and (3) specify 

whether any additional assumptions were made.

As stated in Section 3.7.3.2.2.1 (Methods for Analyzing Impacts 

from Explosives), the derivation of the explosive injury equations 

is provided in the 2017 technical report titled Criteria and 

Thresholds for U.S. Navy Acoustic and Explosive Effects Analysis 

(Phase III).

58 Federal:

F05-07

Multiple common dolphins were killed during one of 

the Navy’s underwater detonation events in March 

2011 (Danil and St. Leger 2011). Although the 

effectiveness of the Navy’s mitigation measures has 

yet to be determined, those circumstances make it 

clear that the Navy’s mitigation measures are not 

fully effective, especially for explosive activities. 

Thus, it would be prudent for the Navy to estimate 

injuries and mortalities based on onset rather than a 

50-percent incidence of occurrence. The Navy did 

indicate that it is reasonable to assume for impact 

analysis—thus its take estimation process—that 

extensive lung hemorrhage is a level of injury that 

would result in wild animal mortality (Department of 

the Navy 2017). It is unclear why the Navy did not

Based on an extensive review of the incident referred to by the 

commenter, the Navy, in consultation with NMFS, revised and 

updated the mitigation for these types of events. There have been 

no further incidents since these mitigation changes were 

instituted.

The Navy used the range to one percent risk of mortality and 

injury (referred to as “onset” in the Draft EIS/OEIS) to inform the 

development of mitigation zones for explosives. In all cases, the 

mitigation zones for explosives extend beyond the range to one 

percent risk of non-auditory injury, even for a small animal 

(representative mass = 5 kg). In the Final EIS/OEIS, the Navy has 

clarified that the “onset” non-auditory injury and mortality criteria

are actually one percent risk criteria.

Over-predicting impacts, which would occur with the use of one 
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Appendix H Public Comment Responses

Table H.3-1. Comment Response Matrix (continued)

Reference 

Number Commenters Comment Response

58 (cont.) follow through with that premise.

The Commission recommends that the Navy use 

onset mortality, onset slight lung injury, and onset GI 

tract injury thresholds to estimate both the numbers 

of marine mammal takes and the respective ranges 

to effect.

percent non-auditory injury risk criteria in the quantitative 

analysis, would not afford extra protection to any animal. The 

Navy, in coordination with NMFS, has determined that the 50 

percent incidence of occurrence is a reasonable representation of 

a potential effect.

59 Federal:

F05-12

Given that sound sources are moving, it may not be 

until later in an exercise that the animal is close 

enough to experience PTS and it is those few close 

pings that contribute to the potential to experience 

PTS. An animal being beyond the PTS zone initially 

has no bearing on whether it will come within close 

range later during an exercise since both sources and 

animals are moving. In addition, Navy vessels may 

move faster than the ability of the animals to

evacuate the area. The Navy should have been able 

to query the dosimeters of the animats to verify 

whether its 5-percent assumption was valid.

As stated in Final EIS/OEIS Section 3.7.3.1.2.1 (Methods for 

Analyzing Impacts from Sonar and Other Transducers), the 

consideration of marine mammals avoiding the area immediately 

around the sound source, is provided in the 2018 technical report 

titled Quantifying Acoustic Impacts on Marine Mammals and Sea 

Turtles: Methods and Analytical Approach for Phase III Training 

and Testing. This report was provided as supporting 

documentation to the Draft EIS/OEIS. As the commenter correctly 

articulates: “For avoidance, the Navy assumed that animals 

present beyond the range to onset PTS for the first three to four 

pings are assumed to avoid any additional exposures at levels that 

could cause PTS.” That equated to approximately 5 percent of the 

total pings or 5 percent of the overall time active; therefore, 95 

percent of marine mammals predicted to experience PTS due to 

sonar and other transducers were instead assumed to experience 

TTS. As discussed in the Quantitative Analysis for Estimating 

Acoustic and Explosive Impacts to Marine Mammals and Sea 

Turtles, animats in the Navy's acoustic effects model do not move 

horizontally or 'react' to sound in any way, necessitating the 

additional step of considering animal avoidance of close-in PTS 

zones. This approach is fully supported by the best available 
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Appendix H Public Comment Responses

Table H.3-1. Comment Response Matrix (continued)

Reference 

Number Commenters Comment Response

59 (cont.) science. Based on a growing body of behavioral response research, 

animals do in fact avoid the immediate area around sound sources 

to a distance of a few hundred meters or more depending upon 

the species. Avoidance to this distance greatly reduces the 

likelihood of impacts to hearing such as (TTS and PTS, 

respectively). Specifically, the ranges to PTS for most marine 

mammal groups are within a few tens of meters and the ranges for 

the most sensitive group, the HF cetaceans, average about 200 m, 

to a maximum of 270 m in limited cases; however HF cetaceans 

such as harbor porpoises, have been observed reacting to 

anthropogenic sound at greater distances than other species and 

are likely to avoid their zones to hearing impacts (TTS and PTS) as 

well. Querying the dosimeters of the animats would not produce 

useful information since, as discussed previously, the animats do 

not move in the horizontal and are not programmed to "react" to 

sound or any other stimulus.

60 Federal:

F05-13

Therefore, the Commission again recommends that 

the Navy (1) provide the total numbers of modelestimated Level A harassment (PTS and slight lung

and GI injuries) and mortality takes rather than 

reduce the estimated numbers of takes based on the 

Navy’s post-model analyses and (2) include the 

model-estimated Level A harassment and mortality 

takes in its LOA application to inform NMFS’s 

negligible impact determination analyses.

As stated in Draft EIS/OEIS Section 3.7.3.1.2.1 (Methods for 

Analyzing Impacts from Sonar and Other Transducers) and in 

Section 3.7.2.2.1 (Methods for Analyzing Impacts from Explosives), 

the consideration of marine mammal avoidance and mitigation 

effectiveness is integral to the Navy's overall analysis of impacts 

from sonar and explosive sources. Details of this analysis are 

provided in the 2018 technical report titled Quantifying Acoustic 

Impacts on Marine Mammals and Sea Turtles: Methods and 

Analytical Approach for Phase III Training and Testing. 

As discussed in the 2018 technical report titled Quantifying 

Acoustic Impacts on Marine Mammals and Sea Turtles: Methods 

and Analytical Approach for Phase III Training and Testing,

animats in the Navy's acoustic effects model do not move 

horizontally or 'react' to sound in any way. The current best 

available science based on a growing body of behavioral response 

research shows that animalsdo in fact avoid the immediate area 

around sound sources to a distance of a few hundred meters or
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Appendix H Public Comment Responses

Table H.3-1. Comment Response Matrix (continued)

Reference 

Number Commenters Comment Response

60 (cont.) more depending upon the species. Avoidance to this distance 

greatly reduces the likelihood of impacts to hearing such as TTS

and PTS, respectively). 

Specifically, the ranges to PTS for most marine mammal groups 

are within a few tens of meters and the ranges for the most 

sensitive group, the HF cetaceans, average about 200 m, to a 

maximum of 270 m in limited cases; however HF cetaceans such 

as harbor porpoises, have been observed reacting to 

anthropogenic sound at greater distances than other species and 

are likely to avoid their zones to hearing impacts (TTS and PTS) as 

well. 

As discussed in the 2018 technical report titled Quantifying 

Acoustic Impacts on Marine Mammals and Sea Turtles: Methods 

and Analytical Approach for Phase III Training and Testing, the 

Navy's acoustic effects model does not consider procedural 

mitigations (i.e., power-down or shut-down of sonars, or pausing 

explosive activities when animals are detected in specific zones 

adjacent to the source) which necessitates consideration of these 

factors in the Navy's overall acoustic analysis. Credit taken for 

mitigation effectiveness is extremely conservative. Not 

considering animal avoidance and mitigation effectiveness would

lead to a great over-estimate of injurious impacts. NMFS has 

concurred with the analytical approach used.

61 Federal:

F05-14

Therefore, the Commission recommends that the 

Navy (1) specify what modeling method and 

underlying assumptions were used to estimate PTS 

and TTS zones for pile driving activities and (2) clarify 

why those zones were estimated to be the same for 

LF and HF.

As stated in Section 3.7.3.1.4.1 (Methods for Analyzing Impacts 

from Pile Driving), the Navy used measured values for source 

levels and transmission loss from pile driving of the Elevated 

Causeway System, the only pile driving activity included in the 

Proposed Action of this EIS/OEIS. These recorded source 

waveforms were weighted using the auditory weighting functions. 

Low-frequency and high-frequency cetaceans have similar ranges 

for impact pile driving since low-frequency cetaceans would be 

relatively more sensitive to the low-frequency sound which is 
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Appendix H Public Comment Responses

Table H.3-1. Comment Response Matrix (continued)

Reference 

Number Commenters Comment Response

61 (cont.) below high-frequency cetaceans best range of hearing. Neither the 

NMFS user spreadsheet nor NAEMO were required for 

calculations. An area density model was developed in MS Excel 

which calculated zones of influence to thresholds of interest (e.g., 

behavioral response) based on durations of pile driving and the 

aforementioned measured and weighted source level values. The 

resulting area was then multiplied by density of each marine 

mammal species that could occur within the vicinity. This 

produced an estimated number of animals that could be impacted 

per pile, per day, and overall during the entire activity for both the 

impact pile driving and vibratory removal phases.

62 Federal:

F07 -01

The NOAA Office of Coast Survey requests that if any 

depth-sounding sonars will be operated in the course 

of the action, please record the collected data and 

share it with NOAA's National Centers for 

Environmental Information (NCEI) database. (See 

https://www.ncei.noaa.gov/.)

Bathymetric surveys are currently not part of the Proposed Action; 

therefore, the requested data is not collected or available from 

the training and testing activities in AFTT.

63 State:

S05-46

We also request that the navy validate its Acoustic 

Effects Model in-situ in Southeast U.S. waters to 

ensure that take estimates from active sonar and 

ordnance detonation are as accurate as possible.

The acoustic propagation models have been validated and 

approved by the Oceanographic and Atmospheric Master Library. 

These models are the same used for Navy’s tactical decision aids.

64 State:

S24-01b

It is recommended the EIS/OEIS contain as much 

descriptive information as to potential effects to 

these resources including cumulative activities that 

may affect certain species to include increased 

anthropogenic noise in the ocean associated with all 

aspects of testing and training within the Northwest 

Atlantic Ocean Distinct Population Segment (DPS). 

Within the North Atlantic DPS, U.S. NMFS has 

designated thirty-six (36) marine areas as critical 

habitat. Each of these areas consist of multiple or a 

combination of habitat types, but the most 

important habitat to consider with regard to

The potential for combined impacts on all of the stressors 

introduced by Navy training and testing activities are evaluated in 

Section 3.8.4 (Summary of Potential Impacts on Reptiles). 

Cumulative impacts from the Proposed Action, as well as Federal 

and non-Federal actions, regarding sea turtles and anthropogenic 

noise, are discussed in Section 4.4.8 (Reptiles) of the Cumulative 

Impacts chapter. Potential impacts of anthropogenic noise 

introduced by Navy training and testing activities are discussed 

and analyzed in Sections 3.8.3.1 (Acoustics Stressors) and 3.8.3.2 

(Explosive Stressors) for sea turtles, including the loggerhead 

Northwest DPS and its designated critical habitat. Only species and 

their critical habitat (if designated) were given a determination of
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Appendix H Public Comment Responses

Table H.3-1. Comment Response Matrix (continued)

Reference 

Number Commenters Comment Response

64 (cont.) testing and training is restricted migratory corridors 

in federal waters. 

NMFS also received special management 

considerations for foraging habitat in two large areas 

that contain Sargassum habitat, which presumably is 

located in the same area as the planned activities.

effect on the potential impacts of the Proposed Action. Foraging 

habitat is not a designated critical habitat type for the loggerhead 

Northwest Atlantic DPS (79 FR 39855) so it was not explicitly 

analyzed for an effect determination. 

Sargassum habitat is a designated critical habitat type and this was 

addressed in the analysis. However, some of the known 

foraging/developmental habitats for the loggerhead Northwest 

Atlantic DPS are addressed in Section 3.8.2.2.4 (Loggerhead Turtle 

(Caretta caretta)) as well as considered in some of the U.S. Navy 

stressor analysis sections in Section 3.8.3 (Environmental 

Consequences). The NMFS consultation document (Biological 

Assessment) and the Final EIS/OEIS include an in depth analysis of 

the impacts on the loggerhead Northwest Atlantic DPS as well as 

its designated critical habitat.

65 Local/Regional:

L03-02

What exactly is meant by "active sonar and 

explosives?"

A description for Acoustic Stressors analyzed as part of the 

Proposed Action (including active sonar) can be found in the 

EIS/OEIS in Section 3.0.3.3.1 (Acoustic Stressors), and a description 

of Explosive Stressors analyzed as part of the Proposed Action can 

be found in Section 3.0.3.3.2 (Explosive Stressors) of the Final 

EIS/OEIS.

66 Organization:

O03-42

While it’s certainly true that some marine mammals 

will flee the sound, there are no data to inform us 

how many would do so, let alone that 95% would 

move as expeditiously as the Navy presumes. Marine 

mammals may remain in important habitat, and the 

most vulnerable individuals may linger in an area, 

notwithstanding the risk of harm; marine mammals 

cannot necessarily predict where an exercise will 

travel; and Navy vessels engaged in certain activities 

may move more rapidly than a marine mammal that 

is attempting to evacuate.

Sound levels diminish quickly below levels that could cause PTS. 

Studies have shown that all animals observed avoid areas well 

beyond these zones; therefore, the vast majority of animals are 

likely to avoid sound levels that could cause injury to their ear. 

Behavioral response literature, including the recent 3S and SOCAL 

BRS studies indicate that the multiple species from different 

cetacean suborders do in fact avoid approaching sound sources by 

a few hundred meters or more which would reduce received 

sound levels for individual marine mammals to levels below those 

that could cause permanent threshold shift (PTS). Specifically, the 

ranges to PTS for most marine mammal groups are within a few 

tens of meters and the ranges for the most sensitive group, the 
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Appendix H Public Comment Responses

Table H.3-1. Comment Response Matrix (continued)

Reference 

Number Commenters Comment Response

66 (cont.) high-frequency cetaceans, average about 200 meters. Animals 

present beyond the range to onset PTS for the first three to four 

pings are assumed to avoid any additional exposures at levels that 

could cause PTS. This equates to approximately 5 percent of the 

total pings or 5 percent of the overall time active; therefore, 95 

percent of marine mammals predicted to experience PTS due to 

sonar and other transducers are instead assumed to experience 

TTS. A detailed analysis, including information on swim speeds, is 

provided in the 2018 technical report titled Quantifying Acoustic 

Impacts on Marine Mammals and Sea Turtles: Methods and 

Analytical; Approach for Phase III Training and Testing. 

Nevertheless, some animals could be caught off-guard at the

beginning of, or after a pause in a training or testing event. 

Therefore, the Navy acknowledges that some animals could 

receive PTS and has estimated these impacts in the analysis. 

Avoidance adjustments to the raw output from the NAEMO are 

necessary because, as described in the EIS/OEIS in Section 

3.7.3.1.2.1 (Methods for Analyzing Impacts from Sonars and Other 

Transducers) and Section 3.7.3.2.2.1 (Methods for Analyzing 

Impacts from Explosives), animats (i.e. computer representations 

of individual marine mammals) in the model are not programmed 

to avoid sound sources or move horizontally in any way.

67 Organization:

O03-44

For purposes of analysis, the Navy should assume 

that beaked whales are subject to both acute and 

chronic injury from gas-bubble formation under 

certain conditions of sonar exposure.

Nitrogen decompression is discussed in the Final EIS/OEIS in 

Section 3.7.3.1.1.1 (Marine Mammals - Injury - Nitrogen 

Decompression). This section discusses the background of 

potential impacts to marine mammals from acoustic stressors, 

such as sonar, and outlines the literature currently available with 

regards to this potential impact.

68 Organization:

O03-45

The draft criteria that SPAWAR has produced to 

estimate temporary and permanent threshold shift 

in marine mammals are erroneous and nonconservative.

Wright (2015) has identified several statistical and 

These are not draft criteria, the permanent threshold 

shift/temporary threshold shift criteria and thresholds were 

established by NMFS through a public notice and comment 

process (81 FR 51694) which included multiple rounds of peer 

reviews, and 83 FR 28824 which was published 21 June 2018, for 
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Appendix H Public Comment Responses

Table H.3-1. Comment Response Matrix (continued)

Reference 

Number Commenters Comment Response

68 (cont.) numerical faults in the Navy’s approach, such as 

pseudoreplication and inconsistent treatment of 

data that tend to bias the proposed criteria towards 

an underestimation of effects. Similar and additional 

issues were raised by a dozen scientists during the 

public comment period on the draft criteria held by 

NMFS. At the root of the problem is the Navy’s broad 

extrapolation from a small number of individual 

animals, mostly bottlenose dolphins, without taking 

account of what Racca et al. (2015b) have succinctly 

characterized as a “non- linear accumulation of 

uncertainty.” The auditory impact criteria should be 

revised.

the 2018 Revision to Technical Guidance for Assessing the Effects 

of Anthropogenic Sound on Marine Mammal Hearing-Underwater 

Acoustic Thresholds for Onset of Permanent and Temporary 

Threshold. These include numerous conservative assumptions, 

such as: (1) Navy assumes no recovery of hearing during time 

intervals between intermittent exposures. However, multiple 

studies from humans, terrestrial mammals, and marine mammals 

have demonstrated less temporary threshold shift from 

intermittent exposures compared to continuous exposures with 

the same total energy because hearing is known to experience 

some recovery in between noise exposures. Therefore, the Navy’s 

approach is known to over-estimate the effects of intermittent 

noise sources such as tactical sonars. (2) Marine mammal 

temporary threshold shift data have shown that, for two 

exposures with equal energy, the longer duration exposure tends 

to produce a larger amount of temporary threshold shift. Since 

most marine mammal temporary threshold shift data have been 

obtained using exposure durations of tens of seconds up to an 

hour, much longer than the durations of many tactical sources, 

the use of the existing marine mammal temporary threshold shift 

data tends to over-estimate the effects of sonars with shorter 

duration signals. Since marine mammal hearing and noise-induced 

hearing loss data are limited, both in the number of species and in 

the number of individual’s available, attempts to minimize 

pseudoreplication would further reduce these already limited data 

sets. Specifically, with marine mammal behavioral temporary 

threshold shift studies, behaviorally-derived data are only 

available for two mid-frequency cetacean species (bottlenose 

dolphin, beluga) and two phocids in water pinniped species 

(harbor seal and northern elephant seal), with OW pinnipeds and 

high-frequency cetaceans only having behaviorally-derived data 

from one species. Arguments from Wright (2015) regarding 

pseudo replication within the temporary threshold shift data are 
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Appendix H Public Comment Responses

Table H.3-1. Comment Response Matrix (continued)

Reference 

Number Commenters Comment Response

68 (cont.) therefore largely irrelevant in a practical sense because there are 

so few data. Multiple data points were not included for the same 

individual at a single frequency - if multiple data existed at one 

frequency, the lowest temporary threshold shift onset was always 

used. There is only a single frequency where temporary threshold 

shift onset data exist for two individuals of the same species: 3 

kHz for dolphins. Their temporary threshold shift (unweighted) 

onset values were 193 and 194 dB re 1 μPa2s. Thus, Navy believes 

that the current approach makes the best use of the given data. 

Appropriate means of reducing pseudoreplication may be 

considered in the future, if more data become available. Many 

other comments from Wright (2015) and the comments from 

Racca et al. (2015b) appear to be erroneously based on the idea 

that the shapes of the auditory weighting functions and temporary 

threshold shift/PTS exposure thresholds are directly related to the 

audiograms; i.e., that changes to the composite audiograms would 

directly influence the threshold shift/PTS exposure functions [e.g., 

Wright (2015) describes weighting functions as “effectively the 

mirror image of an audiogram” (p. 2) and states “The underlying 

goal was to estimate how much a sound level needs to be above 

hearing threshold to induce temporary threshold shift.” (p. 3) —

both statements are incorrect and suggest a fundamental 

misunderstanding of the criteria/threshold derivation.] This would 

require a constant (frequency-independent) relationship between 

hearing threshold and temporary threshold shift onset that is not 

reflected in the actual marine mammal temporary threshold shift 

data. Attempts to create a “cautionary” outcome by artificially 

lowering the composite audiogram thresholds would not 

necessarily result in lower temporary threshold shift/PTS exposure 

levels, since the exposure functions are to a large extent based on 

applying mathematical functions to fit the existing temporary 

threshold shift data.
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Appendix H Public Comment Responses

Table H.3-1. Comment Response Matrix (continued)

Reference 

Number Commenters Comment Response

69 Organization:

O03-46

For example, two of the proposed behavioral 

response functions rely substantially on captive 

animal studies, even though it is generally accepted 

that captive animals, especially (but not limited to) 

those that have previously been trained, are likely to 

be less responsive to intrusive sound. Every data 

point that informs the pinniped function, and nearly 

two-thirds of the data points informing the 

odontocete function (30/49), are derived from a 

captive animal study. In the case of the odontocete 

function, the reliance on captive studies exacerbates 

that function’s heavy dependence on the bottlenose 

dolphin, a species that is generally considered 

relatively insensitive, to represent a diverse set of 

taxa with divergent sensitivity and reactiveness to 

mid-frequency anthropogenic noise.

Please see the 2018 technical report titled Quantifying Acoustic 

Impacts on Marine Mammals and Sea Turtles: Methods and 

Analytical Approach for Phase III Training and Testing (U.S. 

Department of the Navy, 2017) for details on how the Navy 

accounted for the differences in captive and wild animals in the 

development of the BRF’s. 

The Navy uses the best available science in the analysis which has 

been reviewed by external scientists and approved by NMFS. The 

Navy has utilized all available data for the development of 

updated criteria and threshold, and limiting the data to the small 

number of field studies would not provide enough data with which 

to develop the new risk functions. In addition, the Navy accounts 

for the fact that captive animals may be less sensitive, and the 

scale at which a moderate to severe response was considered to 

have occurred is different for captive animals than for wild 

animals, as the Navy understands those responses will be 

different.

70 Organization:

O03-49

As noted above, dipping sonar, like hull-mounted 

sonar, appears on the basis of preliminary data to be 

a significant predictor of deep-dive rates in beaked 

whales on SOAR, with the dive rate falling 

significantly (e.g., to 35% of that individual’s control 

rate) during sonar exposure, and likewise appears 

associated with habitat abandonment. Importantly, 

these effects were observed at substantially greater 

distances (e.g., 30 or more km) from dipping sonar 

than would otherwise be expected given the 

systems’ source levels and the beaked whale 

response thresholds developed from research on 

hull-mounted sonar.

The Navy relied upon the best science that was available to 

develop the BRF’s in consultation with NMFS. The Navy’s current 

beaked whale BRF acknowledges and incorporates the increased 

sensitivity observed in beaked whales during both behavioral 

response studies and during actual Navy training events. This 

article (Associating patterns in movement and diving behavior with 

sonar use during military training exercises: A case study using 

satellite tag data from Cuvier’s beaked whales at the Southern 

California Anti-submarine Warfare Range, supra. ) was not 

available at the time the behavioral response functions were 

developed. The new information and data presented in the new 

article was recently thoroughly reviewed the Navy and will be 

quantitatively incorporated into the Navy's future BRF’s as 

appropriate. However, the Navy’s current beaked whale BRF 

covers the responses observed in the new article since the beaked 

whale risk function is more sensitive than the other risk functions 
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Appendix H Public Comment Responses

Table H.3-1. Comment Response Matrix (continued)

Reference 

Number Commenters Comment Response

70 (cont.) at lower received levels. Thus far, no new information has been 

published or otherwise conveyed that would significantly change 

the assessment change the assessment of impacts or conclusions 

of this Final EIS/OEIS.

71 Organization:

O03-53

As with past analyses, the present DEIS tabulates 

exposures and takes of marine mammal species but 

has not adequately assessed the aggregate impacts. 

On the contrary, it assumes, without explanation, 

that the accumulated annual mortalities, injuries, 

energetic costs, temporary losses of hearing, chronic 

stress, and other impacts would not affect vital rates 

in individuals or populations, even though the Navy’s 

activities would affect the same populations over 

time. This assumption seems predicated, for many 

species, on the unsupported notion that transient 

activity will not accumulate into population-level 

harm.

Within this Study Area the Navy has funded long-term monitoring 

on Navy ranges, areas that have been used for training and testing 

for decades, and has observed no evidence of population-level 

impacts. Based on best available research from NMFS and Navy 

funded marine mammal studies, there is no evidence that 

"population-level harm" to marine mammals, including beaked 

whales, is occurring in the AFTT Study Area. Through the Letter of 

Authorization process Navy works with NMFS to assure that the 

aggregate or cumulative impacts do not have more than a 

negligible impact on populations. The commenter has provided no 

evidence throughout their comment letter that there have been 

stock or population-level consequences resulting from Navy 

training and testing activities, activities that have occurred in 

these areas at similar levels of intensity, for more than 70 years. 

The marine mammal analysis in Section 3.7 does discuss the issues 

raised by the commenter, is based on best available science, 

thoroughly discusses potential effects to marine mammals, and 

provides the supporting science behind Navy’s conclusions.

72 Commercial:

C01-04b

However, the Draft EIS states on page ES-12 that 

“the expected impact of noise on invertebrates 

is...mostly limited to offshore layers of the water 

column where only...squid...are prevalent”. There are 

scientific studies that show significant mortality of 

squid when exposed to low-frequency noise (see 

Andre et al “Low-frequency sounds induce acoustic 

trauma in cephalopods”, Research Communications, 

2011). We would request that this be considered 

when scheduling and locating exercises, as a 

significant portion of our income may be at stake.

The EIS/OEIS has taken a hard look at the impacts on invertebrates 

in Section 3.4.3 (Environmental Consequences - Invertebrates) 

which was based on the best available science. The Navy 

considered Andre et al. 2011 and determined the conditions in the 

study are not likely to be replicated during Navy training and 

testing activities. See Section 3.4.3.1.1.1 (Injury).
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Appendix H Public Comment Responses

Table H.3-1. Comment Response Matrix (continued)

Reference 

Number Commenters Comment Response

Mitigation and Monitoring

73 Federal:

F02-03

We recommend this procedure be included for other 

vessels mooring in waters where manatees could be 

present. This includes Kings Bay, Georgia, the vicinity 

of Mayport, Port Canaveral, and Pensacola, Florida; 

Mobile, Alabama; and any other locations that are 

used from North Carolina south, in the Gulf of 

Mexico, and in the vicinity of Puerto Rico.

These mitigations were agreed to in previous consultations due to

the unique method of mooring submarines to the wharf at Kings 

Bay, and these do not exist for ships listed at these other 

locations. Submarine and surface ship berthing methods are 

primarily based on the type of pier or quay wall within the port 

and the hull configuration. Due to the hull differences between 

submarines and the various surface ships hull shapes they are not 

moored in the same manner and therefore this procedure is not 

practical or necessary.

74 Federal:

F02-05

Add a specific mitigation action that the Navy will 

coordinate with park units and regional offices for 

localized mitigation for activities that could affect 

park resources. Include national park unit locations 

in the development of mitigation areas. For example, 

include units on the map in Figure 2.4-1 on page 2.47 

called Geographic Areas where the Navy proposes to 

conduct mitigation measures. Further, include park 

units in the appropriate sections in the mitigation 

chapter. The following represent specific mitigation 

suggestions to address concerns about potential 

impacts to park resources and values:

Chapter 6 (Regulatory Considerations) presents information on 

the national system of parks located in the Study Area. The Navy 

will avoid or reduce impacts to the maximum extent practicable

through procedural mitigation (see Section 5.3, Procedural 

Mitigation to be Implemented) and mitigation areas (see Section 

5.4, Mitigation Areas to be Implemented). The Navy completed a 

full Biological Assessment and operational analysis of potential 

mitigation areas throughout the entire Study Area. Developing 

additional mitigation areas beyond what is described in Section 

5.4 (Mitigation Areas to be Implemented) would be impractical

due to implications for safety, sustainability, and the Navy’s ability 

to continue meeting its Title 10 requirements to successfully 

accomplish military readiness objectives.

75 Federal:

F02-07

In lieu of analyzing each more localized noise source, 

NPS recommends that when activities are 

anticipated within a range of approximately 15 

nautical miles to an NPS unit, that the Navy 

coordinates with the NPS to set distances or design 

timing of activities to reduce or avoid impacts from 

noise to park resources.

Navy training and testing activities that produce noise are typically 

conducted greater than 12 NM from the coast, as described in 

Section 2.3.3 (Standard Operating Procedures), which would limit 

the potential overlap between these activities and National Park 

Service Units and their resources. Aircraft noise would be 

intermittent due to transits from airfields to the operating areas at 

sea. Any activities occurring on the coast would generally occur on 

Department of Defense controlled beaches.
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Appendix H Public Comment Responses

Table H.3-1. Comment Response Matrix (continued)

Reference 

Number Commenters Comment Response

76 Federal:

F02-10

Provide mitigation for impacts to the Kemp's ridley 

sea turtle migration routes and habitats. In section 

3.8.2.2.3.2 Habitat and Geographic Range for Kemp's 

ridley sea turtles, the fact that this species nests 

primarily during daytime hours is not included in the 

Draft EIS. This corresponds to an oversight in 

Mitigation: Table 5.3-16: Procedural Mitigation for 

Line Charge Testing which states that "From March 

through September (sea turtle nesting season), the 

Navy will not conduct line charge testing at night." 

This mitigation if implemented on the Texas coast 

should limit charge testing during the day due to the 

nesting behavior of Kemp's ridley.

The Navy will avoid or reduce impacts to sea turtles to the 

maximum extent practicable through procedural mitigation (see 

Section 5.3, Procedural Mitigation to be Implemented). Line 

charge testing occurs only within the Naval Surface Warfare 

Center, Panama City Division Testing Range in Florida and 

mitigation was designed for that location. There are no activities 

planned for the nearshore area near Padre Island National

Seashore.

77 Federal:

F02-11

To mitigate impacts to sea turtles using inshore 

habitats, special consideration should be taken to 

cease or limit activities when water temperature 

drops below 12 degrees Celsius. Sea turtles become 

immobilized (stunned) below this temperature and 

cannot move out of the way of machinery. They can 

be struck by boats while floating helplessly on the 

water surface or easily crushed or buried by 

machinery or materials (Shaver et. al. 2017). Adding 

this information to the Mitigation section 5.3.1 

ENVIRONMENTAL AWARENESS AND EDUCATION, 

and in training for observers would further protect 

sea turtles in this vulnerable state.

The Navy will avoid or reduce impacts to sea turtles to the 

maximum extent practicable through procedural mitigation (see 

Section 5.3, Procedural Mitigation to be Implemented). Additional 

restrictions, such as limitations based on water temperature, 

would be impractical because it would prevent the Navy from 

accessing certain facilities, range complexes, testing ranges, and 

open ocean areas with the unique, challenging, and diverse 

environmental and oceanographic conditions (e.g., bathymetry, 

topography, surface fronts, and variations in sea surface 

temperature) needed to achieve the highest skill proficiency and 

most accurate testing results possible. However, as the Navy will 

be updating the required Marine Species Awareness Training, a 

statement regarding the increased chance of cold stunned sea 

turtles in water below 53.6 degree Fahrenheit will be added to the 

training video.
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Appendix H Public Comment Responses

Table H.3-1. Comment Response Matrix (continued)

Reference 

Number Commenters Comment Response

78 Federal:

F05-08

However, the Phase III proposed mitigation zones 

would not protect various functional hearing groups 

from PTS.

Per Section 5.3.3 (Explosive Stressors), for explosive mitigation 

zones, any additional increases in mitigation zone size (beyond 

what is depicted for each explosive activity) or observation 

requirements would be impractical to implement due to 

implications for safety, sustainability, and the Navy’s ability to 

meet Title 10 requirements to successfully accomplish military 

readiness objectives, and the Navy’s ability to conduct testing 

associated with required acquisition milestones or as required on 

an as-needed basis to meet operational requirements. 

Additionally, Navy Senior Leadership has approved and 

determined that the mitigation detailed in Chapter 5 (Mitigation)

provides the greatest extent of protection that is practical to 

implement.

79 Federal:

F05-09

Accordingly, the Commission continues to believe 

that rather than simply reducing the size of the zones 

it plans to monitor, the Navy should supplement its 

visual monitoring efforts with other monitoring 

measures. The Navy did propose to supplement 

visual monitoring with passive acoustic monitoring 

during three explosive activity types but not during 

the remaining explosive activities or during low-, 

mid- and high-frequency active sonar activities.

Per Section 5.3.3 (Explosive Stressors), for explosive mitigation 

zones, any additional increases in mitigation zone size (beyond 

what is depicted for each explosive activity) or observation 

requirements would be impractical to implement due to 

implications for safety, sustainability, and the Navy’s ability to 

meet Title 10 requirements to successfully accomplish military 

readiness objectives. As discussed in the comment, the Navy does 

employ passive acoustic monitoring when practical to do so (i.e., 

when assets that have passive acoustic monitoring capabilities are 

already participating in the activity). For other explosive events, 

there are no platforms participating that have passive acoustic 

monitoring capabilities. Adding a passive acoustic monitoring 

capability (either by adding a passive acoustic monitoring device 

to a platform already participating in the activity, or by adding a 

platform with integrated passive acoustic monitoring capabilities 

to the activity) for mitigation is not practical. As discussed in 

Section 5.5.3 (Active and Passive Acoustic Monitoring Devices), 

there are significant manpower and logistical constraints that 

make constructing and maintaining additional passive acoustic 

monitoring systems or platforms for each training and testing
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Appendix H Public Comment Responses

Table H.3-1. Comment Response Matrix (continued)

Reference 

Number Commenters Comment Response

79 (cont.) activity impractical. Additionally, diverting platforms that have 

passive acoustic monitoring platforms would impact their ability 

to meet their Title 10 requirements and reduce the service life of 

those systems. Lastly, the mitigation zones for active sonar 

systems encompass the ranges to potential injury. The lookout 

effectiveness study mentioned by the commenter is still ongoing. 

This type of study has never been conducted, is extremely 

complex to ensure data validity, requires a substantial amount of 

data to conduct meaningful statistical analysis, and Navy is 

committed completing it. 

As noted by the commenter, there has not been enough data 

collected to conduct a sufficient analysis, therefore drawing 

conclusions on an incomplete data set is not scientifically valid.

80 Federal:

F05-10, F05-11

Two comments recommend more use of passive and 

active acoustic monitoring.

For explosive events without passive acoustic monitoring (for 

example, bombing exercise), there are no platforms participating 

in those activities that have passive acoustic monitoring 

capabilities. Adding a passive acoustic monitoring capability 

(either by adding a passive acoustic monitoring device to a 

platform already participating in the activity, or by adding a

platform with integrated passive acoustic monitoring capabilities 

to the activity) for mitigation is not practical. As discussed in 

Section 5.5.3 (Active and Passive Acoustic Monitoring Devices), 

there are significant manpower and logistical constraints that 

make constructing and maintaining additional passive acoustic 

monitoring systems or platforms for each training and testing 

activity impractical. Additionally, diverting platforms that have 

passive acoustic monitoring capabilities would impact their ability 

to meet their Title 10 requirements and reduce the service life of 

those systems.
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Appendix H Public Comment Responses

Table H.3-1. Comment Response Matrix (continued)

Reference 

Number Commenters Comment Response

81 State:

S02-01

Organization:

O02-06

Two comments urged the Navy to consider avoiding 

activities that could impact coral, specifically the area 

designated as the Frank R. Lautenberg Deep-Sea 

Coral Protection Area. 

In water depths typical of the Frank R. Lautenberg Deep-Sea Coral 

Protection Area, most explosions would occur at or near the water 

surface, and explosives that are detonated on the bottom would 

not be planned. Although it is possible for a portion of military 

expended materials to impact hard substrate and associated 

sensitive invertebrate communities in such deep-sea locations, the 

number of exposed coral individuals is likely to be near zero due 

to: (1) the miniscule footprint of MEM in the vast ocean 

environment in terms of both area and duration, and (2) the rarity 

of living coral on suitable hard substrate that is itself relatively 

rare in the AFTT study area (see Section 3.4.3.4.3, Impacts from 

Military Expended Materials).

Developing additional mitigation areas for seafloor resources 

beyond what is detailed in Section 5.4.1 (Mitigation Areas for 

Seafloor Resources) would be impractical due to implications for 

safety, sustainability, and the Navy’s ability to continue meeting 

its Title 10 requirements to successfully accomplish military 

readiness objectives

82 State:

S02-02

Naval testing, specifically underwater explosives and 

acoustic stressors, along the continental shelf of the 

Mid-Atlantic threaten economically valuable fish 

populations and should be avoided. 

The Navy is committed to developing and implementing 

mitigation to avoid or reduce potential impacts to marine species, 

cultural resources, and the marine environment to the maximum 

extent practicable. Chapter 5 (Mitigation) details the mitigation 

that the Navy will implement under the Proposed Action. The 

Navy completed an Essential Fish Habitat assessment and 

operational analysis of potential mitigation areas throughout the 

entire Study Area. The mitigation identified in Section 5.4 

(Mitigation Areas to be Implemented) represents the maximum 

mitigation within the identified mitigation areas that is practical to 

implement under the Proposed Action.
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Appendix H Public Comment Responses

Table H.3-1. Comment Response Matrix (continued)

Reference 

Number Commenters Comment Response

83 State:

S02-04

Navy testing and training should avoid areas with 

intricate bottom habitat structure and high 

productivity to minimize the cumulative effects of 

the activities and climate change.

The Navy is committed to developing and implementing 

mitigation to avoid or reduce potential impacts to marine species, 

cultural resources, and the marine environment to the maximum 

extent practicable. Chapter 5 (Mitigation) details the mitigation 

that the Navy will implement under the Proposed Action. As 

discussed in Section 5.4.1 (Mitigation Areas for Seafloor 

Resources), the Navy will implement mitigation measures (e.g., 

avoiding bottom-placed explosives) to avoid or reduce potential 

impacts to shallow-water coral reefs, live hard bottom, artificial 

reefs, submerged aquatic vegetation, and shipwrecks.

84 State:

S04-03

We continue to commend the Navy’s support of EWS 

surveys, but would like to note that airspace 

restrictions due to military activities have limited 

these aerial surveys on several occasions in previous 

years including this past season. These airspace 

restrictions limit the mitigation effectiveness of EWS 

surveys, and we encourage the Navy to work with 

the NMFS and its partners to increase the 

effectiveness of EWS surveys as a mitigation measure 

and monitoring tool.

The Navy is a dedicated participant and sponsor of the EWS and 

has made significant strides in recent years to deconflict training 

activities with the EWS flights. Only on rare occasions will training 

or testing activities affect the Early Warning System surveys for 

safety of flight, and Navy will continue to work with the survey 

team for the scheduling of flights and Navy activities to minimize 

any potential conflict to the maximum extent practicable.

85 State:

S04-04, S05-07, S05-38, 

S05-42

Four comments supported expanding the North 

Atlantic Right Whale mitigation areas and including 

time of year restrictions in these areas for come 

Navy activities.

As described in Chapter 5 (Mitigation) of the Final EIS/OEIS, the 

Navy evaluated the effectiveness and practicality of numerous 

potential mitigation measures. Through consultation and 

permitting with NMFS, the Navy evaluated the potential to 

increase the size of its mitigation areas, such as areas that overlap 

North Atlantic right whale calving habitat. The Navy identified 

several opportunities to expand its mitigation areas to enhance 

protections for North Atlantic right whales to the maximum extent 

practicable. Further expansions of the mitigation areas beyond 

what is detailed in Section 5.4.3 (Mitigation Areas off the MidAtlantic and Southeastern United States) would have

unacceptable impacts on safety, sustainability, and the ability for 

the Navy to continue meetings its mission requirements.
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Appendix H Public Comment Responses

Table H.3-1. Comment Response Matrix (continued)

Reference 

Number Commenters Comment Response

86 State:

S05-08

In the event that a NARW is killed or seriously injured 

by a Navy vessel 60 ft or greater in length operating 

within 30 nmi of the Southeast U.S. coast, the Navy 

will implement 10 kt vessel speed restrictions in this 

area from November 15 to April 15.

As discussed in the Draft EIS/OEIS and pursuant to 50 C.F.R. para 

224.105, U.S. Navy vessels are exempt from the 10-knot North 

Atlantic right whale speed restriction. In the event a North Atlantic 

right whale is killed or significantly injured by a Navy vessel, the 

Navy would inform NMFS and evaluate the situation under the 

LOA regulation clauses, particularly 218.87 pertaining to 

modifications of LOAs.

87 State:

S05-10

The Navy will coordinate with the NMFS Ocean 

Acoustics Program to establish maximum and 

cumulative thresholds for active sonar and ordnance 

detonation sound pressure levels detected within 

the NARW calving habitat Mitigation Area.

The Navy is fully integrated with the NMFS Ocean Acoustics 

Program. Any modifications resulting from the program were 

considered during consultations with NMFS and will be considered 

during the adaptive management process.

88 State:

S05-40

We recommend Navy vessels avoid high-speed 

training and testing activities within the expanded 

mitigation area from November 15 to April 15 

annually.

As discussed in Section 5.3.4.1 (Vessel Movement), the Navy 

implements mitigation to avoid vessel strikes throughout the 

Study Area. As described in Section 2.3.3 (Standard Operating 

Procedures) Navy vessels operate in accordance with the 

navigation rules established by the U.S. Coast Guard, which 

require that vessels proceed at a safe speed so that proper and 

effective action can be taken to avoid collision and be stopped

within a distance appropriate to the prevailing circumstances and 

conditions. As described in Section 5.3.4.1 (Vessel Movement), 

any additional vessel speed restrictions would prevent vessel 

operators from gaining skill proficiency, would prevent the Navy

from properly testing vessel capabilities, or would increase the 

time on station during training or testing activities as required to 

achieve skill proficiency or properly test vessel capabilities (which 

would significantly increase fuel consumption); therefore, the 

mitigation proposed by the comment would be impractical to 

implement.

89 State:

S17-06, S17-09a

Two comments do not feel that the proposed 

mitigations are appropriate and recommend further 

mitigation options be explored.

As discussed in Chapter 5 (Mitigation), the Navy will implement a 

robust suite of mitigation measures designed to effect the least 

practicable adverse impact on marine mammal species or stocks 
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Appendix H Public Comment Responses

Table H.3-1. Comment Response Matrix (continued)

Reference 

Number Commenters Comment Response

89 (cont.) and their habitat, and have a negligible impact on marine mammal 

species and stocks (as required under the Marine Mammal 

Protection Act), ensure that the Proposed Action does not 

jeopardize the continued existence of endangered or threatened 

species, or result in destruction or adverse modification of critical 

habitat (as required under the Endangered Species Act), avoid or 

minimize adverse effects on essential fish habitat (as required 

under the Magnuson Stevens Fishery Conservation and 

Management Act), and avoid adversely impacting shipwrecks (as 

required under the Abandoned Shipwreck Act and National 

Historic Preservation Act). Navy Senior Leadership has approved 

and determined that the mitigation detailed in Chapter 5 

(Mitigation) provides the greatest extent of protection that is 

practical to implement. As discussed in Section 5.3 (Procedural 

Mitigation to be Implemented), the Navy implements procedural 

mitigation for 21 different activity categories or stressors 

whenever and wherever those activities occur throughout the 

Study Area. As discussed in Section 5.4 (Mitigation Areas to be 

Implemented), the Navy implements additional mitigation for 

seafloor resources as well as within mitigation areas specifically 

designed to further avoid or reduce potential impacts to marine 

mammals in important habitat areas. During the Phase III 

mitigation development process, the Navy considered several 

measures that would have unacceptable impacts on personnel 

safety, practicality of implementation, and impact on effectiveness 

of the military readiness activities. Information on those measures 

and why the Navy will not implement them is provided in Section 

5.5 (Measures Considered but Eliminated).
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Appendix H Public Comment Responses

Table H.3-1. Comment Response Matrix (continued)

Reference 

Number Commenters Comment Response

90 State:

S17-05

The North Atlantic right whale is one of the most 

critically endangered species on Earth. While 

seemingly greater protection was afforded to the 

species in the form of expanded Critical Habitat 

under the Endangered Species Act in 2016, other 

mitigation measures have not succeeded in 

establishing a coastline fit for their survival. Seasonal 

Management Areas (SMA) have contributed to a 

decline in vessel strikes, but vessel strikes that occur 

just outside the SMA spatial or temporal measure 

are common. Among other concerns noted in the 

2016 Stock Assessment Report, "the reported 

human-caused mortality and serious injury was a 

minimum of 5.6, when Potential Biological Removal 

is calculated as 1, from 2010 through 2014" (Henry et 

al. 2017). Moreover, the recent shift in distribution 

and downward trend in population size are very 

concerning (Hayes et al. 2017). Compounding these 

established trends, at least 13, possibly 15, North 

Atlantic right whale carcasses have been found in the 

Gulf of St. Lawrence and off the coast of 

Massachusetts since the beginning of the year 

(MacKinnon 2017). The large number of deaths 

accounts for over 2% of the population and more 

than doubles the number of calves born this year. 

This dire situation begs serious consideration of 

introducing an additional threat to their habitat 

(Jones 2017). On August25, 2017 NOAA Fisheries 

declared an Unusual Mortality Event for the North 

Atlantic right whales throughout their range based 

on recent elevated strandings along the Atlantic 

coast, predominantly in the Gulf of SI. Lawrence 

region in Canada. As the best available science on

As discussed in Section 5.3.4.1 (Vessel Movement), the Navy 

implements mitigation to avoid vessel strikes throughout the 

Study Area. In addition to procedural mitigation, the Navy 

implements measures for vessel movement within several 

mitigation areas to further avoid or reduce the potential for 

marine mammal vessel strikes. For example, the Navy has 

expanded the extent of the Northeast North Atlantic Right Whale 

Mitigation Area to encompass the entire northeast North Atlantic 

right whale critical habitat. Within this mitigation area, as 

discussed in Section 5.4.2 (Mitigation Areas off the Northeastern 

United States), before vessel transits, the Navy will conduct a web 

query or email inquiry to the National Oceanographic and 

Atmospheric Administration NEFSC’s North Atlantic Right Whale 

Sighting Advisory System to obtain the latest North Atlantic right 

whale sightings information. Vessels will use the obtained 

sightings information to reduce potential interactions with North 

Atlantic right whales during transits. Vessels will implement speed 

reductions after they observe a North Atlantic right whale, if they 

are within 5 NM of a sighting reported to the North Atlantic Right 

Whale Sighting Advisory System within the past week, and when 

operating at night or during periods of reduced visibility. Since the

Navy has implemented mitigation measures and standard 

operating procedures, zero Navy vessel strikes with North Atlantic 

right whales have occurred to date.
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Appendix H Public Comment Responses

Table H.3-1. Comment Response Matrix (continued)

Reference 

Number Commenters Comment Response

90 (cont.) this species stands, any threat to the North Atlantic 

right whale, such as the recent mortality event, 

should be considered significant.

91 State:

S17-07

Marine debris is a growing conservation issue that 

has been recognized to threaten marine organisms 

through entanglement, ingestion, and toxin exposure 

(Laisl 1987, Eriksen el al. 2014, Vegter et al. 2014). 

Rather than leave any debris in the ocean, it would 

be better to avoid deploying it or to retrieve it. Most 

seabirds are attracted to any item near the surface, 

and will attempt to eat even non-digestible items 

(Pierce et al. 2004, Van Franeker et al. 2011, Wilcox 

et al. 2015, Moser et al. 2016). Debris on the seafloor 

can be a dangerous entanglement problem for both 

marine organisms and fishing gear deployed in the 

area. Persistent debris can leach pollutants into the 

environment over the Jong-term (Vegter et al. 2014). 

While there are perhaps other, more significant, 

contributions to the marine litter problem, Navy 

training and testing exercises should endeavor to 

have a minimal impact.

The Navy conducted a full analysis of the potential impacts of 

military expended materials on marine resources and has 

proposed several mitigation measures to help avoid or reduce 

those impacts. The analysis is contained throughout Chapter 3 

(Affected Environment and Environmental Consequences) of the 

Final EIS/OEIS (e.g., Section 3.4.3.4.3, Impacts from Military 

Expended Materials discusses invertebrates; Section 3.5.3.4.3, 

Impacts from Military Expended Materials discusses habitats; 

Section 3.9.3.4.3, Impacts from Military Expended Materials and 

Section 3.9.3.6, Ingestion Stressors discusses birds). The Navy has 

standard operation procedures in place to reduce the amount of 

military expended materials (Section 2.3.3.5, Weapons Firing 

Safety), including recovering targets and associated parachutes to 

the maximum extent practicable.

92 State:

S19-11

Recent research has shown that the use of seismic 

testing may cause reductions of fish abundances and 

diversity with acoustic increases as low as 170 dB re 

1μ Pa (Paxton et al. 2017). To reduce unnecessary 

adverse impacts to hard bottom habitat, it is 

suggested that all Navy activities be performed as far 

away from known hard bottom habitat to the 

greatest extent practicable. Known areas of hard 

bottom habitat can be found via: SEAMAP-SA 

mapping efforts, Moser and Taylor 1995, Crowson 

1980, Lombardero et al. 2008, North Carolina 

Division of Marine Fisheries Artificial Reef website, 

As a matter of practice, the Navy typically does not conduct 

certain activities in the coastal zone due to specific mission 

requirements (see Section 2.3.3.16, Coastal Zone). While active 

sonars or other transducers can be used in shallower waters, only 

some clupeid species (e.g., Atlantic herring) may detect the 

associated sound pressures from a distance, these sources are not 

comparable to seismic testing sound. Most fish and invertebrate 

species can only detect particle motion at very close ranges. As 

discussed in Section 5.4.1 (Mitigation Areas for Seafloor 

Resources), the Navy will implement mitigation measures (e.g., 

avoiding bottom-placed explosives) to avoid or reduce potential 

impacts to shallow-water coral reefs, live hard bottom, artificial
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Appendix H Public Comment Responses

Table H.3-1. Comment Response Matrix (continued)

Reference 

Number Commenters Comment Response

92 (cont.) USACE and NMFS EFH maps and HAPC maps. reefs, submerged aquatic vegetation, and shipwrecks. The Navy 

has developed new mitigation measures for Habitat Areas of 

Particular Concern for sandbar sharks, which are presented in 

Section 5.4.3 (Mitigation Areas off the Mid-Atlantic and 

Southeastern United States).

As such, a relatively low number of pelagic surface or mid-water 

fishes and some benthic/deep-sea reef species may detect and 

react to distant sonar or other transducer noise. However, the 

available research presented in Paxton et al. 2017 does not 

support a biologically relevant effect on EFH because the brief 

alteration of underwater sound properties has not been shown to 

alter the ecological functions of the habitat (including hard 

bottom) for managed species. The Phase III AFTT Draft EIS/OEIS 

Section 3.6.3.1 contains more details and supports the conclusion 

of no adverse effect from sonars and other transducers. The effect 

of sparse and intermittent low-frequency sonar on fish and 

invertebrates (including species with designated EFH and HAPC) 

was therefore not considered significant as a NEPA determination 

and not substantial as an adverse effect on Essential Fish 

Habitat/HAPC.

93 State:

S23-01

The NCWRC appreciates efforts made to minimize 

impacts to wildlife resources through the 

cooperative efforts of the Navy, NOAA, and USFWS. 

We request this cooperation continues and that as 

advances in technology, data, and knowledge of 

wildlife species occur, efforts are made toward 

continued reduction of direct, secondary, and

cumulative resource impacts. 

To limit unintended impacts to nesting sea turtles on 

North Carolina beaches, we would like to request 

near shore, in-water activities adhere to the May 1 -

November 15 sea turtle nesting moratorium.

The Navy will continue to work cooperatively with the appropriate 

regulatory agencies to ensure the best available science is used in 

the Navy analyses. As a matter of practice, the Navy typically does 

not conduct certain activities in the coastal zone due to specific 

mission requirements (see Section 2.3.3.16, Coastal Zone). For 

activities that could potentially be conducted in a coastal zone, the 

Navy will avoid or reduce impacts to sea turtles to the maximum 

extent practicable through procedural mitigation (see Section 5.3, 

Procedural Mitigation to be Implemented). The Navy has a 

mitigation measure specific to sea turtle nesting off North 

Carolina: from March through September within 3.2 NM of an 

estuarine inlet and within 1.6 NM of the shoreline in the Navy 

Cherry Point Range Complex, the Navy will not conduct explosive 
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Appendix H Public Comment Responses

Table H.3-1. Comment Response Matrix (continued)

Reference 

Number Commenters Comment Response

93 (cont.) mine neutralization activities involving Navy divers to avoid sea 

turtles near nesting beaches during the nesting season (see 

Section 5.3.3.8, Explosive Mine Neutralization Activities Involving 

Navy Divers).

As described in Section 5.4.3 (Mitigation Areas off the Mid-Atlantic 

and Southeastern United States), the Navy analyzed numerous 

habitats in the Study Area (including nearshore habitats along the 

coast of North Carolina that overlap with the sea turtle habitat 

identified by the NCWRC) and determined that implementing 

additional mitigation in North Carolina coastal waters would not 

be practical.

94 State:

S23-02

We also are concerned with potential impacts from 

expended sonobuoys, torpedo ballast and other 

training targets on benthic habitats. The Navy has 

relied heavily on ocean currents and dispersal of 

debris over a large area and the DEIS concludes that 

there will be no significant impact to benthic 

habitats. However, we are concerned with the 

impacts from debris on wildlife resources and 

request consideration be made and efforts given to 

remove debris within project operations.

The vast majority of military expended materials are expended 

seaward of state coastal zones where they are typically buried in a 

predominantly unstable soft bottom environment. The relatively 

few items that may sink slowly (e.g., parachutes) south of Cape 

Hatteras are likely carried along the coast by the Gulf Stream. For 

shores north of Cape Hatteras, Ribic et al. (2010) documented 

marine debris from ocean sources along the South Atlantic coast, 

including North Carolina, and found 7.5 items/500 meters of 

shoreline without noting any contribution from military expended 

materials. For this and other reasons, the effort it would take to 

scour the shore for likely rare items of military origin was deemed 

unnecessary. The Navy makes all practical efforts to recover 

targets as discussed in Section 2.3.3.5 (Weapons Firing 

Safety).Ribic, C.A., Sheavly, S.B., Rugg, D.J., & Erdmann, E.S. 

(2010). Trends and drivers of marine debris on the Atlantic coast 

of the United States 1997-2007. Marine Pollution Bulletin. 60: 

1231-1242.
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Appendix H Public Comment Responses

Table H.3-1. Comment Response Matrix (continued)

Reference 

Number Commenters Comment Response

95 State:

S25-02

We suggest that training and testing operations 

requiring the use of underwater explosives be 

conducted as far offshore as possible and limited to 

the minimum time period practicable. Specific areas 

chosen for these operations should be selected to 

avoid areas of Essential Fish Habitat (EFH) and 

Habitat Areas of Particular Concern (HAPC) as 

designated by the South Atlantic Fishery 

Management Council (SAFMC) and National Marine 

Fisheries Service (NMFS).

Mitigation measures related to live hard bottom and artificial 

reefs can be found in Section 5.4.1 (Mitigation Areas for Seafloor 

Resources), which includes a 350-yd. (320-m) radius mitigation 

zone around known locations. The mitigation measures listed in 

the Final EIS/OEIS are the result of consultation with NMFS with 

respect to EFH. The Navy has developed new mitigation measures 

for submerged aquatic vegetation and HAPC for sandbar sharks, 

which are presented in Section 5.4.1 (Mitigation Areas for Seafloor 

Resources) and Section 5.4.3 (Mitigation Areas off the MidAtlantic and Southeastern United States), respectively.

96 State:

S25-03

It is unclear to us whether or not the “Drill 

Minefield” in the nearshore waters off Charleston, SC 

(see Enclosure 2) is actually still active, and if so how 

it might be used in any future training operations.

The area identified as the "Drill Minefield" is not currently used to 

conduct underwater explosives training or testing.

97 State:

S28-01

In order to avoid impacts to sea turtles, TPWD 

recommends avoiding training and testing activities 

along the mid and lower Texas coast during sea 

turtle nesting season (April through September).

As a matter of practice, the Navy typically does not conduct 

certain activities in the coastal zone due to specific mission 

requirements (see Section 2.3.3.16, Coastal Zone). For activities 

that could potentially be conducted in a coastal zone, the Navy 

will avoid or reduce impacts to sea turtles to the maximum extent 

practicable through procedural mitigation (see Section 5.3, 

Procedural Mitigation to be Implemented) to ensure that the 

Proposed Action does not jeopardize the continued existence of 

endangered or threatened species, or result in destruction or 

adverse modification of critical habitat (as required under the 

Endangered Species Act). The Navy completed a full Biological 

Assessment and operational analysis of potential mitigation areas 

throughout the entire Study Area. 

Developing additional mitigation areas beyond what is described 

in Section 5.4 (Mitigation Areas to be Implemented) would be

impractical due to implications for safety, sustainability, and the 

Navy’s ability to continue meeting its Title 10 requirements to 

successfully accomplish military readiness objectives.
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Appendix H Public Comment Responses

Table H.3-1. Comment Response Matrix (continued)

Reference 

Number Commenters Comment Response

98 State:

S28-02

Provisions for a cease and desist order for training 

and testing exercises should be considered in the 

event of a mass marine mammal stranding 

occurrence. Training and testing exercises should be 

suspended until an investigation can determine the 

cause of the stranding.

There has not been any stranding in the AFTT Study Area 

associated with Navy training and testing activities (see the 2017 

technical report Marine Mammal Strandings Associated with 

United States Navy Sonar Activities). As part of the MMPA 

consultation in the NMFS Final Rule, a stranding plan was 

developed that details Navy actions in the event of a mass 

stranding that would be potentially linked to Navy activities.

99 State:

S28-03

If impacts to the State's fish and wildlife resources 

cannot be avoided, potential impacts should be 

minimized to the extent practicable. Mitigation for 

unavoidable impacts to special aquatic sites, 

including wetlands, oyster reefs, seagrass beds, 

rookery islands and/or fish and wildlife species 

should be evaluated in the EIS/OEIS.

The AFTT Study Area does not include bays, estuaries, and 

wetlands in Texas, with the exception of civilian ports in 

Beaumont and Corpus Christi, which have been included in the 

environmental analysis. Furthermore, as a matter of practice, the 

Navy typically does not conduct certain activities in the coastal 

zone due to specific mission requirements (see Section 2.3.3.16, 

Coastal Zone). The Navy submitted a Coastal Consistency 

Determination to the 18 states in the AFTT Study Area. For 

activities that could potentially be conducted in a coastal zone, the 

Navy will avoid or reduce impacts to the maximum extent 

practicable through procedural mitigation (see Section 5.3, 

Procedural Mitigation to be Implemented) and mitigation areas 

(see Section 5.4, Mitigation Areas to be Implemented). The Navy 

completed a full Biological Assessment and operational analysis of 

potential mitigation areas throughout the entire Study Area. 

Developing additional mitigation areas beyond what is described 

in Section 5.4 (Mitigation Areas to be Implemented) would be 

impractical due to implications for safety, sustainability, and the 

Navy’s ability to continue meeting its Title 10 requirements to 

successfully accomplish military readiness objectives.
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Appendix H Public Comment Responses

Table H.3-1. Comment Response Matrix (continued)

Reference 

Number Commenters Comment Response

100 State:

S29-12

DCR-DNH recommends restricting any activities from 

April until August near preserves during 

migration/nesting activities for sea turtles and 

migratory birds.

As a matter of practice, the Navy typically does not conduct 

certain activities in the coastal zone due to specific mission 

requirements (see Section 2.3.3.16, Coastal Zone). For activities 

that could potentially be conducted in a coastal zone, the Navy 

will avoid or reduce impacts to sea turtles to the maximum extent 

practicable through procedural mitigation (see Section 5.3, 

Procedural Mitigation to be Implemented). Additionally, the Navy 

has a mitigation measure that applies year-round to reduce 

impacts on nesting birds from aircraft overflights within the 

VACAPES Range Complex and at Fisherman Island National 

Wildlife Refuge. Implementing additional mitigation in Virginia 

coastal waters would not be practical due to implications for 

safety, sustainability, and the Navy’s ability to continue meeting 

its Title 10 requirements to successfully accomplish military 

readiness objectives.

101 Local/Regional:

L05-02b

As a municipality located on a barrier island, we must 

be a good steward of our fragile and pristine 

environment. Whether it is monitoring Nags Head’s 

water quality or protecting the turtles that nest on 

our beautiful beach, we take great pride in doing 

everything we can to ensure that future generations 

will also be able to experience the magnificence of 

the Outer Banks. As such, we must request that more 

research be conducted to fully understand the 

impacts of sonar and explosives on marine life and 

how those impacts can be mitigated.

The Navy has for years implemented a very broad and 

comprehensive range of measures to mitigate potential impacts 

on marine mammals from military readiness activities. As the

EIS/OEIS documents in Chapter 5 (Mitigation), the Navy is 

increasing its mitigation measures to enhance protections of 

marine mammals to the maximum extent practicable. As noted in 

Section 3.0.1.1 of the EIS/OEIS, the Navy provides extensive 

investment for research programs in basic and applied research. In 

fact, the U.S. Navy is one of the largest sources of funding for 

marine mammal research in the world, which has greatly 

enhanced the scientific community’s understanding of marine 

species much more generally. The Navy’s support and conduct of 

cutting-edge marine mammal research includes: marine mammal 

detection, including the development and testing of new 

autonomous hardware platforms and signal processing algorithms 

for detection, classification, and localization of marine mammals; 

improvements in density information and development of 

abundance models of marine mammals; and advancements in
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Appendix H Public Comment Responses

Table H.3-1. Comment Response Matrix (continued)

Reference 

Number Commenters Comment Response

101

(cont.)

the understanding and characterization of the behavioral, 

physiological (hearing and stress response), and potentially 

population-level consequences of sound exposure on marine life. 

In addition, the Navy is a critical sponsor of the North Atlantic 

Right Whale EWS and the winter aerial surveys, which has 

contributed to a marked reduction in vessel strikes of the North 

Atlantic right whale in the Southeast critical habitat, particularly 

by commercial vessels which represents the greatest threat to the 

North Atlantic right whale. 

102 Individual:

KUNJE-02

I'm also asking for full commitment by the USN to 

protect marine species and habitat as this is directly 

connected to National Security under the current 

conditions challenging marine life by anthropogenic 

abrupt climate disruption at crisis levels; Naval 

activity will compound the collapse of marine 

habitats by adding additional toxic pollution release 

and likely resulting in harassment and 'takes' / 

deaths of marine species that are necessary for the 

health of our coastal waters. 

The Navy is committed to developing and implementing 

mitigation to avoid or reduce potential impacts to marine species, 

cultural resources, and the marine environment to the maximum 

extent practicable. Chapter 5 (Mitigation) details the mitigation 

measures that the Navy will implement under the Proposed Action

to avoid or reduce potential impacts from its training and testing 

activities. Additional information is included in Section 3.1 (Air 

Quality) and Section 3.2 (Sediments and Water Quality). The 

impacts of anthropogenically induced climate change on the 

marine environments is discussed in the individual resource 

sections as well as Chapter 4 (Cumulative Impacts). 

103 Individual:

MAREU-03, MAREU-04, 

MAREU-05, MAREU-06, 

MAREU-07

State:

S19-08

Organization:

O04-09

Six comments encouraged the Navy to avoid certain 

areas for testing and training and, or increase 

mitigation and monitoring to protect marine life, 

specifically benthic fishes and marine mammals.

The Navy is committed to developing and implementing 

mitigation to avoid or reduce potential impacts to marine species, 

cultural resources, and the marine environment to the maximum 

extent practicable. Chapter 5 (Mitigation) details the mitigation 

that the Navy will implement under the Proposed Action. Tables 

5.6-1 and 5.6-2 summarize both the procedural and geographic 

mitigations to be implemented by the Navy for all applicable 

resources.
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Appendix H Public Comment Responses

Table H.3-1. Comment Response Matrix (continued)

Reference 

Number Commenters Comment Response

104 Organization:

O02-02

In addition, we recommend the Navy contact the 

NOAA Fisheries for updates on Voluntary Speed 

Restriction Zones and follow any recommendations 

to avoid ship strikes and encounters with the 

endangered North Atlantic Right Whale and other 

endangered and protected species.

As discussed in Section 5.3.4.1 (Vessel Movement), the Navy 

implements mitigation to avoid vessel strikes throughout the 

Study Area. The Navy developed a new procedural mitigation that 

entails broadcasting awareness notification messages with North 

Atlantic right whale Dynamic Management Area information (e.g., 

location and dates) to applicable Navy assets operating in the 

vicinity of the Dynamic Management Area. The information will 

alert assets to the possible presence of a North Atlantic right 

whale to maintain safety of navigation and further reduce the 

potential for a vessel strike. In addition to procedural mitigation 

for vessel strikes, the Navy implements several additional 

mitigation measures within the Northeast and Southeast North 

Atlantic Right Whale Mitigation Areas to further reduce the 

potential for vessel strikes (see Section 5.4, Mitigation Areas to be 

Implemented). For example, the Navy is a dedicated participant 

and sponsor of the EWS, which is a comprehensive information 

exchange network dedicated to reducing the risk of vessel strikes 

to North Atlantic right whales off the southeast United States from 

all mariners (i.e., Navy and non-Navy vessels). Before transiting or 

conducting training or testing activities, the Navy will initiate 

communication with the Fleet Area Control and Surveillance 

Facility, Jacksonville to obtain Early Warning System North Atlantic 

right whale sightings data. Within the Northeast North Atlantic 

Right Whale Mitigation Area, before vessel transits, the Navy will 

conduct a web query or email inquiry to the National 

Oceanographic and Atmospheric Administration NEFSC’s North 

Atlantic Right Whale Sighting Advisory System to obtain the latest 

North Atlantic right whale sightings information. Vessels will use 

the obtained sightings information to reduce potential 

interactions with North Atlantic right whales in the mitigation 

areas.

105 Organization:

O02-03

There are, however, growing concerns about the 

direct and indirect impacts of acoustic activities,

The Navy is committed to developing and implementing 

mitigation to avoid or reduce potential impacts to marine 
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105 

(cont.)

including sonar and explosions, on marine mammals, 

fishes, and other species. The NOAA Ocean Noise 

Strategy Roadmap recognized that "sound is a 

fundamental component of the physical and 

biological habitat that many aquatic animals and 

ecosystems have evolved to rely on over millions of 

years." High intensity sound-producing activities such 

as sonar and explosions may harm marine life and 

should be minimized to the extent possible.

species, cultural resources, and the marine environment to the 

maximum extent practicable. Chapter 5 (Mitigation) details the 

mitigation that the Navy will implement under the Proposed 

Action.

106 Organization:

O02-04 Avoiding or limiting training nearshore between May 

and October may minimize conflicts with the more 

intensive recreational and commercial fishing that 

occurs during the warmer months. If that is 

impossible, constraining those trainings to small and 

strategically timed areas should help ensure these 

activities are isolated from other fishing activities.

Many Navy at-sea training and testing ranges are accessible to the 

public for recreational and commercial purposes. The Navy strives 

to conduct training and testing activities in a manner compatible 

with commercial and recreational ocean users by minimizing 

temporary access restrictions (Section 3.11, Socioeconomics). The 

Navy acknowledges that during specific exercises, its training and 

testing could briefly limit (usually for a matter of hours) public 

access to a very limited portion of coastal and ocean areas to 

ensure public safety. Notices to Mariners allow commercial and 

recreational fishing and tourism boats to adjust their routes to 

avoid temporary restricted areas. Socioeconomic Resources 

(Section 3.11) addresses the availability of access on the ocean 

and in the air and concludes there would be no impacts on 

commercial and recreational activities when Navy training and 

testing activities temporarily change access to the ocean or 

airspace in the Study Area. Training cycles and testing needs are 

expected to vary due to current and emerging threats. Due to 

changing needs, the EIS/OEIS is structured to provide flexibility in 

training and testing locations.
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Table H.3-1. Comment Response Matrix (continued)

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107 Organization:

O03-03

We urge the Navy to provide more information on its 

preferred alternative, which otherwise, based on the 

information presented in the DEIS, appears to have 

been designed on the basis of factors unrelated to 

avoiding or minimizing adverse impacts. To satisfy 

NEPA, the Navy should develop a fuller range of 

reasonable alternatives, such as by considering 

enhancements to its proposed time-area 

management measures.

The Navy's alternatives were developed in order to satisfy the 

Navy's purpose and need related to fulfilling its Title 10 

requirements. Consistent with 40 C.F.R. 1502.14, the Navy has 

included a robust suite of mitigation measures, which will be 

implemented in both action alternatives (i.e. regardless of which 

alternative is selected). These mitigation measures, as well as 

standard operating procedures that Navy routinely employs, are 

discussed in detail and specifically inform the decision maker and 

the public how the Navy can avoid or minimize adverse impacts. 

NEPA identifies the application of mitigation measures, such as 

those suggested by the comment, to the alternatives "when not 

already included in the proposed action or alternatives" (40 C.F.R. 

1502.14). Details regarding the development of reasonable 

alternatives are provided in Section 2.4, Action Alternative 

Development.

108 Organization:

O03-04

For the six Mitigation Areas to effectively protect 

marine mammals they must be properly sited, and 

the management objectives for each must be based 

on the best available science and be precautionary in 

nature. Below, we evaluate each of the six proposed 

areas and highlight gaps, where they exist, in their 

geographic coverage and mitigation requirements. 

We subsequently highlight additional areas of 

geographic importance for marine mammals for 

which Mitigation Areas should be considered.

Evaluation of proposed mitigation areas.

The Navy has worked collaboratively with NMFS to develop 

mitigation areas using inputs from the operational community, the 

best available science discussed in Chapter 3 (Affected 

Environment and Environmental Consequences), published 

literature, predicted activity impact footprints, and marine species 

monitoring and density data. The Navy completed an extensive 

Biological Assessment and operational analysis (based on a 

detailed and lengthy review by training experts and leadership 

responsible for meeting statutory readiness requirements) of 

potential mitigation areas throughout the entire Study Area. The 

mitigation identified in Section 5.4 (Mitigation Areas to be 

Implemented) represents the maximum mitigation within the 

identified mitigation areas that is practical to implement under 

the Proposed Action. Operational input indicates that designating 

additional mitigation areas (including but not limited to: within 

the southern portion of the Northeast Canyons and Seamounts 

National Marine Monument [as suggested in NRDC comment b.ii], 
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108

(cont.)

within the Charleston Bump[as suggested in NRDC comment 2.b],

or within dolphin habitat within the Deepwater Horizon spill area 

[as suggested in NRDC comment 2.c]), expanding the boundary of 

mitigation areas (including but not limited to: to encompass the 

full extent of the Cape Hatteras Special Research Area [as 

suggested in NRDC comment d.i], or within De Soto canyon [as 

suggested in NRDC comment f.ii]), or implementing further 

restrictions on the level, number, or timing (seasonal or time of 

day) of training or testing activities within the mitigation areas 

(including but not limited to: limiting major training exercises and 

other activities to reduce cumulative exposures [as suggested in 

NRDC comment b.i] or implementing additional mitigation for 

minke whales at Cashes Ledge [as suggested in NRDC comment 

c.ii]) would have a significant impact on the ability for units to 

meet their individual training and certification requirements 

(preventing them from deploying with the required level of 

readiness necessary to accomplish their missions), on the ability to 

certify strike groups to deploy to meet national security tasking 

(limiting the flexibility of Combatant Commanders and warfighters 

to project power, engage in multi-national operations, and 

conduct the full range of naval warfighting capability in support of 

national security interests), on the ability of program managers 

and weapons system acquisition programs to meet testing 

requirements and required acquisition milestones; on operational 

costs (due to extending distance offshore, which would increase 

fuel consumption, maintenance, and time on station to complete 

required training and testing activities), on the safety risk 

associated with conducting training and testing at extended 

distances offshore (farther away from critical medical and search 

and rescue capabilities), on accelerated fatigue-life of aircraft and 

ships (leading to increased safety risk and higher maintenance 

costs), on training and testing realism (due to reduced access to 

necessary environmental or oceanographic conditions that 
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108

(cont.)

replicate potential real world areas in which combat may occur),

and/or on the ability for Navy Sailors to train and become 

proficient in using the sensors and weapons systems as would be 

required in a real world combat situation. Furthermore, the 

iterative and cumulative impact of all commenter-proposed 

mitigation areas and seasonal or temporal restrictions would 

essentially prohibit Navy training and testing using sonar and 

explosives along the entire east coast and most of the Gulf of 

Mexico except in very narrow fragmented timeframes that are not 

compatible with effective, realistic training and testing. It is 

unclear how the Navy would be able to train and test without 

access to the ranges and locations that have been carefully 

developed over decades. Additionally, it would deny operational 

commanders the ability to respond to emerging national security 

challenges, placing national security at risk and sailors in danger 

by not being properly prepared to perform their missions. 

Likewise, these restrictions would have a significant impact on the 

testing of current systems and the development of new systems. 

This would deny weapons system program managers and 

research, testing, and development program managers the 

flexibility to rapidly field or develop necessary systems due to the 

required use of multiple areas within limited timeframes. 

Therefore, implementing additional mitigation areas beyond what 

is described in Section 5.4 (Mitigation Areas to be Implemented) 

would be impractical and would prevent the Navy from meeting 

its Title 10 requirements to successfully accomplish military 

readiness objectives. The Navy’s mitigation measures were 

reviewed and approved by a four-star Admiral, the Fleet 

Commander of all Navy forces in the Study Area, and Navy Senior 

Leadership; therefore, additional permission or authorization from 

Navy Leadership prior to conducting training or testing in the 

Study Area would be redundant. Additional information regarding 

the operational importance, significant negative impacts on Navy 
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Reference 

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108

(cont.)

training and testing operations, and impracticality of 

implementing the mitigation area proposed by commenter in each 

geographic region mentioned is provided in the responses to 

Commenter Reference numbers 109 through 113, 116, 119, and 

124 through 126, as well as in Chapter 5 (Mitigation) of the Final 

EIS/OEIS.

109 Organization:

O03-05

We recommend that the Navy strengthen the 

Mitigation Requirements in the Northeast North 

Atlantic Right Whale Mitigation Areas during the key 

months that the North Atlantic right whale is most 

likely to be using these areas to feed: April through 

June in the Great South Channel Mitigation Area and 

February through April in the Cape Cod Bay 

Mitigation Area. During these months, the Navy 

should prohibit the use of low-, mid-, or highfrequency active sonar for training and testing 

activities and limit the number of activities using 

non-explosive torpedoes to the extent practicable.

To achieve a general prohibition while preserving 

flexibility, we strongly recommend that the Navy use 

an approach similar to that of the Conservation 

Council Settlement Agreement, which, while barring 

or restricting active sonar and explosives activities, 

reserved the Navy’s authority to proceed regardless, 

provided the certain conditions were met: (1) that 

the Navy deemed the activity necessary for national 

defense; (2) that the authority could be invoked only 

by the highest Command authority; and (3) that any 

invocation of the authority be reported to NMFS and, 

through the Navy’s Annual and 5-Year Exercise 

Reports, to the public. Conservation Council, 

Stipulated Settlement Agreement and Order. Such an 

approach would ensure consistency of application 

In addition to the Navy's procedural mitigation described in 

Section 5.3 (Procedural Mitigation to be Implemented), the Navy 

will implement year-round mitigation to further protect North 

Atlantic right whales in their important feeding areas off the 

northeastern United States. The Navy has expanded the extent of 

the Northeast North Atlantic Right Whale Mitigation Area to 

encompass the entire northeast North Atlantic right whale critical 

habitat. The Navy will continue to submit annual training and 

testing activity reports to NMFS, which describe the level of 

training and testing conducted during the reporting period, and if 

unclassified, are made available to the public on the Navy's marine 

species monitoring webpage 

(https://www.navymarinespeciesmonitoring.us/) and the NMFS 

Office of Protected Resources webpage.

Navy Senior Leadership has approved and determined that the 

mitigation detailed in Chapter 5 (Mitigation) provides the greatest 

extent of protection that is practical to implement. The mitigation 

to obtain the latest sighting information from the North Atlantic 

Right Whale Sighting Advisory System will help vessels avoid North 

Atlantic right whales during all training and testing activities that 

occur in these areas. 

In its assessment of potential mitigation, the Navy has additional 

seasonal restrictions on active sonar and non-explosive torpedoes 

in North Atlantic right whale feeding areas off the northeastern 

United States in addition to the mitigation the Navy has proposed 

in this action. Navy operators determined that implementing 

additional mitigation beyond what is described in Section 5.4.2 
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109

(cont.)

and transparency, and would have the public’s 

confidence.

(Mitigation Areas off the Northeastern United States) would be

impractical due to implications for safety, sustainability, and the 

Navy’s ability to continue meeting its mission requirements to 

successfully accomplish military readiness objectives. Some of the 

considerations regarding why it would be impractical to 

implement additional mitigation off the northeastern United 

States are provided below.

The northeastern United States provides valuable access to air and 

sea space conditions that are analogous to areas where the Navy 

operates, or may need to operate in the future. Operating in these 

waters helps to ensure safety of personnel, skill proficiency, and 

validation of testing program requirements. For training, areas in 

this region where exercises are scheduled to occur are chosen to 

allow for the realistic tactical development of the myriad of 

training scenarios that Navy units are required to complete to be 

mission effective.

Locations for training activities are chosen due to the proximity to 

training ranges (e.g., Boston Operating Area), available airspace 

(e.g., warning area W107A in the Atlantic City Range Complex), 

unobstructed sea space (e.g., throughout the Narragansett 

Operating Area), aircraft emergency landing fields (e.g., Quonset 

Point Air National Guard Base, Quonset Point, RI), and with 

consideration for public safety (e.g., located a safe distance away 

from commercial fishing activities).

For testing, areas are chosen to allow the Navy to test systems 

and platforms in a variety of bathymetric and environmental 

conditions to ensure functionality and accuracy in real world 

environments. Off the northeastern United States, the Navy has

used the same torpedo testing areas for decades because they

provide critical bathymetric features and consistency for 

comparative data collection without any discernable degradation 

of the marine environment or impact to marine species. Testing 
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109 

(cont.)

ranges are typically located near the support facilities of the

systems commands, which provide critical safety and 

infrastructure support and technical expertise necessary to 

conduct range testing. For example, the Navy performs acoustic

and oceanographic research in continental shelf areas off the 

northeastern United States that involves active acoustic 

transmissions used for engineering tests of acoustic sources, 

validation of ocean acoustic models, tests of signal processing 

algorithms, and characterization of acoustic interactions with the 

ocean bottom. 

Following the publication of the 2013 Hawaii Southern California 

Training and Testing (HSTT) Final EIS/OEIS, a 2015 settlement 

agreement prohibited or restricted Navy activities within specific 

areas in the HSTT Study Area. 

The provisional prohibitions and restrictions on activities within 

the HSTT Study Area were derived pursuant to negotiations with 

plaintiffs and were specifically not evaluated or selected based on 

the type of thorough examination of best available science that 

occurs through the consultation process under the MMPA, or 

through analysis conducted for NEPA purposes. The agreement 

did not constitute a concession by the Navy as to the potential 

impacts of Navy activities on marine mammals, or any other 

marine species. Furthermore, the Navy's adoption of restrictions 

on its activities as part of a relatively short-term settlement does 

not mean that those restrictions are necessarily supported by the 

best available science, practical to implement from a military 

readiness standpoint over the longer term (in either the HSTT 

Study Area or other Study Areas, such as AFTT). Furthermore, the 

Fleet Commander and Navy Senior Leadership have approved the 

mitigation for the AFTT Study Area as described in Chapter 5 

(Mitigation); therefore, additional permission or authorization 

from Navy Leadership is not required prior to conducting training 
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Reference 

Number Commenters Comment Response

109 

(cont.)

or testing in the Study Area with regard to mitigation 

implementation.

110 Organization:

O03-06

Notably absent from the Northeast North Atlantic 

Right Whale Mitigation Areas is the biologically 

important feeding area identified for Jeffrey’s Ledge 

between June-July and October-December, and the 

biologically important mating area in the Central Gulf 

of Maine from November to January (LaBreque et al. 

2015). 

These areas should be afforded the same level of 

more stringent protection (including our additional 

recommendations noted above) as the two 

Northeast Mitigation Areas, at least for the months 

defined by LaBreque and colleagues (2015). Of 

particular note, Jeffrey’s Ledge is located due east of 

the Portsmouth Naval Shipyard, potentially 

heightening the risk of vessel collision for North 

Atlantic right whales feeding in this area. Given the 

vulnerability of the species to vessel collisions, it is 

essential that the 10-knot vessel speed restriction 

required for the existing two Northeast North 

Atlantic Right Whale Mitigation Areas also be 

observed for within the boundaries of Jeffrey’s 

Ledge, at minimum between the months of June-July 

and October-December, as defined by LaBreque et 

al. (2015).

As discussed in Section 5.4.2 (Mitigation Areas off the 

Northeastern United States), the Navy has expanded the extent of 

the Northeast North Atlantic Right Whale Mitigation Area to 

encompass the entire northeast North Atlantic right whale critical 

habitat. The North Atlantic right whale feeding area on Jeffreys 

Ledge and the mating area in the central Gulf of Maine are located 

within this expanded mitigation area. Mitigation to limit the use of 

active sonar to the maximum extent practicable and not use 

certain explosive and non-explosive munitions will help the Navy 

further avoid or reduce potential impacts on North Atlantic right 

whales year-round in their most important feeding areas, a mating 

area, and the northern portion of their migration habitat. The 

commenter-identified feeding and mating areas are also located 

within the Gulf of Maine Planning Awareness Mitigation Area, 

which will further avoid or reduce impacts from active sonar on 

marine mammals that inhabit, feed in, mate in, or migrate 

through the mitigation area.

There have been no Navy vessel strikes with North Atlantic right 

whales since implementation of mitigation measures and 

Standard Operating Procedures. As discussed in Section 5.3.4.1 

(Vessel Movement), the Navy implements procedural mitigation 

to avoid vessel strikes throughout the Study Area. As described in 

Section 2.3.3 (Standard Operating Procedures) Navy vessels 

operate in accordance with the navigation rules established by the 

U.S. Coast Guard, which require that vessels proceed at a safe 

speed so that proper and effective action can be taken to avoid 

collision and be stopped within a distance appropriate to the
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110 

(cont.)

prevailing circumstances and conditions. The Navy developed a 

new procedural mitigation that entails broadcasting awareness 

notification messages with North Atlantic right whale Dynamic 

Management Area information (e.g., location and dates) to 

applicable Navy assets operating in the vicinity of the Dynamic 

Management Area. The information will alert assets to the 

possible presence of a North Atlantic right whale to maintain 

safety of navigation and further reduce the potential for a vessel 

strike. As described in Section 5.4.2 (Mitigation Areas off the 

Northeastern United States), the Navy implements speed 

restrictions in the Northeast North Atlantic Right Whale Mitigation 

Area year-round during non-explosive torpedo activities. The Navy 

can implement a 10-knot speed restriction during certain portions 

of non-explosive torpedo activities due to the nature of how these 

activities are conducted (e.g., during transits and normal firing, 

maintaining a speed of no more than 10 knots still allows the Navy

to meet associated mission requirements). In its assessment of 

potential mitigation, the Navy considered implementing additional 

vessel speed restrictions (e.g., expanding the 10-knot restriction to 

other activities off the northeastern United States). Navy 

determined that implementing additional vessel speed restrictions 

beyond what is described in Section 5.4.2 (Mitigation Areas off the 

Northeastern United States) would be impractical due to 

implications for safety, sustainability, and the Navy’s ability to 

continue meeting its mission requirements to successfully 

accomplish military readiness objectives. 

For example, the Navy will not implement a 10-knot speed 

restriction during submarine target firing for non-explosive 

torpedo testing activities because it would prevent the Navy from 

properly testing vessel and system capabilities. 

As described in Section 5.3.4.1 (Vessel Movement), any additional 

vessel speed restrictions would prevent vessel operators from
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Reference 

Number Commenters Comment Response

110 

(cont.)

gaining skill proficiency, would prevent the Navy from properly 

testing vessel capabilities, or would increase the time on station 

during training or testing activities as required to achieve skill 

proficiency or properly test vessel capabilities (which would 

significantly increase fuel consumption); therefore, the mitigation 

proposed by the comment would have significant impacts on the 

Navy’s ability to train and test, and would prevent the Navy from 

meeting its mission requirements.

111 Organization:

O03-07

We therefore recommend that the Navy consider 

prohibiting the planning and conduct of major 

exercises within these areas, using the Conservation 

Council approach, as summarized at section III.B.1.a 

above, to provide flexibility.

The commenter indicated that range-limited beaked whale 

populations have been found on the shelf break off Cape Hatteras, 

areas off Canada, in the Mediterranean, off Southern California, in 

the Bahamas, and around the Hawaiian Islands; and range-limited 

sperm whale populations have been found off Cape Hatteras, the 

Gulf of Mexico, and off Western Australia. The commenter 

assumed that beaked whales and sperm whales are also rangelimited within the Northeast Planning Awareness Mitigation Areas, 

and as a result, recommended additional mitigation to limit major 

training exercises and other activities to reduce cumulative 

exposure in the Northeast Planning Awareness Mitigation Areas. 

However, the best available science does not indicate that beaked 

whales and sperm whales are range-limited within the Northeast 

Planning Awareness Mitigation Areas. 

As described in Section 3.7.3.1.2.3 (Impacts from Sonar and Other 

Transducers Under the Action Alternatives), a few minor to 

moderate TTS or behavioral reactions to an individual over the 

course of a year are unlikely to have any significant costs or longterm consequences for that individual. Considering these factors 

and the mitigation measures that would be implemented as 

described in Section 5.3.2.1 (Active Sonar) and Section 5.4.2 

(Mitigation Areas off the Northeastern United States), long-term
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Number Commenters Comment Response

111

(cont.)

consequences for the species or stocks are not expected. The 

Navy does not typically schedule major training exercises in the 

Northeast Range Complexes, where the Northeast Planning 

Awareness Mitigation Area is located, as indicated in Table 2.6-1 

(Proposed Training Activities per Alternative) and Table 5.4-2 

(Mitigation Areas off the Northeastern United States). For training 

and testing that does occur here, this area provides a wide range 

of bathymetric and topographic opportunities that support critical 

smaller scale training and testing necessary to meet mission 

requirements. Additionally, major training exercises originally 

planned for other locations may have to change during an 

exercise, or in exercise planning, based on an assessment of the 

performance of the units, or due to other conditions such as 

weather and mechanical issues. These contingency requirements 

preclude the Navy from completely prohibiting major training 

exercises from occurring in this area.

112 Organization:

O03-08

If major exercises cannot absolutely be avoided, the 

Navy should consider prohibiting conduct of more 

than two major exercises per year, with each 

exercise carried out in different Northeast Planning 

Awareness Mitigation Areas (i.e., one exercise in the 

northern Mitigation Area, and one exercise in the 

southern Mitigation Area), to ensure that marine 

mammal populations with site fidelity are not 

exposed to multiple major training exercises within a 

single year. Similarly, the Navy should consider 

prohibiting testing and unit-level sonar and in-water 

explosives training in the Areas, or alternatively, and 

less preferably, reducing the number of hours 

allowable in a given year, with the prohibition or 

restriction structured as in Conservation Council to 

provide flexibility.

In its assessment of potential mitigation, the Navy considered 

implementing additional restrictions on active sonar and 

explosives in the Northeast Canyons and Seamounts National 

Marine Monument. Navy’s operational assessment determined 

that implementing additional mitigation for the reasons stated in 

Section 5.4.2 (Mitigation Areas off the Northeastern United 

States) would be impractical due to implications for safety, 

sustainability, and the Navy’s ability to continue meeting its 

mission requirements to successfully accomplish military 

readiness objectives.

While the Navy reviewed each additional mitigation measure 

recommended by the commenter, the Navy also reviewed all of 

these measures comprehensively. Adopting all of the limitations 

on training and testing suggested by the commenter would result 

in the Navy effectively losing access to the significant majority of 

the required training space necessary to comply with the Navy’s 

statutory requirement to prepare a ready force. 
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Table H.3-1. Comment Response Matrix (continued)

Reference 

Number Commenters Comment Response

112

(cont.)

As noted in Chapter 2, the Navy also requires extensive sea space 

so that individual training and testing activities can occur at 

sufficiently safe distances such that these activities do not 

interfere with one another and so that Navy units can train to 

communicate and operate in a coordinated fashion over tens or 

hundreds of square miles, as they will have to do when in an 

operational theater. The Navy must also train in these areas 

because it may be called upon to defend the United States from 

direct maritime threats, and the Navy must therefore be familiar 

with the very waters where it may engage in combat. Enemy naval 

forces have historically and consistently operated in U.S. waters, 

from the conflicts following the U.S.’s independence, the World 

Wars, and through the Cold War. To this day, foreign naval forces 

operate in U.S. waters, sometimes clandestinely. To completely 

ban entire areas from training and testing means the Navy will not 

be able to train in the very waters where it may need to fight and 

defend the U.S., thus creating potential sanctuaries where foreign 

naval forces, and submarines in particular, may operate more 

freely.

The commenter proposes, in the alternative to banning Navy 

training and testing, that the Navy require approval in nearly every 

area where the Navy currently trains and tests from the “highest 

command authority.” It is unclear who the commenter means by 

this in that the highest command authority for the military is the 

President. Assuming the commenter is referring to very senior 

military commanders, such a requirement is unwarranted and 

impractical. As noted in Chapter 2 (Description of Proposed Action 

and Alternatives), the Navy conducts thousands of discrete 

training and testing activities, many involving sonar and 

explosives. In most cases, these events are small-scale unit-level 

training activities or testing events with minimal to no impacts on 

marine mammals and the environment. To require that each
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112 

(cont.)

individual event be approved at such an elevated level of 

command, and for all of the areas proposed by the commenter, 

would essentially paralyze Navy decision-making as senior 

commanders would be focused on approving otherwise minor and 

minimally impactful activities. This would lead to fewer training 

and testing evolutions and decreased readiness, and increasing 

the risk to Sailors, platforms, and equipment. For major training 

events, senior commanders are already part of the planning and 

approval processes for the conduct of the event. Adding the 

proposed approval scheme would also be redundant for AFTT 

because the Navy’s mitigation measures described in Chapter 5 

(Mitigation) were reviewed and approved by a four-star Admiral, 

the Fleet Commander of all Navy forces in the Study Area, and 

Navy Senior Leadership. While the approval scheme may have 

been supportable as a short-term settlement measure, it is 

inappropriate for a long-term approach, is not supported at the 

scale suggested by the commenter in AFTT, is otherwise not 

warranted based on the extensive level of mitigation already 

approved by senior Navy leadership, and creates additional 

administrative burdens on operational commanders distracting 

them from preparing a ready force. At its most fundamental level 

an approval scheme of this type runs counter to one of the

foundational concepts of naval command and control at sea –

which is the ability and duty for a commanding officer to train and 

fight their ship. As such, the Navy works to institutionalize 

mitigation procedures in order to ensure that these measures are 

implemented efficiently and consistently across the Navy. To 

accomplish this, the Navy has developed a software tool known as 

the Protective Measures Assessment Protocol (see Section 5.1.2, 

Compliance Initiatives) to reduce the administrative burdens of 

environmental compliance on commanders while ensuring 

required mitigation is implemented correctly. Nor does the 

excessive level of mitigation proposed by the commenter appear
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Reference 

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112 

(cont.)

warranted when compared to the level of environmental impact 

anticipated from Navy training and testing. The Navy has been 

training and testing in these areas for decades without causing 

any discernable degradation of the marine environment or to 

marine species. Many of the impacts to marine species noted by 

the commenter, such as the increase in ambient ocean noise, 

marine mammal injuries, and vessel strikes, are caused primarily 

by other activities, such as commercial fishing and commercial 

shipping. In the last 25 years, commercial shipping has increased 

400%, and the amount of food we obtain from the sea has 

increased 10-fold. Yet, during this time, the U.S. Navy has become 

smaller, and its levels of activities have lessened as a result. The 

Navy represents an extremely small percentage of overall marine 

activities, and these other activities represent the overwhelming 

proportion of impacts on the marine environment, yet the 

mitigation measures proposed by the commenter would impose 

some of the most stringent and restrictive of any requirements on 

any other marine activity, measures that potentially mitigate 

mostly short-term and minor environmental impacts, and would 

essentially preclude effective Navy training and testing. 

Chapter 5 contains a detailed discussion of mitigation that 

includes limitations on sonar and explosives use, time/area 

restrictions, planning areas that elevate environmental 

considerations, and a reporting system. The Navy’s mitigation 

measures represent the greatest level of mitigation that is 

practical to implement, when balanced against impacts to safety, 

sustainability, and the Navy’s ability to continue meeting its 

mission requirements. The Navy’s mitigation measures were 

reviewed and approved by a four-star Admiral, the Fleet 

Commander of all Navy forces in the Study Area, and Navy Senior 

Leadership.
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Table H.3-1. Comment Response Matrix (continued)

Reference 

Number Commenters Comment Response

113 Organization:

O03-09

We commend the Navy for their proposal to not plan 

major training exercises within such a large 

geographic area; however, the Gulf of Maine 

Planning Awareness Mitigation Area encompasses a 

number of habitat areas important for a number of 

endangered and sensitive species, and so, at least in 

some areas and at certain times, additional 

mitigation measures are warranted. (Additional 

measures commenter refers to are addressed as 

individual comments in this appendix.)

The northeastern United States provides valuable access to air and 

sea space conditions that are analogous to areas where the Navy 

operates, or may need to operate in the future. This contributes to 

safety of personnel, skill proficiency, and validation of testing 

program requirements. For training, areas in this region where 

exercises are scheduled to occur are chosen to allow for the 

realistic tactical development of the myriad of training scenarios 

that Navy units are required to complete to be mission effective. 

Locations for training activities are chosen due to the proximity to 

training ranges (e.g., Boston Operating Area), available airspace 

(e.g., warning area W107A in the Atlantic City Range Complex), 

unobstructed sea space (e.g., throughout the Narragansett 

Operating Area), aircraft emergency landing fields (e.g., Quonset 

Point Air National Guard Base, Quonset Point, Rhode Island), and 

with consideration for public safety (e.g., located a safe distance 

away from commercial fishing activities). For testing, areas are 

chosen to allow the Navy to test systems and platforms in a 

variety of bathymetric and environmental conditions to ensure 

functionality and accuracy in real world environments. 

Testing ranges are typically located near the support facilities of 

the systems commands, which provide critical safety and 

infrastructure support and technical expertise necessary to 

conduct range testing. For example, the Navy performs acoustic 

and oceanographic research in continental shelf areas off the 

northeastern United States that involves active acoustic 

transmissions used for engineering tests of acoustic sources, 

validation of ocean acoustic models, tests of signal processing

algorithms, and characterization of acoustic interactions with the 

ocean bottom. The Navy will continue to submit annual training 

and testing activity reports to NMFS (some data is classified), 

which describe the level of training and testing conducted during 

the reporting period, and the unclassified data are made available 

to the public on the Navy's marine species monitoring webpage
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Table H.3-1. Comment Response Matrix (continued)

Reference 

Number Commenters Comment Response

113 

(cont.)

(https://www.navymarinespeciesmonitoring.us/) and the NMFS 

Office of Protected Resources webpage. Implementing additional 

mitigation in mitigation areas off the northeastern United States 

beyond what is described in Section 5.4.2 (Mitigation Areas off the 

Northeastern United States) be impractical due to implications for 

safety, sustainability, and the Navy’s ability to continue meeting

its Title 10 requirements to successfully accomplish military 

readiness objectives.

114 Organization:

O03-10

The harbor porpoise is particularly sensitive to 

disturbance from noise, and these impacts are may 

lead to population-level effects when a population is 

resident to a limited geographic area. The Gulf of 

Maine Planning Awareness Mitigation Area includes 

a biologically important area for the small population 

of harbor porpoise resident to the Gulf of Maine 

from July-September. Within the boundaries of this 

area between the months of July- September, the 

Navy should prohibit the use of mid- and highfrequency sonar for training and testing activities and 

prohibit the use of in-water explosives for training 

and testing activities.

As described in Chapter 3.7 (Marine Mammals), with additional 

details in sections 3.7.2.3.27.2 (Habitat and Geographic Range), 

3.7.3 (Environmental Consequences), 3.7.4 (Summary of Potential 

Impacts on Marine Mammals), and 3.7.6 (Marine Mammal 

Protection Act Determinations), where the analysis does consider 

the factors discussed in the Forney, K.A., et. al. 2017 paper, it is 

unlikely that any takes resulting from training and testing activities 

would cause the harbor porpoise to abandon the BIA cited by the 

commenter. The activities conducted by Navy are of short 

duration (minutes to a few hours) and widely dispersed 

temporally and geographically, therefore, would not significantly 

affect an animal’s natural behavioral patterns such as feeding, 

breeding, etc., where those impacts will affect stocks or 

populations. Additionally, the Navy has been conducting training 

and testing in these areas and at similar levels of activity for 

decades with no evidence those activities are having a measurable 

impact on stocks or populations. As discussed in Section 5.4.2 

(Mitigation Areas off the Northeastern United States), the Navy 

has expanded the extent of the Northeast North Atlantic Right 

Whale Mitigation Area to encompass the entire northeast North 

Atlantic right whale critical habitat. The newly expanded 

mitigation area now covers the extent of the harbor porpoise 

small and resident population area. Mitigation to limit the use of 

active sonar to the maximum extent practicable and not use 

certain explosive and non-explosive munitions within the
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Table H.3-1. Comment Response Matrix (continued)

Reference 

Number Commenters Comment Response

114 

(cont.)

mitigation area will help the Navy further avoid or reduce 

potential impacts on harbor porpoises year-round.

115 Organization:

O03-11, O03-12, O03-13

Three comments recommend that the Navy prohibit 

the use of active sonar and in-water explosions.

Specifically in the following areas:

 Biologically important feeding habitat for minke 

whales at Cashes Ledge

 Northeast Canyons and Seamounts National 

Marine Monument

The Navy has worked collaboratively with NMFS to develop 

mitigation areas using inputs from the operational community, the 

best available science discussed in Chapter 3 (Affected 

Environment and Environmental Consequences), published 

literature, predicted activity impact footprints, and marine species 

monitoring and density data. The Navy completed an extensive 

Biological Assessment and operational analysis (based on a 

detailed and lengthy review by training experts and leadership 

responsible for meeting statutory readiness requirements) of 

potential mitigation areas throughout the entire Study Area. The 

mitigation identified in Section 5.4 (Mitigation Areas to be 

Implemented) represents the maximum mitigation within the 

identified mitigation areas that is practical to implement under 

the Proposed Action. 

Operational input indicates that designating additional mitigation 

areas (including but not limited to: within the southern portion of 

the Northeast Canyons and Seamounts National Marine 

Monument [as suggested in NRDC comment b.ii], within the 

Charleston Bump [as suggested in NRDC comment 2.b], or within 

dolphin habitat within the Deepwater Horizon spill area [as 

suggested in NRDC comment 2.c]), expanding the boundary of 

mitigation areas (including but not limited to: to encompass the 

full extent of the Cape Hatteras Special Research Area [as 

suggested in NRDC comment d.i], or within De Soto canyon [as 

suggested in NRDC comment f.ii]), or implementing further 

restrictions on the level, number, or timing (seasonal or time of 

day) of training or testing activities within the mitigation areas 

(including but not limited to: limiting major training exercises and 

other activities to reduce cumulative exposures [as suggested in 

NRDC comment b.i] or implementing additional mitigation for 

minke whales at Cashes Ledge [as suggested in NRDC comment 
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Appendix H Public Comment Responses

Table H.3-1. Comment Response Matrix (continued)

Reference 

Number Commenters Comment Response

115 

(cont.)

c.ii]) would have a significant impact on the ability for units to 

meet their individual training and certification requirements 

(preventing them from deploying with the required level of 

readiness necessary to accomplish their missions), on the ability to 

certify strike groups to deploy to meet national security tasking 

(limiting the flexibility of Combatant Commanders and warfighters 

to project power, engage in multi-national operations, and 

conduct the full range of naval warfighting capability in support of 

national security interests), on the ability of program managers 

and weapons system acquisition programs to meet testing 

requirements and required acquisition milestones; on operational 

costs (due to extending distance offshore, which would increase 

fuel consumption, maintenance, and time on station to complete 

required training and testing activities), on the safety risk 

associated with conducting training and testing at extended 

distances offshore (farther away from critical medical and search 

and rescue capabilities), on accelerated fatigue-life of aircraft and 

ships (leading to increased safety risk and higher maintenance 

costs), on training and testing realism (due to reduced access to 

necessary environmental or oceanographic conditions that 

replicate potential real world areas in which combat may occur), 

and/or on the ability for Navy Sailors to train and become 

proficient in using the sensors and weapons systems as would be 

required in a real world combat situation. Furthermore, the 

iterative and cumulative impact of all commenter-proposed

mitigation areas and seasonal or temporal restrictions would 

essentially prohibit Navy training and testing using sonar and 

explosives along the entire east coast and most of the Gulf of 

Mexico except in very narrow fragmented areas and timeframes 

that are not compatible with effective, realistic training and 

testing. It is unclear how the Navy would be able to train and test 

without access to the ranges and locations that have been 

carefully developed over decades. Additionally, it would deny
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Table H.3-1. Comment Response Matrix (continued)

Reference 

Number Commenters Comment Response

115 

(cont.)

operational commanders the ability to respond to emerging 

national security challenges, placing national security at risk and 

sailors in danger by not being properly prepared to perform their 

missions. Likewise, these restrictions would have a significant 

impact on the testing of current systems and the development of 

new systems. This would deny weapons system program 

managers and research, testing, and development program 

managers the flexibility to rapidly field or develop necessary 

systems due to the required use of multiple areas within limited 

timeframes. Therefore, implementing additional mitigation areas 

beyond what is described in Section 5.4 (Mitigation Areas to be 

Implemented) would be impractical and would prevent the Navy 

from meeting its Title 10 requirements to successfully accomplish 

military readiness objectives.

The Navy’s mitigation measures were reviewed and approved by a 

four-star Admiral, the Fleet Commander of all Navy forces in the 

Study Area, and Navy Senior Leadership; therefore, additional 

permission or authorization from Navy Leadership will not be 

required prior to conducting training or testing in the Study Area 

with regard to mitigation implementation. Additional information 

regarding the operational importance, significant negative impacts 

on Navy training and testing operations, and impracticality of 

implementing the mitigation area proposed by commenter in each 

geographic region mentioned is provided in the responses to 

Commenter Reference numbers 109 through 113, 116, 119, and 

124 through126, as well as in Chapter 5 (Mitigation) of the 

EIS/OEIS.

116 Organization:

O03-14

The Navy proposes two Mid-Atlantic Planning 

Awareness Mitigation Areas, one of which is situated 

within the North Atlantic right whale migratory 

corridor and includes waters seaward of Cape 

Hatteras to the shelf break, including a central 

portion of the Cape Hatteras Special Research Area 

The waters off the mid-Atlantic and southeastern United States 

encompass part of the primary water space in the AFTT Study Area 

where unit-level training, integrated training, and deployment 

certification exercises occur, and are critical for these and other 

training and testing activities. The Navy conducts training and 

testing activities off the mid-Atlantic and southeastern United 
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Table H.3-1. Comment Response Matrix (continued)

Reference 

Number Commenters Comment Response

116 

(cont.)

(“CHSRA”), and a portion of the shelf break to the 

south. The second encompasses a north-south 

portion of the North Atlantic right whale migratory 

corridor offshore of Virginia.

States because this region provides valuable access to air and sea 

space conditions that are analogous to areas where the Navy 

operates, or may need to operate in the future. This contributes to 

safety of personnel, skill proficiency, and validation of testing 

program requirements. For training and testing, areas in this 

region where exercises are scheduled to occur are chosen to allow 

for the realistic tactical development of the myriad of training and 

testing scenarios that Navy units are required to complete to be 

mission effective. Certain activities, such as deployment 

certification exercises using integrated warfare components, 

require large areas of the littorals and open ocean for realistic and 

safe training.

Locations for other training and testing activities are chosen due 

to the proximity of associated training and testing ranges and 

operating areas (e.g., VACAPES), available airspace (e.g. W-50), 

unobstructed sea space, aircraft emergency landing fields (e.g., 

Naval Air Station Oceana), and with consideration for public safety 

(e.g., avoiding areas popular for recreational boating). Further 

restrictions in this area (e.g., further restricting the number of 

major training events or seasonal restrictions on major training 

exercises based on predicted density of marine mammal species) 

for mitigation would be impractical to implement and would 

significantly impact the scheduling, training, and certifications 

required to prepare naval forces for deployment. Seasonal or 

temporal restrictions would not be practical to implement for all 

training and testing in this region (including within the Cape 

Hatteras Special Research Area) because training and testing 

schedules are based on national tasking, the number and duration 

of training cycles identified in the Optimized Fleet Response Plan 

and various training plans, and forecasting of future testing 

requirements (including emerging requirements). Although the 

Navy has the ability to restrict, as identified in Table 5.4-3 

(Mitigation Areas off the Mid-Atlantic and Southeastern United 
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Table H.3-1. Comment Response Matrix (continued)

Reference 

Number Commenters Comment Response

116 

(cont.)

States), the number of major training exercises in the Mid-Atlantic 

Planning Awareness Mitigation Areas, the Navy is unable to 

prohibit all major training exercises in this area, as it provides air 

and sea conditions necessary to meet real world requirements. 

Additionally, major training exercises originally planned for other 

locations may have to change during an exercise, or in exercise 

planning, based on an assessment of the performance of the units, 

or due to other conditions such as weather and mechanical issues. 

These contingency requirements preclude the Navy from 

completely prohibiting major training exercises from occurring in 

this area.

117 Organization:

O03-15

These range-restricted populations are therefore all 

at risk of cumulative exposure to multiple training 

and testing activities, including multiple major 

exercises per year, which may lead to populationlevel consequences.

While these species may show site fidelity to this area, tagging 

data indicates they also move throughout the central western 

Atlantic area and are not range-restricted (Thorne et al. 2017, 

Baird et al. 2018). As described in section 3.7.3.1 (Acoustic 

Stressors) and Section 3.7.3.2 (Explosive Stressors), the Navy does 

not anticipate population-level impacts to marine mammals from 

the Proposed Action, including to beaked whales, pilot whales, 

and sperm whales at Cape Hatteras or elsewhere in the U.S. MidAtlantic region. Additionally, the Navy has been conducting 

training and testing in these areas and at similar levels of activity 

for decades with no evidence those activities are having an impact 

on stocks or populations of any of the species mentioned.

118 Organization:

O03-16, O03-17, O03-18

Three comments suggested if major exercises cannot 

be avoided in the Cape Hatteras Special Research 

Area then the amount conducted should be limited, 

specifically in Mitigation Areas.

In its assessment of potential mitigation, the Navy considered 

implementing additional restrictions on active sonar and 

explosives in the U.S. mid-Atlantic region, including expanding the 

boundaries of the mitigation area to fully encompass the Cape 

Hatteras Special Research Area, limiting major training exercises, 

and planning activities to avoid times of predicted high North 

Atlantic right whale density. Navy operators determined that 

implementing additional mitigation beyond what is described in 

Section 5.4.3 (Mitigation Areas off the mid-Atlantic and 

Southeastern United States) would be impractical due to 
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Appendix H Public Comment Responses

Table H.3-1. Comment Response Matrix (continued)

Reference 

Number Commenters Comment Response

118 

(cont.)

implications for safety, sustainability, and the Navy’s ability to 

continue meeting its Title 10 requirements to successfully 

accomplish military readiness objectives. Some of the 

considerations regarding why it would be impractical to 

implement additional mitigation in the U.S. mid-Atlantic region 

are provided below.

The waters off the mid-Atlantic and southeastern United States 

encompass part of the primary water space in the AFTT Study Area 

where unit-level training, integrated training, and deployment 

certification exercises occur, and are critical for these and other 

training and testing activities. The Navy conducts training and 

testing activities off the mid-Atlantic and southeastern United 

States because this region provides valuable access to air and sea 

space conditions that are analogous to areas where the Navy 

operates, or may need to operate in the future. This contributes to 

ensure safety of personnel, skill proficiency, and validation of

testing program requirements. Areas in this region where 

activities are scheduled to occur are chosen to allow for the 

realistic tactical development of the myriad training and testing 

scenarios that Navy units are required to complete to be mission 

effective. Certain activities, such as deployment certification 

exercises using integrated warfare components, require large 

areas of the littorals and open ocean for realistic and safe training. 

Locations for other training and testing activities are chosen due 

to the proximity of associated training and testing ranges and 

operating areas (e.g., VACAPES), available airspace (e.g. W-50 in 

VACAPES), unobstructed sea space, aircraft emergency landing 

fields (e.g., Naval Air Station Oceana), and with consideration for 

public safety (e.g., avoiding areas popular for recreational 

boating). Further restrictions in this area (e.g., further restricting 

the number of major training events or seasonal restrictions on 

major training exercises based on predicted density of marine 

mammal species, such as North Atlantic right whales) for 
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Table H.3-1. Comment Response Matrix (continued)

Reference 

Number Commenters Comment Response

118 

(cont.)

mitigation would be impractical to implement and would 

significantly impact the scheduling, training, and certifications 

required to prepare naval forces for deployment.

Seasonal or temporal restrictions would not be practical to 

implement for all training and testing in this region (including 

within the Cape Hatteras Special Research Area) because training 

and testing schedules are based on national tasking, the number 

and duration of training cycles identified in the Optimized Fleet 

Response Plan and various training plans, and forecasting of 

future testing requirements (including emerging requirements). 

Although the Navy has the ability to restrict, as identified in Table 

5.4-3 (Mitigation Areas off the Mid-Atlantic and Southeastern 

United States), the number of major training exercises in the MidAtlantic Planning Awareness Mitigation Areas, the Navy is unable 

to prohibit all major training exercises in this area, as it provides 

air and sea conditions necessary to meet real world requirements. 

Additionally, major training exercise locations may have to change 

during an exercise, or in exercise planning, based on an 

assessment of the performance of the units, or due to other 

conditions such as weather and mechanical issues, which 

precludes the ability to completely prohibit major training 

exercises from occurring in this area.

119 Organization:

O03-19

In full acknowledgement of the Navy’s position that 

additional mitigation for training and testing 

activities across the expanded Critical Habitat area 

may compromise national security, as well as the 

determination by NMFS that the definition of areas 

should be based on areas of predicted high North 

Atlantic right whale density, we suggest that the 

Navy assess its planned activities across the broader 

high density are described above and consider 

additional mitigation measures for at least those 

activities that may cause the most harm (i.e., lowThe Navy developed a new procedural mitigation that entails 

broadcasting awareness notification messages with North Atlantic 

right whale Dynamic Management Area information (e.g., location 

and dates) to applicable Navy assets operating in the vicinity of 

the Dynamic Management Area. The information will alert assets 

to the possible presence of a North Atlantic right whale to 

maintain safety of navigation and further reduce the potential for 

a vessel strike. Within the Mid-Atlantic and southeastern region, 

the Navy identified an opportunity to expand the mitigation area 

for North Atlantic right whales off the southeastern United States 

in a way that would enhance protections for the species, while
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Appendix H Public Comment Responses

Table H.3-1. Comment Response Matrix (continued)

Reference 

Number Commenters Comment Response

119 

(cont.)

frequency and hull-mounted mid- frequency active 

sonar, dipping sonar, and in-water detonations and 

explosives). In addition, the dynamic vessel speed 

reduction strategy should be observed throughout 

this high density area.

balancing the practicality of implementation. The Navy expanded 

the Southeast North Atlantic Right Whale Mitigation Area to 

correlate with the occurrence of North Atlantic right whales to the 

maximum extent practicable based on readiness requirements. 

Certain activities, such as deployment certification exercises using 

integrated warfare components, require large areas of the littorals 

and open ocean for realistic and safe training. 

Locations for other training activities are chosen due to the 

proximity of associated training ranges (e.g., Jacksonville Range 

Complex), available airspace (e.g., avoiding airspace conflicts with 

major airports such as Jacksonville International Airport), 

unobstructed sea space, aircraft emergency landing fields (e.g., 

Naval Air Station Jacksonville), and with consideration for public 

safety (e.g., avoiding areas popular for recreational boating). The 

Jacksonville Operating Area and Charleston Operating Area 

represent critical training sea spaces that are necessary to prepare 

naval forces for combat. Areas where testing events are scheduled 

to occur are chosen to allow the Navy to test systems and 

platforms in a variety of bathymetric and environmental 

conditions to ensure functionality and accuracy in real world 

environments. Test locations are typically located near the support 

facilities of the systems commands, which provide critical safety, 

platform, and infrastructure support and technical expertise 

necessary to conduct testing (e.g., proximity to air squadrons). 

Additional mitigation, such as expanding the Southeast North 

Atlantic Right Whale Mitigation Area eastward to mirror the 

boundary of the expanded critical habitat or northward to 

encompass all areas of high animal density, would require training 

to move farther north or farther out to sea, which would be 

impractical due to implications for safety and sustainability, as 

detailed in Section 5.4.3 (Mitigation Areas off the Mid-Atlantic and 

Southeastern United States).
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Appendix H Public Comment Responses

Table H.3-1. Comment Response Matrix (continued)

Reference 

Number Commenters Comment Response

120 Organization:

O03-20

Dipping sonar should be prohibited within the 

Southeast North Atlantic Right Whale Mitigation 

Area.

As discussed in Section 5.4.3 (Mitigation Areas off the Mid-Atlantic 

and Southeastern United States), the Navy will minimize the use 

of helicopter dipping sonar to the maximum extent practicable. 

The only helicopter dipping sonar activity that could potentially be 

conducted in the mitigation area is Kilo Dip, which could involve 1-

2 pings of active sonar infrequently. Kilo Dip is a functional check 

activity that needs to occur close to an air station in the event of a 

system failure (i.e., all systems are not functioning properly). 

During this activity, the Navy will implement the procedural 

mitigation described in Section 5.3.2.1 (Active Sonar), with visual 

observations aided by EWS North Atlantic right whale sightings 

data.

121 Organization:

O03-21

The Navy should also prohibit low-frequency active 

sonar within the Southeast North Atlantic Right 

Whale Mitigation Area.

As discussed in Section 5.4.3 (Mitigation Areas off the Mid-Atlantic 

and Southeastern United States), the Navy will not conduct lowfrequency active sonar in the mitigation area, with the exception 

of low-frequency active sonar used for navigation training, which 

will be minimized to the maximum extent practicable. During this 

activity, crews train to operate sonar for navigation, an ability that 

is critical for safety while transiting into and out of port during 

periods of reduced visibility. The Navy will implement the 

procedural mitigation described in Section 5.3.2.1 (Active Sonar), 

with visual observations aided by EWS North Atlantic right whale 

sightings data.

122 Organization:

O03-22

Should the Navy choose Alternative 2, we urge the 

Navy to plan major training exercises, if they are 

absolutely necessary, in other operating areas that 

do not directly overlap with areas in which small 

resident populations of endangered whales reside.

At this time, the Navy's preferred alternative is Alternative 1.

123 Organization:

O03-23

Regardless of the alternative chosen, and recognizing 

the limitations discussed at 5-78, the Navy should 

also consider prohibiting or strictly limiting testing 

and unit-level training of active sonar and in-water 

explosives to the greatest extent practicable within 

The Gulf of Mexico encompasses part of the primary water space 

in the AFTT Study Area where unit-level training, integrated 

training, and deployment certification exercises occur (as well as 

supporting composite training unit exercises proposed only under 

Alternative 2), and are critical for these and other training and 
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Table H.3-1. Comment Response Matrix (continued)

Reference 

Number Commenters Comment Response

123 

(cont.)

these areas—especially within the De Soto Canyon 

area.

testing activities. The Navy conducts training and testing activities 

in the Gulf of Mexico because this region provides valuable access 

to air and sea space conditions that are analogous to areas where 

the Navy operates, or may need to operate in the future. This 

contributes to ensure safety of personnel, skill proficiency, and 

validation of testing program requirements. For training, areas in 

this region where exercises are scheduled to occur are chosen to 

allow for the realistic tactical development of the myriad of 

training scenarios Navy units are required to complete to be 

mission effective. Certain activities, such as deployment 

certification exercises using integrated warfare components, 

require large areas of the littorals and open ocean for realistic and 

safe training. Locations for other training activities are chosen due 

to the proximity of associated training ranges (e.g., Pensacola 

Operating Area), available airspace (e.g., avoiding airspace 

conflicts with major airports, such as Key West International 

Airport), unobstructed sea space (e.g., throughout the New 

Orleans Operating Area), aircraft emergency landing fields (e.g., 

Naval Air Station Pensacola), and with consideration of public 

safety (e.g., avoiding areas popular for recreational boating). 

Areas where testing events are scheduled to occur are chosen to 

allow the Navy to test systems and platforms in a variety of 

bathymetric and environmental conditions to ensure functionality 

and accuracy in real world environments. Test locations are 

typically located near the support facilities of the systems 

commands, which provide critical safety, platforms, infrastructure 

support and technical expertise necessary to conduct testing (e.g., 

proximity to air squadrons).

124 Organization:

O03-24

Finally, given the known vulnerability of Gulf Bryde’s 

whales to ship strikes and the extreme 

endangerment of the subspecies, we recommend 

that the Navy consider establishing a 10-knot speed 

limit within the De Soto Canyon Mitigation Area and 

As discussed in Section 5.3.4.1 (Vessel Movement), the Navy 

implements mitigation to avoid vessel strikes throughout the 

Study Area. As described in Section 2.3.3 (Standard Operating 

Procedures) Navy vessels operate in accordance with the 

navigation rules established by the U.S. Coast Guard, which 
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Table H.3-1. Comment Response Matrix (continued)

Reference 

Number Commenters Comment Response

124 

(cont.)

a measure, analogous to the one proposed for the 

Southeast North Atlantic Right Whale Mitigation 

Area (see DEIS at Table 5.4-3), that would minimize 

transits through the De Soto Canyon Mitigation Area 

to the maximum extent practicable.

require that vessels proceed at a safe speed so that proper and 

effective action can be taken to avoid collision and be stopped 

within a distance appropriate to the prevailing circumstances and 

conditions. In its assessment of potential mitigation, the Navy 

considered implementing additional vessel speed restrictions (e.g., 

expanding the 10-knot restriction to other activities off the 

northeastern United States). Navy determined that implementing 

additional vessel speed restrictions beyond what is described in 

Section 5.3.4.1 (Vessel Movement), would be impractical due to 

implications for safety, sustainability, and the Navy’s ability to 

continue meeting its mission requirements to successfully 

accomplish military readiness objectives. Additionally, as 

described in Section 5.3.4.1 (Vessel Movement), any additional 

vessel speed restrictions would prevent vessel operators from 

gaining skill proficiency, would prevent the Navy from properly 

testing vessel capabilities, or would increase the time on station 

during training or testing activities as required to achieve skill 

proficiency or properly test vessel capabilities (which would 

significantly increase fuel consumption). Furthermore, there have 

been no Navy vessel strikes within the Gulf of Mexico to date.

125 Organization:

O03-25

The Navy should extend the boundaries of the 

Mitigation Area wherever necessary to reflect the 

recommendations of NMFS’ Status Review.

In its assessment of potential mitigation, the Navy considered 

implementing additional restrictions on active sonar and 

explosives in the Gulf of Mexico, including prohibiting all major 

training exercises and expanding the boundaries of the mitigation 

area for De Soto Canyon. The Navy is enlarging the more eastern 

Gulf of Mexico Planning Awareness Mitigation Area to fully 

encompass the Bryde’s whale small and resident population area 

and the extended area identified by NMFS in its 2016 Bryde’s 

whale status review. The Navy also developed a new mitigation 

area known as the Bryde’s Whale Mitigation Area, which covers 

the extent of the Bryde’s whale small and resident population 

area and the extended area identified by NMFS in its 2016 Bryde’s 

whale status review. These mitigation areas will help the Navy 
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Table H.3-1. Comment Response Matrix (continued)

Reference 

Number Commenters Comment Response

125 

(cont.)

avoid or reduce potential impacts on the small and resident 

population of Bryde’s whales.

126 Organization:

O03-27

The Charleston Bump is a deepwater bottom feature 

80 to 100 miles southeast of Charleston, SC. This 

feature represents essential habitat for wreckfish 

and represents their only known spawning ground in 

the western North Atlantic. The Charleston Bump 

also deflects the flow of the Gulf Stream, creating 

eddies and other oceanographic features that 

elevate the primary productivity and support the 

growth and production of larval fishes for the entire 

region.

The concentrations of juvenile fish attract larger 

marine fauna, including swordfish, for which the 

Bump constitutes a persistent nursery area; sea 

turtles; and a diversity of marine mammals, including 

pilot whale and false killer whale.

The area is also a productive fishing ground. Based 

on the evidence presented above, we recommend 

that the Charleston Bump be considered for 

designation as a year-round time-area management 

area.

In its assessment of potential mitigation, the Navy considered 

implementing additional restrictions on active sonar and 

explosives in the U.S. Mid--Atlantic region, including at the 

Charleston Bump. Navy operators determined that implementing 

additional mitigation beyond what is described in Section 5.4.3 

(Mitigation Areas off the mid-Atlantic and Southeastern United 

States) would be impractical due to implications for safety, 

sustainability, and the Navy’s ability to continue meeting its 

mission requirements to successfully accomplish military 

readiness objectives. Some of the considerations regarding why it 

would be impractical to implement additional mitigation in the 

U.S. mid-Atlantic region are provided below.

The mitigation identified in Section 5.4 (Mitigation Areas to be 

Implemented) represents the maximum mitigation within the 

identified mitigation areas that is practical to implement under

the Proposed Action. Operational input indicates that designating 

additional mitigation areas (including the Charleston Bump) would 

have a significant impact on the ability for units to meet their 

individual training and certification requirements (preventing 

them from deploying with the required level of readiness 

necessary to accomplish their missions), on the ability to certify 

strike groups to deploy to meet national security tasking (limiting 

the flexibility of Combatant Commanders and warfighters to 

project power, engage in multi-national operations, and conduct 

the full range of naval warfighting capability in support of national 

security interests), on the ability of program managers and 

weapons system acquisition programs to meet testing 

requirements and required acquisition milestones; on operational 

costs (due to extending distance offshore, which would increase 

fuel consumption, maintenance, and time on station to complete
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Table H.3-1. Comment Response Matrix (continued)

Reference 

Number Commenters Comment Response

126

(cont.)

required training and testing activities), on the safety risk 

associated with conducting training and testing at extended 

distances offshore (farther away from critical medical and search 

and rescue capabilities), on accelerated fatigue-life of aircraft and 

ships (leading to increased safety risk and higher maintenance 

costs), on training and testing realism (due to reduced access to 

necessary environmental or oceanographic conditions that 

replicate potential real world areas in which combat may occur), 

and/or on the ability for Navy Sailors to train and become 

proficient in using the sensors and weapons systems as would be 

required in a real world combat situation. Furthermore, the 

iterative and cumulative impact of all commenter-proposed 

mitigation areas and seasonal or temporal restrictions would deny 

national command authorities the flexibility to respond to national 

security challenges as required training necessary for deployment 

would entail movements to multiple operational areas along the 

Eastern seaboard and the Gulf of Mexico to conduct training 

within set time frames. Likewise, this iterative and cumulative 

impact would deny weapons system program managers and 

research, testing, and development program managers the 

flexibility to rapidly field or develop necessary systems due to the 

required use of multiple areas within limited timeframes. 

Additional information regarding the operational importance, 

significant negative impacts on Navy training and testing 

operations, and impracticality of implementing the mitigation area 

proposed by commenter in each geographic region mentioned is 

provided in the responses to Commenter Reference numbers 109 

through 113, 116, 119, and 124 through 126, as well as in Chapter 

5 (Mitigation) of the EIS/OEIS.

127 Organization:

O03-29

Therefore, in addition to the designation of timearea management areas at the Cul de Sac, the 

Charleston Bump, and coastal Gulf waters, we 

strongly recommend that efforts are undertaken in 

The Navy has worked collaboratively with NMFS to develop 

mitigation areas using inputs from the operational community, the 

best available science discussed in Chapter 3 (Affected 

Environment and Environmental Consequences), published 
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Appendix H Public Comment Responses

Table H.3-1. Comment Response Matrix (continued)

Reference 

Number Commenters Comment Response

127 

(cont.)

an iterative manner by the Navy and NMFS to 

identify additional important habitat areas across the 

AFTT Study Area, using the full range of data and 

information available to them (e.g., habitat-based 

density models, NOAA recognized BIAs, survey data, 

etc.)

literature, predicted activity impact footprints, and marine species 

monitoring and density data. The Navy completed a Biological 

Assessment and operational analysis of potential mitigation areas 

throughout the entire Study Area. The mitigation identified in

Section 5.4 (Mitigation Areas to be Implemented) represents the 

maximum mitigation within the identified mitigation areas that is 

practical to implement under the Proposed Action. Operational 

input indicates that designating additional mitigation areas 

(including areas identified by habitat-based model, NOAA 

recognized BIAs, or survey data) would have a significant impact 

on the ability for units to meet their individual training and 

certification requirements (preventing them from deploying with 

the required level of readiness necessary to accomplish their 

missions), on the ability to certify strike groups to deploy to meet 

national security tasking (limiting the flexibility of Combatant 

Commanders and warfighters to project power, engage in multinational operations, and conduct the full range of naval 

warfighting capability in support of national security interests), on 

the ability of program managers and weapons system acquisition 

programs to meet testing requirements and required acquisition 

milestones; on operational costs (due to extending distance 

offshore, which would increase fuel consumption, maintenance, 

and time on station to complete required training and testing 

activities), on the safety risk associated with conducting training 

and testing at extended distances offshore (farther away from 

critical medical and search and rescue capabilities), on accelerated 

fatigue-life of aircraft and ships (leading to increased safety risk 

and higher maintenance costs), on training and testing realism 

(due to reduced access to necessary environmental or 

oceanographic conditions that replicate potential real world areas 

in which combat may occur), and/or on the ability for Navy Sailors 

to train and become proficient in using the sensors and weapons 

systems as would be required in a real world combat situation.
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Appendix H Public Comment Responses

Table H.3-1. Comment Response Matrix (continued)

Reference 

Number Commenters Comment Response

127 

(cont.)

Furthermore, the iterative and cumulative impact of all 

commenter-proposed mitigation areas and seasonal or temporal 

restrictions would deny national command authorities the 

flexibility to respond to national security challenges as required 

training necessary for deployment would entail movements to 

multiple operational areas along the Eastern seaboard and the 

Gulf of Mexico to conduct training within set time frames.

Likewise, this iterative and cumulative impact would deny 

weapons system program managers and research, testing, and 

development program managers the flexibility to rapidly field or 

develop necessary systems due to the required use of multiple 

areas within limited timeframes.Therefore, implementing 

additional mitigation areas beyond what is described in Section 

5.4 (Mitigation Areas to be Implemented) would be impractical

and would prevent the Navy from meeting its Title 10 

requirements to successfully accomplish military readiness

objectives. Navy Senior Leadership has approved the mitigation as 

described in Chapter 5 (Mitigation); therefore, additional 

permission or authorization from Navy Leadership will not be 

required prior to conducting training or testing in the Study Area 

with regard to mitigation implementation. Additional information 

regarding the operational importance, significant negative impacts 

on Navy training and testing operations, and impracticality of 

implementing the mitigation area proposed by commenter in each 

geographic region mentioned is provided in the responses to 

Commenter Reference numbers 111, 116 through 118, and 121 

through 123, as well as in Chapter 5 (Mitigation) of the EIS/OEIS.

128 Organization:

O03-30

The Navy should consider establishing stand-off 

distances around its Mitigation Areas to the greatest 

extent practicable, allowing for variability in size 

given the location of the Area, the type of operation 

at issue, and the species of concern.

The mitigation identified in Section 5.4 (Mitigation Areas to be 

Implemented) represents the maximum mitigation within 

mitigation areas and the maximum size of mitigation areas that 

are practical to implement under the Proposed Action. 

Implementing additional mitigation (e.g., stand-off distances that 

would extend the size of the mitigation areas) beyond what is 
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Appendix H Public Comment Responses

Table H.3-1. Comment Response Matrix (continued)

Reference 

Number Commenters Comment Response

128 

(cont.)

described in Section 5.4 (Mitigation Areas to be Implemented) 

would be impractical due to implications for safety, sustainability, 

and the Navy’s ability to continue meeting its mission 

requirements. The Navy’s mitigation measures were reviewed and 

approved by a four-star Admiral, the Fleet Commander of all Navy 

forces in the Study Area, and Navy Senior Leadership.

129 Organization:

O03-34

The Navy should therefore consider requiring 

thermal detection in optimal conditions, or, 

alternatively, establishing a pilot program for 

thermal detection, with annual review under the 

adaptive management system. According to the 

DEIS, the Navy “plans to continue researching 

thermal detection systems to determine their 

effectiveness and compatibility with Navy 

applications” (DEIS at 5-84). A pilot program would 

be consistent with that interest, while allowing for 

trial use as a monitoring measure. We further 

recommend that the Navy conduct a limited trial of 

thermal detection during the EIS preparation period, 

to determine the potential benefit for marine 

mammal detectability and to explore how such a 

system might be integrated into the Navy’s present 

real-time marine mammal monitoring measures.

The Office of Naval Research Marine Mammals and Biology 

program is currently funding an ongoing project (2013-2018) that 

is testing the thermal limits of infrared based automatic whale 

detection technology (Principal Investigators: Olaf Boebel and 

Daniel Zitterbart). This project is focused on 1) capturing whale 

spouts at two different locations featuring subtropical and tropical 

water temperatures; 2) optimizing detector/classifier performance 

on the collected data; and 3) testing system performance by 

comparing system detections with concurrent visual observations. 

In addition, Defense Advanced Research Projects Agency has 

funded six initial studies to test and evaluate current technologies 

and algorithms to automatically detect marine mammals (IR 

thermal detection being one of thetechnologies) on an unmanned 

surface vehicle. Based on the outcome of these initial studies, 

follow-on efforts and testing are planned for 2018-2019. The Navy 

plans to continue researching thermal detection systems to 

determine their effectiveness and compatibility with Navy 

applications. If the technology matures to the state where thermal 

detection is determined to be an effective mitigation tool during 

training and testing, the Navy will assess the practicality of using 

the technology during training and testing events and retrofitting 

its observation platforms with thermal detection devices.

130 Organization:

O03-35

For most other areas important to right whales, 

however, including the Navy’s Gulf of Maine Planning 

Awareness Area, right whale critical habitat in the 

southeast, and the right whale migratory corridor, 

the DEIS does not contain any indication that a 

The Navy conducted an operational analysis of potential 

mitigation areas throughout the entire Study Area to consider a 

wide range of mitigation options, including but not limited to 

vessel speed restrictions. As discussed in Section 3.0.3.3.4.1 

(Vessels and In-Water Devices), Navy ships transit at speeds that 
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Appendix H Public Comment Responses

Table H.3-1. Comment Response Matrix (continued)

Reference 

Number Commenters Comment Response

130 

(cont.)

practicability analysis was conducted, nor does it 

prescribe any speed reduction measures. Similar 

concerns exist for the De Soto Canyon, within the 

Navy’s Gulf of Mexico Mitigation Areas, where the 

Gulf subspecies of Bryde’s whales also require 

protection from potential vessel collision (see section 

III.B.1.f.i above). We urge the Navy to conduct a

practicability analysis and implement vessel speed 

reduction in these areas.

Additionally, given that the speed of Navy ships 

during all aspects of their operations potentially 

impacts marine mammals, we recommend that the 

Navy collect data on ship speed and report them to 

NMFS as part of the EIS process. This will allow for 

objective evaluation by NMFS of ship strike risk, of 

harassment resulting from vessel activity, and of the 

potential benefit of additional speed-focused 

mitigation measures. (Note: comment contained 

footnotes. See comment letter).

are optimal for fuel conservation or to meet operational 

requirements. Operational input indicated that implementing 

additional vessel speed restrictions beyond what is identified in 

Section 5.4 (Mitigation Areas to be Implemented) would be 

impractical to implement due to implications for safety and 

sustainability. In its assessment of potential mitigation, the Navy 

considered implementing additional vessel speed restrictions e.g., 

expanding the 10-knot restriction to other activities.) Navy 

determined that implementing additional vessel speed 

(restrictions beyond what is described in Section 5.3.4.1 (Vessel 

Movement), would be impractical due to implications for safety, 

sustainability, and the Navy’s ability to continue meeting its 

mission requirements to successfully accomplish military 

readiness objectives. Additionally, as described in Section 5.3.4.1 

(Vessel Movement), any additional vessel speed restrictions would 

prevent vessel operators from gaining skill proficiency, would 

prevent the Navy from properly testing vessel capabilities, or 

would increase the time on station during training or testing 

activities as required to achieve skill proficiency or properly test 

vessel capabilities (which would significantly increase fuel 

consumption). As discussed in Section 5.3.4.1 (Vessel Movement), 

the Navy implements mitigation to avoid vessel strikes throughout 

the Study Area.

Regarding the recommended additional Navy collection of data on 

ship speed and reporting that data to NMFS, see the discussion in 

Section 5.5.7 (Reporting Requirements). The Navy developed its 

reporting requirements in conjunction with NMFS. As directed by 

the Chief of Naval Operations Instruction (OPNAVINST) 5090.1D, 

Environmental Readiness Program, Navy vessels report all marine 

mammal incidents worldwide, to include ship speed. Therefore 

the data required for the analysis discussed in the comment is 

already being collected, and any additional data collection 

required for the sake of collecting data would create an 
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Appendix H Public Comment Responses

Table H.3-1. Comment Response Matrix (continued)

Reference 

Number Commenters Comment Response

130 

(cont.)

unnecessary and impractical administrative burden on ships crews 

while not providing any additional meaningful data to support the 

type of analysis mentioned in the comment.

131 Organization:

O03-36

To the extent that additional operational mitigation 

is impractical, the Navy should consider adopting 

compensatory mitigation to help improve the

As indicated previously, the Navy has for years implemented a 

very broad and comprehensive range of measures to mitigate 

potential impacts on marine mammals from military readiness 

activities. As the EIS/OEIS documents in Chapter 5 (Mitigation), 

the Navy is increasing its mitigation measures to enhance marine 

mammal protections to the maximum extent practicable. Aside 

from direct mitigation, as noted by the comment, the Navy 

engages in an extensive spectrum of other activities that greatly 

benefit marine species in a more general manner that is not 

necessarily tied to just military readiness activities. 

As noted in section 3.0.1.1 of the EIS/OEIS, the Navy provides 

extensive investment for research programs in basic and applied 

research. In fact, the U.S. Navy is one of the largest sources of 

funding for marine mammal research in the world, which has 

greatly enhanced the scientific community’s understanding of 

marine species much more generally. The Navy’s support and 

conduct of cutting-edge marine mammal research includes: 

marine mammal detection, including the development and testing 

of new autonomous hardware platforms and signal processing 

algorithms for detection, classification, and localization of marine 

mammals; improvements in density information and development 

of abundance models of marine mammals; and advancements in 

the understanding and characterization of the behavioral, 

physiological (hearing and stress response), and potentially 

population-level consequences of sound exposure on marine life. 

In addition, the Navy is a critical sponsor of the North Atlantic 

Right Whale EWS and the winter aerial surveys, which has 

contributed to a marked reduction in vessel strikes of the North 

Atlantic right whale in the Southeast critical habitat, particularly 

by commercial vessels which represents the greatest threat to the 
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Appendix H Public Comment Responses

Table H.3-1. Comment Response Matrix (continued)

Reference 

Number Commenters Comment Response

131 

(cont.)

conservation status or habitat of affected 

populations. The Navy should consider 

compensatory mitigation for the adverse impacts of 

the permitted activity on marine mammals and their 

habitat that cannot be prevented or mitigated.

North Atlantic right whale.

Regarding compensatory mitigation, as a matter of law 

compensatory mitigation is not required or authorized to be 

imposed upon federal agencies under the ESA. For federal 

agencies (which are not subject to Section 10 permits 

whereapplicants must minimize and mitigate impacts), FWS/NMFS 

can only require measures that comport with the minor change 

rule and seek to minimize take, not “mitigate” (in the sense of 

compensatory mitigation) (see p. 4-19 and 4-50 of Consultation 

Handbook). Similarly, there is no provision in the MMPA that 

provides for compensatory mitigation and no NMFS policy that 

directs compensatory mitigation for any applicant. Additionally, 

the commenter did not recommend any specific measure(s), 

rendering it impossible to conduct any meaningful evaluation of 

their recommendation. The vast majority of Navy takes of marine 

mammals are relatively minor and temporary behavioral reactions 

that do not have measurable long-term or permanent impacts to 

stocks or species. The Navy is unaware of any proven or effective 

mechanisms for using compensatory mitigation for offsetting 

temporary behavioral reactions to marine mammals. Many of the 

methods of compensatory mitigation that have proven successful 

in terrestrial settings (purchasing or preserving land with 

important habitat, improving habitat through plantings, etc.) are 

not applicable in a marine setting with such far-ranging species. 

Thus, any presumed conservation value from such an idea would 

be purely speculative at this time.

132 Organization:

O03-43

The Navy’s adjustment of injury and mortality 

numbers for “mitigation effectiveness” is also 

problematic. The DEIS starts with species-specific 

g(0) factors applied in professional marine mammal 

abundance surveys, then multiplies them by a simple 

factor to reflect the relative effectiveness of its 

Information about the quantitative analysis process, including the 

consideration of mitigation effectiveness, is described in detail in 

the 2018 technical report titled Quantifying Acoustic Impacts on 

Marine Mammals and Sea Turtles: Methods and Analytical 

Approach for Phase III Training and Testing. The Navy 

quantitatively assessed the effectiveness of its mitigation 
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Appendix H Public Comment Responses

Table H.3-1. Comment Response Matrix (continued)

Reference 

Number Commenters Comment Response

132 

(cont.)

lookouts in routine operating conditions. Yet the 

Navy’s sighting effectiveness is likely to be much 

poorer than that of experienced biologists dedicated 

exclusively to marine mammal detection, operating 

under conditions that maximize sightings. As one 

recent paper observed, for example, abundance 

survey rates declined significantly as sea states rose 

above Beaufort 1,104 and average Beaufort sea 

states in the mid- and southeast Atlantic average 

Beaufort 3-4 throughout the year (see Table 1). 

Given this, it seems seldom that Navy visual surveys 

can approximate the sighting effectiveness of a largevessel abundance survey. 

measures on a per-scenario basis for four factors: (1) species 

sightability, (2) a Lookout’s ability to observe the range to PTS (for 

sonar and other transducers) and range to mortality (for 

explosives), (3) the portion of time when mitigation could 

potentially be conducted during periods of reduced daytime 

visibility (to include inclement weather and high sea state) and the 

portion of time when mitigation could potentially be conducted at 

night, and (4) the ability for sound sources to be positively 

controlled (e.g., powered down). The g(0) values used by the Navy 

for their mitigation effectiveness adjustments take into account 

the differences in sightability with sea state, and utilize averaged 

g(0) values for sea states of 1-4 and weighted as suggested by 

Barlow (2015). This helps to account for reduced sightability in 

varying conditions, as does the fact that, during active sonar 

activities, Navy lookouts tend to look in the water near the vessel, 

within 1 km, rather than out to the horizon as marine mammal 

observers do. During training and testing activities, there is 

typically at least one, if not numerous, support personnel involved 

in the activity (e.g., range support personnel aboard a torpedo 

retrieval boat or support aircraft). In addition to the Lookout 

posted for the purpose of mitigation, these additional personnel 

observe for and disseminate marine species sighting information

amongst the units participating in the activity whenever possible 

as they conduct their primary mission responsibilities. 

However, as a conservative approach to assigning mitigation 

effectiveness factors, the Navy elected to account only for the 

minimum number of required Lookouts used for each activity; 

therefore, the mitigation effectiveness factors may underestimate 

the likelihood that some marine mammals and sea turtles may be 

detected during activities that are supported by additional 

personnel who may also be observing the mitigation zone.
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Appendix H Public Comment Responses

Table H.3-1. Comment Response Matrix (continued)

Reference 

Number Commenters Comment Response

133 Organization:

O04-02

We recommend that the Navy become familiar with 

the locations of scallop beds and avoid activities that 

might impact the seabed in these areas.

There are no training or testing activities planned using bottomplaced explosive charges in locations where scallop beds are 

known to occur, such as within the Northeast Range Complexes or 

the NUWC Newport Testing Range.

134 Organization:

O04-03, O04-04

Two comments recommend avoiding sensitive 

habitats such as seep habitats and deep-sea corals.

The Navy is committed to developing and implementing 

mitigation to avoid or reduce potential impacts to marine species, 

cultural resources, and the marine environment to the maximum 

extent practicable. Chapter 5 (Mitigation) details the mitigation 

that the Navy will implement under the Proposed Action. As 

discussed in Section 5.4.1 (Mitigation Areas for Seafloor 

Resources), the Navy will implement mitigation measures (e.g., 

avoiding bottom-placed explosives) to avoid or reduce potential 

impacts to shallow-water coral reefs, live hard bottom, artificial 

reefs, submerged aquatic vegetation, and shipwrecks. 

Implementing additional mitigation would be impractical due to 

implications for safety, sustainability, and the Navy’s ability to 

continue meeting its Title 10 requirements to successfully 

accomplish military readiness objectives. Furthermore, there are 

no training or testing activities planned using bottom-placed 

explosive charges in locations where deep-sea corals are known to 

occur.

135 Organization:

O04-05

The habitat suitability modeling referenced in the 

technical report "Building and Maintaining a 

Comprehensive Database and Prioritization Scheme 

for Overlapping Habitat Data - Focus on Abiotic 

Substrate" is useful for estimating the approximate 

footprint of coral habitats in the canyon, but the 

spatial domain of the model does not encompass all 

the seamounts within the Exclusive Economic Zone 

(EEZ), and the model does not identify high suitability 

habitats in the Gulf of Maine, likely due to low 

resolution seabed data underlying the analysis in 

that part of the region. 

As described in Section 5.4.1 (Mitigation Areas for Seafloor 

Resources), the database of abiotic substrate uses polygon data 

(areal), with the exception of artificial structures (e.g., shipwrecks, 

artificial reefs), because polygon data is more applicable to habitat 

analysis. The abiotic substrate polygons do incorporate the 

seamounts that are shallow enough to harbor deep-sea corals 

based on the available scientific literature. The Navy is not aware 

of any higher quality validated polygon seabed data for the Gulf of 

Maine. NMFS has been and will continue to be a major source of 

benthic habitat data used in Navy environmental compliance 

documentation.
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Appendix H Public Comment Responses

Table H.3-1. Comment Response Matrix (continued)

Reference 

Number Commenters Comment Response

136 Organization:

O04-07

We were pleased to note that recently discovered 

cold seep habitats are identified as occurring in the 

affected environment for this action (page 3.4-7). As 

far as we are aware, these cold seeps occur beyond 

water depths commercially fished, but we would 

nonetheless recommend avoiding impacts to known 

seep habitats to the extent possible, given that they 

are little studied but may be ecologically important.

The Navy is committed to developing and implementing 

mitigation to avoid or reduce potential impacts to marine species, 

cultural resources, and the marine environment to the maximum 

extent practicable. Chapter 5 (Mitigation) details the mitigation 

that the Navy will implement under the Proposed Action. As 

discussed in Section 5.4.1 (Mitigation Areas for Seafloor 

Resources), the Navy will implement mitigation measures (e.g., 

avoiding bottom-placed explosives) to avoid or reduce potential 

impacts to shallow-water coral reefs, live hard bottom, artificial 

reefs, submerged aquatic vegetation, and shipwrecks. 

Implementing additional mitigation would be impractical due to 

implications for safety, sustainability, and the Navy’s ability to 

continue meeting its Title 10 requirements to successfully 

accomplish military readiness objectives. Furthermore, there are 

no training or testing activities planned using bottom-placed 

explosive charges in locations where cold seep habitats are known 

to occur.

137 Organization:

O05-05

Describe mitigation considered and recommended. The environmental analysis in Chapter 3 (Affected Environment 

and Environmental Consequences) identified that certain acoustic, 

explosive, and physical disturbance and strike stressors have the 

potential to impact certain biological or cultural resources. The 

Navy will implement mitigation to avoid or reduce potential 

impacts on these stressors to the maximum extent practicable, as 

discussed in Chapter 5 (Mitigation).

138 Organization:

O05-06

We ask that you specifically describe the amount of 

expended materials that will be expended in 

Narragansett Bay and address mitigation of the 

materials in the EIS. All materials that have been and 

will be expended should be addressed including; 

wires, projectile casings, marine markers, flares, flare 

parts, and everything else that may have been 

expended regardless of perceived environmental 

impact.

All expended materials associated with the Proposed Action are 

discussed in Chapter 3.0 (see sections 3.0.3.3.4 - 3.0.3.3.6) and in 

Appendix F (Military Expended Material and Direct Strike Impact 

Analysis) of the EIS/OEIS. This information includes expended 

materials in the offshore range complexes, as well as the inshore 

waters, including Narragansett Bay. The Navy has standard 

operating procedures in place to reduce the amount of military 

expended materials (Section 2.3.3.5, Weapons Firing Safety), 

including recovering targets and associated parachutes 
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Appendix H Public Comment Responses

Table H.3-1. Comment Response Matrix (continued)

Reference 

Number Commenters Comment Response

138 

(cont.)

to the maximum extent practicable. In addition, the Navy has 

developed mitigation areas (Section 5.4.1, Seafloor Resources) to 

avoid or reduce potential impacts of certain explosives and 

physical disturbance and strike stressors (such as military 

expended materials) on seafloor resources, including shallowwater coral, live hard bottom, artificial reefs, submerged aquatic 

vegetation, and shipwrecks.

139 Organization:

O05-07

Combining activities. All efforts should be made to 

combine activities, in terms of timing and area, to 

reduce overall impacts to the use of Narragansett 

Bay. Activities should also be combined if the 

combination will not exacerbate environmental 

impact and will assist in timely mitigation.

Additionally, when combining activities, 

consideration should be given to the timing of 

potential impacts including, but not limited to, 

impacts to seasonal seal and other marine mammal 

populations, bird/fish migration, and impacts on 

resources and other Bay stakeholders.

Training and testing events are combined to the extent 

practicable. Testing activities are generally not combined due to 

various limitations, such as differing testing requirements and 

incompatible schedules. Training activities are generally not 

combined with testing activities due to differing mission 

requirements. 

The Navy implements mitigation measures to avoid or reduce 

potential impacts on marine species. All mitigation measures can 

be found in Chapter 5 (Mitigation) of the EIS/OEIS.

140 Organization:

O05-10

Rhode Island law further requires mitigation of all 

impacts. Section 3.3.2.1.2.6 of the EIS/OEIS states 

that “marine debris is not a threat to vegetation.” 

We disagree. Marine debris can settle on SAV, 

blocking it from light and hindering its ability to 

survive. We ask that you review training and testing 

procedures as they relate to sensitive SAV, 

particularly within the Narragansett Bay Shallow

Water Test Facility and again, address the impacts 

and demonstrate that the Navy has taken all 

necessary steps to avoid impacts to SAV.

The Navy has reviewed Rhode Island’s Coastal Zone Management 

Program and determined that three policies are applicable to the 

Proposed Action; Section 1.2.1: Tidal and Coastal Pond Waters 

(Types 1-6), Section 1.2.3: Areas of Historic and Archaeological 

Significance, Section 1160.2 Areas of Particular Concern described 

in Table 4. All other policies do not apply to the proposed 

activities. Pursuant to the Coastal Zone Management Act, the 

Navy has consulted with the State of Rhode Island on the 

proposed activities. Rhode Island concurred with the Navy’s 

Coastal Consistency Determination. Section 3.3.2.1.2.6 (Marine 

Debris) has been updated to reflect the circumstances in which 

marine vegetation could be impacted by marine debris. Military 

expended material is unlikely to fall on any seagrass bed. This low 

probability is based on the very limited footprint associated with
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Appendix H Public Comment Responses

Table H.3-1. Comment Response Matrix (continued)

Reference 

Number Commenters Comment Response

140 

(cont.)

the military expended materials expended in Narragansett Bay 

and the tiny portion of Narragansett Bay where military expended 

materials could potentially overlap with the location of seagrass 

beds. Seagrass beds are considered hazardous to navigation and 

are avoided during Navy training and testing activities. In the 

unlikely event of expended material landing in a seagrass bed, the 

material footprint suggests a negligible impact on the viability of 

seagrass beds. The Phase III EFH Assessment examined the impact 

of small vessel movement, military expended materials, and 

seafloor devices on seagrass beds and concluded that impacts 

would be unlikely. The Navy has developed new mitigation 

measures for submerged aquatic vegetation, which are presented 

in Section 5.4.1 (Mitigation Areas for Seafloor Resources).

Consultation Response/Concurrence

141 Federal:

F01-01, F02-01, F03-01, 

F04-09

State:

S01-01, S01-03, S08-01, 

S10-01, S11-01, S11-03, 

S13-01, S21-01, S21-03, 

S21-05, S21-06, S25-01, 

S26-01, S29-01, S29-05, 

S29-07, S29-09, S29-11, 

S30-01, S30-02

Twenty-four comments indicated that they concur 

with the project.

Thank you for your review.

142 State:

S03-01, S06-01, S16-01, 

S27-02, S27-01

Five comments referenced concerns about the 

Section 106 process and architectural and historical 

resources of concern in various states located within 

the Study Area. 

Thank you for your review. The Navy consulted with all applicable 

State Historic Preservation Offices pursuant to Section 106 of the 

National Historic Preservation Act.

143 State:

S05-17

The Georgia Coastal Management Program requests 

the Navy reconsider our 2013 comments and 

requests, including expanding the Southeast NARW 

Mitigation Area to correspond with the revised

After reviewing the entire Georgia Department of Natural 

Resources comment package, all comments submitted by the 

Georgia Department of Natural Resources in previous years for 

the AFTT 2013 Draft EIS/OEIS have been summarized in their
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Appendix H Public Comment Responses

Table H.3-1. Comment Response Matrix (continued)

Reference 

Number Commenters Comment Response

143 

(cont.)

NARW Critical Habitat which was expanded by NMFS 

in 2015. Recent research by NMFS shows that the 

NARW species declined from 2010 to 2015. Since 

2015 the species has experienced historically high 

mortality rates and low calving rates, so the species 

has likely declined even further. As such, it is 

essential that the Navy adequately mitigate potential 

causes of mortality, injury and harassment in the 

NARW calving habitat.

current letter submittal for the AFTT 2017 Draft EIS/OEIS. By 

addressing the comments contained within the letters received in 

2017, the Navy is also addressing Georgia Department of Natural 

Resources previous comments from previous years.

144 State:

S05-18, S07-01, S07-03, 

S29-16

Four comments regarding Coastal Zone Consistency 

determinations.

Thank you for your review. The Navy prepared Coastal Zone 

Management Act consistency determinations to ensure 

consistency with the enforceable policies of the applicable Coastal 

Zone Management Programs. Please see Section 6.1.1 (Coastal 

Zone Management Act Compliance) of the Final EIS/OEIS for 

details.

145 State:

S16-02

In addition, a listing of Native American tribes who 

may have an interest in projects within New Jersey 

has been included with this letter. Please note that 

the HPO is not a source of information regarding 

Native American religious sites in New Jersey. The list 

provided is not comprehensive and does not 

represent a complete listing of Native American 

entities that may have an interest in the proposed 

undertaking. Further research will need to be 

completed to identify all Native American entities 

that may have an interest in the proposed project. In 

addition, a listing of Native American tribes who may 

have an interest in projects within New Jersey has 

been included with this letter. Please note that the

Thank you for your review. The Navy consulted with all applicable 

State Historic Preservation Offices pursuant to Section 106 of the 

National Historic Preservation Act. In addition, the Navy has been 

corresponding with several tribes about their concerns.
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Appendix H Public Comment Responses

Table H.3-1. Comment Response Matrix (continued)

Reference 

Number Commenters Comment Response

145 

(cont.)

HPO is not a source of information regarding Native 

American religious sites in New Jersey. The list 

provided is not comprehensive and does not 

represent a complete listing of Native American 

entities that may have an interest in the proposed 

undertaking. Further research will need to be 

completed to identify all Native American entities 

that may have an interest in the proposed project.

146 State:

S29-02, S29-13, S29-14

Three comments suggest close coordination be 

conducted with the USFWS, NMFS, Virginia 

Department of Game and Inland Fishers, and the 

Virginia Department of Conservation and Recreation 

concerning protected species in the Study Area. 

Thank you for your review. The Navy consulted with the United 

States Fish and Wildlife Service and the NMFS under the 

Endangered Species Act and the NMFS under the Marine Mammal 

Protection Act. The Navy also coordinated with the Virginia 

Department of Game and Inland Fisheries as part of the Coastal 

Zone Management Act. 

147 State:

S29-03, S29-04

Two comments regarding Pollution Discharge 

Elimination and Water Protection permits.

Thank you for your review. The Proposed Action does not require 

a Virginia Pollution Discharge Elimination System permit or a 

Section 401 Water Quality certification. 

148 State:

S29-06

2(b) Agency Findings. According to the DEQ Air 

Division, the VACAPES Range Complex in Virginia 

includes ozone (03) attainment areas, 03 

maintenance areas, 03 nonattainment areas and 

emission control areas for the contributors to ozone 

pollution, which are volatile organic compounds 

(VOCs) and nitrogen oxides (NOx).

2(c) Recommendation. The Navy should take all 

reasonable precautions to limit emissions of VOCs 

and NO, principally by controlling or limiting the 

burning of fossil fuels.

The Navy is committed to taking all reasonable precautions 

practical based on mission requirements, particularly those within 

the state waters that include the rivers of Virginia and the 

Chesapeake Bay to ensure that training and testing requirements 

are met with the most efficient use of boats and vessel operations 

in these areas.

149 Native American:

N01-02, N02-02

Two comments requested that the tribe be notified if 

any archaeological discoveries are uncovered. 

Thank you for your review. The Navy will provide notification if 

new historic or archaeological resources are discovered.
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Appendix H Public Comment Responses

Table H.3-1. Comment Response Matrix (continued)

Reference 

Number Commenters Comment Response

Consultation concerns under ESA, MMPA, CZMA, MBTA, NHPA, etc.

150 Federal:

F02-02

Although the Department can consult with the Navy 

as required by the ESA, it will be important to note 

that we cannot authorize incidental take of 

manatees under the MMPA. We also are unaware of 

any pending request for such authorization as is 

referenced in the DEIS. These and similar statements 

should be corrected in the final EIS.

This statement was an error in the Draft EIS/OEIS and has been 

corrected in the Final EIS/OEIS.

151 Federal:

F02-06

Work with NPS to evaluate activities occurring within 

range that produce noise that may impact wildlife in 

parks. Although the analysis in the Draft EIS is 

focused on effects at the population levels of wildlife 

due to the broad scope of the planning area, the 

impact and injury to individuals from noise should 

not be dismissed.

Chapter 6 (Regulatory Considerations) presents information on 

the national system of marine protected areas located in the 

Study Area, as well as the training and testing activities that could 

occur within each area and the marine protected area 

considerations at the local level. The Navy will avoid or reduce 

impacts to the maximum extent practicable through procedural 

mitigation (see Section 5.3, Procedural Mitigation to be 

Implemented) and mitigation areas (see Section 5.4, Mitigation 

Areas to be Implemented). The Navy completed a full Biological 

Assessment and operational analysis of potential mitigation areas 

throughout the entire Study Area. Developing additional 

mitigation areas beyond what is described in Section 5.4 

(Mitigation Areas to be Implemented) would be impractical due to 

implications for safety, sustainability, and the Navy’s ability to 

continue meeting its Title 10 requirements to successfully 

accomplish military readiness objectives.

152 Federal:

F02-08, F02-09

Two comments suggested creating or making 

personnel available to respond to stranding and 

mortality events and conduct agency coordination 

should such events in coastal waters.

There has not been any stranding in the AFTT study area 

associated with Navy training and testing activities (see the 2017 

technical report titled Marine Mammal Strandings Associated with 

U.S. Navy Sonar Activities). As part of the MMPA consultation and 

in the NMFS Final Rule a stranding plan was developed that details 

Navy actions in the event of a mass stranding that would be 

potentially linked to Navy activities. NMFS is the lead agency for 

stranding response and Navy will continue to support NMFS as 

required and outlined in the stranding plan.
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Appendix H Public Comment Responses

Table H.3-1. Comment Response Matrix (continued)

Reference 

Number Commenters Comment Response

153 Organization:

O03-02

The Navy and NMFS should include information that 

is essential to evaluate the compliance of the Navy’s 

proposed activities with the MMPA and ESA. Such 

information includes, but is not limited to:

 Species- or stock-specific information 

supporting findings for each affected marine 

mammal species or stock, as NMFS may not 

conclude, under the Marine Mammal 

Protection Act, that an activity will have 

only a “negligible impact” on a particular 

species or stock if it has no information on 

which to do so, see id. at 1225;

 A comparison of levels of incidental 

mortality to each marine mammal stock’s 

potential biological removal (“PBR”) level 

and an evaluation of potentially nonnegligible impacts where incidental 

mortality exceeds PBR, see id. at 1225-28;

Thorough “analysis of ways to mitigate the 

negative effects of the Navy’s activities on 

affected species and stocks,” id. at 1229, 

including consideration of time/area

restrictions or “measures of equivalent 

effect,” id. at 1231; and

 The impact on endangered sea turtles of the 

levels of take for which the Navy seeks ESA 

authorization, id. at 1234-35.

The Navy considered and discussed in the EIS/OEIS all of the 

factors enumerated by the commenter. For analysis of potential 

effects to marine mammal species or stocks as required by the 

MMPA, Navy presented this analysis by species, population, 

and/or stock in sections 3.7.3.1 (Acoustic Stressors) and 3.7.3.2 

(Explosive stressors). PBR is discussed in detail in sections 3.7.3.2 

(Explosive stressors) and 3.7.3.4 (Physical Disturbance and Strike 

Stressors). A complete analysis of Navy’s mitigation measures is 

discussed in detail in Chapter 5 (Mitigation). A complete analysis 

of sea turtles is discussed in detail in section 3.8.3 (Environmental 

Consequences).

154 State:

S05-06

Annual activity reports should be provided that 

quantify vessel activity, active sonar and ordnance 

detonation levels from November 15 to April 15 

within 1) the USWTR area, 2) NARW critical habitat 

offshore of a) Georgia and b) northeast Florida, and 

3) ocean waters within 30 nmi of the a) Georgia and 

Annual activity reports have been, and will continue to be, 

submitted to NMFS. A large portion of the information is classified 

for national security, and this information is submitted to NMFS to 

certify our permit compliance. The unclassified reports are posted 

on the Navy marine species web site 

(http://www.navymarinespeciesmonitoring.us/), and this 
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Appendix H Public Comment Responses

Table H.3-1. Comment Response Matrix (continued)

Reference 

Number Commenters Comment Response

154 

(cont.)

b) northeast Florida coast. information was provided to Georgia Department of Natural 

Resources in 2013.

155 State:

S05-12

Make available to GCMP unclassified monitoring and 

activity reports associated with USWTR.

The activity and monitoring reports have been, and will continue 

to be presented on the Navy’s Marine Species Monitoring web site 

(http://www.navymarinespeciesmonitoring.us/).

156 State:

S05-13

Make available to GCMP copies of the annual North 

Atlantic right whale calving season and migration 

message.

The message reiterates the mitigation required during the calving 

season and is available in the EIS/OEIS Section 5.4.3 (Mitigation 

Areas off the Mid-Atlantic and Southeastern United States).

157 State:

S05-14

Should there be an unanticipated ship strike of a 

North Atlantic right whale associated with USWTR 

activities, the Navy will open a dialogue with the 

State of Georgia.

In the event a North Atlantic right whale is killed or significantly 

injured, the Navy follow the reasonable and prudent measures 

and terms and conditions within the incidental take statement of 

the NMFS issued Biological Opinion.

158 State:

S05-15

Should a right whale be struck the Navy would 

consult with NMFS (National Marine Fisheries 

Service). Should that consultation result in changes 

to Navy activities so that their effects on any land or

water use or natural resource of Georgia's coastal 

zone are substantially different than the effects 

anticipated in the Phase II DEIS, the Navy will enter

into CZMA consultation with the State of Georgia on

the new activities.

If Navy activities change for any reason that result in new 

reasonably foreseeable effects to coastal resources within the 

coastal zone, Navy will adhere to requirements under CZMA.

159 State:

S05-16

Fully disclose unclassified scientifically-based 

information from monitoring report.

The activity and monitoring reports have been, and will continue 

to be presented on the Navy’s Marine Species Monitoring web site 

(http://www.navymarinespeciesmonitoring.us/), as provided to 

Georgia Department of Natural Resources in 2013.

160 State:

S05-47a

Individual NARWs may be exposed to chronic noise 

and other sub-lethal AFTT impacts for months at a 

time during a single winter, and in subsequent 

winters over the course of their lives. Additionally, 

recent research indicates that the species' health is 

being negatively impacted by vessel strikes, fishing 

rope entanglement, and possibly by forage 

limitations and chronic noise throughout the NARW 

The Navy worked collaboratively with NMFS to develop mitigation 

areas using inputs from the operational community, the best 

available science discussed in Chapter 3 (Affected Environment 

and Environmental Consequences), published literature, predicted 

activity impact footprints, and marine species monitoring and 

density data. The Navy also consulted with NMFS under the 

Endangered Species Act and the Marine Mammal Protection Act. 

The Navy discusses mitigation and monitoring programs in 
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Appendix H Public Comment Responses

Table H.3-1. Comment Response Matrix (continued)

Reference 

Number Commenters Comment Response

160 

(cont.)

range (Rolland et al. 2015, 2016). As such, we 

encourage the Navy to work with National Marine 

Fisheries Service, state natural resources agencies 

and the research community to develop and 

implement a long-term monitoring program to 

assess cumulative impacts of AFTT activities on 

NARWs and their Southeast U.S. habitat.

Chapter 5 (Mitigation).

161 State:

S07-02

Most of the proposed activities will take place far 

from Louisiana’s coastal zone, and relatively few 

effects to the State’s coastal resources are 

anticipated. Among the State’s coastal uses and 

resources for which there may be reasonably 

foreseeable impacts, are the offshore oil and gas 

industry, shipping, and commercial and recreational 

fishing. These uses have a significant presence in the 

Gulf, and may occur in proximity to Navy operations.

The Navy strives to conduct training and testing activities in a 

manner compatible with commercial and recreational ocean users 

by minimizing temporary access restrictions (Section 3.11). 

Notices to Mariners allow commercial and recreational fishing and 

tourism boats to adjust their routes to avoid temporary restricted 

areas. Given the size of the Study Area, the opportunities for Navy 

activities to interfere with commercial and recreational ocean 

users are minimal because the majority of fishing and other 

tourism activities would occur closer to the shore. Because the 

proposed activities would not lead to a noticeable change in Navy 

presence, and because the proposed locations for these activities 

do not differ much from historical use, it is unlikely that 

commercial and recreational activities would be noticeably 

affected by Navy activities requiring area restrictions.

162 State:

S17-04

Likewise, the current Unusual Mortality Event (UME) 

for humpback whale strandings on the east coast, 

which is swiftly approaching 50 whales to date, 

should be weighted heavily.

The humpback whale Unusual Mortality Event is discussed in the 

humpback whale species profile within the Affected Environment 

section of the AFTT Final EIS/OEIS (see Section 3.7.2.3.1.5 -

Species- Specific Threats). All information within the Affected 

Environment section is taken into account when analyzing the 

overall impacts of Navy training and testing to a resource.

163 State:

S19-09

There is insufficient information in the application to 

determine if a 401 Water Quality Certification would 

be required.

Thank you for your review. The Proposed Action does not require 

a 401 Water Quality Certification because discharges associated 

with the Proposed Action are regulated under the Uniform 

National Discharge Standards Program of the Clean Water Act.

164 State:

S19-10

North Carolina recognizes hard bottom habitat as 

one of the six habitat types in the Coastal Habitat 

The Navy has incorporated the referenced spatial data sources 

and an additional source from the North Carolina Natural Heritage 
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Appendix H Public Comment Responses

Table H.3-1. Comment Response Matrix (continued)

Reference 

Number Commenters Comment Response

164 

(cont.)

Protection Plan (CHPP 2016). Extensive hard bottom 

habitat exists on the continental shelf off North 

Carolina in both state and federal waters. Artificial 

hard bottom is also particularly abundant in North 

Carolina Waters in the form of manmade structures, 

including artificial reefs, shipwrecks, and jetties. This 

habitat is home to many of the commercially and 

recreationally important finfish species in North 

Carolina, including reef complex species like 

groupers, flounders, snappers, black sea bass, gray 

triggerfish, sheepshead, spadefish, and grunts; and 

transient pelagic species like amberjack, mackerel, 

cobia, and coastal sharks. Nearshore hard bottom 

areas in particular serve as secondary nursery areas 

(Deaton et al. 2010) and a migratory corridor 

(Lindeman and Snyder 1999; Baron et al. 2004) for 

estuarine dependent reef species such as black sea 

bass and gag grouper. Not only does hard bottom 

provide an ecological benefit, but these areas are 

also used by commercial and recreational fishermen, 

providing a socio-economic benefit for North 

Carolinians.

Specific areas are designated as essential fish habitathabitat area of particular concern (EFH-HAPC) by the 

South Atlantic Fishery Management Council. 

These areas are considered particularly complexes do 

importance of ecological functions provided, and are 

at risk due to their rarity or sensitivity to human 

degradation. Disturbance in these areas of 

concentrated fish use that results in displacement of 

fish could impact local fish abundance by deterring 

foraging, refuge and spawning activities in preferred 

habitat areas.

Program in the Protective Measures Assessment Protocol for 

planning training/testing events involving bottom-placed 

explosives. Such activities do not typically occur within the North 

Carolina coastal zone and will not be planned within 350 yards of 

mapped live hard bottom areas elsewhere, based on standard 

operating procedures and modeling of crater and expelled 

material impacts. The Navy has developed new mitigation 

measures for submerged aquatic vegetation and HAPC for sandbar 

sharks, which are presented in Section 5.4.1 (Mitigation Areas for 

Seafloor Resources) and Section 5.4.3 (Mitigation Areas off the 

Mid-Atlantic and Southeastern United States), respectively.
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Appendix H Public Comment Responses

Table H.3-1. Comment Response Matrix (continued)

Reference 

Number Commenters Comment Response

165 State:

S20-01

I wanted to make you aware of several park units 

that the North Carolina Division of Parks and 

Recreation operates in the study areas indicated in 

your scoping document.

These include:

 Run Hill State Natural Area - Located within the 

Virginia Capes OPAREA

 Jockey's Ridge State Park - Located within the 

Virginia Capes OPAREA

 Fort Macon State Park - Located within the 

Cherry Point OPAREA

 Theodore Roosevelt State Natural Area - Located 

within the Cherry Point OPAREA

 Hammocks Beach State Park - Located within the 

Cherry Point OPAREA

 Lea Island State Natural Area - Located within the 

Cherry Point OPAREA

 Masonboro Island State Natural Area - Located 

within the Charleston OPAREA

 Carolina Beach State Park - Located within the 

Charleston OPAREA

 Fort Fisher State Recreation Area - Located 

within the Charleston OPAREA

 Bald Head Island State Natural Area - Located 

within the Charleston OPAREA

If there are any direct impacts to these properties, 

please coordinate with North Carolina Division of 

Parks and Recreation. Please let me know if you need 

additional information.

Thank you for your review. All these locations are either within the 

Study Area or are directly adjacent to the Study Area. Regarding 

locations in close proximity, yet not directly adjacent, to the Study 

Area, noise producing activities that would generally be conducted 

near coastal National Parks, Historic Sites or Monuments would 

occur greater than 12 NM from the coast. Aircraft noise would be 

intermittent due to transits from airfields to the operating areas 

at-sea. Any activities occurring on the coast, would generally occur 

on Department of Defense controlled beaches. These operating 

parameters will prevent or reduce any noise impacts to park 

resources. The Final EIS/OEIS includes some more information 

regarding potential impacts of wilderness values, recreational 

activities and visitor experience from airborne noise to Section 

3.11 (Socioeconomics) with regard to park units.

166 State:

S29-10

DGIF recommends that the Navy continue to 

coordinate its activities with the National Marine 

Fisheries Service (NMFS) and the U.S. Fish and 

Wildlife Service (USFWS) to ensure protection of 

fisheries associated with the proposed activities.

Thank you for your review. The Navy consulted with the NMFS and 

the United States Fish and Wildlife Service.
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Appendix H Public Comment Responses

Table H.3-1. Comment Response Matrix (continued)

Reference 

Number Commenters Comment Response

167 Individual:

MAREU-01, MAREU-02

Two comments recommended consultation with the 

Marine Mammal Commission.

The Marine Mammal Commission has reviewed the Draft EIS/OEIS 

and provided comments. The Navy has considered all of the 

comments submitted from the Marine Mammal Commission. The 

Marine Mammal Commission letter is located on the project 

website and the Navy's responses are provided in Appendix H.

168 Individual:

KUNJE-01

State:

S14-02b

Two comments shared concerns for potential 

impacts to marine life and sensitive areas and one 

asked that no permit to be granted. 

The Navy is concerned for marine life. The analysis and the science 

show that there is not a significant impact on marine species. All 

of the potential effects from Navy training and testing activities 

were analyzed in Chapter 3 (Affected Environment and 

Environmental Consequences) of the EIS/OEIS. Also, as described 

in Chapter 5 (Mitigation) of the EIS/OEIS, the Navy implements to 

the maximum extent practicable, mitigation measures during its 

training and testing activities. The Navy has conducted active 

sonar training and testing for decades in the sea space depicted in 

the Study Area with no documented proof of injuries to marine 

mammals.

Concerns about alternatives/expansion of alternatives

169 Individual:

HOPCH-04

The planned area of actions is way too large. The size of the study area is based on Navy training and testing 

requirements.

170 Individual:

GALEV-03, MCGSA-02

Two comments suggested using simulation and other 

technology for virtual training to minimize the need 

for real world training.

Military readiness training must be as realistic as possible to 

provide the experiences vital to success and survival during 

military operations because simulated training, even in 

technologically advanced simulators, cannot duplicate the 

complexity faced by Sailors and Marines in the real world. While 

simulators and synthetic training are critical elements that provide 

early skill repetition and enhance teamwork, there is no substitute 

for live training in a realistic environment. The Navy currently uses 

simulation for training and testing whenever possible (e.g., 

command and control exercises are conducted without 

operational forces); however, there are significant limitations, and 

its use cannot replace live training or testing. Section 2.4.3.2 

(Simulated Training and Testing Only) discusses the limitations of 

simulated training.
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Appendix H Public Comment Responses

Table H.3-1. Comment Response Matrix (continued)

Reference 

Number Commenters Comment Response

171 Individual:

SPEJA-03

Sonar technology dates from the 1920s; surely by 

now newer, more effective technologies are 

available which may have a relatively insignificant 

impact on marine life, such as low-powered scalar 

systems.

Modern sonar technology includes a variety of sonar sensor and 

processing systems. The Navy utilizes sonar systems and other 

acoustic sensors in support of a variety of mission requirements. 

Primary uses include detection of and defense against submarines 

(anti-submarine warfare) and mines (mine warfare), safe 

navigation and effective communications, and oceanographic 

surveys. 

172 Individual:

xxxJO-02

You tube had a video about the Navy doing training 

on the east coast, I would like to know if you could 

move the training to the west coast. The reason 

being the ocean is full of radiation there and Japan is 

about to dump more radiation into the Pacific. This 

would protect the sea life in the Atlantic because the 

sea life in the Pacific might be dead by the year 2018 

and nothing will harm the sea life this way.

Thank you for your participation in the National Environmental 

Policy Act process. The Navy developed the alternatives 

considered in this EIS/OEIS after careful assessment by subject 

matter experts, including military units and commands that utilize 

the ranges, military range management professionals, and Navy 

environmental managers and scientists. The alternatives carried 

forward meet the Navy's purpose and need (Section 1.4, Purpose 

and Need) to ensure that it can fulfill its obligation under Title 10. 

See Section 2.4 (Action Alternative Development) for more 

detailed information on the development of alternatives. For 

information regarding west coast Navy training and testing 

activities refer to the Hawaii Southern California Training and 

Testing EIS/OEIS (www.hstteis.com) and the Northwest Training 

and Testing EIS/OEIS (www.nwtteis.com).

173 Organization:

O03-01

Following the court’s summary judgment ruling, the 

Navy and NMFS voluntarily entered into a settlement 

agreement that imposed time and geographic 

restrictions on HSTT activities to protect marine 

areas identified as biologically important to various 

marine mammal populations. In so doing, the 

agencies acknowledged the feasibility of adopting 

time/area restrictions to reduce adverse impacts on 

marine mammals. In completing its EIS, the Navy 

must thoroughly analyze a range of alternatives 

involving varying levels of restrictions in sensitive 

marine habitat “to permit informed public comment 

While the Navy reviewed each additional mitigation measure 

recommended by the commenter, the Navy also reviewed all of 

these measures comprehensively. Adopting all of the limitations 

on training and testing suggested by the commenter would result 

in the Navy effectively losing access to the significant majority of 

the required training space necessary to comply with the Navy’s 

statutory requirement to prepare a ready force. While certain 

time and area restrictions were agreed to in the HSTT settlement, 

the terms of the settlement do not extend ad infinitum (in fact, 

the settlement did not consider the measures permanent and 

speaks to their eventual expiration), and are specific to those 

regions and litigation. They were not selected based on scientific 
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Table H.3-1. Comment Response Matrix (continued)

Reference 

Number Commenters Comment Response

173

(cont.)

on” not only the agencies’ preferred course of 

action, but also “any choices or alternatives that 

might be pursued with less environmental 

harm.” Lands Council, 395 F.3d at 1027.

analysis, but instead were agreed to as a temporary measure to settle 

the pending lawsuit. As such, the settlement and its terms were never 

intended to be a framework for how the Navy models future mitigation. 

There are many different factors to consider within the AFTT study area 

relative to mitigation, and the HSTT settlement cannot be used as a 

template for a one-size-fits-all approach to mitigation. The commenterproposed mitigation measures would essentially prohibit Navy training 

and testing using sonar and explosives along the entire East Coast and 

most of the Gulf of Mexico except in very narrow circumstances. It is 

unclear how the Navy would be able to train and test without access to 

the ranges and locations that have been carefully developed over 

decades. These areas allow for Navy activities to be conducted in a 

manner compatible with multiple other activities in the marine 

environment, such as energy exploration, alternative energy 

development, commercial fishing, recreational activities, and 

commercial shipping. 

As noted in Chapter 2, the Navy also requires extensive sea space so 

that individual training and testing activities can occur at sufficiently 

safe distances such that these activities do not interfere with one 

another and so that Navy units can train to communicate and operate in 

a coordinated fashion over tens or hundreds of square miles, as they

will have to do when in an operational theater. The Navy must also train 

in these areas because it may be called upon to defend the United 

States from direct maritime threats, and the Navy must therefore be 

familiar with the very waters where it may engage in combat. Enemy 

naval forces have historically and consistently operated in U.S. waters, 

from the conflicts following the U.S.’s independence, the World Wars, 

and through the Cold War. To this day, foreign naval forces operate in 

U.S. waters, sometimes clandestinely. To completely ban entire areas 

from training and testing means the Navy will not be able to train in the 

very waters where it may need to fight and defend the U.S., thus 

creating potential sanctuaries where foreign naval forces and 

submarines in particular, may operate more freely.
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Appendix H Public Comment Responses

Table H.3-1. Comment Response Matrix (continued)

Reference 

Number Commenters Comment Response

173

(cont.)

The commenter proposes, in the alternative to banning Navy training 

and testing, that the Navy require approval in nearly every area where 

the Navy currently trains and tests from the “highest command 

authority.” It is unclear who the commenter means as the highest 

command authority for the military is the President. Assuming the 

commenter is referring to very senior military commanders, such a 

requirement is unwarranted and impractical. As noted in Chapter 2, the 

Navy conducts thousands of discrete training and testing activities, 

many involving sonar and explosives. In most cases, these events are 

small-scale unit-level training activities or testing events with minimal to 

no impacts on marine mammals and the environment. To require that 

each individual event be approved at such an elevated level of 

command, and for all of the areas proposed by the commenter, would 

essentially paralyze Navy decision-making as senior commanders would 

be focused on approving otherwise minor and minimally impactful 

activities. This would lead to fewer training and testing evolutions and 

decreased readiness, and increasing the risk to Sailors, platforms, and 

equipment. For major training events, senior commanders are already 

part of the planning and approval processes for the event. The Navy’s 

mitigation measures were reviewed and approved by a four-star 

Admiral, the Fleet Commander of all Navy forces in the Study Area, and 

Navy Senior Leadership; therefore, additional permission or 

authorization from Navy Leadership prior to conducting training or 

testing in the Study Area would be redundant.

While the approval scheme may have been supportable as a short-term 

settlement measure, it is inappropriate for a long-term approach, is not 

supported at the scale suggested by the commenter in the AFTT study 

area, is otherwise not warranted based on the extensive level of 

mitigation previously approved by NMFS and already approved by senior 

Navy leadership, and runs counter to one of the foundational concepts 

of naval command and control at sea – which is the ability and duty for a 

commanding officer to train and fight their ship. As such, the Navy works
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Appendix H Public Comment Responses

Table H.3-1. Comment Response Matrix (continued)

Reference 

Number Commenters Comment Response

173

(cont.)

to institutionalize standardized mitigation procedures to ensure that 

these measures are implemented efficiently and consistently across the 

Navy. To accomplish this, the Navy has developed a software tool known 

as the Protective Measures Assessment Protocol (see Section 5.1.2, 

Compliance Initiatives) to reduce the administrative burdens of 

environmental compliance on commanders while ensuring required 

mitigation is implemented correctly.

Nor does the excessive level of mitigation proposed by the commenter 

appear warranted when compared to the level of environmental impact 

anticipated from Navy training and testing. The Navy has been training 

and testing in these areas for decades without causing any discernable 

degradation of the marine environment or to marine species. Many of 

the impacts to marine species noted by the commenter, such as the 

increase in ambient ocean noise, marine mammal injuries, and vessel 

strikes, are caused primarily by other activities, such as commercial 

fishing and commercial shipping. In the last 25 years, commercial 

shipping has increased 400%, and the amount of food we obtain from 

the sea has increased 10 fold. Yet, during this time, the U.S. Navy has 

become smaller, and its levels of activities have lessened as a result. The 

Navy represents an extremely small percentage of overall marine 

activities, and these other activities represent the overwhelming 

proportion of impacts on the marine environment, yet the mitigation 

measures proposed by the commenter would impose some of the most

stringent and restrictive of any requirements on any other marine 

activity, measures that potentially mitigate mostly short-term and minor 

environmental impacts, and would essentially preclude effective Navy 

training and testing.

Chapter 5 contains a detailed discussion of mitigation that includes 

limitations on sonar and explosives use, time/area restrictions, planning 

areas that elevate environmental considerations, and a reporting 

system. As discussed in Chapter 5 (Mitigation), the mitigation measures 

represent the maximum level of mitigation that the Navy can 
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Appendix H Public Comment Responses

Table H.3-1. Comment Response Matrix (continued)

Reference 

Number Commenters Comment Response

173

(cont.)

implement after consideration of personnel safety, practicality of 

implementation, and impact on the effectiveness of the military 

readiness activities. The Navy’s mitigation measures were reviewed and 

approved by a four-star Admiral, the Fleet Commander of all Navy 

forces in the Study Area, and Navy Senior Leadership.

174 Organization:

O03-03

We urge the Navy to provide more information 

on its preferred alternative, which otherwise, 

based on the information presented in the DEIS, 

appears to have been designed on the basis of 

factors unrelated to avoiding or minimizing 

adverse impacts. To satisfy NEPA, the Navy 

should develop a fuller range of reasonable 

alternatives, such as by considering 

enhancements to its proposed time-area 

management measures.

The Navy's alternatives were developed in order to satisfy the Navy's 

purpose and need related to fulfilling its Title 10 requirements. 

Consistent with 40 C.F.R. 1502.14, the Navy has included a robust suite 

of mitigation measures, which will be implemented in both action 

alternatives (i.e. regardless of which alternative is selected). These 

mitigation measures, as well as standard operating procedures that 

Navy routinely employs, are discussed in detail and specifically inform 

the decision maker and the public how the Navy can avoid or minimize 

adverse impacts. NEPA identifies the application of mitigation measures, 

such as those suggested by the comment, to the alternatives "when not 

already included in the proposed action or alternatives" (40 C.F.R. 

1502.14). Details regarding the development of reasonable alternatives 

are provided in Section 2.4, Action Alternative Development.

Commercial/Socioeconomic concerns

175 Organization:

O01-08, O04-11

State:

S29-08

Individual:

COEPH-02b,

MCGSA-01b

Five comments expressed concern over the 

impact the proposed activities could have on 

commercial activities.

Many Navy at-sea training and testing ranges are accessible to the 

public for recreational and commercial purposes. The proposed training 

and testing activities are generally consistent with training and testing 

that the Navy has been conducting in the AFTT Study Area for decades. 

The Navy strives to conduct training and testing activities in a manner 

compatible with commercial and recreational ocean users by minimizing 

temporary access restrictions (Section 3.11, Socioeconomics). The Navy 

acknowledges that during specific exercises, its training and testing 

could briefly limit (usually for a matter of hours) public access to a very 

limited portion of coastal and ocean areas to ensure public safety. 

Notices to Mariners allow commercial and recreational fishing and 

tourism boats to adjust their routes to avoid temporary restricted areas. 

Socioeconomic Resources (Section 3.11) addresses the availability of 

access on the ocean and in the air and concludes there would be no 
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Appendix H Public Comment Responses

Table H.3-1. Comment Response Matrix (continued)

Reference 

Number Commenters Comment Response

175 (cont.) impacts on commercial and recreational activities when Navy training 

and testing activities temporarily change access to the ocean or airspace 

in the Study Area. Training cycles and testing needs are expected to vary 

due to current and emerging threats. Due to changing needs, the 

EIS/OEIS is structured to provide flexibility in training and testing 

locations.

176 State:

S24-02

Secondly, it is possible that planned activities 

could have effects on commercial and 

recreational fisheries specifically within Essential 

Fish Habitat/Habitat Areas of Particular Concern 

(EFH-HAPCs) as designated by South Atlantic 

Fisheries Management Council (SAFMC), 

specifically related to the Charleston Bump 

Complex.

The Navy has worked collaboratively with NMFS to identify and develop 

mitigation areas using inputs from the operational community, the best 

available science discussed in Chapter 3 (Affected Environment and 

Environmental Consequences), published literature, predicted activity 

impact footprints, and marine species monitoring and density data. The 

proposed training and testing activities are generally consistent with 

training and testing that the Navy has been conducting in the AFTT 

Study Area for decades. The Charleston Bump is located seaward of the 

nearshore continental shelf, where most of the bottom-placed 

explosives training or testing would occur. Bottom-placed explosives 

training or testing will not be planned on or near mapped areas of live 

hard bottom on the continental shelf, per established mitigation 

measures and mapping that is kept up-to-date. The Navy completed an 

Essential Fish Habitat assessment and operational analysis of potential 

mitigation areas throughout the entire Study Area. The Navy has 

developed new mitigation measures for submerged aquatic vegetation 

and HAPC for sandbar sharks, which are presented in Section 5.4.1 

(Mitigation Areas for Seafloor Resources) and Section 5.4.3 (Mitigation 

Areas off the Mid-Atlantic and Southeastern United States), 

respectively. The mitigation identified in Section 5.4 (Mitigation Areas to 

be Implemented) represents the maximum mitigation within the 

identified mitigation areas that is practical to implement under the 

Proposed Action.
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Appendix H Public Comment Responses

Table H.3-1. Comment Response Matrix (continued)

Reference 

Number Commenters Comment Response

177 Commercial:

C01-02, C01-03

Individual:

COEPH-03, 

COEPH-04b, 

COEPH-05,

RAYSU-03b

Local/Regional:

L03-01

Organization:

O01-02b,

O04-13

State:

S02-03,

S14-03, S24-03

Twelve comments expressed concern over 

potential impacts to recreational and 

commercial fishing and boating activities. 

The Navy strives to conduct training and testing activities in a manner 

compatible with commercial and recreational ocean users by minimizing 

temporary access restrictions (Section 3.11, Socioeconomics). The 

proposed training and testing activities are generally consistent with 

training and testing that the Navy has been conducting in the AFTT 

Study Area for decades. Notices to Mariners allow commercial and 

recreational fishing and tourism boats to adjust their routes to avoid 

temporary restricted areas. Given the size of the Study Area, the 

opportunities for Navy activities to interfere with commercial and 

recreational ocean users are minimal because the majority of fishing 

and other tourism activities would occur closer to the shore. Because 

the proposed activities would not lead to a noticeable change in Navy 

presence, and because the proposed locations for these activities do not 

differ much from historical use, it is unlikely that commercial and 

recreational activities would be noticeably affected by Navy activities 

requiring area restrictions.

178 Commercial:

C01-04a

However, the Draft EIS states on page ES-12 that 

“the expected impact of noise on invertebrates 

is...mostly limited to offshore layers of the water 

column where only...squid...are prevalent”. 

There are scientific studies that show significant 

mortality of squid when exposed to lowfrequency noise (see Andre et al “Low-frequency 

sounds induce acoustic trauma in cephalopods”, 

Research Communications, 2011). We would 

request that this be considered when scheduling 

and locating exercises, as a significant portion of 

our income may be at stake.

The Navy strives to conduct training and testing activities in a manner 

compatible with commercial and recreational ocean users by minimizing 

temporary access restrictions (Section 3.11, Socioeconomics). Andre et 

al. is referenced in Section 3.4.3.1.1.1, Injury, of the EIS/OEIS. Andre et 

al. presents a highly unlikely scenario (e.g.-close proximity/prolonged 

duration) involving Navy training and testing activities. It is unlikely that 

cephalopods would be in close proximity to Navy vessels/devices during 

training and testing activities, and exposure duration would be 

temporary. The proposed training and testing activities are generally 

consistent with training and testing that the Navy has been conducting 

in the AFTT Study Area for decades.

179 Commercial:

C01-05

The impact will be long term but not minimal if 

the objects are released in heavily fished areas, 

so we would request that the Navy avoid fishing 

The Navy strives to conduct training and testing in a manner compatible 

with commercial and recreational ocean users by minimizing temporary 

access restrictions (Section 3.11, Socioeconomics). The proposed 
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Appendix H Public Comment Responses

Table H.3-1. Comment Response Matrix (continued)

Reference 

Number Commenters Comment Response

179

(cont.)

grounds when releasing metal objects, or 

otherwise provide compensation to fishing 

businesses for loss of gear. Each of our vessels 

trawls with a net and associated hardware worth 

over $130,000 each.

training and testing activities are generally consistent with training and 

testing that the Navy has been conducting in the AFTT Study Area for 

decades. Notices to Mariners allow commercial and recreational fishing 

and tourism boats to adjust their routes to avoid temporary restricted 

areas. Given the size of the Study Area, the opportunities for Navy 

activities to interfere with commercial and recreational ocean users are 

minimal because the majority of fishing and other tourism activities 

would occur closer to the shore. Because the proposed activities would 

not lead to a noticeable change in Navy presence, and because the 

proposed locations for these activities do not differ much from historical 

use, it is unlikely that commercial and recreational activities would be 

noticeably affected by Navy activities requiring area restrictions. 

Damage to fishing gear from Navy training and testing activities in the 

Study Area is rare. When damage does occur to commercial fishing gear 

due to Navy actions (e.g., net entanglement, destructions of buoys), the 

fishermen (or the owner of the property damaged) can file a claim with 

the Department of the Navy under the Federal Tort Claims Act under 

the provisions of 28 U.S. Code Section 2671, et seq. and request 

reimbursement. Forms for filing a claim under the act can be obtained 

from any Regional Legal Service Office. Reimbursement requests must 

be made within 2 years of incurring damage.

180 Organization:

O04-12b

With respect to fishing activity, the summary 

provided in section 3.11.2.4 is a good overview 

of commercial and recreational fishing in the 

Atlantic and Gulf regions, but would benefit 

from additional specifics. It would be helpful to 

include an assessment of the likely spatial 

overlap between specific types of fishing 

activities with the locations where training and 

testing activities are likely to be concentrated. 

Fishing activities could be grouped by target 

species, fishery management plan, or gear type. 

Such an analysis would not need to be overly 

Within the AFTT Study Area, the Northeast and Mid-Atlantic Regional 

Planning Bodies developed Plans that were certified by the National 

Ocean Council in December 2016. In those Plans, the Department of 

Defense committed to using the Plans and Regional Data Portals to 

inform pertinent environmental programs, initiatives, and planning 

documents. The Regional Ocean Plans and Data Portals were used as a 

resource throughout the development of this EIS/OEIS. Additionally, 

because the proposed activities would not lead to a noticeable change 

in Navy presence, and because the proposed locations for these 

activities do not differ much from historical use, it is unlikely that 

commercial and recreational fishing activities would be noticeably 

affected by Navy activities requiring area restrictions.
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Appendix H Public Comment Responses

Table H.3-1. Comment Response Matrix (continued)

Reference 

Number Commenters Comment Response

180 (cont.) specific to be useful; as both fishing activities 

and Naval testing and training are somewhat 

difficult to forecast precisely, this would be 

challenging in any case. Fishing effort maps are 

available on regional ocean data portals such as 

http://www. northeastoceandata .org/ and

http://portal .midatlanticocean .org/.

Pollutants

181 Organization:

O02-07b

Lastly, we are concerned about the use of live 

munitions or chemical compounds that may 

either persist in the environment offshore or be 

a hazard to fishing vessels using bottom-tending 

gear. To the extent possible, live munitions 

should be used further offshore outside the 

range where most fishing operations are being 

conducted, and efforts should be made to 

minimize the release of harmful chemical 

compounds.

As discussed in Chapter 3.6 (Fishes), effects on sediment or water 

quality would not result in persistent or large scale effects on the 

growth, survival, distribution, or population-level impacts of fishes. As a 

matter of practice, the Navy typically does not conduct certain activities 

in coastal areas due to specific mission requirements (see Section 

2.3.3.16, Coastal Zone). The Navy will avoid or reduce impacts from 

training and testing throughout the Study Area to the maximum extent 

practicable through procedural mitigation (see Section 5.3, Procedural 

Mitigation to be Implemented) and mitigation areas (see Section 5.4, 

Mitigation Areas to be Implemented). Implementing additional 

mitigation would be impractical due to implications for safety, 

sustainability, and the Navy’s ability to continue meeting its Title 10 

requirements to successfully accomplish military readiness objectives.

182 State:

S19-04

Emergency fuel dumping of aircraft over waters. The analysis presented in Chapter 3 (Affected Environment and 

Environmental Consequences) of the EIS/OEIS is limited to the activities 

and reasonable outcomes of such activities. Accidents or emergencies 

are not reasonably foreseeable, nor anticipated, as part of the Proposed 

Action, the impacts of such occurrences is not addressed or analyzed in 

Chapter 3 (Affected Environment and Environmental Consequences). 

The Navy has plans and procedures for preventing, reporting, and 

responding to spills. Generally, worse case scenarios such as ship 

explosions, collisions, and toxic releases are not analyzed as part of the 

National Environmental Policy Act process.

183 State:

S19-06

Dumping of waste, garbage, spent and defective 

munitions into waters.

Thank you for your participation in the National Environmental Policy 

Act process. The dumping of waste, garbage, and spent and defective 
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Appendix H Public Comment Responses

Table H.3-1. Comment Response Matrix (continued)

Reference 

Number Commenters Comment Response

183 (cont.) munitions is not part of the Proposed Action. The Navy will comply with 

all applicable laws and regulations.

184 State:

S31-01

Any debris or waste disposal should be at an 

appropriately authorized disposal facility.

The Navy will comply with all applicable laws and regulations.

185 State:

S28-04

The EIS/OEIS should also include response plans 

in the event of accidental spills of oil or other 

hazardous materials due to either mechanical or 

human failure.

The Navy has plans and procedures for preventing, reporting, and 

responding to spills.

186 Individual:

AUBMA-02b, 

COEPH-02a, 

DIAJO-03, 

FRISU-02b,

GAGBR-01b,

LEPSH-01b,

LEPSH-02,

Federal:

F01-02

Organization:

O01-03, O01-07, 

O01-09, O04-08

State:

S19-02, S19-03, 

S19-05

Fifteen comments expressed concern over 

pollution from the proposed activities.

The Navy is concerned for the heath of coastal communities, fisheries, 

and ecosystems. Section 3.1 (Sediments and Water Quality) concludes 

that chemical, physical, and biological changes to sediment or water 

quality would be measureable but below applicable standards, 

regulations, and guidelines, and would be within the existing conditions 

or designated uses. The Navy will comply with all applicable laws and 

regulations.

Provide data for peer review

187 Organization:

O03-47

Additionally, the risk functions do not 

incorporate (nor does the Navy apparently 

consider) a number of relevant studies on wild 

marine mammals, such as a passive acoustic 

study on blue whale vocalizations and a tagging 

study on behavioral responses to dipping sonar, 

for which received levels are either available or 

The new risk functions were developed in 2016, before several recent 

papers were published or the data were available. As new science is 

published, the Navy continues to evaluate the information. The criteria 

have been rigorously vetted within the Navy community, among 

scientists during expert elicitation, and then reviewed by the public 

before being applied, it is unreasonable to revise and update the criteria 

and risk functions every time a new paper is published. These new and 
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Appendix H Public Comment Responses

Table H.3-1. Comment Response Matrix (continued)

Reference 

Number Commenters Comment Response

187 (cont.) can be estimated. future papers provide additional valuable information, and the Navy has 

already begun to consult them for updates to the criteria in the future, 

when the next round of updated criteria will be developed. Thus far, no 

new information has been published or otherwise conveyed that would

fundamentally change the assessment of impacts or conclusions of this 

Final EIS/OEIS. To be included in the behavioral response function, data 

sets needed to relate known or estimable received levels to 

observations of individual or group behavior. Melcon et al. (2012) does 

not relate observations of individual/group behavior to known or 

estimable received levels [at that individual/group]. In Melcon et al. 

(2012), received levels at the HARP buoy averaged over many hours are 

related to probabilities of D-calls, but the received level at the blue 

whale individuals/group are unknown. 

188 Organization:

O03-48

For this reason and others, and given the 

obvious importance of this analysis for future 

acoustic impact analyses, we ask the Navy to 

make additional technical information available, 

including expert elicitation and peer review (if 

any), so that the public can fully comment.

As stated in EIS/OEIS Section 3.7.3.1.2.1 (Methods for Analyzing Impacts 

from Sonar and Other Transducers), the derivation of the BRF’s is 

provided in the 2017 technical report titled Criteria and Thresholds for 

U.S. Navy Acoustic and Explosive Effects Analysis (Phase III). The 

appendices to this report detail the specific data points used to 

generate the BRF’s. Data points come from published data that is readily 

available and cited within the technical report.

Ship Strikes

189 Organization:

O03-51

This approach, however, fails to account for the 

likelihood that ship strikes since 2009 were 

unintentionally underreported.

The Navy does not underreport ship strikes. The Navy found that use of 

historical data was more appropriate for the analysis. The strike 

probability analysis completed in this EIS/OEIS is based upon actual data 

collected from historical use of vessels and represents a more realistic 

approach to account for real world variables. NRDC’s assertion that 

Navy ships cannot detect ship strikes is categorically incorrect. In the 

extremely few instances where Navy ships have struck whales, these 

ships ranged in size from small to aircraft carrier size. Additionally, Navy 

ships have multiple lookouts, including on the after part of the ship that

can visually detect a hit whale (which has occurred), in the unlikely 

event the ship does not feel the strike. The commenter otherwise 

provides no evidence demonstrating Navy vessels are striking whales 
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Appendix H Public Comment Responses

Table H.3-1. Comment Response Matrix (continued)

Reference 

Number Commenters Comment Response

189 (cont.) and not reporting these strikes.

190 Organization:

O03-52

Additionally, the Navy’s analysis does not 

address the potential for increased strike risk of 

non-Navy vessels as a consequence of acoustic 

disturbance. For example, some types of 

anthropogenic noise have been shown to induce 

near-surfacing behavior in right whales, 

increasing the risk of ship strike at relatively 

moderate levels of exposure.122 An analysis 

based on reported strikes by Navy vessels does 

not account for this additional risk. In assessing 

ship- strike risk, the Navy should include offsets 

to account for potentially undetected and 

unreported collisions. (Note: comment 

contained footnotes. See comment letter).

There is no evidence that Navy training and testing activities increase 

the risk of non-Navy vessels striking marine mammals. Additionally, the 

signal referred to in the comment was developed specifically to elicit a 

response from the right whales. This type of signal is not analogous to 

any sound source used by Navy.

191 State:

S05-41

In Appendix F the probability of vessel strikes 

with large whales are calculated with a simple 

Poisson model that uses: 1) the number of 

observed large whale strikes during 2009-2016 

(n 3), and 2) the number of anticipated steaming 

days in AFTT Phase III compared to 2009- 2016. 

The results indicate that the probability of 

striking one or more whales during AFTT Phase 

III is very low. This approach is only appropriate 

if the spatiotemporal distribution of whales and 

vessels is very similar between the two time 

periods, which may not be the case. For 

example, the low number of whale strikes from 

2009 to 2016 may be due in part because low 

numbers of NARWs have been sighted in the 

Southeast U.S. since 2010 (GDNR, unpublished 

data). If the nu1nber of NARWs increases in the 

next five years (which we hope it will), the risk of 

The strike probability analysis completed in this EIS/OEIS is based upon 

actual data collected from historical use of vessels. Also, the Navy 

acknowledges the risk that vessels pose to right whales and, therefore,

has developed a unique suite of mitigation measures for this species. 

For years, the Navy has successfully been employing these Navy-specific 

mitigation measures designed to avoid ship strikes to North Atlantic 

right whales.
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Appendix H Public Comment Responses

Table H.3-1. Comment Response Matrix (continued)

Reference 

Number Commenters Comment Response

191 (cont.) a strike would increase beyond the Navy's 

estimates. Likewise, if the number of vessels 

departing Mayport Naval Station in Florida til 

February (i.e., peak NARW season) is greater in 

the future than it was in the past, the risk of 

striking whales would increase accordingly. We 

recommend that the Navy use a more rigorous 

approach to model vessel strike risk.

Cumulative impacts

192 State:

S02-05,

S05-47b, S17-03

Three comments expressed concern that the 

EIS/OEIS does not adequately address the extent 

of potential cumulative impacts.

The Navy has taken a hard look at the incremental, potential cumulative 

effects of its actions, against the appropriate resource and regulatory 

baselines. The Navy used the best available science and a 

comprehensive review of past, present, and reasonably foreseeable 

actions to develop its Cumulative Impacts analysis. As required under 

NEPA, the level and scope of the analysis is commensurate with the 

potential impacts of the action as reflected in the resource-specific 

discussions in Chapter 3 (Affected Environment and Environmental 

consequences). The EIS/OEIS considered its activities alongside those of 

other activities in the region whose impacts are "truly meaningful" to 

the analysis. Information on the Navy's two conditions for analysis are 

provided in section 4.1.1. (Determination of Significance). Further, the 

U.S. EPA has reviewed the Draft EIS/OEIS and rated the document as LO 

- lack of objections - which means it has not identified any 

environmental impact requiring substantive changes to the proposal.

193 State:

S02-06

The Navy should consider coordinating efforts 

with other entities conducting seismic activity in 

the region to minimize the impacts of 

overlapping surveys.

The Navy coordinates with other Federal Agencies to the greatest 

extent practicable. However, for operational security and safety 

considerations, it is not always possible or preferable to disclose the 

precise location and timing of given maneuvers and training scenarios.

194 State:

S05-02

The extent to which active sonar sound will likely 

propagate from the USWTR and into the 

adjacent right whale calving habitat.

Acoustic modeling accounted for the levels that would propagate 

throughout the Jacksonville range complex, including areas where right 

whales may be. This information was included in the analysis for North 

Atlantic right whales.
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Appendix H Public Comment Responses

Table H.3-1. Comment Response Matrix (continued)

Reference 

Number Commenters Comment Response

195 State:

S05-03

Whether active sonar sound emitted from the 

USWTR will raise ambient noise levels within the 

adjacent calving habitat.

Active sonar activity is relatively short in duration and is not shown to 

measurably increase ambient noise levels.

196 State:

S05-11

In the event that these thresholds are exceeded, 

training and testing activities will cease in the 

USWTR area during November 15 to April 15 

pending re-initiation of an ESA Section 7 

consultation with NMFS.

The Navy is fully integrated with the NMFS Ocean Acoustics Program. 

Any modifications resulting from the program were considered during 

consultations with NMFS and will be considered during the adaptive 

management process.

197 State:

S05-05

Passive acoustic monitoring of the USWTR, 

NARW calving habitat and intervening ocean 

waters should be conducted to assess ambient 

and operational noise levels.

Long-term passive acoustic monitoring has been occurring, and is 

planned to continue to occur in the JAX OPAREA, and the results of the 

monitoring are presented on the Navy’s Marine Species Monitoring web 

site (http://www.navymarinespeciesmonitoring.us/).

198 State:

S05-09

In the event that a NARW is killed or severely 

injured in the USWTR area by a vessel strike, 

active sonar or ordnance detonation, USWTR 

training and testing activities will cease during 

November 15 to April 15 pending re-initiation of 

an ESA Section 7 consultation with NMFS.

In the event a North Atlantic right whale is killed or significantly injured 

by a Navy vessel, the Navy will follow the terms and conditions of the 

NMFS issued Biological Opinion.

199 State:

S05-45

We request that the Navy quantify the amount 

and spatial extent of vessel traffic, active sonar 

and explosives that will be used in the USWTR 

from November to April annually, and how this 

compares with the status quo.

Activities on USWTR will occur year-round and are estimated to be 

evenly distributed throughout the year. The Navy vessel traffic in and 

out of the listed ports will not change from current levels as activities 

occurring on the USWTR range already take place in this area, just not 

currently on an instrumented range.

200 Individual:

ARRRI-01,

GAGBR-03

State:

S17-02

Three comments expressed concern with an 

undersea warfare training range and its 

potential impacts to North Atlantic Right Whales 

and one comment expressed concern over the 

cumulative impacts from human activities, 

especially noise, on the marine environment. 

The potential cumulative impacts of ocean traffic, climate change, water 

quality, offshore energy exploration and development, and other 

activities and stressors are summarized in Table 4.2-1 (Past, Present and 

Reasonably Foreseeable Actions) and specifically analyzed with regard 

to potential impacts to marine mammals in Section 4.4.7 (Cumulative 

Impacts on Marine Mammals).
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Appendix H Public Comment Responses

Table H.3-1. Comment Response Matrix (continued)

Reference 

Number Commenters Comment Response

201 State:

S17-09b

DEC remains very concerned that, should the 

extent of training and testing occur without the 

review of additional mitigation effort and 

understanding of cumulative impacts from 

increased human activity in the ocean 

environment, the subsequent occurrence of the 

Proposed Action can have more than negligible 

effects on marine species and habitat, not only 

in New York waters but adjacent areas as well.

The Navy’s analysis of direct and indirect effects is described in Chapter 

3.0.3 (Overall Approach to Analysis). Generally for each resource 

analyzed in Chapter 3 (Affected Environment and Environmental 

Consequences), the direct impacts from individual stressors are 

analyzed first, followed by, where applicable, the secondary stressors, 

and then concludes with a summary of the potential impacts of 

combined stressors (all direct and indirect). The analysis of cumulative 

impacts is provided in Chapter 4 (Cumulative Impacts). Further, the U.S. 

EPA has reviewed the EIS/OEIS and rated the Draft EIS/OEIS as LO - Lack 

of Objections - which means, it has not identified any environmental 

impacts requiring substantive changes to the proposal.

202 State:

S19-07

Long-term cumulative effects of spent munitions 

on sediments and water quality of range areas 

off shore of North Carolina.

Explosives byproducts and the potential for munition constituents and 

constituent accumulation are discussed in Section 3.2.3.1 (Explosives 

and Explosive Byproducts). Full discussion of studies pertaining to the 

Potomac River Test Range at Dahlgren and Virginia Beach, VA, Hawaii 

and other WWII locations, and Vieques, Puerto Rico are on pages 3.2-42 

and 3.2-43. The results of these studies are extrapolated as relevant 

throughout the project study area, including NC. To our knowledge, no 

similar studies have been conducted specific to NC locations.

203 State:

S24-01a

It is recommended the EIS/OEIS contain as much 

descriptive information as to potential effects to 

these resources including cumulative activities 

that may affect certain species to include 

increased anthropogenic noise in the ocean 

associated with all aspects of testing and 

training within the Northwest Atlantic Ocean 

Distinct Population Segment (DPS). Within the 

North Atlantic DPS, U.S. NOAA's National Marine 

Fisheries Service (NMFS) has designated thirtysix (36) marine areas as critical habitat. Each of 

these areas consist of multiple or a combination 

of habitat types, but the most important habitat 

to consider with regard to testing and training is 

The potential for combined impacts on all of the stressors introduced by 

Navy training and testing activities are evaluated in Section 3.8.4 

(Summary of Potential Impacts on Reptiles). Cumulative impacts from 

the Proposed Action, as well as Federal and non-Federal actions, 

regarding sea turtles and anthropogenic noise, are discussed in Section 

4.4.8 (Reptiles) of the Cumulative Impacts chapter. Potential impacts of 

anthropogenic noise introduced by Navy training and testing activities 

are discussed and analyzed in Sections 3.8.3.1 (Acoustics Stressors) and 

3.8.3.2 (Explosive Stressors) for sea turtles, including the loggerhead 

Northwest Atlantic DPS and its designated critical habitat. Only species 

and their critical habitat (if designated) were given a determination of 

effect on the potential impacts of the Proposed Action. Foraging habitat 

is not a designated critical habitat type for the loggerhead Northwest 

Atlantic DPS (79 FR 39855) so it was not explicitly analyzed for an effect 
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Appendix H Public Comment Responses

Table H.3-1. Comment Response Matrix (continued)

Reference 

Number Commenters Comment Response

203 (cont.) restricted migratory corridors in federal waters. 

NMFS also received special management 

considerations for foraging habitat in two large 

areas that contain Sargassum habitat, which 

presumably is located in the same area as the 

planned activities.

determination. Sargassum habitat is a designated critical habitat type 

and this was addressed in the analysis. However, some of the known 

foraging/developmental habitats for the loggerhead Northwest Atlantic 

DPS are addressed in Section 3.8.2.2.4 (Loggerhead Turtle (Caretta 

caretta)) as well as considered in some of the U.S. Navy stressor analysis 

sections in Section 3.8.3 (Environmental Consequences). The NMFS 

consultation document, the Biological Assessment, and the Final 

EIS/OEIS will include a more in depth analysis of the impacts on the 

loggerhead Northwest Atlantic DPS as well as its designated critical 

habitat.

204 Organization:

O03-54

Nor does the Navy’s treatment of cumulative 

impacts, adding the impacts of other reasonably 

foreseeable activities to its own projected 

training and testing, result in an adequate 

analysis. Unfortunately, in assessing the additive 

and synergistic impacts of its own activities, the 

Navy provides only abstract rationalization. 

Finally, it suggests that NMFS’ stock assessment 

reports, which track Potential Biological 

Removal, and take authorization and adaptive 

management processes provide a sufficient 

safeguard against population-level harm (DEIS at 

4-44), yet Potential Biological Removal considers 

only mortality, not sublethal effects, and, given 

the difficulty of tracking population trends in 

long- lived marine wildlife, NMFS biologists have 

stated that population surveys would usually fail 

to detect even catastrophic declines in the vast 

majority of cetaceans. At present, the Navy’s 

analysis is arbitrary and does not meet NEPA’s 

requirement to assess the overall impact of the 

accumulation of individual impacts. (Note: 

comment contained footnotes. See comment

The commenters’ assertion regarding the analysis is incorrect. The Navy, 

in cooperation with NMFS, has taken a hard look at the cumulative 

effects of the incremental impact of its proposed actions when added to 

other past present and future actions, against the appropriate resources 

and regulatory baselines. The Navy used the best available science and a 

comprehensive review of past, present, and reasonably foreseeable 

actions to develop its Cumulative Impacts analysis. As required under 

NEPA, the level and scope of the analysis is commensurate with the 

potential impacts of the action as reflected in the resource-specific EIS, 

discussions in Chapter 3 (Affected Environment and Environmental 

consequences). The EIS/OEIS considered its activities alongside other 

actions in the region when those impacts are cumulatively significant. 

Past and present actions are also included in the analytical process as 

part of the affected environment baseline conditions presented in 

Chapter 3. The Navy has done so in accordance with the Council on 

Environmental Quality 1997 guidance. Per the guidance, a qualitative 

approach and best professional judgment are appropriate where precise 

measurements are not available. Where precise measurements and/or 

methodologies were available they were used. Guidance from the 

Council on Environmental Quality states it “is not practical to analyze 

cumulative effects of an action on the universe; the list of 

environmental effects must focus on those that are truly meaningful.” 

Further, the U.S. EPA has reviewed the Draft EIS/OEIS and rated the 
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Appendix H Public Comment Responses

Table H.3-1. Comment Response Matrix (continued)

Reference 

Number Commenters Comment Response

204 (cont.) letter). document as LO - lack of objections - which means it has not identified 

any environmental impact requiring substantive changes to the 

proposal. Information on the Navy's analysis is provided in section 4.1.1. 

(Determination of Significance). Lastly, all of the potential effects on 

marine mammals from Navy training and testing were analyzed in 

Chapter 3.7 (Affected Environment and Environmental Consequences -

Marine mammals). Based on the best available science, it was 

determined that population-level impacts would not occur. The 

commenter otherwise has provided no evidence that demonstrates 

stock or population-level consequences resulting from Navy training and 

testing activities have occurred, activities that have occurred in these 

areas at similar levels of intensity, for more than 70 years.

The commenters’ characterization of the Hildebrand 2006 citation is 

incorrect. In this paper, the author clearly states that the comparison of 

potential sound energy does not consider other important factors such 

as the distribution of the sound sources in space and time. Therefore, 

the findings in the paper do not represent how Navy activities are 

conducted, or represent how sound from those activities realistically 

interacts in the natural environment. As clearly stated throughout the

AFTT Final EIS/OEIS, the Navy’s activities are typically of short duration 

(minutes to hours) and widely dispersed throughout the study are in 

space and time. The commenters’ characterization of the New et al 

2013 paper is also incorrect. New presents a modeling approach that 

considers many factors, sound being one, to establish a process that 

could be used to investigate potential effects to beaked whales when 

data for the biological factors required by the model becomes available. 

New 2013 is thoroughly discussed throughout Section 3.7.3 

(Environmental Consequences). Lastly, the authors note the need for 

more data on prey species and reproductive parameters including 

gestation and lactation duration, as the model results are particularly 

affected by these assumptions. 

Through the consultation and permitting processes with the NMFS,
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Appendix H Public Comment Responses

Table H.3-1. Comment Response Matrix (continued)

Reference 

Number Commenters Comment Response

204 (cont.) which also considered the Stock Assessment Reports and ensure any 

potential effect does not exceed PBR, it was determined that the Navy's 

Proposed Action would not have measurable, long-term effects on 

marine mammals. PBR is one tool NMFS uses to ensure population-level 

harm does not occur. The Navy's monitoring program has also 

demonstrated no evidence of population-level harm to marine 

mammals in the AFTT Study Area.

205 Organization:

O04-10

However, we note that the affected 

environment of the study area could change 

with respect to oil and gas leasing and 

development over the next few years, 

depending on the outcome of BOEM's 5-year oil 

and gas planning process that will replace the 

2017-2022 plan currently in effect. In addition, 

the Navy is likely aware, and the EIS should 

probably reflect, that specific offshore 

windfarms are actively moving forward with site 

assessment activities and drafting construction 

and operations plans. Given these specific 

activities, the reference to the Smart from the 

Start wind energy development plans in the EIS 

seems overly general.

The April 2017 Executive Order Implementing an America-First Offshore 

Energy Strategy and May 2017 Department of the Interior Secretary 

Order 3350 Implementing the America-First Offshore Energy Strategy 

are discussed in Table 4.2-1 (Past, Present, and Reasonably Foreseeable 

Actions) including the ensuing development of a new BOEM 5-Year 

Outer Continental Shelf Oil and Gas Leasing Program that considers 

additional exploration, leasing, and development in the Atlantic Ocean 

and Gulf of Mexico. The development of wind energy resources is 

discussed in Section 3.11.2.1.2 (Wind) and summarized in Table 4.2-1 

(Past, Present, and Reasonably Foreseeable Actions). Section 3.11.2.1.2 

(Wind) will be updated to reflect the current state of wind energy 

development projects in the United States. In Section 4.2 (Projects and 

Other Activities Analyzed for Cumulative Impact) state and Federal wind 

projects are discussed, but the specific extent of proposed 

developments are not fully detailed. The Draft EIS/OEIS analysis focused 

on the potential impacts of windfarms in general and whether those 

impacts would overlap the Proposed Action impacts on the same 

species. As with oil and gas leasing activities, it was not previously 

possible to describe with enduring accuracy the location of all proposed 

operations due to the uncertain and changing nature of the details for 

individual windfarm projects and the lack of consistency in the 

information offered between states. Details regarding specific windfarm 

developments, as available and pertinent to the analysis, have been 

included in the Final EIS/OEIS.
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Appendix H Public Comment Responses

Table H.3-1. Comment Response Matrix (continued)

Reference 

Number Commenters Comment Response

206 Organization:

O05-01

However, Save The Bay submits that the Draft 

Environmental Impact Statement (EIS/OEIS) 

does not adequately inform the public of the 

direct, secondary or cumulative environmental 

impacts from the training activities.

The Navy’s analysis of direct and indirect effects is described in Chapter 

3.0.3 (Overall Approach to Analysis). Generally for each resource 

analyzed in Chapter 3 (Affected Environment and Environmental 

Consequences), the direct impacts from individual stressors are 

analyzed first, followed by, where applicable, the secondary stressors, 

and then concludes with a summary of the potential impacts of 

combined stressors (all direct and indirect). The analysis of cumulative 

impacts is provided in Chapter 4 (Cumulative Impacts). Further, the U.S. 

EPA has reviewed the Draft EIS/OEIS and rated it as LO - Lack of 

Objections - which means, it has not identified any environmental 

impacts requiring substantive changes to the proposal.

207 Organization:

O05-08

We ask that you amend the EIS/OEIS to address 

all plastic debris as potential microplastics, and 

examine likely direct, indirect and cumulative 

impacts accordingly.

The small number of blank fire casings and marine markers expended in 

Narragansett Bay have very little if any plastic components. Plastics are 

discussed in Section 3.2.2.2.6 (Marine Debris and Water Quality) and 

impacts of the Proposed Action associated with the potential to 

contribute other materials to the ocean environment is analyzed in 

Section 3.2.3.4 (Other Materials). The cumulative impacts analysis 

provided in Section 4.4.2 (Sediments and Water Quality) states that:

Other military expended materials, such as marine markers and flares, 

chaff, unrecovered towed and stationary targets, sonobuoys, fiber-optic 

cables, and miscellaneous plastic and rubber components of other 

expended objects are expected to sink to the seafloor and become 

buried in sediments. Depending on the environmental conditions, 

including the availability of oxygen in sediments and water temperate at 

the seafloor and the type of material (e.g., metal or plastic), expended 

material may degrade relatively quickly or persist in the environment 

indefinitely. Plastic and other persistent materials could incrementally 

contribute to marine “garbage patches” or other areas with 

accumulated debris but still have only minimal impact compared to 

other sources of debris.
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Appendix H Public Comment Responses

Table H.3-1. Comment Response Matrix (continued)

Reference 

Number Commenters Comment Response

Improving communication with public

208 Local / Regional:

L04-02, L04-03

State:

S25-04

Three comments expressed concern over the 

potential impact the proposed activities may 

have on commercial and recreational access to 

ocean space and air space within the study area. 

The Navy understands the importance of communication in order to 

protect public health and safety, and therefore includes communication 

as part of Standard Operating Procedures (Section 3.12, Public Health 

and Safety). These procedures include ensuring that training areas are 

clear before commencing hazardous activities, conducting all activities 

in accordance with established safety instructions, conducting 

underwater detonations only at established and approved locations, 

posting Navy lookouts at all times during an exercise to ensure nonparticipants do not enter the area, and, where appropriate, 

coordinating with the U.S. Coast Guard to issue Notices to Mariners and 

the Federal Aviation Administration (FAA) to issue Notice to Airmen 

notifying the public about durations and locations of hazardous 

activities.

Use of Live Munitions

209 Organization:

O01-10b

I get that practice is important in any field, and I 

certainly don't want the military going and doing its 

practice off the coast of some third world country, 

but question the use of live ammunition. That stuff 

is super expensive. The waste in unacceptable.

Thank you for your participation in the National Environmental Policy 

Act process. Your comment is part of the official project record.

210 Organization:

O02-07a

Lastly, we are concerned about the use of live 

munitions or chemical compounds that may 

either persist in the environment offshore or be 

a hazard to fishing vessels using bottom-tending 

gear. To the extent possible, live munitions 

should be used further offshore outside the 

range where most fishing operations are being 

conducted, and efforts should be made to 

minimize the release of harmful chemical 

compounds.

As discussed in Chapter 3.6 (Fishes), effects on sediment or water 

quality would not result in persistent or large scale effects on the 

growth, survival, distribution, or population-level impacts of fishes. As a 

matter of practice, the Navy typically does not conduct certain activities 

in coastal areas due to specific mission requirements (see Section 

2.3.3.16, Coastal Zone). The Navy will avoid or reduce impacts from 

training and testing throughout the Study Area to the maximum extent 

practicable through procedural mitigation (see Section 5.3, Procedural 

Mitigation to be Implemented) and mitigation areas (see Section 5.4, 

Mitigation Areas to be Implemented). Implementing additional 

mitigation would be impractical due to implications for safety, 

sustainability, and the Navy’s ability to continue meeting its Title 10 

requirements to successfully accomplish military readiness objectives.
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Appendix H Public Comment Responses

Table H.3-1. Comment Response Matrix (continued)

Reference 

Number Commenters Comment Response

211 Individual:

AUBMA-02a, 

COEPH-07, 

GAGBR-01c, 

HOPCH-03, 

NAPSA-01, 

SNOBA-02, 

VENPA-02, 

xxxJO-01

Organization:

O01-11a

Commercial:

C01-07

Ten comments expressed concern over the use 

of live munitions.

The Navy is concerned for the safety and health of coastal communities, 

fisheries, and ecosystems. Our analysis of the best available science 

indicate that the proposed activities, including the use of live munitions, 

do not represent threat to nearby human communities (Section 3.11, 

Socioeconomics and Section 3.12, Public Health and Safety), or the 

ecosystems (Section 3.1, Air quality; Section 3.3, Vegetation; Section 

3.5, Habitats) where these testing and training events will take place. 

Naval forces must be ready for a variety of military operations-from 

large scale conflict to maritime security to humanitarian 

assistance/disaster relief-to address the dynamic, social, political, 

economic, and environmental issues that occur in today's rapidly 

evolving world. Military readiness training must be as realistic as 

possible to provide the experiences vital to success and survival during 

military operations because simulated training, even in technologically 

advanced simulators, cannot duplicate the complexity faced by Sailors 

and Marines in the real world.

Public Safety

212 Commercial:

C01-06

Organization:

O04-14

Two comments expressed concern with the 

retrieval of munitions and the potential for loss 

of human life resulting from unexploded 

munitions and the damage to fishing gear from 

entanglement with expended materials. 

The Navy is concerned for public safety (Section 3.12). Section 3.12.3.3 

(Physical Interactions) discusses the potential for commercial and 

recreational fishing activities to encounter military expended materials 

that could entangle fishing gear and pose a safety risk. The footprint of 

military expended materials in the Study Area is discussed in Habitats, 

Section 3.5.3.4.3 (Impacts from Military Expended Materials). Section 

3.2 (Sediments and Water Quality) discusses the low failure rate of 

munitions, which indicates that most munitions operate as intended. If 

unexploded ordnance are recovered by fishing vessels, Navy Explosive 

Ordnance Disposal teams would respond and safely dispose of any 

hazardous munitions.

Request for Additional Research

213 State:

S05-04

As we have requested previously, we 

recommend that the Navy conduct a study to 

validate the Acoustic Effects Model in-situ in 

Southeast U.S. littoral waters.

The acoustic propagation models have been validated and approved by 

the Oceanographic and Atmospheric Master Library. These models are 

the same used for Navy’s tactical decision aids.
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Appendix H Public Comment Responses

Table H.3-1. Comment Response Matrix (continued)

Reference 

Number Commenters Comment Response

214 State:

S05-39

We request that the Navy commission a report 

summarizing research that has been conducted 

on NARW distribution, findings to date and 

questions that remain.

As described in Chapter 5 (Mitigation) of the Final EIS/OEIS, the Navy 

evaluated the effectiveness and practicability of numerous potential 

mitigation measures. Through consultation and permitting with NMFS, 

the Navy evaluated a larger mitigation area to address North Atlantic 

right whale calving habitat concerns; however, an expanded mitigation 

area is not being recommended due to the unacceptable impacts it 

would have with regard to personnel safety, practicality of 

implementation, and impact on effectiveness of the military readiness 

activities that occur in that area, see section 5.4.3.2 (Mitigation Area 

Assessment). Section 5.4.3 (Mitigation Areas off the Mid-Atlantic and 

Southeastern United States) describes the mitigation measures.

215 Local / Regional:

L05-02a

As a municipality located on a barrier island, we 

must be a good steward of our fragile and 

pristine environment. Whether it is monitoring 

Nags Head’s water quality or protecting the 

turtles that nest on our beautiful beach, we take 

great pride in doing everything we can to ensure 

that future generations will also be able to 

experience the magnificence of the Outer Banks. 

As such, we must request that more research be 

conducted to fully understand the impacts of 

sonar and explosives on marine life and how 

those impacts can be mitigated.

The Navy has for years implemented a very broad and comprehensive 

range of measures to mitigate potential impacts on marine mammals 

from military readiness activities. As the Final EIS/OEIS documents in 

Chapter 5 (Mitigation), the Navy is increasing its mitigation measures to 

enhance protections of marine mammals to the maximum extent 

practicable. Aside from direct mitigation, as noted by the comment, the 

Navy engages in an extensive spectrum of other activities that greatly 

benefit marine species in a more general manner that is not necessarily 

tied to just military readiness activities. As noted in Section 3.0.1.1 of 

the EIS/OEIS, the Navy provides extensive investment for research 

programs in basic and applied research. In fact, the U.S. Navy is one of 

the largest sources of funding for marine mammal research in the 

world, which has greatly enhanced the scientific community’s 

understanding of marine species generally. The Navy’s support and 

conduct of cutting-edge marine mammal research includes: marine 

mammal detection, including the development and testing of new 

autonomous hardware platforms and signal processing algorithms for 

detection, classification, and localization of marine mammals; 

improvements in density information and development of abundance 

models of marine mammals; and advancements in the understanding 

and characterization of the behavioral, physiological (hearing and stress 

response), and potentially population-level consequences of sound 
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Appendix H Public Comment Responses

Table H.3-1. Comment Response Matrix (continued)

Reference 

Number Commenters Comment Response

215

(cont.)

exposure on marine life. In addition, the Navy is a critical sponsor of the 

North Atlantic Right Whale EWS and the winter aerial surveys, which 

has contributed to a marked reduction in vessel strikes of the North 

Atlantic right whale in the Southeast critical habitat, particularly by 

commercial vessels which represents the greatest threat to the North 

Atlantic right whale.
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Appendix H Public Comment Responses

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Appendix I Geographic Information System Data Sources

APPENDIX I

GEOGRAPHIC INFORMATION SYSTEM DATA SOURCES
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Appendix I Geographic Information System Data Sources

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i

Table of Contents

Final 

Environmental Impact Statement/Overseas Environmental Impact Statement 

Atlantic Fleet Training and Testing

TABLE OF CONTENTS

APPENDIX I GEOGRAPHIC INFORMATION SYSTEM DATA SOURCES______________ I-1

List of Figures

This section does not contain figures.

List of Tables

Table I-1: Data Sources by Feature/Layer...................................................................................................I-1
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ii

Table of Contents

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Appendix I Geographic Information System Data Sources

APPENDIX I GEOGRAPHIC INFORMATION SYSTEM DATA 

SOURCES

Table I-1: Data Sources by Feature/Layer

Feature/Layer Applicable 

Figures Data Source References

AFTT Study Area Multiple 

Figures (Global)

Department of the Navy (2016)

Navy POC: Jonathan Crain

Jonathan.crain@navy.mil

Military 

Training/Range/Operation 

Areas

Multiple 

Figures (Global)

Training Areas - Commander, U.S. Fleet Forces - U.S. Navy, 

Common Operating Picture (COP) Atlantic Gomex. Updated 

5/2018. SDSFIE Version 2.6.

Navy POC: David Urbik

David.urbik@navy.mil

Special Use Airspace Multiple 

Figures (Global) NGA Digital Aeronautical Flight Information File (DAFIF) (2010).

Large Marine Ecosystems Multiple 

Figures (Global)

Large Marine Ecosystem Program, NOAA Fisheries, 

Narragansett Laboratory, Narragansett, RI. Updated 

06/26/2014. SDSFIE Version 2.6. www.lme.noaa.gov

Kenneth.Sherman@NOAA.gov

Bays or Inshore Waters, 

and Civilian Ports

Multiple 

Figures (Global)

Department of Navy (DON) – U.S. Navy. Updated 07/02/2018. 

SDSFIE Version 2.6.

Navy POC: David Urbik

David.urbik.ctr@navy.mil

Navy Contractor Shipyard Multiple 

Figures (Global)

National Geospatial Intelligence Agency (NGA). Updated 

05/25/2016. SDSIFIE Version 2.6.

Navy Port or Pierside 

Location

Multiple 

Figures (Global)

National Geospatial Intelligence Agency (NGA). Updated 

05/25/2016. SDSIFIE Version 2.6.

Ocean Base Map Multiple 

Figures (Global)

Amante, C. and B.W. Eakins, 2009. ETOPO1 1 Arc-Minute 

Global Relief Model: Procedures, Data Sources and Analysis. 

NOAA Technical Memorandum NESDIS NGDC-24. National 

Geophysical Data Center, NOAA. doi:10.7289/V5C8276M 

[2017]

https://www.ngdc.noaa.gov/docucomp/page?xml=NOAA/NES

DIS/NGDC/MGG/DEM/iso/xml/316.xml&view=getDataView&h

eader=none

Naval Air Station 1.2-1

Naval Air Stations – Commander, U.S. Fleet Forces – U.S. Navy, 

Common Operating Picture (COP) Atlantic Gomex. Updated 

10/27/2017. SDSFIE Version 2.6

3NM/9NM State/Federal 

Boundary 2.3-1

FWC-FWRI (Florida Fish and Wildlife Conservation CommissionFish and Wildlife Research Institute), updated July 21, 2017

Bryde’s Whale 2.3-2

Rosel, P. E., P. Corkeron, L. Engleby, D. Epperson, K. D. Mullin, 

M. S. Soldevilla, B. L. Taylor. 2016. Status Review of Bryde's 

Whales (Balaenoptera edeni) in the Gulf of Mexico under the 

Endangered Species Act. NOAA Technical Memorandum NMFSSEFSC-692

Bottom Substrate 2.3-2, 3.5-1, 

3.5-2, 3.5-3, 

National Ocean Service, National Centers for Coastal Ocean 

Science, Center for Coastal Monitoring and Assessment, the 
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Training and Testing Final EIS/OEIS September 2018

I-2

Appendix I Geographic Information System Data Sources

Table I-1: Data Sources by Feature/Layer (continued)

Feature/Layer Applicable 

Figures Data Source References

Bottom Substrate

(continued) 3.5-4, 3.5-5

University of Hawaii, BAE Systems Spectral Solutions and 

Analytical Laboratories of Hawaii, LLC, 2007

Planning Awareness 

Mitigation Areas 2.3-2

Department of the Navy (2018)

Navy POC: Brittany Bartlett

Brittany.bartlett@navy.mil

Florida Manatee Critical 

Habitat 2.3-2, 3.7-3 NOAA Fisheries Greater Atlantic Regional Fisheries Office, 2016

Open Ocean Areas 3.0-1

NOAA-Fisheries, US LME Program, Narragansett Laboratory 

Kenneth.Sherman@NOAA.gov 

www.lme.noaa.gov

Bathymetry 3.0-3, 3.0-4, 

3.0-5, 3.0-6

Amante, C. and B.W. Eakins, 2009. ETOPO1 1 Arc-Minute Global 

Relief Model: Procedures, Data Sources and Analysis. NOAA 

Technical Memorandum NESDIS NGDC-24. National Geophysical 

Data Center, NOAA. doi:10.7289/V5C8276M [2017] 

https://www.ngdc.noaa.gov/docucomp/page?xml=NOAA/NESDIS

/NGDC/MGG/DEM/iso/xml/316.xml&view=getDataView&header

=none

Major Ocean Currents 3.0-7

Department of the Navy (2015)

Navy POC: David Urbik

David.urbik.ctr@navy.mil

Average Sea Surface 

Temperature 3.0-8

NOAA Optimum Interpolation (OI) Sea Surface Temperature (SST) 

V2 (2016).

NCEP/NWS/NOAA. Climate Modeling Branch 

W/NP24http://www.esrl.noaa.gov/psd/data/gridded/data.noaa.

oisst.v2.html#references

Ozone, PM2.5, and PM10 

Nonattainment/ 

Maintenance Areas

3.1-1, 3.1-2, 

3.1-3, 3.1-4

U.S. Environmental Protection Agency:

Ozone 2014; PM2.5 – 2015; PM 10 Nonattainment/Maintenance 

Areas – 2013

Sediment Quality 3.2-2, 3.2-3, 

3.2-4

EPA National Aquatic Resource Surveys

https://www.epa.gov/national-aquatic-resource-surveys/datanational-aquatic-resource-surveys

2010

Water Quality 3.2-6, 3.2-7, 

3.2-8

EPA National Aquatic Resource Surveys

https://www.epa.gov/national-aquatic-resource-surveys/datanational-aquatic-resource-surveys

2010

Johnson’s Seagrass 

Critical Habitat 3.3-1

NOAA, 2000. USFWS Critical Habitat Portal: 

https://ecos.fws.gov/ecp/report/table/critical-habitat.html 

Seagrass Areas 3.3-2, 3.3-3,

3.3-4

Department of Navy (DON). Updated 07/02/2018.

Navy POC: Scott Chappell

william.s.chappell@navy.mil

Reef Habitat 3.4-1

National Oceanic and Atmospheric Administration 2009: US Dept 

of the Navy 2008b, 2011; US Fish and Wildlife Service 2005, 2008, 

2010

Artificial Reefs, 

Shipwrecks, Oil and Gas 

Platforms, Towers

3.5-5, 3.5-6,

3.5-7, 3.5-8

Complete list of sources located in the Navy Technical Report 

entitled "Building and Maintaining a Comprehensive Database 

and Prioritization Scheme for Overlapping Habitat Data - Focus
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I-3

Appendix I Geographic Information System Data Sources

Table I-1: Data Sources by Feature/Layer (continued)

Feature/Layer Applicable 

Figures Data Source References

(Air Force and Navy), and 

Wind Turbines

on Abiotic Substrates in the Atlantic Fleet Training and Testing 

Study Area" (12 December 2017)

meta_id Citation:

Berg and Berg (1989): Berg, D., & Berg, D. (1989). Tropical 

shipwrecks. East Rockaway, New York: Aqua Explorers Inc.

BOEM (2013) Bureau of Ocean Energy Management. (2013). 

Platform Locations - Gulf of Mexico. Available from 

http://www.boem.gov/Oil-and-Gas-Energy-Program/Mappingand-Data/Index.aspx. Accessed in June 2015

Cerame Vivas (1988) "Cerame Vivas, M. J. (1988). Coastal atlas of 

Puerto Rico. Boquerón, Puerto Rico: M.J. Cerame Vivas, Inc.

Chesapeake Bay Office - National Oceanographic and 

Atmospheric Administration. (2011). Chesapeake Bay Benthic 

Habitat Integration."

DFW (2015) "Delaware Division of Fish and Wildlife. (2015). 

Delaware reef guide (2013-2014). Available from 

http://www.dnrec.delaware.gov/fw/Fisheries/Documents/2013a

nd14DEReefGuide.pdf. Accessed in July 2015.

Federal Geographic Data Committee."

FFWCC & FWRI (2014) Florida Fish and Wildlife Conservation 

Commission and Fish and Wildlife Research Institute. (2014). 

Artificial Reefs Florida Point. Tallahassee, FL. Page

GDNR (2015) Georgia Department of Natural Resources. (2015). 

Artificial Reef (Offshore). Available from 

http://coastalgadnr.org/ArtificialReef. Accessed in July 2015

Handler (2001) Handler, M. (2001). Diving and snorkeling: British 

Virgin Islands (2nd ed.). Melbourne, Australia: Lonely Planet 

Publications.

Longley-Wood (2015) Longley-Wood, K. (2015). Block Island wind 

farm turbine locations - GIS metadata prepared for the Northeast 

Ocean Data Portal (www.northeastoceandata.org). 3 pages.

Louisiana DWF (2015) Louisiana Department of Wildlife and 

Fisheries. (2015). Artificial Reef Program. Available from 

http://www.wlf.louisiana.gov/fishing/artificial-reef-program. 

Accessed in July 2015.

MDMF (2015) Massachusetts Division of Marine Fisheries. 

(2015). Artificial Reefs [Website]. Available from
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Appendix I Geographic Information System Data Sources

Table I-1: Data Sources by Feature/Layer (continued)

Feature/Layer Applicable 

Figures Data Source References

Artificial Reefs, 

Shipwrecks, Oil and Gas 

Platforms, Towers (Air 

Force and Navy), and 

Wind Turbines

(continued)

http://www.mass.gov/eea/agencies/dfg/dmf/programs-andprojects/artificial-reefs.html. Accessed in July 2015.

MS DMR (2015) Mississippi Department of Marine Resources. 

(2015). Artificial Reefs [Website]. Available from 

http://www.dmr.state.ms.us/index.php/marinefisheries/artificial-reef. Accessed in July 2015.

NC DMF (2015) North Carolina Division of Marine Fisheries. 

(2015). Artificial Reef Guide. Available from 

http://portal.ncdenr.org/web/mf/artificial-reefs-program. 

Accessed in July 2015.

NOAA (2015) National Oceanic and Atmospheric Administration. 

(2015). Automated Wreck and Obstruction Avoidance database. 

[Web Page] Available from 

http://www.nauticalcharts.noaa.gov/hsd/wrecks_and_obstructio

ns.html. Accessed in August 2015.

NRHP National Register of Historic Places

NRHP Eligible National Register of Historic Places-Eligible

NRHP Listed National Register of Historic Places-Listed

NRHP Listed- FORT National Register of Historic Places-Fort

NRHP Listed, ad.res. National Register of Historic Places-Listed 

address restricted

OCRF (2013) O.C. Reef Foundation. (2013). Ocean -Artificial Reef 

Location (Maryland) [Website]. Available from 

www.ocreeffoundation.com. Accessed in July 2015.

Outdoor AL (2015) Outdoor Alabama - Alabama Department of 

Conservation and Natural Resources. (2015). Artificial Reefs. 

Available from http://www.outdooralabama.com/artificial-reefs. 

Accessed in July 2015.

RI ARP (2015) Rhode Island Artificial Reef Program. (2015). 

Artificial reef off Newport and Block Island [Website]. Available 

from http://www.risaa.org/reefs.html. Accessed in July 2015.

SCDNR (2015) South Carolina Department of Natural Resources. 

(2015). Marine - Artificial Reefs. Available from 

https://www.dnr.sc.gov/reefguide/artreefgraphic. Accessed in 

July 2015.
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Appendix I Geographic Information System Data Sources

Table I-1: Data Sources by Feature/Layer (continued)

Feature/Layer Applicable 

Figures Data Source References

Artificial Reefs, 

Shipwrecks, Oil and Gas 

Platforms, Towers (Air 

Force and Navy), and 

Wind Turbines

(continued)

Simonsen (2000) Simonsen, S. (2000). Diving & snorkeling: Puerto 

Rico. Melbourne, Australia: Lonely Planet Publications.

TPWD (2015) Texas Parks and Wildlife Department. (2015). Texas 

Artificial Reef [Interactive Mapping Application]. Available from 

http://tpwd.texas.gov/gis/ris/artificialreefs/. Accessed in July 

2015.

U.S. Navy (2002) U.S. Department of the Navy. (2002). SINKEX 

shipwrecks around Puerto Rico. Data reported in the 2002 

Marine Resource Assessment for Puerto Rico/St. Croix operating 

area

Veridian Corp (2001) Veridian Corporation. (2001). The global 

maritime wreck database. Falls Church, Virginia: General 

Dynamics Corporation.

VMRC (2005,2009) Virginia Marine Resources Commission. 

(2005). Artificial Reef Program: Newport News, Virginia: Virginia 

Marine Resources Commission; Virginia Marine Resources 

Commission. (2009). Shipwrecks and Artificial Reefs of Maryland 

and Virginia.

Department of the Navy (ND) War Grave data collected by NAVY 

contractor. NAVY POC Scott Chappell 

William.S.Chappel@navy.mil

WC Inc #53F (1998) Waterproof Charts Inc. (1998). Waterproof 

Chart #53F: Eastern Puerto Rico to St. Thomas–fishing. Punta 

Gorda, Florida: Waterproof Charts, Inc.

Atlantic Salmon Critical 

Habitat 3.6-1

National Oceanic and Atmospheric Administration National 

Marine Fisheries Service, 2009. 

http://www.nmfs.noaa.gov/pr/species/criticalhabitat.htm

Atlantic Sturgeon 

Proposed Critical Habitat 3.6-2, 3.6-3

NOAA NMFS

http://sero.nmfs.noaa.gov/maps_gis_data/protected_resources/

critical_habitat/geodata/proposed_atlantic_sturgeon_critical_ha

bitat_ln.htm

2016

Smalltooth Sawfish 

Critical Habitat 3.6-4 NMFS, Office of Protected Resources, October 2009

Gulf Sturgeon Critical 

Habitat 3.6-5 National Coastal Data Development Center, 2003

North Atlantic Right 

Whale Critical Habitat

3.7-3, 5.4-4, 

5.4-5

NOAA Fisheries Greater Atlantic Regional Fisheries Office, 2016 

http://www.nmfs.noaa.gov/pr/species/criticalhabitat.htm. 

Green Turtle Critical 

Habitat 3.8-4

National Oceanic and Atmospheric Administration National 

Marine Fisheries Service, 1998

Hawksbill Turtle Critical 

Habitat 3.8-5

National Oceanic and Atmospheric Administration National 

Marine Fisheries Service, 1998
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Appendix I Geographic Information System Data Sources

Table I-1: Data Sources by Feature/Layer (continued)

Feature/Layer Applicable 

Figures Data Source References

Loggerhead Turtle Critical 

Habitat

3.8-6, 3.8-7, 

3.8-8

NOAA Fisheries

http://www.nmfs.noaa.gov/pr/species/turtles/criticalhabitat_log

gerhead.htm

2014

Leatherback Turtle 

Critical Habitat 3.8-9

National Oceanic and Atmospheric Administration National 

Marine Fisheries Service, 1979

American Crocodile 3.8-10 U.S. Fish and Wildlife Service, 2003 

https://www.fws.gov/verobeach/GIS.html.

Piping Plover Critical 

Habitat

3.9-1, 3.9-2,

3.9-3

U.S. Fish and Wildlife Service, 2009 

https://www.fws.gov/verobeach/GIS.html.

NRHP Eligible or Listed 

Resources/Sovereign 

Immunity, Shipwrecks

3.10-4, 3.10-5, 

3.10-6 

NOAA Automated Wreck and Obstruction Information System 

[AWOIS] (2002). https://nauticalcharts.noaa.gov/data/wrecksand-obstructions.html.

Veridian Corporation (2001)

National Registry of Historic Places (2016). 

https://www.nps.gov/nr/research/.

Bureau of Ocean Energy 

Management Planning 

Areas

3.11-1

Bureau of Ocean Energy Management 

http://www.boem.gov/Maps-and-GIS-Data/

2016

Maritime Boundaries 3.11-2, 3.11-3

FWC-FWRI (Florida Fish and Wildlife Conservation CommissionFish and Wildlife Research Institute), 2017. 

http://myfwc.com/research/gis/.

Oil and Gas Pipelines 3.11-3

Department of the Navy (2015)

Navy POC: Jonathan Crain

Jonathan.crain@navy.mil

Oil and Gas Pipelines 3.11-3

United States Department of the Interior, Minerals Management 

Service. Updated 02/10/2014. SDSFIE Version 2.6.

Commercially Used 

Waterways 3.11-4

Research and Innovative Technology Administration’s Bureau of 

Transportation Statistics (RITA/BTS) National Transportation 

Atlas Database (2007). National Waterway Network

Ports 3.11-4 NGA (2016). World Port Index

Danger Zones and 

Restricted Areas

3.11-15, 3.11-

16, 3.11-17

Title 33-Navigation and Navigable Waters, Chapter II-Corps of 

Engineers, Department of the Army, Department of Defense, Part 

334-Danger Zone and Restricted Area Regulations 2005

Seafloor Resource 

Mitigation Areas 5.4-3, 5.6-1

US NAVY (2013). Seafloor Resource Mitigation Areas was created 

to implement AFTT Phase II mitigation measures in the Protective 

Measures Assessment Protocol. The data represents a refined 

subset of Phase II EIS/OEIS marine habitat data. The marine 

habitat data used is located in the AFTT II GIS deliverable (feature 

classes: aquatic_habitat_area, ecology_reef_habitat_point). 

Biologically Important 

Areas for Cetaceans 5.4-4, 5.4-5

National Oceanic and Atmospheric Administration 2015 

https://cetsound.noaa.gov/important.

National Marine 

Sanctuaries

2.3-2, 6.1-5, 

6.1-6

NOAA National Marine Sanctuaries, 2004 

https://sanctuaries.noaa.gov/library/imast_gis.html

Marine Protected Areas 

6.1-1, 6.1-2, 

6.1-3, 6.1-4

NOAA National Marine Protected Areas Center, 2015

United States Fish and Wildlife Service, 

2017https://marinecadastre.gov/data/.
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Appendix I Geographic Information System Data Sources

Table I-1: Data Sources by Feature/Layer (continued)

Feature/Layer Applicable 

Figures Data Source References

National Park Boundaries 6.1-1, 6.1-2, 

6.1-3, 6.1-4

National Park Service, 

2017https://catalog.data.gov/dataset/national-parkboundariesf0a4c#sec-dates.

Notes: AUTEC = Atlantic Undersea Test and Evaluation Center, EPA = Environmental Protections Agency, MRA = Marine 

Resources Assessment, NGA = National Geospatial-Intelligence Agency, NMFS = National Marine Fisheries Service, NOAA 

= National Oceanic and Atmospheric Administration, U.S. = United States, OPAREA = Operating Area, VACAPES = Virginia 

Capes, HAPC = Habitat Area of Particular Concern, AWOIS = Automated Wreck and Obstruction Information System, 

NRHP = National Register of Historic Places, OCS = Office of Coast Survey
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APPENDIX J

Agency Correspondence
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Table of Contents

Final

Environmental Impact Statement/Overseas Environmental Impact Statement 

Atlantic Fleet Training and Testing Activities

TABLE OF CONTENTS

APPENDIX J AGENCY CORRESPONDENCE___________________________________ J-1

J.1 Cooperating Agency Status ..............................................................................J-2

J.2 Coastal Zone Management Act.........................................................................J-7

J.2.1 Alabama ..................................................................................................................J-8

J.2.2 Connecticut...........................................................................................................J-10

J.2.3 Delaware...............................................................................................................J-11

J.2.4 Florida ...................................................................................................................J-21

J.2.5 Georgia..................................................................................................................J-25

J.2.6 Louisiana ...............................................................................................................J-39

J.2.7 Maine ....................................................................................................................J-41

J.2.8 Maryland...............................................................................................................J-46

J.2.8 Massachusetts ......................................................................................................J-47

J.2.9 Mississippi.............................................................................................................J-48

J.2.10 New Hampshire.....................................................................................................J-50

J.2.11 New Jersey ............................................................................................................J-52

J.2.12 New York...............................................................................................................J-53

J.2.13 North Carolina.......................................................................................................J-59

J.2.14 Rhode Island..........................................................................................................J-62

J.2.15 South Carolina.......................................................................................................J-64

J.2.16 Texas.....................................................................................................................J-68

J.2.17 Virginia ..................................................................................................................J-70

J.3 Endangered Species Act .................................................................................J-88

J.4 Magnuson-Stevens Fishery Conservation and Management Act .....................J-96

J.5 Marine Mammal Protection Act................................................................... J-107

J.6 National Historic Preservation Act................................................................ J-111

J.6.1 Alabama ..............................................................................................................J-112

J.6.2 Conneticut...........................................................................................................J-115

J.6.3 Delaware.............................................................................................................J-118

J.6.4 Florida .................................................................................................................J-120

J.6.5 Georgia................................................................................................................J-122

J.6.6 Louisiana .............................................................................................................J-125
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J.6.7 Maine ..................................................................................................................J-129

J.6.8 Maryland.............................................................................................................J-131

J.6.9 Massachusettes ..................................................................................................J-133

J.6.10 Mississippi...........................................................................................................J-136

J.6.11 New Hampshire...................................................................................................J-138

J.6.12 New Jersey ..........................................................................................................J-141

J.6.13 New York.............................................................................................................J-143

J.6.14 North Carolina.....................................................................................................J-146

J.6.15 Rhode Island........................................................................................................J-148

J.6.16 South Carolina.....................................................................................................J-150

J.6.17 Texas...................................................................................................................J-154

J.6.18 Virginia ................................................................................................................J-163

J.7 National Marine Sanctuaries Act.................................................................. J-166

List of Figures

This section does not contain figures.

List of Tables

This section does not contain tables.
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Appendix J Agency Correspondence

APPENDIX J AGENCY CORRESPONDENCE

Appendix J contains the correspondence between the Navy and federal or state agencies with respect to 

cooperating agency status (Section J.1), Coastal Zone Management Act (Section J.2), Endangered Species 

Act (Section J.3), Magnuson-Stevens Fishery Conservation and Management Act (Section J.4), Marine

Mammal Protection Act (Section J.5), National Historic Preservation Act (Section J.6), and the National 

Marine Sanctuaries Act (Section J.7).
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J.1 COOPERATING AGENCY STATUS
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J.2 COASTAL ZONE MANAGEMENT ACT

Under the Coastal Zone Management Act, states/territories have 60 days to respond to federal 

consistency reviews or their concurrence is assumed. Consistency determinations were submitted to 18 

states adjacent to the Study Area. Correspondence indicating concurrence were received from Alabama, 

Delaware, Florida, Louisiana, Maine, Mississippi, New Hampshire, New York, North Carolina, Rhode 

Island, South Carolina, Texas, and Virginia. Concurrence was assumed for the remaining states. 
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J.2.1 ALABAMA
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J.2.2 CONNECTICUT
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J.2.3 DELAWARE
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J.2.4 FLORIDA
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J.2.5 GEORGIA
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J.2.6 LOUISIANA
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J.2.7 MAINE 
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J.2.8 MARYLAND
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J.2.8 MASSACHUSETTS
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J.2.9 MISSISSIPPI
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J.2.10 NEW HAMPSHIRE
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J.2.11 NEW JERSEY 
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J.2.12 NEW YORK
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J.2.13 NORTH CAROLINA
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J.2.14 RHODE ISLAND
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J.2.15 SOUTH CAROLINA
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J.2.16 TEXAS
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J.2.17 VIRGINIA
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J.3 ENDANGERED SPECIES ACT
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J.4 MAGNUSON-STEVENS FISHERY CONSERVATION AND MANAGEMENT ACT
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J.5 MARINE MAMMAL PROTECTION ACT
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J.6 NATIONAL HISTORIC PRESERVATION ACT

Under Section 106 of the National Historic Preservation Act, states/territories have 30 days to respond 

to the federal agency determination or their concurrence is assumed. The Navy submitted 

determinations to 18 states adjacent to the Study Area. Correspondence indicating concurrence were 

received from Alabama, Connecticut, Georgia, Louisiana, Massachusetts, New Hampshire, New York, 

South Carolina, Texas, and Virginia. Concurrence was assumed for the remaining states.
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J.6.1 ALABAMA
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J.6.2 CONNETICUT
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J.6.3 DELAWARE
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J.6.4 FLORIDA
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J.6.5 GEORGIA 
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J.6.6 LOUISIANA 
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J.6.7 MAINE
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J.6.8 MARYLAND
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J.6.9 MASSACHUSETTES
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J.6.10 MISSISSIPPI
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J.6.11 NEW HAMPSHIRE
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J.6.12 NEW JERSEY
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J.6.13 NEW YORK
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J.6.14 NORTH CAROLINA
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J.6.15 RHODE ISLAND
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J.6.16 SOUTH CAROLINA
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J.6.17 TEXAS
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J.6.18 VIRGINIA
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J.7 NATIONAL MARINE SANCTUARIES ACT

As part of the EIS/OEIS process, and in accordance with Section 304 (d) of the National Marine 

Sanctuaries Act, the Navy submitted a Sanctuary Resource Statement in December of 2017 to initiate 

consultation for the training and testing activities occurring within the Gulf of Mexico and Atlantic Ocean 

as described in the AFTT Draft EIS/OEIS. The Sanctuary Resource Statement further describes the AFTT 

activities and study area, and provides the specific information required by the Office of National Marine 

Sanctuaries for consultation. Since the Draft EIS/OEIS was released, adjustments were made to add 

additional details to the analysis contained within Section 6.1.2.6 (National Marine Sanctuaries) based 

on feedback received from the Office of National Marine Sanctuaries.
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