United States Department of the Navy September 2018

Volume III

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 III

United States Department of the Navy

September 2018
Atlantic Fleet 

Training and Testing Final EIS/OEIS September 2018

i

Table of Contents

Final

Environmental Impact Statement/Overseas Environmental Impact Statement 

Atlantic Fleet Training and Testing 

TABLE OF CONTENTS

3.8 Reptiles............................................................................................................ 3.8-1

3.8.1 Introduction ........................................................................................................3.8-3

3.8.2 Affected Environment.........................................................................................3.8-4

3.8.2.1 General Background ...........................................................................3.8-4

3.8.2.2 Endangered Species Act-Listed Species............................................3.8-15

3.8.2.3 Species Not Listed under the Endangered Species Act ....................3.8-44

3.8.3 Environmental Consequences ..........................................................................3.8-46

3.8.3.1 Acoustic Stressors.............................................................................3.8-46

3.8.3.2 Explosive Stressors............................................................................3.8-86

3.8.3.3 Energy Stressors..............................................................................3.8-120

3.8.3.4 Physical Disturbance and Strike Stressors......................................3.8-129

3.8.3.5 Entanglement Stressors..................................................................3.8-155

3.8.3.6 Ingestion Stressors..........................................................................3.8-172

3.8.3.7 Secondary Stressors........................................................................3.8-191

3.8.4 Summary of Potential Impacts on Reptiles.....................................................3.8-196

3.8.4.1 Combined Impacts of All Stressors under Alternative 1.................3.8-196

3.8.4.2 Combined Impacts of All Stressors under Alternative 2.................3.8-198

3.8.4.3 Combined Impacts of All Stressors under the No Action 

Alternative......................................................................................3.8-198

3.8.5 Endangered Species Act Determinations........................................................3.8-198

List of Figures

Figure 3.8-1: Dive Depth and Duration Summaries for Sea Turtle Species............................................3.8-6

Figure 3.8-2: Generalized Dive Profiles and Activities Described for Sea Turtles...................................3.8-7

Figure 3.8-3: Composite Underwater Audiogram for Sea Turtles..........................................................3.8-8

Figure 3.8-4: Critical Habitat Designated for the Green Sea Turtles in the Study Area........................3.8-20

Figure 3.8-5: Critical Habitat Designation for the Hawksbill Sea Turtle within the Study Area............3.8-24

Figure 3.8-6: Critical Habitat Designation for the Loggerhead Turtle within the Study Area: 

Mid-Atlantic .....................................................................................................................3.8-30

Figure 3.8-7: Critical Habitat Designation for the Loggerhead Turtle within the Study Area: 

Southeast.........................................................................................................................3.8-31
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Figure 3.8-8: Critical Habitat Designation for the Loggerhead Turtle within the Study Area: 

Gulf of Mexico..................................................................................................................3.8-32

Figure 3.8-9: Critical Habitat Designation for the Leatherback Sea Turtle within the Study 

Area..................................................................................................................................3.8-37

Figure 3.8-10: Critical Habitat Designation for the American Crocodile within the Study Area ..........3.8-41

Figure 3.8-11: Auditory Weighting Function for Sea Turtles................................................................3.8-52

Figure 3.8-12: TTS and PTS Exposure Functions for Sonar and Other Transducers..............................3.8-53

Figure 3.8-13: Kemp’s Ridley Turtle Impacts Estimated per Year from Sonar and Other 

Transducers Used During Training and Testing under Alternative 1...............................3.8-58

Figure 3.8-14: Leatherback Sea Turtle Impacts Estimated per Year from Sonar and Other 

Transducers Used During Training and Testing under Alternative 1...............................3.8-58

Figure 3.8-15: Loggerhead Sea Turtle Impacts Estimated per Year from Sonar and Other 

Transducers Used During Training and Testing under Alternative 1...............................3.8-59

Figure 3.8-16: Kemp’s Ridley Turtle Impacts Estimated per Year from Sonar and Other 

Transducers Used During Training and Testing under Alternative 2...............................3.8-63

Figure 3.8-17: Leatherback Sea Turtle Impacts Estimated per Year from Sonar and Other 

Transducers Used During Training and Testing under Alternative 2...............................3.8-64

Figure 3.8-18: Loggerhead Sea Turtle Impacts Estimated per Year from Sonar and Other 

Transducers Used During Training and Testing under Alternative 2...............................3.8-65

Figure 3.8-19: TTS and PTS Exposure Functions for Impulsive Sounds.................................................3.8-68

Figure 3.8-20: Auditory Weighting Function for Sea Turtles................................................................3.8-94

Figure 3.8-21: TTS and PTS Exposure Functions for Impulsive Sounds.................................................3.8-95

Figure 3.8-22: Green Turtle Impacts Estimated per Year from the Maximum Number of 

Explosions During Training and Testing under Alternative 1 (Excluding Full Ship 

Shock Trials)...................................................................................................................3.8-102

Figure 3.8-23: Kemp’s Ridley Turtle Impacts Estimated per Year from the Maximum Number 

of Explosions During Training and Testing under Alternative 1 (Excluding Full 

Ship Shock Trials) ...........................................................................................................3.8-103

Figure 3.8-24: Leatherback Turtle Impacts Estimated per Year from the Maximum Number 

of Explosions During Training and Testing under Alternative 1 (Excluding Full 

Ship Shock Trials) ...........................................................................................................3.8-104

Figure 3.8-25: Loggerhead Turtle Impacts Estimated per Year from the Maximum Number 

of Explosions during Training and Testing under Alternative 1 (Excluding Full 

Ship Shock Trials) ...........................................................................................................3.8-105

Figure 3.8-26: Estimated Impacts on Sea Turtles from a Small Ship Shock Trial under 

Alternative 1 ..................................................................................................................3.8-108

Figure 3.8-27: Estimated Impacts on Sea Turtles from a Large Ship Shock Trial under 

Alternative 1 ..................................................................................................................3.8-109

Figure 3.8-28: Green Turtle Impacts Estimated per Year from the Maximum Number of 

Explosions During Training and Testing under Alternative 2 (Excluding Full Ship 

Shock Trials)...................................................................................................................3.8-112
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Figure 3.8-29: Kemp’s Ridley Turtle Impacts Estimated per Year from the Maximum Number 

of Explosions During Training and Testing under Alternative 2 (Excluding Full 

Ship Shock Trials) ...........................................................................................................3.8-113

Figure 3.8-30: Leatherback Sea Turtle Impacts Estimated per Year from the Maximum 

Number of Explosions During Training and Testing under Alternative 2 

(Excluding Full Ship Shock Trials)...................................................................................3.8-114

Figure 3.8-31: Loggerhead Sea Turtle Impacts Estimated per Year from the Maximum 

Number of Explosions During Training and Testing under Alternative 2 

(Excluding Full Ship Shock Trials)...................................................................................3.8-115

Figure 3.8-32: Estimated Impacts on Sea Turtles from a Small Ship Shock Trial................................3.8-118

List of Tables

Table 3.8-1: Current Regulatory Status and Presence of Endangered Species Act-Listed 

Reptiles in the Study Area................................................................................................3.8-16

Table 3.8-2: PTS and TTS Peak Pressure Thresholds for Sea Turtles Exposed to Impulsive 

Sounds..............................................................................................................................3.8-68

Table 3.8-3: Ranges to Permanent Threshold Shift and Temporary Threshold Shift for Sea 

Turtles Exposed to 100 Air Gun Firings............................................................................3.8-69

Table 3.8-4: Ranges to PTS and TTS Sea Turtles Exposed to Impact Pile Driving .................................3.8-72

Table 3.8-5: Criteria to Quantitatively Assess Non-Auditory Injury due to Underwater 

Explosions........................................................................................................................3.8-93

Table 3.8-6: TTS and PTS Peak Pressure Thresholds Derived for Sea Turtles Exposed to 

Impulsive Sounds.............................................................................................................3.8-95

Table 3.8-7: Ranges to Mortality for Sea Turtles Exposed to Explosives as a Function of 

Animal Mass1...................................................................................................................3.8-97

Table 3.8-8: Ranges to Non-Auditory Injury1(in meters) for Sea Turtles Exposed to 

Explosives as a Function of Animal Mass.........................................................................3.8-98

Table 3.8-9: Peak Pressure Based Ranges to PTS and TTS for Sea Turtles Exposed to 

Explosives.........................................................................................................................3.8-99

Table 3.8-10: SEL Based Ranges to PTS and TTS for Sea Turtles Exposed to Explosives.....................3.8-100

Table 3.8-11: Summary of ESA-Effects Determinations for Reptiles (Alternative 1)..........................3.8-200
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3.8-1

3.8 Reptiles

3.8 REPTILES

REPTILES SYNOPSIS

The United States Department of the Navy (Navy) considered all potential stressors that reptiles 

could potentially be exposed to from the Proposed Action. The following conclusions have been

reached for the Preferred Alternative (Alternative 1):

 Acoustic: Navy training and testing activities have the potential to expose reptiles to multiple 

types of acoustic stressors, including sonars, other transducers, air guns, pile driving, and 

vessel, aircraft, and weapons noise. Reptiles could be affected by only a limited portion of 

acoustic stressors because reptiles have limited hearing abilities. Exposures to soundproducing activities present risks that could range from hearing loss, auditory masking, 

physiological stress, and changes in behavior; however, no injurious impacts are predicted 

due to exposure to any acoustic stressor. Because the number of sea turtles potentially 

impacted by sound-producing activities is small, population-level effects are unlikely. Few, if 

any impacts on crocodilians or terrapins are anticipated from acoustic stressors because of 

the location of training activities relative to crocodilian and terrapin habitats.

 Explosive: Explosions in the water or near the water's surface present a risk to reptiles 

located in close proximity to the explosion, because the shock waves produced by explosives 

could cause injury or result in the death. If further away from the explosion, impulsive, 

broadband sounds introduced into the marine environment may cause hearing loss, auditory 

masking, physiological stress, or changes in behavior. Sea turtles would be exposed to 

explosive stressors in the nearshore and offshore portions of the Study Area, while 

crocodilians and terrapins would be exposed to explosive stressors at two inshore training 

and testing locations. One loggerhead sea turtle mortality is predicted. Because the number 

of sea turtles potentially impacted by explosives is small, population-level effects are 

unlikely. It is unlikely that crocodilians and terrapins would be in close proximity to inshore 

explosions because they would likely, if present, flee the area in response to other stressors 

(e.g., vessel noise, visual stimulus). Also, the types of explosives are small limpet mine 

charges, which limits the area where crocodilians and terrapins could be exposed to injurious 

impacts from explosives. Because inshore explosives training activities would impact few, if 

any, crocodilians or terrapins, population-level effects are unlikely. 

 Energy: Navy training and testing activities have the potential to expose reptiles to multiple 

energy stressors in offshore and inshore training and testing locations. The likelihood and 

magnitude of energy impacts depends on the proximity of a reptile to energy stressors. 

Based on the relatively weak strength of the electromagnetic field created by Navy activities, 

impacts on sea turtle migrating behaviors and navigational patterns are not anticipated. 

Potential impacts from high-energy lasers would only result for sea turtles directly struck by 

the laser beam. Statistical probability analyses demonstrate with a high level of certainty 

that no sea turtles would be struck by a high-energy laser. Activities that generate

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3.8 Reptiles

Continued from the previous page...

REPTILES SYNOPSIS

electromagnetic fields would occur in inshore habitats potentially inhabited by crocodilians 

and terrapins; however, no measureable impacts on individuals would be expected to occur. 

Activities using high-energy lasers would not occur in inshore training and testing locations. 

Energy stressors associated with Navy training and testing activities are temporary and 

localized in nature, and based on patchy distribution of reptiles, impacts on individual 

reptiles are unlikely and no impacts on populations are anticipated.

 Physical Disturbance and Strike: Vessels, in-water devices, and seafloor devices present a risk 

for collision with sea turtles, particularly in coastal areas where densities are higher. Strike 

potential by expended materials is statistically small. Because of the low numbers of sea

turtles potentially impacted by activities that may potentially cause a physical disturbance 

and strike, population-level effects are unlikely. Activities that use vessels, in-water devices, 

and seafloor devices would occur in habitats used by crocodilians and terrapins. Activities 

that expend materials would also occur in inshore habitats inhabited by crocodilians and 

terrapins; however, interactions with materials would not likely occur, and no impacts on 

individual crocodilians and terrapins are expected if a reptile encountered expended 

material. Because of the low numbers of crocodilians and terrapins potentially impacted by 

activities that may potentially cause a physical disturbance and strike, population-level 

effects are unlikely.

 Entanglement: Sea turtles could be exposed to multiple entanglement stressors in inshore 

and offshore training and testing locations. The potential for impacts is dependent on the 

physical properties of the expended materials and the likelihood that a sea turtle would 

encounter a potential entanglement stressor and then become entangled in it. Physical 

characteristics of wires and cables, decelerators/parachutes, and biodegradable polymers 

combined with the sparse distribution of these items throughout the Study Area indicates a 

very low potential for sea turtles to encounter and become entangled in them. Long-term 

impacts on individual sea turtles and sea turtle populations from entanglement stressors 

associated with Navy training and testing activities are not anticipated. Entanglement 

stressors are not anticipated to impact crocodilians or terrapins because activities that 

expend materials that present a potential entanglement risk would not co-occur with 

crocodilian or terrapin habitats.

 Ingestion: Navy training and testing activities have the potential to expose reptiles to 

multiple ingestion stressors and associated impacts in inshore and offshore training and 

testing locations. The likelihood and magnitude of impacts depends on the physical 

properties of the military expended items and the feeding behaviors of the particular species 

of reptiles that occur in specific areas where potentially ingestible items are used. Adverse 

impacts from ingestion of military expended materials would be limited to the unlikely event

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3.8 Reptiles

3.8.1 INTRODUCTION

This section provides a brief introduction to reptiles that occur within the boundaries of the Study Area

and whose distribution may overlap with stressors associated with the Proposed Action. The National 

Marine Fisheries Service (NMFS) and the United States Fish and Wildlife Service (USFWS) share 

jurisdictional responsibility for sea turtles under the Endangered Species Act (ESA). USFWS has 

responsibility in the terrestrial environment (e.g., nesting beaches), while NMFS has responsibility in the 

marine environment. Jurisdictional management of the crocodilian species included in this analysis is the 

responsibility of the USFWS.

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REPTILES SYNOPSIS

that a sea turtle, crocodilian, or terrapin would be harmed by ingesting an item that becomes 

embedded in tissue or is too large to be passed through the digestive system. The likelihood 

that a reptile would encounter and subsequently ingest a military expended item associated 

with Navy training and testing activities is considered low. Long-term consequences to 

reptile populations from ingestion stressors associated with Navy training and testing 

activities are not anticipated. 

 Secondary: Reptiles could be exposed to multiple secondary stressors (indirect stressors to 

habitat or prey) associated with Navy training and testing activities in the Study Area. Inwater explosions have the potential to injure or kill prey species that sea turtles feed on 

within a small area affected by the blast; however, impacts would not substantially impact 

prey availability for sea turtles, crocodilians, or terrapins. Explosion byproducts and 

unexploded munitions would have no meaningful effect on water or sediment quality; 

therefore, they are not considered to be secondary stressors for reptiles. Metals are 

introduced into the water and sediments from multiple types of military expended materials. 

Available research indicates metal contamination is very localized and that bioaccumulation 

resulting from munitions would not occur. Several Navy training and testing activities 

introduce chemicals into offshore and inshore environments that are potentially harmful in 

concentration; however, through rapid dilution, toxic concentrations are unlikely to be 

encountered by sea turtles, crocodilians, or terrapins. Furthermore, bioconcentration or 

bioaccumulation of chemicals introduced by Navy activities to levels that would significantly 

alter water quality and degrade sea turtle habitat has not been documented. Secondary 

stressors from Navy training and testing activities in the Study Area are not expected to have 

long-term impacts on sea turtle populations. Secondary stressors discussed above would 

overlap with crocodilian and terrapin habitats at inshore training locations. As with sea 

turtles, toxic concentrations of chemicals and munitions constituents are unlikely to be 

encountered by crocodilians and terrapins; therefore, bioconcentration or bioaccumulation 

of chemicals introduced by Navy activities would not likely alter water quality, degrade 

habitats, or reduce prey availability. Any indirect stressors to habitat or prey from training 

and testing activities are anticipated to be negligible, and no population-level impacts are 

anticipated.
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3.8 Reptiles

Sea turtles considered in this analysis are found in coastal waters and on nesting beaches of the United 

States (U.S.) Atlantic Coast, Gulf of Mexico, Caribbean Sea, and in open ocean areas.1 These species 

include green sea turtles (Chelonia mydas), hawksbill turtle (Eretmochelys imbricata), Kemp’s ridley 

turtle (Lepidochelys kempii), leatherback turtle (Dermochelys coriacea), and loggerhead turtle (Caretta 

caretta). The American crocodile (Crocodylus acutus) and American alligator (Alligator mississippiensis)

belong to group of reptiles called crocodilians. The American crocodile inhabits coastal areas of south 

Florida where they are at the northern extreme of their range. American alligators range throughout the 

southeastern U.S., in estuaries and freshwater habitats along rivers and lakes. The diamondback terrapin 

(Malaclemys terrapin) is also found in nearshore and inshore waters along the Atlantic and Gulf coasts. 

All of the sea turtles analyzed in this document are ESA listed, along with the American crocodile. The 

American alligator is listed under the ESA classification of “threatened due to similarity of appearance” 

to the American crocodile. The diamondback terrapin is not ESA listed. Each species is discussed further 

in Section 3.8.2 (Affected Environment). 

3.8.2 AFFECTED ENVIRONMENT

3.8.2.1 General Background

All reptiles are ectotherms, commonly referred to as “cold-blooded” animals that have adopted 

different strategies to use external sources of heat to regulate body temperature. Within the Atlantic 

Fleet Training and Testing (AFTT) Study Area, sea turtles, crocodilians, and diamondback terrapins are 

analyzed for potential impacts.

Sea turtles are highly migratory, long-lived reptiles that occur throughout the open-ocean and coastal 

regions of the Study Area. Generally, sea turtles are distributed throughout tropical to subtropical 

latitudes, with some species extending into temperate seasonal foraging grounds. In general, sea turtles 

spend most of their time at sea, with female turtles returning to land to nest. Habitat and distribution 

vary depending on species and life stages, and is discussed further in the species profiles and 

summarized in the following sections.

Crocodilians are also long-lived reptiles whose life spans can exceed 40 years in the wild. Crocodilians 

control their body temperature by basking in the sun or moving to areas with warmer or cooler air and 

water temperatures. The American crocodile inhabits freshwater wetland habitats, including rivers, 

lakes, and reservoirs, and can also be found in brackish environments such as estuaries and swamps 

(Fishman et al., 2009). It occurs within the Study Area in coastal portions of the Caribbean and in Florida. 

The alligator is found throughout the southeastern United States, from the Carolinas to Texas. Unlike 

American crocodiles, American alligators lack lingual salt glands and are therefore unable to remove 

excess salt from their bodies (Nifong & Silliman, 2017). Gardner et al. (2016) predictively modeled 

alligator occurrence in North Carolina and found a strong negative relationship between water salinity 

 

1 The olive ridley sea turtle (Lepidochelys olivacea) was considered for inclusion in this document, but because its 

occurrence in the Study Area is extralimital (outside the species’ normal range), the species will not be analyzed. 

Western Atlantic olive ridley sea turtle populations are centered near Suriname/French Guiana and Brazil. 

Occurrences as far north as Puerto Rico, the Dominican Republic, and Cuba are considered rare. Between 1999 and 

2001, three individuals were reported in coastal south Florida; however, all were strandings (Foley et al., 2003). 

Currently, there are no olive ridley nesting beaches in the eastern United States, and there are no known feeding, 

breeding, or migration areas within the Study Area; therefore, there does not appear to be a nexus between olive 

ridley sea turtles and Navy training and testing activities.
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3.8 Reptiles

and alligator occurrence and abundance. Throughout their range, American alligators are usually found 

in freshwater wetland habitats, in slow-moving rivers, or in the brackish waters of swamps, marshes, 

and lakes. Neither species occurs in offshore oceanic waters.

Diamondback terrapins can be found along the eastern and gulf coasts of the United States, from Cape 

Cod (Massachusetts) to Texas. They are most common in salt marshes and shallow bays. They are 

usually found in brackish water and occasionally travel out into the open ocean. However, they cannot 

tolerate full-strength salty water for long periods of time, or they may dehydrate.

Additional species profiles and information on the biology, life history, species distribution, and 

conservation of reptile species can also be found on the following organizations:

 NMFS Office of Protected Resources (includes sea turtle species distribution maps),

 USFWS Ecological Services Field Office and Region Offices (for sea turtle nesting habitat and 

general locations of nesting beaches),

 Ocean Biogeographic Information System-Spatial Ecological Analysis of Megavertebrate 

Populations (known as OBIS-SEAMAP) species profiles,

 International Union for Conservation of Nature, Marine Turtle Specialist Group, and

 State resource agencies (for sea turtle nesting information, status and management for 

American alligators and diamondback terrapins).

Detailed information about threats to these species and life history information can be found in the ESA 

listing documentation and their recovery plans (Federal Register 44 (244): 75074–75076, December 18, 

1979; Federal Register 52 (107): 21059–21064, June 4, 1987; Federal Register 72 (53): 13027–13040, 

March 20, 2007).

3.8.2.1.1 Group Size

Sea turtles are generally solitary animals, but they tend to group during migrations and mating. Because 

they do not show territoriality, foraging areas often overlap. New hatchlings, which often emerge from 

nesting beaches in groups, are solitary until they are sexually mature (Bolten, 2003b; Bowen et al., 2004; 

James et al., 2005a; Schroeder et al., 2003).

Crocodiles and alligators are territorial, but will gather in groups as juveniles (as a defense against 

predators), and as adults when exhibiting courtship behavior and feeding (Hidalgo-Ruz et al., 2012; 

National Park Service, 2012). For both American crocodiles and American alligators, courtship and 

mating take place during the spring warming period (typically April and May), and nesting and egg-laying 

is initiated during the early part of the warm, wet summers (Briggs‐Gonzalez et al., 2017; Vliet, 2001).

Diamondback terrapins may hibernate individually or hibernate together in large groups (Sheridan et al., 

2010). Pfau and Roosenburg (2010) used harvesting records in the Chesapeake Bay to estimate that 

large hibernating groups may number as many as 200 individual diamondback terrapins. 

3.8.2.1.2 Habitat Use

Sea turtles are dependent on beaches for nesting habitat, in locations that have sand deposits that are 

not inundated with tides or storm events prior to hatching. In the water, sea turtle habitat use is 

dependent on species and corresponds to dive behavior because of foraging and migration strategies, as 

well as behavior state (e.g., diving deep at night for resting purposes) (Hart et al., 2016). 
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3.8 Reptiles

Crocodiles and alligators depend on brackish and fresh water estuarine wetland types, where there is 

sufficient water to use as concealment for hunting and stalking of prey. Nesting habitats are on dry land, 

with eggs deposited in holes dug in soft mud and sediments (Britton, 2009).

Although diamondback terrapins are an aquatic turtle and spend the majority of their life in water, they 

do leave the water to bask and lay eggs. One biological advantage these turtles have acquired over time 

is the ability to survive in salt waters of variable salinities (Pfau & Roosenburg, 2010).

3.8.2.1.3 Dive Behavior

While the American crocodile, American alligator, and diamondback terrapin do submerge, they do not 

dive in the traditional sense; thus these species are not discussed in this section. Sea turtle dive depth 

and duration varies by species, the age of the animal, the location of the animal, and the activity 

(e.g., foraging, resting, and migrating). Dive durations are often a function of turtle size, with larger 

turtles being capable of diving to greater depths and for longer periods. The diving behavior of a 

particular species or individual has implications for mitigation, monitoring, and developing sound 

conservation strategies. In addition, their relative distribution through the water column is an important 

consideration when conducting acoustic exposure analyses. Methods of collecting dive behavior data 

over the years has varied in study design, configuration of electronic tags, parameters collected in the 

field, and data analyses. Collected data from 57 studies were published between 1986 and 2013, which 

summarized depths and durations of dives of datasets including an overall total of 538 sea turtles. Figure 

3.8-1 presents the ranges of maximum dive depths for each sea turtle species found in the Study Area.

Sources: Hochscheid (2014); Sakamoto et al. (1993); (Rice & Balazs, 2008) ; Gitschlag (1996); Salmon et al. (2004)

Note: This figure shows the ranges of maximum dive depths and durations reported in the literature for the sea turtle species 

included in this analysis. Only one study was reviewed for Kemp’s ridley turtle, which recorded depths of one juvenile 

Kemp’s ridley turtle, and was not comparable to other data collected on other species.

Figure 3.8-1: Dive Depth and Duration Summaries for Sea Turtle Species

Hochscheid (2014) also collected information on generalized dive profiles, with correlations to specific 

activities, such as bottom resting, bottom feeding, orientation and exploration, pelagic foraging and 

feeding, mid-water resting, and traveling during migrations. Generalized dive profiles compiled from 

11 different studies by Hochscheid (2014) show eight distinct profiles tied to specific activities. These 

profiles and activities are shown in Figure 3.8-2.

0 200 400 600 800 1000 1200 1400

Green turtle

Max dive duration: 307 min

Hawksbill turtle

Max dive duration: 138 min

Kemp's Ridley turtle

(See note 1)

Max dive duration: 217 min

Loggerhead turtle

Max dive duration: 614 min

Leatherback turtle

Max dive duration: 86.5 min

Range of Recorded Maximum Depths by Species (meters)
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3.8 Reptiles

Sources: Hochscheid (2014); Rice and Balazs (2008), Sakamoto et al. (1993), Houghton et al. (2003), Fossette et al. (2007), 

Salmon et al. (2004), Hays et al. (2004); Southwood et al. (1999)

Note: Profiles A-H, as reported in the literature and compiled by Hochscheid (2014). The depth and time arrows indicate the 

axis variables, but the figure does not represent true proportions of depths and durations for the various profiles. In other

words, the depths can vary greatly, but behavioral activity seems to dictate the shape of the profile. Profiles G and H have 

only been described for shallow dives (less than 5 m).

Figure 3.8-2: Generalized Dive Profiles and Activities Described for Sea Turtles

3.8.2.1.4 Hearing and Vocalization

3.8.2.1.4.1 Sea Turtles

Sea turtle ears are adapted for hearing underwater and in air, with auditory structures that receive 

sound via bone conduction (Lenhardt et al., 1985), via resonance of the middle ear cavity (Willis et al., 

2013), or via standard tympanic middle ear path (Hetherington, 2008). Studies of hearing ability show 

that sea turtles’ ranges of in-water hearing detection generally lie between 50 and 1600 hertz (Hz), with 

maximum sensitivity between 100 and 400 Hz, and that hearing sensitivity drops off rapidly at higher 

frequencies. Sea turtles are also limited to low-frequency hearing in-air, with hearing detection in 

juveniles possible between 50 and 800 Hz, with a maximum hearing sensitivity around 300 to 400 Hz 

(Bartol & Ketten, 2006; Piniak et al., 2016). Hearing abilities have primarily been studied with sub-adult, 

juvenile, and hatchling subjects in four sea turtle species, including green (Bartol & Ketten, 2006; Ketten 

& Moein-Bartol, 2006; Piniak et al., 2016; Ridgway et al., 1969), Kemp’s ridley (Bartol & Ketten, 2006), 

loggerhead (Bartol et al., 1999; Lavender et al., 2014; Martin et al., 2012), and leatherback. Only one 

study examined the auditory capabilities of an adult sea turtle (Martin et al., 2012); the hearing range of 

the adult loggerhead turtle was similar to other measurements of juvenile and hatchling sea turtle 

hearing ranges. 
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3.8 Reptiles

Using existing data on sea turtle hearing sensitivity, the U.S. Department of the Navy (Navy) developed a 

composite sea turtle audiogram for underwater hearing (Figure 3.8-3), as described in the technical 

report Criteria and Thresholds for U.S. Navy Acoustic and Explosive Effects Analysis (Phase III) (U.S. 

Department of the Navy, 2017).

Source: U.S. Department of the Navy (2017)

Notes: dB re 1 μPa: decibels referenced to 1 micropascal; kHz: kilohertz

Figure 3.8-3: Composite Underwater Audiogram for Sea Turtles

The role of underwater hearing in sea turtles is unclear. Sea turtles may use acoustic signals from their 

environment as guideposts during migration and as cues to identify their natal beaches (Lenhardt et al., 

1983). However, they may rely more on other senses, such as vision and magnetic orientation, to 

interact with their environment (Avens, 2003; Narazaki et al., 2013). 

Sea turtles are not known to vocalize underwater. Some sounds have been recorded during nesting 

activities ashore, including belch-like sounds and sighs (Mrosovsky, 1972), exhale/inhales, gular pumps, 

and grunts (Cook & Forrest, 2005) by nesting female leatherback turtles and low-frequency pulsed and 

harmonic sounds by leatherback embryos in eggs and hatchlings (Ferrara et al., 2014).

3.8.2.1.4.2 Crocodilians

Crocodilians (e.g., crocodiles and alligators), like other amphibious species, have both in-air and 

underwater hearing capabilities. However, crocodilians appear to be structurally adapted for detection 

of airborne sound based on the similarities between crocodilian and avian ear morphology and the 

corresponding auditory brainstem structures (Gleich & Manley, 2000). Crocodilians detect airborne 

sound via the tympanic membrane, while sounds in water appear to be detected via bone conduction 

(Higgs et al., 2002). Crocodilians have external muscular flaps both above and below the opening of the 

external auditory canal that reflexively close to seal off the canal when submerged and relax to open 

above/out of the water (Saunders et al., 2000; Shute & Bellairs, 1955).

The hearing ranges for crocodilians was observed to extend to higher frequencies in air than in water 

(Higgs et al., 2002). Crocodilians use hearing for prey detection and social communication, but also rely 

on good vision, scent, and touch for interacting with their environment (Grigg & Gans, 1993; Wever, 

1971). With regard to sound production, crocodilian calls are typically low frequency, short, and 

repetitive. Adult calls include courtship bellows at the air-water interface with a notable in-water 
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component (20–250 Hz); grunts (up to 1 kHz); hisses during threat displays, and coughs (Garrick et al., 

1978; Vergne et al., 2009; Vliet, 1989). Hatchling and juvenile American alligators have a more restricted 

communication repertoire (Higgs et al., 2002). Sound production includes contact calls made when 

feeding or moving in groups and hisses or snarls when threatened (Bierman et al., 2014).

3.8.2.1.4.3 Terrapins

No definitive research is available to ascertain how terrapins use sound in the environment. Hearing 

may be used to locate food or mates, avoid predators, navigate, or communicate (Lester, 2013). Lester 

et al. (2012) determined that diamondback terrapins can hear a limited range of low-frequency tones 

less than 1,000 Hz. Terrapins responded to in-air sounds from 100 to 1,000 Hz, with the range of best 

hearing from 400 to 600 Hz with mean lowest threshold of 64 dB re 20 μPa SPL (Lester, 2013). In-water, 

terrapins responded to sounds from 50 to 800 Hz with mean lowest threshold of 86 dB re 1 μPa SPL 

(Lester, 2013).

3.8.2.1.5 General Threats

3.8.2.1.5.1 Water Quality

Sea Turtles

Water quality in sea turtle habitats can be affected by a wide range of activities. The potential for energy 

exploration and extraction activities to degrade nearshore and offshore habitats are discussed in Section 

3.8.2.1.5.2 (Commercial Industries). Marine debris in sea turtle habitats is discussed in Section 

3.8.2.1.5.6 (Marine Debris). Chemical pollution and impacts on water quality is also of great concern, 

although its effects on reptiles are just starting to be understood in marine organisms (Law et al., 2014; 

Ortmann et al., 2012). Oil and other chemical spills are a specific type of ocean contamination that can 

have damaging effects on some sea turtle and other marine reptile species directly through exposure to 

oil or chemicals and indirectly due to pollutants’ impacts on prey and habitat quality. Ingested plastics, 

discussed in more detail in Section 3.8.2.1.5.6 (Marine Debris), can also release toxins, such as 

bisphenol-A (commonly known as “BPA”) and phthalates, and organisms may absorb heavy metals from 

the ocean and release those into tissues (Fukuoka et al., 2016; Teuten et al., 2007). Life stage, 

geographic location relative to concentrations of pollutants, and feeding preference affects the severity 

of impacts on sea turtles associated with chemical pollution in the marine environment.

Crocodilians

For the American crocodile, the increase in salinity levels from fresh water input reductions may 

influence distributions in southern Florida (Mazzotti et al., 2016). One of the goals of the Comprehensive 

Everglades Restoration Plan is to restore historic freshwater flows through portions of the Everglades. 

Henry et al. (2016) modeled potential effects of restoring freshwater flows to the Everglades, predicting 

crocodile populations across south Florida decreasing approximately 3 percent after the restoration of 

flows compared to future conditions without restoration, but local increases up to 30 percent in the Joe 

Bay area near Taylor Slough, and local decreases up to 30 percent in the vicinity of Buttonwood Canal.

American alligators are often cited as indicators for water quality, in particular for heavy metal pollution 

(Brandt et al., 2016; Hodge, 2011). Fluctuations in water levels are a primary driver for alligator presence 

in inland freshwater systems (Brandt et al., 2016; Hidalgo-Ruz et al., 2012; National Park Service, 2012), 

along with lower salinities (Gardner et al., 2016; Nifong & Silliman, 2017).
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Terrapins

Diamondback terrapins are also considered to be an indicator species for water quality (Pfau & 

Roosenburg, 2010). Although it is unclear how pollutants in terrapin habitats may impact individual 

terrapins and populations, studies on terrapins in polluted waters indicate that terrapins uptake 

pollutants into tissues, and higher abundances of terrapins are found in relatively higher quality waters 

than polluted waters within the same bay system. For example, Basile et al. (2011) measured fat content 

in diamondback terrapins for a number of contaminants, including persistent organic pollutants 

(e.g., polychlorinated biphenyls, polybrominated diphenyl ethers, chlorinated pesticides, and methyltriclosan). This study was conducted by collecting fat biopsies on terrapins in Barnegat Bay in New 

Jersey, covering industrial areas and outfalls, as well as less polluted areas of the bay (e.g., Forsythe 

National Wildlife Refuge). Basile et al. (2011) found that terrapins closer to the industrial area had 

higher persistent organic pollutants in fat stores than terrapins further from sources of industrial 

pollution. Male terrapins had higher concentrations of pollutants in fat stores than females, while 

females had higher concentrations of persistent organic pollutants in plasma than males (Basile et al., 

2011).

3.8.2.1.5.2 Commercial Industries

Sea Turtles

In offshore areas of the Study Area, bycatch from commercial fisheries is a primary threat to sea turtles. 

In U.S. fisheries, Finkbeiner et al. (2011) estimate that bycatch resulted in 71,000 sea turtle deaths per 

year prior to effective regulations that protect sea turtles (e.g., regulations adopted since the mid-1990s 

in different U.S. fisheries for turtle exclusion devices). Current mortality estimates are 94 percent lower 

(4,600 deaths) than pre-regulation estimates (Finkbeiner et al., 2011). One comprehensive study 

estimates that worldwide, 447,000 sea turtles are killed each year from bycatch in commercial fisheries 

around the world (Wallace et al., 2010a; Wallace et al., 2010b). Lewison et al. (2014) compared bycatch 

using three different gear types (longline, gillnet, and trawling nets) for sea turtles, marine mammals, 

and seabirds. Sea turtles were most susceptible to bycatch, with the Mediterranean and waters off the 

Atlantic coast of South America as the two highest fisheries reporting sea turtle mortalities (primarily 

through trawling) (Lewison et al., 2014). Offshore energy development, including oil and natural gas 

extraction in coastal and deep waters on the continental shelf, as well as renewable energy projects, can 

degrade habitats during pre-construction and operation phases (Bergström et al., 2014; Finkbeiner et 

al., 2011; Wright & Kyhn, 2015).

In nearshore areas, large-scale commercial exploitation also contributes to global decline in marine 

turtle populations. Currently, 42 countries and territories allow direct take of turtles and collectively 

take in excess of 42,000 turtles per year, the majority of which (greater than 80 percent) are green sea 

turtles (Humber et al., 2014). Illegal fishing for turtles and nest harvesting also continues to be a major 

cause of sea turtle mortality, both in countries that allow sea turtle take and in countries that outlaw the 

practice (Lam et al., 2011; Maison et al., 2010). For example, Humber et al. (2014) estimated that in 

Mexico, 65,000 sea turtles have been illegally harvested since 2000. The authors, however, noted a 

downward trend of legal and illegal direct takes of sea turtles over the past three decades—citing a 

greater than 40 percent decline in green sea turtle take since the 1980s, a greater than 60 percent 

decline in hawksbill and leatherback take, and a greater than 30 percent decline in loggerhead take 

(Humber et al., 2014).
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Offshore energy development activities have likely led to negative consequences for sea turtle 

populations within the Study Area. The Deepwater Horizon spill in 2010, releasing 200 million gallons of 

crude oil into the Gulf of Mexico (Putman et al., 2015a), is anticipated to have long-term effects that 

persist for decades (National Marine Fisheries Service, 2011, 2014a). Prior to drilling operations, vessel 

traffic and seismic disturbances through exploration activities can degrade sea turtle coastal and open 

ocean foraging habitats. As of 2017, the global offshore wind industry had a current installed capacity of 

nearly 18,000 megawatts (Mills, et al. 2018) and is expected to grow to more than 37,000 megawatts by 

2020 (Smith et al., 2015). Off of U.S. shores, approximately 20,000 megawatts of installed capacity is 

planned over the next few years, with most development occurring off the coasts of Massachusetts, 

New Jersey, Virginia, and North Carolina (Smith et al., 2015). Construction of offshore wind energy 

facilities in mid-Atlantic is likely to occur in warmer months, and sea turtles will be present during these 

periods (Williams et al., 2015). Onshore development can lead to nesting habitat loss or habitat 

degradation. Construction activities can facilitate erosion or inhibit natural sediment deposition to form 

beaches. Once facilities are operational, artificial lighting, noise, and other stressors can degrade nesting 

habitats (Seminoff et al., 2015).

Boat strike has been identified as one of the important mortality factors in several nearshore turtle 

habitats worldwide. Precise data are lacking for sea turtle mortalities directly caused by ship strikes; 

however, live and dead turtles are often found with deep cuts and fractures indicative of collision with a 

boat hull or propeller (Hazel et al., 2007; Lutcavage et al., 1997). For example, scientists in Hawaii 

reported that 2.5 percent of green sea turtles found dead on the beaches between 1982 and 2003 had 

been killed by boat strike (Chaloupka et al., 2008), and in the Canary Islands, 23 percent of stranded sea 

turtles showed lesions from boat strikes or fishing gear (Oros et al., 2005). Denkinger et al. (2013)

reports that boat strikes in the Galapagos Islands were most frequent at foraging sites close to a 

commercial and tourism port.

Crocodilians

American crocodiles and American alligators were widely hunted for their skins from 1920 to 1970, 

which led to significant population declines across all parts of the species range. Country-specific 

(e.g., the listing of the American crocodile as endangered in 1973 under the ESA) and international trade 

restrictions, along with the availability of legally obtained skins from other crocodilians, have 

significantly reduced commercial hunting in recent decades (Brandt et al., 2016; National Park Service, 

2012; Thorbjarnarson et al., 2006). Regulated commercial use of captive reared crocodilians has relieved 

commercial exploitation for wild crocodilians. The American alligator population has expanded greatly 

throughout its historic range in wetlands of the southeastern United States (Brandt et al., 2016; National 

Park Service, 2012). 

Oil spills that impact freshwater and estuarine habitats will alter important wetland ecological functions, 

such as removing sediments, nutrients, pesticides, metals, and other pollutants, and provide essential 

foundations for food chains for wildlife (Corn, 2010), including crocodilians. Oil spills that occur in or 

wash into these wetlands could reduce prey availability for both the American alligator and the 

American crocodile. For the American alligator, coastal oil pollution likely has only limited impacts 

because the highest abundance of alligators are found in inland freshwater systems (Corn, 2010). For 

American crocodiles, oil spills would have to occur within, or wash into, crocodile habitats in southern 

Florida for impacts to occur, and would likely be a significant and persistent inhibiting factor in American 

crocodile recovery.
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Habitat destruction (through the filling in of wetlands and altering of hydrologic connectivity, water 

levels, and salinities) is the primary limiting factor on crocodilian recovery in the United States (Green et 

al., 2014; Mazzotti et al., 2007; Thorbjarnarson et al., 2006). 

Terrapins

Commercial activities that threaten diamondback terrapins include commercial harvesting, bycatch 

mortality in crab pots, and pollution. Up until the beginning of the 20th century, diamondback terrapins 

were in great demand by gourmet restaurants in major metropolitan areas of the United States. (Pfau & 

Roosenburg, 2010). Dredging of shallow water habitats and scraping of hibernacula where terrapins 

congregate during the winter were the most effective forms of commercial harvesting. Commercial 

harvesting, as determined by test dredging, tended to capture more females than males, which likely 

severely reduced the reproductive potential for populations in terrapin fisheries. The commercial 

demand for terrapins generally subsided through the 20th century. However, there was an increase in 

terrapin exports to China from the United States in the late 1980s, but by 2007, all of the states within 

the diamondback terrapin range within the United States had prohibited commercial harvest of 

terrapins (Pfau & Roosenburg, 2010).

Roosenburg et al. (1997) studied crab pot use in the Chesapeake Bay and estimated that 15–78 percent 

of the local terrapin population can be captured in crab pots in a single year. Crab pots are designed 

with small entrances, which tend to capture smaller males rather than larger females. Because of the 

selective mortality of males in crab pots, Pfau and Roosenburg (2010) estimated that the terrapin sex 

ratio in the Chesapeake bay at one male to two, possibly three females. New crab traps with terrapin 

exclusions have greatly reduced terrapin bycatch (Lester, 2013; Pfau & Roosenburg, 2010; University of 

Georgia, 2017). 

Oil spills in coastal areas directly impact diamondback terrapins by oiling and drowning the animals and 

indirectly by contaminating their nesting beaches (Pfau & Roosenburg, 2010). The short-term impacts of 

the oil spill from a leak in an underground oil pipeline near Chalk Point, Maryland, showed direct 

impacts on adult terrapins and decline in hatchling survivability where the oil leak polluted sand in a 

nesting location (Michel et al., 2001).

Residential and urban development restricts freshwater flow into swamps and estuaries, which may 

limit diamondback terrapin growth, survival, and abundance, and potentially impact diamondback 

terrapin habitats if spills reach estuaries and riverine areas (Basile et al., 2011).

3.8.2.1.5.3 Disease and Parasites

Fibropapillomatosis is a disease of sea turtles that results in the production of tumors, both external and 

internal, that are considered benign, but may obstruct crucial functions, such as swimming, feeding, 

sight, and buoyancy, and can lead to death (Balazs, 1986; Patrício et al., 2016). The disease was first 

noticed in 1928, and was not observed again until the 1970s (Day et al., 2016). The disease shows the 

highest prevalence among green sea turtles (Patrício et al., 2016), with rapid spread of the disease was 

recorded through the 1980s, becoming an endemic in both Florida and Hawaii in green sea turtle

populations (Day et al., 2016; Work & Balazs, 2013). By 1995 the concentration of disease in the 

population reached its climax and has showed a decline in prevalence since (Patrício et al., 2016). 

Edmonds et al. (2016) lists 16 parasites known to occur in sea turtles, with the most common and 

significant (in terms of impacts on health) being blood flukes and flatworms (Watson et al., 2017). Some 

of the common external parasites found on sea turtles include leeches and a number of different species 
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that reside on the shell called epibiota (Glandon & Miller, 2016). Leeches are usually seen around where 

the flippers attach to the rest of the body. Parasitic isopods (e.g., sea lice) can attach themselves to sea 

turtle soft tissue on the outside and within the mouth (Foster & Gilmour, 2016). 

The type and severity of disease in crocodilians and terrapins is poorly understood, and is not 

considered as a significant threat to species recovery (Florida Fish and Wildlife Conservation 

Commission, n.d.; Hackney, 2010; National Park Service, 2012; Savannah River Ecology Laboratory & 

Herpetology Program, 2012).

3.8.2.1.5.4 Invasive Species

Invasive species have been shown to have both harmful and beneficial impacts on sea turtles. Impacts 

on sea turtles associated with invasive species primarily concern nest predation and prey base. For 

example, feral hogs (Sus scrofa) have been known to destroy several sea turtle nests during a season on 

certain nesting beaches in Florida (Engeman et al., 2016). Engeman et al. (2016) noted nesting success 

after a successful implementation of a feral hog control program in Florida. In foraging grounds, sea 

turtles have been shown to adapt their foraging preferences for invasive seagrass and algae. Becking et 

al. (2014) showed green sea turtle foraging behavior shift to consumption of Halophila stipulacea, a 

rapidly spreading seagrass in the Caribbean. In Hawaii, green sea turtles in Kaneohe Bay have modified 

their diets over several decades to include seven non-native species (Spiny Seaweed, Acanthophora 

spicifera; Hypnea musciformis, Gracilaria salicornia, Eucheuma denticulatum, Graceful Red Weed, 

Gracilaria tikvahiae; Agar-agar, Kappaphycus striatum; and Elkhorn Sea Moss, Kappaphycus alvarezii), 

with non-native algae accounting for over 60 percent of turtle diet (Russell & Balazs, 2015).

Burmese pythons (Python bivitattus) are large generalist predators that have established an expanding 

breeding population in Florida (Walters et al., 2016). Introduced pythons present a direct threat to the 

American alligator and American crocodile through predation, where predation of alligators up to 2 m in 

length have been reported (Dorcas et al., 2012). Introduced pythons were thought to be primarily 

restricted to freshwater habitats in Florida, but Hart et al. (2012) has shown salt water tolerance in 

newly-hatched pythons, which may increase the risk for American crocodiles and terrapins. Introduced 

pythons can also negatively impact crocodilians and terrapins through competition for food. Dorcas et 

al. (2012) noted severe declines in mammals attributed to python population increases, which remove a 

small, but significant prey base for alligators and crocodiles.

Draud et al. (2004) and Pfau and Roosenburg (2010) noted that terrapin nests and hatchlings are 

vulnerable to predation from non-native rats and ants, along with other native terrestrial and avian 

predators. In addition, invasive vegetation can severely impact wetlands when made vulnerable by high 

amounts of disturbance. Phragmites australis, an invasive emergent marsh reed, is rapidly expanding in 

coastal wetlands of the United States, particularly brackish wetlands, which likely degrades terrapin 

nesting areas. Cook (2016) found that Phragmites australis can alter vegetation structure, soil 

temperature, and moisture in nesting locations, which may limit preferred nesting habitats (replacing 

sparsely vegetated sandy locations with thick stands of Phragmites australis), potentially skew sex ratios 

towards males, and reduce nesting success through the encroachment of root systems into nests.

3.8.2.1.5.5 Climate Change

Sea turtles, crocodilians, and terrapins are particularly susceptible to climate change effects because 

their life history, physiology, and behavior are extremely sensitive to environmental temperatures 

(Fuentes et al., 2013; Green et al., 2014; Hart & Lee, 2006; University of Georgia, 2017; Wheatley et al., 

2012). Climate change models predict sea level rise and increased intensity of storms and hurricanes in 
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tropical sea turtle nesting areas (Patino-Martinez et al., 2008), as well as coastal areas of the United 

States where crocodilians and terrapins may nest (Frost et al., 2017). These factors could significantly 

increase beach inundation and erosion, thus affecting water content of sea turtle, crocodilian, and 

terrapin nesting beaches and potentially inundating nests (Pike et al., 2015). Climate change may 

negatively impact reptiles in multiple ways and at all life stages. These impacts may include the potential 

loss of nesting beaches due to sea level rise and increasingly intense storm surge (Patino-Martinez et al., 

2008), feminization of populations from elevated nest temperatures (and skewing populations to more 

females than males unless nesting shifts to northward cooler beaches) (Reneker & Kamel, 2016) (Pfau & 

Roosenburg, 2010), decreased reproductive success (Hawkes et al., 2006; Laloë et al., 2016; Pike, 2014), 

shifts in reproductive periodicity and latitudinal ranges (Pike, 2014), disruption of hatchling dispersal and 

migration, and indirect effects to food availability (Witt et al., 2010). Erosion, water contaminants, and 

sea level rise may further increase vulnerability of nesting sites for both the American crocodile and 

American alligator (Mazzotti et al., 2007; Mazzotti et al., 2016; Savannah River Ecology Laboratory & 

Herpetology Program, 2012), as well as the diamondback terrapin. Short-term effects on aquatic reptiles

and their habitat also include the potential impacts caused by increased hurricane occurrence and 

intensity (Elsey et al., 2006; Elsey & Woodward, 2010). American alligators are likely less affected by 

coastal impacts associated with climate change because they occur in freshwater systems further inland 

(Eversole et al., 2015). 

Adaption strategies to protect coastal infrastructure are an anticipated response to rising sea levels. 

These activities may include shoreline stabilization projects and infrastructure hardening, which could 

contribute to the loss of nesting habitat. Shoreline stabilization may hold in place beach sediments in a 

specific location; however, the disruption of onshore currents can reduce the beach replenishment of 

sediments further away (Boyer et al., 1999; Fish et al., 2008).

3.8.2.1.5.6 Marine Debris

Debris in offshore and inshore waters present ingestion and entanglement risks for sea turtles, 

crocodilians, and terrapins. Ingestion of marine debris can cause mortality or injury to sea turtles. The 

United Nations Environment Program estimates that approximately 6.4 million tons of anthropogenic 

debris enters the marine environment every year (United Nations Environmental Program, 2005). This 

estimate, however, does not account for cataclysmic events, such as the 2011 Japanese tsunami 

estimated to have generated 1.5 million tons of floating debris (Murray et al., 2015). Plastic is the 

primary type of debris found in marine and coastal environments, and plastics are the most common 

type of marine debris ingested by sea turtles (Schuyler et al., 2014). Sea turtles can mistake debris for 

prey; one study found 37 percent of dead leatherback turtles to have ingested various types of plastic 

(Mrosovsky et al., 2009), and Narazaki et al. (2013) noted an observation of a loggerhead exhibiting 

hunting behavior on approach to a plastic bag, possibly mistaking the bag for a jelly fish. Even small 

amounts of plastic ingestion can cause an obstruction in a sea turtle’s digestive track and mortality 

(Balazs et al., 1994; Bjorndal, 1997), and hatchlings are at risk for ingesting small plastic fragments. 

Ingested plastics can also release toxins, such as bisphenol-A (commonly known as “BPA”) and 

phthalates, or absorb heavy metals from the ocean and release those into tissues (Fukuoka et al., 2016; 

Teuten et al., 2007). Life stage and feeding preference affects the likelihood of ingestion. Turtles living in 

oceanic or coastal environments and feeding in the open ocean or on the seafloor may encounter 

different types and densities of debris, and may therefore have different probabilities of ingesting 

debris. In 2014, Schuyler et al. (2014) reviewed 37 studies of debris ingestion by sea turtles, showing 
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that young oceanic sea turtles are more likely to ingest debris (particularly plastic), and that green and 

loggerhead turtles were significantly more likely to ingest debris than other sea turtle species.

Ribic et al. (2010) documented regional differences in amounts and long-term trends of marine debris

(land-based and ocean-based) along the U.S. Atlantic coast, while indexing debris amounts with 

population growth and fisheries activity. Based on their analysis, Ribic et al. (2010) concluded that the 

vast majority of marine debris was either land-based (38 percent), general-source debris (42 percent), or 

ocean-based (20 percent) recreational and commercial sources (Ribic et al., 2010); no items of military 

origin were differentiated. The inland portions along the southeast Atlantic coast contributed the lowest 

amounts of debris despite a 19 percent increase in coastal population from 1997 through 2007. The 

northeast Atlantic coast also contributed low amounts of marine debris, although the coastal population 

increased by 8 percent. Most of the marine debris inputs along the U.S. Atlantic coast was sourced from 

inland portions of the mid-Atlantic. With a 10 percent population increase, the types of debris included 

heavy land-based and general-source debris loads. Where fisheries were stable, ocean-based debris 

either stayed steady or declined.

Because of the limited overlap of crocodilian habitats and marine debris, marine debris as an 

entanglement or ingestion hazard for the American crocodile and American alligator is not likely a 

concern for crocodilian conservation. There is one reported mortality of an estuarine crocodile 

(Crocodylus porosus) in Australia entangled by plastic marine debris (Ceccarelli, 2009); however, Platt 

and Thorbjarnarson et al. (2006) suggested that accidental drowning in monofilament fishing nets was 

likely a significant source of mortality for American crocodiles in Belize in conservation areas where 

poaching is not likely to occur. Outside of conservation areas in Belize, the authors found that poaching 

was a major cause of crocodile deaths, in addition to drownings in derelict and active fishing nets.

Terrapin drowning events are most often associated with bycatch in crab pots (Roosenburg et al., 1997)

as well as derelict crab traps (Bilkovic et al., 2014); however, marine debris in estuarine environments 

likely pose an entanglement hazard for diamondback terrapins.

3.8.2.2 Endangered Species Act-Listed Species

As shown in Table 3.8-1, there are seven species of reptiles listed as Endangered or Threatened under 

the ESA in the Study Area. Life history descriptions of these species are provided in more detail in the 

following sections.
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Table 3.8-1: Current Regulatory Status and Presence of Endangered Species Act-Listed 

Reptiles in the Study Area

Species Name and Regulatory Status Presence in Study Area

Common 

Name

Scientific Name

Endangered 

Species Act 

Status

Open Ocean Large Marine 

Ecosystem

Inshore Waters

Family Cheloniidae (hard-shelled sea turtles)

Green 

Turtle

(North 

Atlantic 

DPS, South 

Atlantic 

DPS)

Chelonia mydas Threatened1

North 

Atlantic 

Subtropical 

Gyre, Gulf 

Stream

Northeast 

U.S. Continental 

Shelf, Southeast 

U.S. Continental 

Shelf, Caribbean 

Sea, Gulf of 

Mexico

Chesapeake Bay, 

Narragansett Bay, 

Kings Bay, Port 

Canaveral, St. Andrew 

Bay, Corpus Christi 

Bay

Hawksbill 

Turtle

Eretmochelys 

imbricata Endangered2

North 

Atlantic 

Subtropical 

Gyre, Gulf 

Stream

Northeast 

U.S. Continental 

Shelf, Southeast 

U.S. Continental 

Shelf, Caribbean 

Sea, Gulf of 

Mexico

NA

Kemp’s 

Ridley 

Turtle

Lepidochelys 

kempii Endangered

North 

Atlantic 

Subtropical 

Gyre, Gulf 

Stream

Northeast 

U.S. Continental 

Shelf, Southeast 

U.S. Continental 

Shelf, Gulf of 

Mexico

Narragansett Bay, 

Chesapeake Bay, 

Corpus Christi Bay 

Loggerhead 

Turtle

(Northwest 

Atlantic 

Ocean DPS)

Caretta caretta

Threatened/

Endangered3

North 

Atlantic 

Subtropical 

Gyre, Gulf 

Stream

NewfoundlandLabrador Shelf, 

Scotian Shelf, 

Northeast 

U.S. Continental 

Shelf, Southeast 

U.S. Continental 

Shelf, Caribbean 

Sea, Gulf of 

Mexico 

Narragansett Bay, 

Chesapeake Bay, St. 

Andrew Bay, Kings 

Bay, Port Canaveral
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Table 3.8-1: Current Regulatory Status and Presence of Endangered Species Act-Listed 

Reptiles in the Study Area (continued)

Species Name and Regulatory Status Presence in Study Area

Common 

Name

Scientific Name

Endangered 

Species Act 

Status

Open Ocean Large Marine 

Ecosystem

Inshore waters

Family Dermochelyidae (leatherback sea turtle)

Leatherback 

Turtle

Dermochelys 

coriacea Endangered

North 

Atlantic 

Subtropical 

Gyre, Gulf 

Stream

NewfoundlandLabrador Shelf, 

Scotian Shelf, 

Northeast 

U.S. Continental 

Shelf, Southeast 

U.S. Continental 

Shelf, Caribbean 

Sea, Gulf of 

Mexico

Narragansett Bay, 

Chesapeake Bay, Port 

Canaveral

Family Crocodylidae (true crocodiles)

American 

Crocodile

Crocodylus 

acutus

Threatened NA

Southeast 

U.S. Continental 

Shelf, Gulf of 

Mexico

NA

American 

Alligator

Alligator 

mississippiensis

Threatened 

due to 

similarity of 

appearance4

NA

Southeast 

U.S. Continental 

Shelf, Gulf of 

Mexico

Kings Bay, Port 

Canaveral, St. Andrew 

Bay, Corpus Christi 

Bay

1 On April 6, 2016, the NMFS and USFWS listed the Central West Pacific, Central South Pacific, and Mediterranean distinct 

population segments as endangered, while listing the other eight distinct population segments (Central North Pacific, 

East Indian-West Pacific, East Pacific, North Atlantic, North Indian, South Atlantic, Southwest Indian, and Southwest 

Pacific) as threatened. The AFTT Study Area shares portions of the geographic extents identified for the North 

Atlantic distinct population segment, including breeding populations along the U.S. Atlantic and Gulf of 

Mexico coasts.

2 Hawksbills have been recorded in the Study Area rarely; occurrence in the Northeast U.S. Continental Shelf Large Marine 

Ecosystem is extralimital (outside of their normal range).

3 On September 22, 2011, the NMFS and USFWS listed the North Pacific Ocean, South Pacific Ocean, North Indian Ocean, 

Northeast Atlantic Ocean, and Mediterranean Sea distinct population segments of the loggerhead sea turtle as 

endangered under the ESA, while the other four distinct population segments (the Southeast Indo-Pacific Ocean, 

Southwest Indian Ocean, Northwest Atlantic Ocean, and South Atlantic Ocean) are listed as threatened. The AFTT 

Study Area shares portions of the geographic extents identified for the Northwest Atlantic Ocean distinct 

population segment. 

4 The American alligator is listed under the Endangered Species Act (ESA) classification of "threatened due to similarity of 

appearance" to the American crocodile.

Sources: 81 Federal Register 20057, 35 Federal Register 18319, 35 Federal Register 8491, 43 Federal Register 32800, 76 

Federal Register 58868

Note: NA = not applicable
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3.8.2.2.1 Green Turtle (Chelonia mydas)

3.8.2.2.1.1 Status and Management

The green sea turtle was first listed under the ESA in 1978. In 2016, the NMFS and USFWS reclassified 

the species into 11 “distinct population segments,” which maintains federal protections while providing 

a more tailored approach for managers to address specific threats facing different populations (see the 

NMFS and USFWS Final Rule published on April 6, 2016). The geographic areas that include these distinct 

population segments are: (1) North Atlantic Ocean, (2) Mediterranean Sea, (3) South Atlantic Ocean, 

(4) Southwest Indian Ocean, (5) North Indian Ocean, (6) East Indian Ocean – West Pacific Ocean, 

(7) Central West Pacific Ocean, (8) Southwest Pacific Ocean, (9) Central South Pacific Ocean, (10) Central 

North Pacific Ocean, and (11) East Pacific Ocean.

Only the North Atlantic distinct population segment (which was listed as threatened) is within the Study 

Area and is discussed further in the document. It should be noted, however, that North Atlantic green 

sea turtle populations have minimal mixing (gene flow) with the South Atlantic regions and no mixing 

with the Mediterranean region, and juvenile turtles from the North Atlantic may occasionally use south 

Atlantic or Mediterranean foraging grounds (Seminoff et al., 2015).

Critical habitat is designated within the Study Area (Figure 3.8-4). In 1998, critical habitat was designated 

for green sea turtles in coastal waters around Culebra Island, Puerto Rico, from the mean high water line 

seaward to three nautical miles (NM) to include Culebra’s outlying Keys (63 Federal Register 46693). The 

essential physical and biological features of this critical habitat include (1) seagrass beds, which provide 

valuable foraging habitat; (2) coastal waters of Culebra, which serve as a developmental habitat and 

support juvenile, subadult, and adult green sea turtle populations; and (3) coral reefs and other 

topographic features that provide shelter (63 Federal Register 46693). Puerto Rico’s Culebra Island, 

where the NMFS and USFWS designated Critical Habitat for green sea turtles, supports important 

habitat for juveniles, subadults, and a small population of adults. Green turtles are most abundant at 

Culebrita, Mosquito Bay, Puerto Manglar, and Tamarindo Grande, probably due to the presence of 

dense seagrass beds in those areas (Collazo et al., 1992; Patrício et al., 2016; Patrício et al., 2014). Higher 

concentrations and abundance in other locations throughout the green sea turtle range also support 

dense marine vegetation used as foraging grounds (Patrício et al., 2014; Seminoff et al., 2015).

3.8.2.2.1.2 Habitat and Geographic Range

The green sea turtle is distributed worldwide across tropical and subtropical coastal waters generally 

between 45 degrees (°) north and 40° south. After emerging from the nest, green sea turtle hatchlings 

swim to offshore areas where they float passively in major current systems; however, laboratory and 

modeling studies suggest that dispersal trajectories might also be shaped by active swimming 

(Christiansen et al., 2016; Putman & Mansfield, 2015). Post-hatchling green sea turtles forage and 

develop in floating Sargassum habitats of the open ocean. At the juvenile stage (estimated at five to 

six years), they leave the open-ocean habitat and retreat to protected lagoons and open coastal areas 

that are rich in seagrass or marine algae (Bresette et al., 2006), where they will spend most of their lives 

(Bjorndal & Bolten, 1988). The optimal developmental habitats for late juveniles and foraging habitats 

for adults are warm shallow waters (3–5 m), with abundant submerged aquatic vegetation and close to 

nearshore reefs or rocky areas (Holloway-Adkins, 2006; Seminoff et al., 2002; Seminoff et al., 2015). 

Climate change and ocean warming trends may impact the habitat and range of this species over time 

(Fuentes et al., 2013). These impacts apply to all sea turtle species and are discussed in Section 

3.8.2.1.5.5 (Climate Change).
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Four regions within the North Atlantic distinct population segment support nesting concentrations: 

Costa Rica (Tortuguero), Mexico (Campeche, Yucatan, and Quintana Roo), United States (Florida), and 

Cuba. The highest concentration of nesting is in Tortuguero, and in Mexico, where nesting occurs 

primarily along the Yucatan Peninsula. Most green sea turtle nesting occurs in along the Atlantic coast of 

eastern central Florida, with smaller concentrations along the Gulf coast and Florida Keys. In Cuba, 

nesting primarily occurs on the extreme western tip of the country and on islands off the southern shore 

of Cuba. Nesting also occurs in the Bahamas, Belize, Cayman Islands, Dominican Republic, Haiti, 

Honduras, Jamaica, Nicaragua, Panama, Puerto Rico, Turks and Caicos Islands, North Carolina, South 

Carolina, Georgia, Texas, and Virginia.

Green sea turtles are known to live in the open-ocean waters of the Gulf Stream and North Atlantic Gyre 

during the first five to six years of life, but little is known about preferred habitat or general distribution 

during this life phase beyond the information presented in the introduction to this resource. Although 

information on migratory routes within this area is limited, recent research has shown that juvenile 

green sea turtles have the ability to migrate independently of ocean currents (directional and active 

swimming) to access productive foraging grounds (Christiansen et al., 2016; Putman & Mansfield, 2015; 

Ribic et al., 2010). The main source of information on distribution in the Study Area comes from 

U.S. fisheries bycatch. Green turtle post-hatchling and juvenile foraging grounds in the North Atlantic 

range from coral or nearshore reefs and seagrass beds, to inshore bays and estuaries (Bresette et al., 

1998; Plotkin & Amos, 1998). In the western North Atlantic, juvenile green sea turtles forage as far north 

as Cape Cod Bay, Massachusetts; as far east as Bermuda; and throughout the Caribbean. However, 

foraging adults are only found from the southernmost reach of the Florida peninsula (Witherington & 

Hirama, 2006). 

As ocean temperatures increase in the spring, green sea turtles migrate from southeastern U.S. waters 

to the estuarine habitats of Long Island Sound, Peconic Bay, Chesapeake Bay, and possibly Nantucket 

Sound, where an abundance of algae and eelgrass occurs. Peak occurrence in the Northeast U.S. 

Continental Shelf Large Marine Ecosystem is likely in September (Berry et al., 2000). During nonbreeding 

periods, adult and juvenile distributions may overlap in coastal feeding areas (Hirth, 1997; Weishampel 

et al., 2006). 

Juveniles use the estuarine and nearshore waters of central Florida throughout the year, including 

Pensacola Bay, St. Joseph Bay, Charlotte Harbor, Cedar Keys, Homosassa Springs, Crystal River, and 

Tampa Bay (Lamont et al., 2015; Langhamer et al., 2016; Renaud et al., 1995; Seminoff et al., 2015). In 

the northern Gulf of Mexico, green sea turtles prefer the coastal habitats of southern Texas (e.g.,

lagoons, channels, inlets, bays) where seagrass beds and macroalgae are abundant, including Texas’ 

Laguna Madre (Renaud et al., 1995). As water temperatures rise from April to June, green sea turtle 

numbers increase in the continental shelf waters of the Gulf of Mexico Large Marine Ecosystem, off 

Galveston Bay, and in those waters associated with the continental shelf break northeast of Corpus 

Christi. Green sea turtles found in these deeper waters are likely adults migrating from resident foraging 

grounds to distant nesting grounds (Meylan, 1995). The sparse sighting records in Louisiana and Texas 

waters, as well as nesting records on the southern Texas coast, indicate that green sea turtles are found

in the northwestern Gulf of Mexico during spring but in far fewer numbers than in the northeastern 

Gulf.
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Note: AFTT: Atlantic Fleet Training and Testing

Figure 3.8-4: Critical Habitat Designated for the Green Sea Turtles in the Study Area
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3.8.2.2.1.3 Population Trends

Green turtle nesting has shown an exponential increase over the past 29 years, with nests reported 

along the Florida panhandle, Florida Gulf coast, Florida Atlantic coast, Georgia, Alabama, South Carolina, 

North Carolina, and Texas, along with the wider Caribbean, Yucatan Coast of Mexico, Suriname, and Isla

Trindade (Brazil) (Florida Fish and Wildlife Conservation Commission, 2017; Seminoff et al., 2015). A 

green sea turtle nested at Cape Henlopen State Park in Delaware in August 2011, which was the first 

green sea turtle nesting ever observed north of Virginia (Murray, 2011). While nesting abundance has 

been monitored at these sites for decades, in-water abundance in the Gulf of Mexico or along the 

Atlantic coast remains unavailable (Seminoff et al., 2015). Adult and juvenile males and females from 

nesting colonies in the Yucatan Peninsula (Mexico), Aves Island (Venezuela), Galibi Reserve (Suriname), 

and Isla Trindade (Brazil) could also occur in the waters of the Study Area.

The Marine Turtle Specialist Group (under the International Union for Conservation of Nature’s Species 

Survival Commission) conducted a worldwide analysis of the green sea turtle population based on 

32 index nesting sites around the world (Seminoff & Marine Turtle Specialist Group Green Turtle Task 

Force, 2004). The analysis concluded there has been a 48–65 percent decline in the number of females 

nesting annually over the past 100 to 150 years. About 80 percent of nesting in the Western Atlantic 

Ocean occurs at Tortuguero, Costa Rica (Seminoff et al., 2015). 

Generally, nesting trends in the Western Atlantic Ocean are stable to increasing and are increasing in 

Florida, as shown by annual total nest counts for green sea turtles on Florida’s index beaches (27 out of 

215 nesting beaches selected to monitor long-term nesting trends). Green turtle nest counts in Florida 

have increased by a factor of 80 since counts began in 1989 (Florida Fish and Wildlife Conservation 

Commission, 2017). In 2017, green turtle nest counts on the 27 core index beaches reached a new 

record high with almost 39,000 nests recorded. Green turtles set record highs in 2011, 2013, 2015, and 

2017. The nest count in 2017 was almost 40 percent higher than the 2015 previous record. Nesting 

green turtles tend to follow a two-year reproductive cycle. Typically, there are wide year-to-year 

fluctuations in the number of nests recorded (Florida Fish and Wildlife Conservation Commission, 2017).

Although these data appear to present an encouraging global outlook, datasets for fewer than half of 

these sites (9 of 23) document a time span of longer than 20 years, which limits the strength of the data. 

A standard timeframe of data that would be necessary to properly assess population trends is three 

generations, which for the green sea turtle is between 100 and 150 years. Consequently, the impact of 

changes in juvenile recruitment that occurred four decades ago may not yet be manifested in changes in 

nesting abundance (Seminoff et al., 2015).

3.8.2.2.1.4 Predator and Prey Interactions

The green sea turtle is the only species of sea turtle that, as an adult, primarily consumes plants and 

other types of vegetation (Mortimer, 1995; Nagaoka et al., 2012). While primarily herbivorous, a green 

sea turtle’s diet changes substantially throughout its life. Very young green sea turtles are omnivorous 

(Bjorndal, 1997). Salmon et al. (2004) reported that post-hatchling green sea turtles were found to feed 

near the surface on seagrasses or at shallow depths on comb jellies and unidentified gelatinous eggs off 

the coast of southeastern Florida. Nagaoka et al. (2012) analyzed 50 incidentally caught juvenile green 

sea turtles in Brazil and determined that juveniles consumed an omnivorous diet, including terrestrial 

plants (floating in the water), algae, invertebrates, and seagrass. Black mangrove leaves were of the 

greatest importance to diet at this location (adjacent to a black mangrove forest). Sampson and Giraldo 

(2014) observed opportunistic foraging of tunicates (a type of filter-feeding marine invertebrate) by 

green sea turtles in the eastern tropical Pacific. Pelagic juveniles smaller than 8–10 inches (in.) in length 

eat worms, young crustaceans, aquatic insects, grasses, and algae (Bjorndal, 1997). After settling in 
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coastal juvenile developmental habitat at 8–10 in. in length, they eat mostly mangrove leaves, seagrass 

and algae (Balazs et al., 1994; Nagaoka et al., 2012). Research indicates that green sea turtles in the 

open-ocean environment, and even in coastal waters, also consume jellyfish, sponges, and sea pens

(Hatase et al., 2006; Seminoff et al., 2015). Fukuoka et al. (2016) also noted that juvenile green sea 

turtles were at higher risk to marine debris ingestion, likely due to the resemblance of small pieces of 

debris to omnivorous dietary items.

The loss of eggs to land-based predators such as mammals, snakes, crabs, and ants occurs on some 

nesting beaches. As with other sea turtles, hatchlings may be preyed on by birds and fish. Sharks are the 

primary nonhuman predators of juvenile and adult green sea turtles at sea (National Marine Fisheries 

Service & U.S. Fish and Wildlife Service, 1991; Seminoff et al., 2015).

3.8.2.2.1.5 Species-Specific Threats

In addition to the general threats described previously in Section 3.8.2.1.5 (General Threats), damage to 

seagrass beds and declines in seagrass distribution can reduce foraging habitat for green sea turtles 

(National Marine Fisheries Service & U.S. Fish and Wildlife Service, 1991; Seminoff et al., 2015). Green 

sea turtles are susceptible to the disease fibropapillomatosis, which causes tumor-like growths 

(fibropapillomas) resulting in reduced vision, disorientation, blindness, physical obstruction to swimming 

and feeding, increased susceptibility to parasites, and increased susceptibility to entanglement (Balazs, 

1986; National Marine Fisheries Service & U.S. Fish and Wildlife Service, 1991; Patrício et al., 2016; Work 

& Balazs, 2013). Some populations (e.g., the Florida population) have begun to show resistance to the 

disease, but it remains an issue for others, such as Pacific populations, and Hawaii’s green sea turtles in 

particular (Chaloupka et al., 2009; Seminoff et al., 2015). Patrício et al. (2016) noted that 

fibropapillomatosis recovery was likely in a resident population in Puerto Rico, with tumor regression 

occurring within three years of formation. Other factors, such as increased stressors and selection of 

healthy turtles during illegal poaching activities may increase susceptibility of turtles (Patrício et al., 

2016). 

3.8.2.2.2 Hawksbill Sea Turtle (Eretmochelys imbricata)

3.8.2.2.2.1 Status and Management

The hawksbill turtle is listed as endangered under the ESA (35 Federal Register 8491). While the current 

listing as a single global population remains valid, data may support separating populations at least by 

ocean basin under the distinct population segment policy (National Marine Fisheries Service & U. S. Fish 

and Wildlife Service, 2007). The most recent status review document was released in 2013 by the NMFS 

and USFWS (National Marine Fisheries Service, 2013a).

Critical habitat has been designated in the Study Area, as shown in Figure 3.8-5. Critical habitat for 

hawksbill terrestrial nesting areas was designated in Puerto Rico in 1982. This designation includes

portions of Mona Island, Culebra Island, Cayo Norte, and Island Culebrita, from the mean high tide line 

to a point 150 meters (m) from shore. Critical marine habitat was also designated in 1998 for the coastal 

waters surrounding Mona and Monito Islands, Puerto Rico, from the mean high water line seaward to 

3 NM (National Marine Fisheries Service, 2013a). Critical habitat includes (1) coral reefs for food and 

shelter and (2) nesting beaches. The essential physical and biological features of coral reefs support a 

large, long-term juvenile hawksbill population, in addition to subadults and adults. The types of sponges 

that hawksbills prefer for food are found on the reefs around these islands. Reef ledges and caves also 

provide resting areas and protection from predators. Nesting beaches on Mona Island support the 
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largest population of nesting hawksbill turtles in the U.S. Caribbean (National Marine Fisheries Service, 

2013a).

3.8.2.2.2.2 Habitat and Geographic Range

The hawksbill is the most tropical of the world’s sea turtles, rarely occurring above 35° north or below 

30° south (Witzell, 1983). While hawksbills are known to occasionally migrate long distances in the open 

ocean, they are primarily found in coastal habitats and use nearshore areas more exclusively than other 

sea turtles. Hatchlings in the AFTT Study Area are believed to occupy open-ocean waters, associating 

themselves with surface algal mats in the Atlantic Ocean (Parker, 1995; Witherington & Hirama, 2006; 

Witzell, 1983). Juveniles leave the open-ocean habitat after three to four years and settle in coastal 

foraging areas, typically coral reefs but occasionally seagrass beds, algal beds, mangrove bays, and 

creeks (Mortimer & Donnelly, 2008). 

Less is known about the hawksbill’s oceanic stage, but it is thought that neonates live in the oceanic 

zone where water depths are greater than 200 m. Distribution in the oceanic zone may be influenced by 

surface gyres (Leon & Bjorndal, 2002; National Marine Fisheries Service, 2013a).

Juveniles and adults share the same foraging areas, including tropical nearshore waters associated with 

coral reefs, hard bottoms, or estuaries with mangroves (Musick & Limpus, 1997). In nearshore habitats, 

resting areas for late juvenile and adult hawksbills are typically in deeper waters, such as sandy bottoms 

at the base of a reef flat (Houghton et al., 2003). As they mature into adults, hawksbills move to deeper 

habitats and may forage to depths greater than 90 m. During this stage, hawksbills are seldom found in 

waters beyond the continental or insular shelf unless they are in transit between distant foraging and 

nesting grounds (Renaud et al., 1996). Ledges and caves of coral reefs provide shelter for resting 

hawksbills during both day and night, where an individual often inhabits the same resting spot. 

Hawksbills are also found around rocky outcrops and high-energy shoals, where sponges are abundant, 

and in mangrove-fringed bays and estuaries. Female hawksbills return to their natal beach every two to 

three years to nest at night, every 14—16 days during the nesting season. 

In the Caribbean Sea and Gulf of Mexico Large Marine Ecosystems, the principal nesting season is from 

June to November (Hillis, 1990), with only rare nesting activity in Florida, which is restricted to Volusia, 

Martin, Palm Beach, Broward, Miami-Dade, and Monroe Counties (Meylan et al., 2006; National Marine 

Fisheries Service, 2013a). Throughout their range, hawksbill turtles typically nest in low densities; 

aggregations of nesting activity that usually include approximately 20 nests, but can exceed a few 

hundred nests in some locations (National Marine Fisheries Service, 2013a).

The greatest hawksbill turtle numbers in the southeastern United States are found off the coast of 

southern Florida. There, hawksbills are documented from winter to summer from Palm Beach, Broward, 

and Dade Counties to the Florida Keys, and to coastal waters just northwest of Tampa Bay, where the 

northernmost stranding records typically occur. Foraging juveniles and adults settle on coral reef and 

hard-bottom habitats off southern Florida throughout the year (Musick & Limpus, 1997). Hawksbill 

turtle sightings in waters off the Florida panhandle, Alabama, Mississippi, Louisiana, and Texas (Rester & 

Condrey, 1996; Witzell, 1983), though rare, are likely of early juveniles born on nesting beaches in 

Mexico that have drifted north with the dominant currents (National Marine Fisheries Service & U.S. 

Fish and Wildlife Service, 1993). 
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Note: AFTT: Atlantic Fleet Training and Testing

Figure 3.8-5: Critical Habitat Designation for the Hawksbill Sea Turtle within the Study Area
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3.8.2.2.2.3 Population Trends

Since the last five-year status review for hawksbill turtles (National Marine Fisheries Service & U. S. Fish 

and Wildlife Service, 2007), recent information on nesting populations in the eastern Pacific and the 

Nicaragua nesting population in the western Caribbean appears to have improved (National Marine 

Fisheries Service, 2013a). Global trends and distribution, however, have remained the same. An 

estimated 22,004–29,035 turtles nest each year in the Atlantic, Indian, and Pacific oceans; of these, 

3,626–6,108 occur in the Atlantic Ocean alone. Historical population trends showed overall declines for 

the 20- to 100-year period of evaluation. Among the 88 sites worldwide for which historic trends could 

be assessed, 63 (72 percent) showed a decline. Shorter-term population trends, however, show more 

increases at some nesting sites, particularly in the north Atlantic and Pacific Oceans with 10 (24 percent) 

increasing, 3 (7 percent) stable, and 28 (68 percent) decreasing (National Marine Fisheries Service, 

2013a). 

3.8.2.2.2.4 Predator and Prey Interactions

Hawksbill turtles have a varying diet and feeding habitat preference throughout different lifestages. 

Post-hatchling hawksbills feed on floating habitats (e.g., Sargassum) in the open ocean (Bresette et al., 

1998; Plotkin & Amos, 1998; Van Houtan et al., 2016). During the later juvenile stage, hawksbills are 

considered omnivorous, feeding on sponges, sea squirts, algae, molluscs, crustaceans, jellyfish, and 

other aquatic invertebrates (Bjorndal, 1997). Older juveniles and adults are more specialized, feeding 

primarily on sponges, which compose as much as 95 percent of their diet in some locations (Meylan, 

1988; Witzell, 1983). As adults, Hawksbill turtles fill a unique ecological niche in marine and coastal 

ecosystems, supporting the natural functions of coral reefs by keeping sponge populations in check (Hill, 

1998; Leon & Bjorndal, 2002). Feeding on sponges helps to control populations of sponges that may 

otherwise compete for space with reef-building corals (Hill, 1998; Leon & Bjorndal, 2002). 

The loss of hawksbill eggs to predators such as feral pigs, mongoose, rats, snakes, crabs, and ants is a 

severe problem on some nesting beaches. As with other sea turtles, hatchlings may be preyed on by 

birds and fish. Sharks are the primary nonhuman predators of juvenile and adult hawksbills at sea 

(National Ocean Service, 2016; Southern California Marine Institute, 2016).

3.8.2.2.2.5 Species-Specific Threats

In addition to the general threats described in Section 3.8.2.1.5 (General Threats), the greatest threat to 

hawksbills is harvest for commercial and subsistence use. Direct harvest of eggs and nesting adult 

females from beaches, as well as direct hunting of turtles in foraging areas, continues in many countries. 

International trade of tortoise shells is thought to be the most important factor endangering the species 

worldwide. The second-most significant threat to hawksbill sea turtles is loss of nesting habitat caused 

by the expansion of human populations in coastal areas of the world, as well as the increased 

destruction or modification of coastal ecosystems to support tourism (National Marine Fisheries Service 

& U.S. Fish and Wildlife Service, 1998a). Coastal pollution as a result of increased development degrades 

water quality, particularly coral reefs, which are primary foraging areas for hawksbills. Due to their 

preference for nearshore areas, hawksbills are particularly susceptible to nearshore fisheries gear such 

as drift nets, entanglement in gill nets, and capture on fish hooks of fishermen (National Marine 

Fisheries Service & U.S. Fish and Wildlife Service, 1993; National Marine Fisheries Service, 2013a).
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3.8.2.2.3 Kemp’s Ridley Sea Turtle (Lepidochelys kempii)

3.8.2.2.3.1 Status and Management

The Kemp’s ridley sea turtle is listed as a single population and is classified as endangered under the ESA 

(35 Federal Register 18319). The most recent status review was released in 2015 by the USFWS and 

NMFS (National Marine Fisheries Service & U.S. Fish and Wildlife Service, 2015). There is no critical 

habitat currently designated for this species. In 2010, the USFWS and NMFS received a petition to 

designate critical habitat on nesting beaches in Texas and along gulf coast states. The petition is still 

under consideration, and no proposed rule on the establishment of critical habitat has been released by 

either agency.

3.8.2.2.3.2 Habitat and Geographic Range

Kemp's ridley turtle nesting is essentially limited to the beaches of the western Gulf of Mexico, primarily 

in Tamaulipas, Mexico. Nesting also occurs in Veracruz, and a few historical records exist for Campeche, 

Mexico. Since 1978, the U.S. National Park Service, in partnership with USFWS, NMFS, Texas Parks and 

Wildlife Department, and the Instituto Nacional de Pesca (a Mexican federal agency), has led an effort to 

increase Kemp's ridley turtle nesting at Padre Island National Seashore, south Texas, to form a 

secondary nesting colony to safeguard against extinction (National Marine Fisheries Service & U.S. Fish 

and Wildlife Service, 2011). Occasional nesting has been reported from Florida, Alabama, Georgia, South 

Carolina, North Carolina, with the furthest north nesting occurring in Virginia (in 2012 and 2014) 

(National Marine Fisheries Service & U.S. Fish and Wildlife Service, 2015). Shaver et al. (2016) has noted 

that the known nesting range for the Kemp’s ridley turtle has expanded since the late 1980s, possibly 

due to “head start” releases in Florida. Head starting is an accepted conservation intervention involving 

captive rearing and release of sea turtles, but the range expansion may also be associated with 

increased nesting numbers (Shaver et al., 2016).

Habitats frequently used by Kemp’s ridley sea turtles in U.S. waters are warm-temperate to subtropical 

sounds, bays, estuaries, tidal passes, shipping channels, and beachfront waters, where their preferred 

food, the blue crab, is abundant (Lutcavage & Musick, 1985). The general migration pattern of females 

begins with travel through relatively shallow migratory corridors toward the nesting beach in the late 

winter in order to arrive at the nesting beach by early spring. Males and females can loop along the U.S. 

continental shelf large marine ecosystem in the spring, and back down the southeast U.S. continental 

shelf in the fall. From nesting beaches in the Gulf of Mexico, the migratory corridor traverses neritic 

areas of the Mexico and U.S. Gulf coasts with a mean water depth of 26 m approximately 20 kilometers 

(km) from the coast, occurring in late May through August with a peak in June (Shaver et al., 2016). 

Kemp’s ridley turtles that headed north and east traveled as far as the waters off southwest Florida; 

however, waters off the upper Texas coast through Mississippi, especially off Louisiana, appear to be a 

“hotspot” as turtles returned to the area to forage over multiple years (National Marine Fisheries 

Service & U.S. Fish and Wildlife Service, 2015).

Evidence suggests that post-hatchling and small juvenile Kemp’s ridley sea turtles, similar to loggerhead 

and green sea turtles of the same region, forage and develop in floating Sargassum habitats of the North 

Atlantic Ocean. Juveniles migrate to habitats along the U.S. Atlantic continental shelf from Florida to 

New England (Morreale & Standora, 1998; Peña, 2006) at around two years of age. A tag study funded 

by the U.S. Navy and completed by Barco and Lockhart (2015) indicates that waters off of Norfolk Naval 

Base and the Chesapeake Bay may be foraging grounds while juveniles are in transit along the Atlantic 

coast. Migrating juvenile Kemp’s ridleys travel along coastal corridors generally shallower than 50 m in 

bottom depth (National Marine Fisheries Service & U.S. Fish and Wildlife Service, 2011). Suitable 

developmental habitats are seagrass beds and mud bottoms in waters of less than 10 m bottom depth 
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and with sea surface temperatures between 72 degrees Fahrenheit (°F) and 90°F (22 degrees Celsius [°C]

and 32°C) (Coyne et al., 2000).

Important year-round developmental habitats in the northern Gulf of Mexico include the western coast 

of Florida (particularly the Cedar Keys area), the eastern coast of Alabama, and the mouth of the 

Mississippi River (Lazell, 1980; Lutcavage & Musick, 1985; Weber, 1995). Coastal waters off western 

Louisiana and eastern Texas also provide adequate habitats for bottom feeding. Verkaik et al. (2016)

found strong site fidelity within and between years to the Mississippi Sound during spring, summer, and 

fall for juvenile Kemp’s ridley turtles. During the winter, turtles migrated to the nearshore waters 

of Louisiana.

As adults, many turtles remain in the Gulf of Mexico Large Marine Ecosystem, with only occasional 

occurrence in the Atlantic Ocean (National Marine Fisheries Service & U.S. Fish and Wildlife Service, 

2011). While the understanding of adult males’ distribution and habitat usage is limited, satellite 

telemetry of males caught near Padre Island, Texas, indicates that they do not migrate, remaining 

year-round in nearshore waters of less than 50 m. Many of the post-nesting females from Rancho Nuevo 

migrate north to areas offshore of Texas and Louisiana (Marquez, 1994). Farther south, some 

post-nesting females migrate from Rancho Nuevo to the northern and western Yucatán Peninsula in the 

Southern Gulf of Mexico, which contains important seasonal foraging sites for adult females—

specifically the Bay of Campeche (Marquez, 1994; Márquez, 1990; Pritchard & Marquez, 1973).

3.8.2.2.3.3 Population Trends

The earliest estimate of population size was derived from analyzing archival film footage of a large 

arribada (mass nesting) event in 1947 and other life history information of the Kemp’s ridley turtle. From 

these data sources and the analysis of the raw footage, Gonzalez (2011) suggest that the Kemp’s ridley 

population during and prior to the 1947 nesting season was relatively robust, with the estimated 

number of nests exceeding 121,000. The lowest point in the decline of Kemp’s ridleys occurred in 1985 

(approximately 700 nests), representing a 99 percent decline in the number of nests compared to the 

1947 estimate. Although the Kemp’s ridley population has shown increases since 1985, the rate of 

recovery has declined in recent years. In 2010, Kemp’s ridley nesting showed a steep decline 

(35 percent) followed by some recovery to 2009 levels, with other declines in 2013 and 2014 (Caillouet 

et al., 2016; National Marine Fisheries Service & U.S. Fish and Wildlife Service, 2015; Shaver et al., 2016). 

The numbers of Kemp’s ridley sea turtle nests counted along Texas beaches have increased from 2015 

(159 nests) to 2016 (186 nests) and 2017 (353 nests) (Shaver, 2018).

Subadult and adult females were presumed to have suffered a high mortality rate in 2009, which has 

manifested in a 40 percent decline in nesting activity in Mexico and Texas. The causes of this mortality 

event and the ramifications for population recovery and growth rates are still being analyzed (National 

Marine Fisheries Service & U.S. Fish and Wildlife Service, 2015).

3.8.2.2.3.4 Predator and Prey Interactions

Kemp’s ridley sea turtles feed primarily on crabs but are also known to prey on molluscs, shrimp, fish, 

jellyfish, and plant material (Frick et al., 1999; Marquez, 1994; Seney, 2016). Plant material, primarily 

macroalgae, is likely consumed incidentally with invertebrate prey items (Seney, 2016). Blue crabs and 

spider crabs are important prey species for the Kemp’s ridley (Keinath et al., 1987; Lutcavage & Musick, 

1985; Seney, 2016). They may also feed on shrimp fishery bycatch (National Marine Fisheries Service & 

U.S. Fish and Wildlife Service, 1993), and Servis et al. (2015) noted instances of fish and horseshoe crab 

predation, indicating that Kemp’s ridley turtles may opportunistically feed to supplement their diet. 
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Major predators of Kemp’s ridley sea turtle eggs and hatchlings on nesting beaches include raccoons, 

dogs, feral pigs, skunks, badgers, and fire ants. Predatory fishes such as jackfish and redfish may feed on 

hatchlings at sea. Sharks are the primary predator of juvenile and adult Kemp’s ridley sea turtles 

(National Marine Fisheries Service & U.S. Fish and Wildlife Service, 2011).

3.8.2.2.3.5 Species-Specific Threats

Because the Kemp’s ridley turtle is very range limited, the general threats facing sea turtles described 

previously may increase impacts on this species. For example, energy extraction and development in the 

Gulf of Mexico are a particular threat to Kemp’s ridley sea turtles because most of the nesting activity 

occurs there (Shaver & Caillouet, 1998). Kemp’s ridley sea turtles periodically strand on beaches in 

Mexico covered in crude oil, and most of the turtles found injured and dead following the Deepwater 

Horizon oil spill were Kemp’s ridley sea turtles (National Marine Fisheries Service & U.S. Fish and Wildlife 

Service, 2011; Wilkin et al., 2017). It should be noted that the dramatic reversal of an increasing nesting 

trend in the Gulf of Mexico followed the Deepwater Horizon, and the removal of a cohort of Kemp’s 

ridleys that would be sexually mature now may be responsible for declines shown in 2013 and 2014 

(Caillouet et al., 2016; Putman et al., 2015a). Shrimp trawling in the southeastern U.S. Atlantic and Gulf 

of Mexico was once a significant threat to Kemp’s ridleys; however, the use of turtle excluder devices 

and the general decline of shrimp fishing in recent years have greatly reduced mortality levels (Caillouet 

et al., 2008; Nance et al., 2012). Vehicle activity on sea turtle nesting beaches can also disrupt the 

nesting process, crush nests, and create ruts and ridges in the sand that pose obstacles to turtles 

(National Marine Fisheries Service & U.S. Fish and Wildlife Service, 2011). Beach vehicular driving is 

permitted on most beaches in Texas, where adult turtles and hatchlings have been crushed by passing 

vehicles, as well as on some beaches in Mexico.

3.8.2.2.4 Loggerhead Turtle (Caretta caretta)

3.8.2.2.4.1 Status and Management

In 2009, a status review conducted for the loggerhead (the first turtle species subjected to a complete 

stock analysis) identified nine distinct population segments within the global population (Conant et al., 

2009). In a September 2011 rulemaking, the NMFS and USFWS listed five of these distinct population 

segments as endangered and kept four as threatened under the ESA, effective as of October 24, 2011

(76 Federal Register 58868). The North Pacific Ocean, South Pacific Ocean, North Indian Ocean, 

Northeast Atlantic Ocean, and Mediterranean Sea distinct population segments of the loggerhead sea 

turtle are classified as endangered under the ESA, and the Southeast Indo-Pacific Ocean, Southwest 

Indian Ocean, Northwest Atlantic Ocean, and South Atlantic Ocean distinct population segments are 

classified as threatened. The Northwest Atlantic Ocean distinct population segment is the only one that 

occurs entirely within the Study Area; however, loggerheads from other distinct population segments 

may occur rarely within the Study Area. For example, mixing likely occurs, rarely, with South Atlantic 

loggerheads enabling a limited amount of gene flow between these two distinct population segments

(National Marine Fisheries Service, 2010; Tucker et al., 2014). Critical Habitat has been designated within 

the Study Area, and is shown in Figure 3.8-6 (for critical habitat along the mid-Atlantic coast), 

Figure 3.8-7 (for critical habitat along southeast Atlantic states), and Figure 3.8-8 (for critical habitat in 

the Gulf of Mexico). 

Specific areas designated as critical habitat include 38 occupied marine areas within the range of the 

Northwest Atlantic Ocean distinct population segment of loggerhead turtles (79 Federal Register 39856). 

In order to characterize different use patterns and concentrations both seasonally and geographically, 

the NMFS named five different habitat types that comprise the critical habitat designation, which 
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include (1) nearshore reproductive habitat (portions of nearshore waters adjacent to nesting beaches 

used by females and hatchlings to egress to open-water environments), (2) winter habitats (warm 

waters south of Cape Hatteras where juveniles and adults tend to concentrate during winter months), 

(3) breeding habitats (areas with high concentrations of both male and female adults during the 

breeding season in proximity to Florida migratory corridor and nesting grounds), (4) constricted 

migratory habitat (migratory corridors restricted in width), (5) Sargassum habitat (juvenile loggerhead 

developmental habitats where Sargassum supports adequate prey abundance and cover) (National 

Marine Fisheries Service, 2014b). Physical and biological features that support the five habitat types 

summarized above for loggerhead sea turtle conservation include oceanic conditions that would 

concentrate certain life-stage loggerheads together at different locations and in different seasons. The 

USFWS designated approximately 685 miles of nesting beaches (in North Carolina, South Carolina, 

Georgia, Florida, Alabama, and Mississippi) in a separate rulemaking (79 Federal Register 51264), which 

is also shown on Figure 3.8-6, Figure 3.8-7, and Figure 3.8-8.

None of these critical habitat areas include Department of Defense areas of Marine Corps Base Camp 

Lejeune (Onslow Beach), Cape Canaveral Air Force Station, Patrick Air Force Base, and Eglin Air Force 

Base, which are exempt from critical habitat designation because their Integrated Natural Resources 

Management Plans incorporate measures that provide a benefit for the conservation of the loggerhead 

sea turtle.

3.8.2.2.4.2 Habitat and Geographic Range

Loggerhead turtles occur in U.S. waters in habitats ranging from coastal estuaries to waters far beyond 

the continental shelf (Chapman & Seminoff, 2016; Dodd, 1988). Loggerheads typically nest on beaches 

close to reef formations and in close proximity to warm currents (Dodd, 1988), preferring beaches facing 

the ocean or along narrow bays (National Marine Fisheries Service, 2014b; Reece et al., 2013). Nesting in 

the Study Area occurs from April through September, with a peak in June and July (Dodd, 1988; 

Weishampel et al., 2006; Williams-Walls et al., 1983). Large nesting colonies exist in Florida, with more 

limited nesting along the Gulf coast and north through Virginia. At emergence, hatchlings swim to 

offshore currents and remain in the open ocean, often associating with floating mats of Sargassum

(Carr, 1986, 1987; Witherington & Hirama, 2006). Nesting activity within the North Atlantic Ocean 

distinct population segment include the eastern Bahamas, southwestern Cuba, the eastern Caribbean 

Islands, and numerous locations from the Yucatán Peninsula to Virginia (Conant et al., 2009; National 

Marine Fisheries Service & U.S. Fish and Wildlife Service, 2007; National Marine Fisheries Service, 2010). 

Within the United States, the highest concentration of loggerhead nesting occurs in Florida, discussed in 

more detail in Section 3.8.2.2.4.3 (Population Trends), with additional nesting reported in Texas, 

Alabama, Georgia, North Carolina, and Virginia. Genetic studies indicate that, although females routinely 

return to natal beaches, males may breed with females from multiple populations and facilitate gene 

flow (Bowen et al., 2005). 
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Notes: AFTT: Atlantic Fleet Training and Testing; OPAREA: Operating Area

Figure 3.8-6: Critical Habitat Designation for the Loggerhead Turtle within the Study Area: 

Mid-Atlantic
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Notes: AFTT: Atlantic Fleet Training and Testing; OPAREA: Operating Area

Figure 3.8-7: Critical Habitat Designation for the Loggerhead Turtle within the Study Area: 

Southeast
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Notes: AFTT: Atlantic Fleet Training and Testing; OPAREA: Operating Area

Figure 3.8-8: Critical Habitat Designation for the Loggerhead Turtle within the Study Area: Gulf of 

Mexico
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Migration between oceanic and nearshore habitats occurs during the juvenile stage as turtles move 

seasonally from open-ocean current systems to nearshore foraging areas (Bolten, 2003a; Mansfield, 

2006). After reaching a length of 40 centimeters (cm) (Carr, 1987), early juvenile loggerheads make a 

transoceanic crossing, swimming back to nearshore feeding grounds near their beach of origin in the 

western Atlantic Ocean (Bowen et al., 2004; Musick & Limpus, 1997). Juveniles are frequently observed 

in developmental habitats, including coastal inlets, sounds, bays, estuaries, and lagoons with depths less 

than 100 m (Hopkins-Murphy et al., 2003). Based on growth rate estimates, the duration of the 

open-ocean juvenile stage for North Atlantic loggerhead sea turtles is estimated to be 8.2 years 

(Bjorndal et al., 2000). 

Juvenile loggerhead sea turtles inhabit offshore waters in the North Atlantic Ocean. These offshore

habitats provide juveniles with an abundance of prey and sheltered locations where they can rest 

(Rosman et al., 1987). Loggerheads are generally observed in the northern extent of their range during 

the summer, in shallow water habitats with large expanses of open-ocean access. This summer 

distribution extends into the Gulf of Maine and waters over the Scotian Shelf, with some individuals 

venturing as far north as Newfoundland (Arendt et al., 2012; Bolten et al., 1992; National Marine 

Fisheries Service, 2010; Witherington & Hirama, 2006). Juveniles also use the strong current of the 

North Atlantic Gyre to move from developmental nursery habitats to later developmental habitats, and 

to and from adult foraging, nesting, and breeding habitats (Bolten et al., 1998; Musick & Limpus, 1997).

Small bottom-feeding juveniles in Delaware Bay are the predominant loggerhead size class found along 

the northeast and mid-Atlantic U.S. coast, while adults inhabit the entire continental shelf area 

(Hopkins-Murphy et al., 2003). Long Island Sound, Cape Cod Bay, and Chesapeake Bay are the most 

frequently used juvenile developmental habitats along the Northeast U.S. Continental Shelf Large 

Marine Ecosystem (Mansfield, 2006). 

Navy-funded aerial surveys and stranding data suggest that this species is the most abundant sea turtle 

species using Chesapeake Bay and waters off of Cape Hatteras (Andrady, 2011; Barco & Lockhart, 2015; 

Burt et al., 2014; National Oceanic and Atmospheric Administration, 2015; Swingle et al., 2016). 

Abundances in these waters were highest in the spring relative to summer and fall, with no presence in 

winter (Burt et al., 2014). Core Sound and Pamlico Sound, North Carolina, on the border between the 

Northeast and Southeast U.S. Continental Shelf Large Marine Ecosystems, represent important 

developmental habitat for juvenile loggerheads (Epperly et al., 1995a). Although these habitats are also 

used by greens and Kemp’s ridleys, loggerheads are the most abundant sea turtle species within the 

summer developmental habitats of North Carolina (Epperly et al., 1995a; Epperly et al., 1995b; Epperly 

et al., 1995c). In a sampling study from 2004 to 2007, juveniles were the most abundant age group 

among loggerheads found in the Charleston, South Carolina, shipping channel between May and August 

(Arendt et al., 2012). Immature loggerhead sea turtles may occupy coastal feeding grounds for 20 years 

before their first reproductive migration (Bjorndal et al., 2001; Putman et al., 2015b).

Sub-adult and adult loggerhead turtles tend to inhabit deeper offshore feeding areas along the western 

Atlantic coast, from mid-Florida to New Jersey (Hopkins-Murphy et al., 2003; Roberts et al., 2005). As 

late juveniles and adults, loggerhead sea turtles most often occur on the continental shelf and along the 

shelf break of the U.S. Atlantic and Gulf coasts, as well as in coastal estuaries and bays (Putman et al., 

2015b). Hawkes et al. (2006) found that adult females forage predominantly in shallow coastal waters 

along the U.S. Atlantic coast less than 100 m deep, likely exploiting bottom-dwelling prey.

As water temperatures drop from October to December, most loggerheads emigrate from their summer 

developmental habitats and eventually return to warmer waters south of Cape Hatteras, where they 
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spend the winter (Morreale & Standora, 1998). From a southwestern Florida nesting location, Tucker et 

al. (2014) tracked nine loggerheads over multiple nesting seasons, showing five distinct winter migration 

destinations—islands in the Caribbean, Florida Keys, West Florida Shelf, northern Gulf of Mexico, and 

Yucatan Peninsula. Bovery and Wyneken (2015) analyzed seasonal variation in sea turtle density and 

abundance off southeastern Florida, and found that loggerheads were the most frequently sighted 

species, with increased sightings in spring. Turtles were often found in coastal waters that were west of 

the Florida Current (approximately 20 km offshore).

Griffin et al. (2013) offered a conceptual model of foraging strategies, as shown by tagged loggerhead 

turtles from Georgia, South Carolina, and North Carolina nesting beaches. These strategies included 

seasonal strategies and year-round strategies, with summer prevalence in waters north of Cape Hatteras 

along neritic habitats to Cape Canaveral, Florida, with winter foraging occurring further out on the mid 

to outer continental shelf. Large juvenile and adult loggerhead turtles are captured or observed along 

Florida’s Atlantic coast year-round (Bovery & Wyneken, 2015; Pajuelo et al., 2016). As stated previously, 

loggerheads were the highest occurring sea turtle species within the AFTT Study Area, with higher 

occurrences in spring (Bovery & Wyneken, 2015).

3.8.2.2.4.3 Population Trends

There are at least five demographically independent loggerhead sea turtle nesting groups or 

subpopulations of the Northwest Atlantic Ocean: (1) the Northern Recovery Unit, from the 

Florida-Georgia border to southern Virginia; (2) the Peninsular Florida Recovery Unit, along Florida’s 

Atlantic coast to Key West; (3) the Dry Tortugas Recovery Unit, encompassing all islands west of Key 

West; (4) the Northern Gulf of Mexico Recovery Unit, from the Florida panhandle through Texas; and (5) 

the Greater Caribbean Recovery Unit, from Mexico through French Guiana, the Bahamas, and the Lesser 

and Greater Antilles (National Marine Fisheries Service & U.S. Fish and Wildlife Service, 2008). 

Annual total nest counts for loggerhead sea turtles on Florida’s index beaches (27 beaches identified as 

a subset for measuring long-term nesting trends) fluctuate widely, and scientists do not yet understand 

fully what drives these changes. A detailed analysis of Florida's long-term loggerhead nesting data from 

1989 to 2017 shows three distinct phases. Following a 52 percent increase between 1989 and 1998, nest 

counts declined sharply (53 percent) over nearly a decade (1998–2007). However, annual nest counts 

showed a strong increase (65 percent) through 2017. Overall, nest counts in Florida over the monitoring 

period (1989–2017) increased by approximately 19 percent (Florida Fish and Wildlife Conservation 

Commission, 2017).

3.8.2.2.4.4 Predator and Prey Interactions

Loggerhead sea turtles are primarily carnivorous in both open ocean and nearshore habitats, although 

they also consume some algae (Bjorndal, 1997), Diet varies by age class (Godley et al., 1998) and by 

specializing in specific prey groups dependent on location. For post hatchlings that tend to be grouped in 

masses of Sargassum and other floating habitats, various diet analyses of gut contents show parts of 

Sargassum, zooplankton, jellyfish, larval shrimp and crabs, and gastropods (Burkholder et al., 2004; Carr 

& Meylan, 1980; Richardson & McGillvary, 1991). Both juveniles and adults forage in coastal habitats, 

where they feed primarily on the bottom, although they also capture prey throughout the water column

(Bjorndal, 2003). Adult loggerheads feed on a variety of bottom-dwelling animals, such as crabs, shrimp, 

sea urchins, sponges, and fish. They have powerful jaws that enable them to feed on hard-shelled prey, 

such as whelks and conch. During migration through the open sea, they eat jellyfish, molluscs, flying fish, 

and squid (Briscoe et al., 2016; Fukuoka et al., 2016; Pajuelo et al., 2016).
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Common predators of eggs and hatchlings on nesting beaches are ghost crabs, raccoons, feral pigs, 

foxes, coyotes, armadillos, and fire ants (Campbell, 2016; Dodd, 1988; Engeman et al., 2016). Eriksson 

and Burton (2003) has shown that management interventions for feral pigs and raccoons can 

significantly increase nest success in Florida, one of the main nesting concentrations of loggerheads. 

Arroyo-Arce et al. (2017) documented an apparently rare instance of a jaguar (Panthera onca) in 2014

predating a loggerhead turtle at Tortuguero National Park, Costa Rica, while the turtle was on the beach. 

In the water, hatchlings are susceptible to predation by birds and fish. Sharks are the primary predator 

of juvenile and adult loggerhead sea turtles (Fergusson et al., 2000).

3.8.2.2.4.5 Species-Specific Threats

In addition to the general threats described previously, mortality associated with shrimp trawls has been 

a substantial threat to large juvenile and subadult loggerheads because these trawls operate in the 

nearshore habitats commonly used by this species. Although shrimping nets have been modified with 

turtle excluder devices to allow sea turtles to escape, the overall effectiveness of these devices has been 

difficult to assess (Bugoni et al., 2008). Shrimp trawl fisheries account for the highest number of 

loggerhead sea turtle fishery mortalities; however, loggerheads are also captured and killed in trawls, 

traps and pots, longlines, and dredges. Along the Atlantic coast of the United States, NMFS estimated 

that almost 163,000 loggerhead sea turtles are captured in shrimp trawl fisheries each year in the Gulf 

of Mexico, with 3,948 of those sea turtles dying as a result of their capture. Each year, several hundred 

loggerhead sea turtles are also captured in herring, mackerel, squid, butterfish, and monkfish fisheries; 

pound net fisheries, summer flounder, and scup fisheries; Atlantic pelagic longline fisheries; and gillnet 

fisheries in Pamlico Sound. Combined, these fisheries capture about 2,000 loggerhead sea turtles each 

year. Although most are released alive, about 700 turtles are killed annually. 

Vehicle use on sea turtle nesting beaches is also an issue for loggerheads. Vehicles are allowed on some 

beaches in Florida, Georgia, North Carolina, Virginia, and Texas. Vehicles can run over and kill hatchlings 

or nesting adult turtles on the beach, disrupt the nesting process, create ruts in the sand that impede 

turtle movement, and crush nests (National Marine Fisheries Service & U.S. Fish and Wildlife Service, 

2008).

3.8.2.2.5 Leatherback Sea Turtle (Dermochelys coriacea)

3.8.2.2.5.1 Status and Management

The leatherback sea turtle is listed as a single population and is classified as endangered under the ESA 

(35 Federal Register 8491). Although USFWS and NMFS believe the current listing is valid, preliminary 

information indicates an analysis and review of the species should be conducted under the distinct 

population segment policy (National Marine Fisheries Service & U.S. Fish and Wildlife Service, 2013b). 

Recent information on population structure (through genetic studies) and distribution (through 

telemetry, tagging, and genetic studies) have led to an increased understanding and refinement of the 

global stock structure. Leatherback sea turtles from nesting stocks originating throughout the Atlantic 

have the potential to be within the offshore portions of the Study Area, but only two of these—the 

Florida genetic stock and the Northern Caribbean genetic stock—nest on beaches in the jurisdiction of 

the United States.

Critical habitat has been designated in the Study Area for this species (Figure 3.8-9). In 1978, critical 

habitat was designated for the leatherback’s terrestrial environment on St. Croix Island at Sandy Point 

because of its importance as a nesting habitat (43 Federal Register 43688). In 1979, critical habitat was 

designated for the waters next to Sandy Point, St. Croix, up to and including the waters from the 
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100-fathom curve shoreward to the mean high tide line (44 Federal Register 17710). The essential 

physical and biological feature of this critical habitat is its function as an important courtship and mating 

area adjacent to the nesting beach. 

3.8.2.2.5.2 Habitat and Geographic Range

The leatherback turtle is distributed worldwide in tropical and temperate waters of the Atlantic, Pacific, 

and Indian Oceans. (National Marine Fisheries Service & U.S. Fish and Wildlife Service, 2013b).

Important nesting areas in the western Atlantic Ocean occur in Florida, St. Croix, Puerto Rico, Costa Rica, 

Panama, Colombia, Trinidad and Tobago, Guyana, Suriname, French Guiana, and southern Brazil

(Brautigam & Eckert, 2006; Márquez, 1990; Spotila et al., 1996). Other minor nesting beaches are 

scattered throughout the Caribbean, Brazil, and Venezuela (National Marine Fisheries Service & U.S. Fish 

and Wildlife Service, 2013b). Leatherback nesting season begins and ends a few months earlier than that 

of the other sea turtle species that nest in the Study Area, beginning in March in the more northern 

nesting habitats (e.g., Florida) and continues in more southern nesting habitats (e.g., Puerto Rico). 

Females remain in the general vicinity of the nesting habitat between nestings, with total residence in 

the nesting and inter-nesting habitat lasting up to four months. Horrocks et al. (2016) tagged over 3,100 

female leatherbacks in the Caribbean Sea and found that females traveled an average of 160 km

between nesting events within the same season. Migrations between nesting seasons were typically to 

the north towards more temperate latitudes, which support high densities of jellyfish prey in 

the summer.

In the Atlantic Ocean, equatorial waters appear to be a barrier between breeding populations. In the 

northwestern Atlantic Ocean, post-nesting female migrations appear to be restricted to north of the 

equator, but the migration routes vary (National Marine Fisheries Service & U.S. Fish and Wildlife 

Service, 2013b). Leatherbacks made round-trip migrations from where they started through the North 

Atlantic Ocean heading northwest to fertile foraging areas off the Gulf of Maine, Canada, and Gulf of 

Mexico; others crossed the ocean to areas off Western Europe and Africa; while others spent time 

between northern and equatorial waters. These data support earlier studies that found adults and 

subadults captured in waters off Nova Scotia stayed in waters north of the Equator (James et al., 2005a; 

James et al., 2005b; James et al., 2006). 

Limited information is available on the habitats used by post-hatchling and early juvenile leatherback 

sea turtles because these age classes are entirely oceanic (National Marine Fisheries Service and U.S. 

Fish and Wildlife Service, 1992). These life stages are restricted to waters warmer than 79°F (26°C); 

consequently, much time is spent in the tropics (Eckert, 2002). They are not considered to associate with 

Sargassum or other flotsam, as is the case for all other sea turtle species (Horrocks, 1987; Johnson, 

1989). Upwelling areas, such as equatorial convergence zones, serve as nursery grounds for posthatchling and early juvenile leatherback sea turtles because these areas provide a high biomass of prey 

(Musick & Limpus, 1997).
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Note: AFTT: Atlantic Fleet Training and Testing

Figure 3.8-9: Critical Habitat Designation for the Leatherback Sea Turtle within the Study Area
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Late juvenile and adult leatherback sea turtles are known to range from mid-ocean to the continental 

shelf and nearshore waters (Barco & Lockhart, 2015; Grant & Ferrell, 1993; Schroeder & Thompson, 

1987; Shoop & Kenney, 1992). Although leatherbacks were observed annually in Chesapeake Bay, they 

were not common and unevenly distributed. Juvenile and adult foraging habitats include both coastal 

and offshore feeding areas in temperate waters and offshore feeding areas in tropical waters. 

Leatherbacks have been shown to travel shorter distances at slower rates and increased diving rates in 

areas of high prey abundance, which is related to seasonal availability of prey (Wallace et al., 2015).

Leatherback sea turtles mate in waters adjacent to nesting beaches and along migratory corridors

(Cummings et al., 2016; Figgener et al., 2016). 

3.8.2.2.5.3 Population Trends

Population trends for leatherback turtles in Florida show increases, with leatherback populations north 

of Florida being a stable population (National Marine Fisheries Service, 2013b; Stewart et al., 2014). This 

increase has coincided with an upsurge in the Caribbean population. Sporadic nesting also occurs in 

Georgia, South Carolina, as far north as North Carolina (National Marine Fisheries Service and U.S. Fish 

and Wildlife Service, 1992; Rabon et al., 2003; Schwartz, 1989), and in the Gulf of Mexico on the Florida 

panhandle. One of the most globally important stocks of leatherback turtles, the Southern Caribbean 

Stock, nests in French Guiana, Guyana, Suriname, and Trinidad but migrates and forages throughout the 

North Atlantic. The Western Caribbean stock of the Central American coast also migrates through the 

Study Area en route to North Atlantic foraging grounds. Nesting populations in southern Florida, 

Culebra, Puerto Rico, and the U.S. Virgin Islands are believed to be increasing due to heightened 

protection and monitoring of the nesting habitat over the past 30 years (National Marine Fisheries 

Service, 2011; National Marine Fisheries Service & U.S. Fish and Wildlife Service, 2013b; Turtle Expert 

Working Group, 2007).

The Florida nesting stock comes ashore primarily along the east coast of Florida. In the 1980s, fewer 

than 100 nests per year were reported. Based on data extrapolated from the index nesting beach 

surveys, nesting activity has shown an annual growth rate of 1 percent between 1989 and 2005 

(National Marine Fisheries Service, 2013b). Larger growth rates (10.2 percent increases per year) in 

nesting activity in this area have been shown from 68 Florida beaches since 1979 (Stewart et al., 2011; 

Stewart et al., 2014). Florida statewide nesting reports show nesting numbers fluctuating between 896 

nests and 1,712 nests during a five-year period between 2011 and 2015. Surveyors counted 205 

leatherback nests on the 27 core index beaches in 2017 in Florida, which represents the lowest number 

of nests reported since 2006. While green turtle nest numbers on Florida’s index beaches continue to 

rise, leatherback nest numbers have been declining since 2014 (Florida Fish and Wildlife Conservation 

Commission, 2017). 

3.8.2.2.5.4 Predator and Prey Interactions

Leatherbacks lack the crushing chewing plates characteristic of hard-shelled sea turtles that feed on 

hard-bodied prey. Instead, they have pointed tooth-like cusps and sharp-edged jaws that are adapted 

for a diet of soft-bodied open-ocean prey such as jellyfish and salps. Leatherback sea turtles feed 

throughout the water column (Davenport, 1988; Eckert et al., 1989; Eisenberg & Frazier, 1983; Grant & 

Ferrell, 1993; James et al., 2005b; James et al., 2005c; Salmon et al., 2004). Leatherback prey is 

predominantly jellyfish (National Marine Fisheries Service & U.S. Fish and Wildlife Service, 2013b; 

Wallace et al., 2015).In Atlantic Canada, leatherbacks feed on jellyfish of Cyanea spp. and Aurelia spp. 

(James & Herman, 2001; Votier et al., 2011). In North Carolina and Georgia, turtles feed on cannonball 
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jellies (Stomolophus meleagris) (Frick et al., 1999; Grant & Ferrell, 1993). Patterns in feeding behavior off 

St. Croix, U.S. Virgin Islands, over a 24-hour period suggest an interaction between leatherback diving 

and vertical movements of the deep scattering layer (a horizontal zone of planktonic organisms), with 

more frequent and shallower dives at night compared with fewer and deeper day dives (Eckert et al., 

1989). Research in the feeding grounds of Georgia (Frick et al., 1999), North Carolina (Grant & Ferrell, 

1993), and Atlantic Canada (James & Herman, 2001) has documented leatherbacks foraging on jellyfish 

at the surface. 

Predators of leatherback nests are common to other sea turtle species (e.g., terrestrial mammals and 

invertebrates). Burns et al. (2016) found that nesting female leatherbacks expend a significant amount 

of time and energy, despite increased risk of direct predation while on land, to obscure nests. After 

laying nests and covering with sand, the female’s return to the ocean is not linear, and is likely an 

attempt at decoy behavior as a further measure to protect the clutch. In the water, hatchlings are 

susceptible to predation by birds and fish. Sharks are the primary predator of juvenile and adult 

leatherback sea turtles (National Marine Fisheries Service & U.S. Fish and Wildlife Service, 2013b).

3.8.2.2.5.5 Species-Specific Threats

In addition to the general threats to sea turtles described previously, bycatch in commercial fisheries is a 

particular threat to leatherback sea turtles. Incidental capture in longline and coastal gillnet fisheries has 

caused a substantial number of leatherback sea turtle deaths, likely because leatherback sea turtles dive 

to depths targeted by longline fishermen and are less maneuverable than other sea turtle species.

Shrimp trawls in the Gulf of Mexico have been estimated to capture about 3,000 leatherback sea turtles, 

with 80 of those sea turtles dying as a result (Finkbeiner et al., 2011; Wallace et al., 2010b). Along the 

Atlantic coast of the United States, NMFS estimated that about 800 leatherback sea turtles are captured 

in pelagic longline fisheries, bottom longline, and drift gillnet fisheries for sharks as well as lobster, deepsea red crab, Jonah crab, dolphin fish and wahoo, and Pamlico Sound gillnet fisheries. Although most of 

these turtles are released alive, these fisheries kill about 300 leatherback sea turtles each year (National 

Marine Fisheries Service & U.S. Fish and Wildlife Service, 2013b; Stewart et al., 2016). Harvest of 

leatherback sea turtle eggs and adult turtles continues to be a threat in many parts of the world

(Humber et al., 2014). Lastly, climate change may impact leatherbacks in ways different from other sea 

turtle species because their distribution is so closely associated with jellyfish aggregations (which are 

affected by changing ocean temperatures and dynamics) (Pike, 2014). Robinson et al. (2013) suggest 

that climate change impacts are contributing to the Pacific leatherback population declines through a 

shifting of nesting dates to increase stressor exposure. The observed mean nesting date shifts in the 

Atlantic leatherback genetic stocks, in contrast to Pacific populations, may increase resiliency of Atlantic 

leatherbacks to climate-related impacts.

3.8.2.2.6 American Crocodile (Crocodylus acutus)

3.8.2.2.6.1 Status and Management

The American crocodile occurs within the jurisdictional boundaries of many different countries and is 

distributed in primarily coastal waters throughout the Caribbean Sea and on the Pacific coast of Central 

and South America from Mexico to Ecuador (Thorbjarnarson et al., 2006). Population declines have been 

attributed to loss of habitat and extensive poaching for their hides (U.S. Fish and Wildlife Service, 2010). 

The Florida population marks the northern extent of this species’ range and is classified as a distinct 

population segment due to its genetic isolation (U.S. Fish and Wildlife Service, 2010). The American 

crocodile was listed as endangered under the ESA throughout its range in 1979 (44 Federal Register
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17710). In 2007, the Florida population of American crocodiles was reclassified as a distinct population 

segment and was designated as threatened under the ESA; the population outside of Florida remains 

listed as endangered under the ESA. Critical habitat was designated for the Florida population in 1976 

and was slightly modified in 1977 to include a more accurate map of the habitat (41 Federal Register

41914, 44 Federal Register 75074) (Figure 3.8-10). The essential physical and biological feature of this 

critical habitat is Florida Bay and its associated brackish marshes, swamps, creeks, and canals because 

the crocodile population is concentrated in these waters, and all known breeding females inhabit and 

nest here (41 Federal Register 41914).

3.8.2.2.6.2 Habitat and Geographic Range

The American crocodile is typically found in fresh or brackish coastal habitats, including, but not limited 

to rivers, ponds, lagoons, and mangrove swamps (Mazzotti et al., 2007; Mazzotti, 2014; Wheatley et al., 

2012). American crocodiles generally occur in water with salinities less than 20 parts per thousand; 

however, they possess salt lingual glands allowing them to excrete excess salt (Cherkiss et al., 2014; 

Wheatley et al., 2012) and occasionally inhabit more saline environments (e.g., Florida Bay) (Wheatley 

et al., 2012). Most crocodile sightings in more saline water are females attending nest sites, hatchlings at 

nest sites, or juveniles presumably avoiding adults (Mazzotti et al., 2007). Females construct nests on 

elevated, well-drained sites near the water such as ditch banks and beaches. In the United States, 

artificial nesting sites within berms along canal banks provide nearly ideal nesting conditions because 

they are elevated, well drained, and near relatively deep, low-to-intermediate salinity water (Mazzotti et 

al., 2007). These artificial nesting habitats appear to be compensating for natural habitat elsewhere in 

Florida and account for much of the increase in nesting documented since 1975.

The American crocodile is known to inhabit inshore marine waters and is not predisposed to travel 

across the open ocean (Cherkiss et al., 2014). Instead, they prefer calm warm waters with minimal wave 

action, and most frequently occur in sheltered, mangrove-lined estuaries (Mazzotti, 1983). No available 

evidence suggests that crocodiles cross the Florida Straits; therefore, this species is not expected to 

occur in offshore areas within the Study Area. The American crocodile, however, can travel long 

distances in nearshore environments. For example, Cherkiss et al. (2014) tracked an individual American

crocodile over a 14-year period. The crocodile was originally marked in Homestead, Florida, as a youngof-the-year in 1999, and was later recaptured multiple times more than 388 km away along the

southwest coast of Florida. After several relocations and numerous sightings, this individual returned 

the same canal system in which it was first captured.

Within the United States, distribution is limited to the southern tip of mainland Florida and the Florida 

Keys, which represents the northern extent of its range. The American crocodile range appears to be 

expanding (Mazzotti et al., 2007) (70 Federal Register 15052). Regular nesting occurs within Biscayne 

Bay on Florida’s east coast, on the border between the Southeast U.S. Continental Shelf and Gulf of 

Mexico Large Marine Ecosystems, and there is evidence that the species is expanding its current range 

to occupy portions of its historic range within the Florida Keys (Mazzotti et al., 2007). Most nesting 

occurs in the Everglades National Park, the cooling water discharge canal of the Turkey Point Power 

Plant (Homestead, Florida), and Crocodile Lake National Wildlife Refuge in the Gulf of Mexico Large 

Marine Ecosystem (Mazzotti et al., 2007). Currently, few crocodiles are found north of Biscayne Bay on 

the Atlantic Coast of Florida, or north of Sanibel Island on Florida’s gulf coast. However, sightings have 

occurred in the coastal counties of mainland Florida from as far north as Indian River County on the 

Atlantic coast and Sarasota County on the Gulf coast (72 Federal Register 13027) and Lee County on the

west coast (Green et al., 2014; U.S. Fish and Wildlife Service, 2010; Wheatley et al., 2012). 
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Notes: AFTT: Atlantic Fleet Training and Testing; OPAREA: Operating Area

Figure 3.8-10: Critical Habitat Designation for the American Crocodile within the Study Area
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3.8.2.2.6.3 Population Trends

In 1976, the American crocodile population in Florida was estimated to be between 200 and 300 

individuals (40 Federal Register 58308), with only 10–20 breeding females estimated in 1975 (40 Federal 

Register 58308). An estimated 20 nests were laid in Florida in 1975. As a result of conservation 

measures, including habitat protection, the number of nests increased to 85 in 2004 (Mazzotti et al., 

2007). The most recent population estimate, provided by the Florida Fish and Wildlife Commission, 

estimates the current Florida population of crocodiles to range between 1,500 and 2,000 adults, with an 

estimated 100 nests per year occurring in Florida (Florida Fish and Wildlife Conservation Commission, 

n.d.). The species is gradually recovering in the United States, but survey data from Central and South 

America are relatively poor. The Florida population of the American crocodile has increased, and its 

distribution has expanded, since it was listed as endangered. 

Increased sightings of crocodiles on the airfield at the Naval Air Station Key West has initiated interest in 

having surveys for crocodiles performed on station. The Navy is currently monitoring occurrences of 

American crocodiles at Naval Air Station Key West. In 2014, 21 American crocodiles (along with one 

American alligator and two indistinguishable eye shines) were identified at the air station. Nesting may 

also occur on the coastal portions of the air station (Mazzotti, 2014). During 2016 spotlight surveys 

(occurring in January, April, June, and August), a total of seven crocodiles and one alligator were 

observed at Naval Air Station Key West. No nesting activity was observed on the Naval Air Station Key 

West properties.

3.8.2.2.6.4 Predator and Prey Interactions

The American crocodile typically forages from shortly before sunset to shortly after sunrise (U.S. Fish 

and Wildlife Service, 2010). During these times, crocodiles feed on any prey items that can be caught 

and overpowered (Mazzotti et al., 2007). Adults feed on fish, crabs, birds, turtles, snakes, and small 

mammals, while young feed on aquatic invertebrates and small fish. 

Fire ants are predators of crocodile eggs. Crocodile hatchlings may be preyed on by large fish, birds, 

other large reptiles and amphibians, or even other crocodiles. Larger juvenile and adult crocodiles have 

no known natural predators (Mazzotti et al., 2007).

3.8.2.2.6.5 Species-Specific Threats

Habitat loss is a primary threat to the American crocodile (U.S. Fish and Wildlife Service, 2010). 

Development in coastal areas of Florida diminishes American crocodile habitat and restricts the species’ 

breeding range. Erosion or sea level rise may further increase vulnerability of nesting sites. In addition to 

direct habitat loss, alteration of habitat is a concern. Urban and residential development restricts 

freshwater flow into swamps and estuaries, which may limit crocodile growth, survival, and abundance 

(Mazzotti et al., 2007). Collisions with automobiles are also a documented cause of mortality in Florida’s 

southernmost Miami-Dade and Monroe Counties (Mazzotti et al., 2007). Cold weather has also been 

cited as a primary constraint on American crocodile recovery and expansion into suitable habitats within 

this species’ historic range. For example, a 2010 freeze in south Florida resulted in a mass die off of 

reptiles and fish, including more than 150 American crocodiles (Mazzotti et al., 2016).

The introduction in Florida of Nile crocodiles (Crocodulus niloticus), confirmed recently through genetic 

analyses, presents threats to the American crocodile (Rochford et al., 2016). As a competitor for prey 

and habitat, the Nile crocodile can also likely predate smaller American crocodiles. In addition, many 

crocodilian species are already known to hybridize in captivity and where their native ranges overlap in 
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the wild (e.g., Cuban crocodile [Crocodulus rhombifer]), which can degrade the genetic integrity of the 

American crocodile (Weaver et al., 2008). Because of similarity of appearance, Nile crocodile 

persecution by humans would likely include accidental poaching of American crocodiles (Rochford et al., 

2016). Burmese pythons, as discussed previously in Section 3.8.2.1.5.4 (Invasive Species), may prey upon 

juvenile and small adult crocodiles and compete for crocodile prey base. Hart et al. (2012) have shown 

salt water tolerance in newly hatched pythons, which may increase the predation risk of American 

crocodiles and increase competition for crocodile prey base.

3.8.2.2.7 American Alligator (Alligator mississippiensis)

3.8.2.2.7.1 Status and Management

American alligator populations began to decline in the late 1800s, when unregulated hunting for the 

hides became prevalent, with population numbers close to extinction in some areas (Savannah River 

Ecology Laboratory & Herpetology Program, 2012). A hunting ban in the 1950s and other recovery 

efforts allowed the species to rebound (52 Federal Register 21059). American alligators were listed as an 

endangered species in 1967 under a law that preceded the ESA of 1973 (National Park Service, 2012). No 

critical habitat has been designated for this species. Federal legislation in the 1970s and 1980s, including 

the ESA and amendments to the Lacey Act in 1981, ensured the alligators’ protection, and eventually 

their comeback. In 1987, the alligator was declared “no longer biologically threatened or endangered” 

(52 Federal Register 21059). However, to ensure protections to the American crocodile and other 

endangered crocodilians, the American alligator is listed under the ESA classification of “threatened due 

to similarity of appearance” to the American crocodile (52 Federal Register 21059). Accordingly, federal 

agencies are no longer required to consult with USFWS pursuant to section 7 of the ESA. Hunting and 

trade of the American alligator are now permitted and regulated by USFWS (National Park Service, 2012; 

Savannah River Ecology Laboratory & Herpetology Program, 2012).

3.8.2.2.7.2 Habitat and Geographic Range

The American alligator resides along the southeastern coast of the United States from North Carolina 

south through Florida and westward to the Texas coast (Elsey & Woodward, 2010). The American 

alligator’s primary habitats are freshwater swamps and marshes but may also include lakes, canals, 

ponds, reservoirs, and rivers. As alligators lack lingual salt glands, the species has a limited capacity to 

tolerate highly saline environments (Mazzotti & Dunson, 1989). In coastal areas, alligators move 

between freshwater and estuarine waters. Size and sex influences the habitat that alligators reside in; 

adult males generally prefer deep, open water within coastal water bodies, while adult females prefer 

coastal open water habitats only during the spring breeding season. After the breeding season, adult 

females prefer to move to lake and marsh edges during nesting and hatching seasons (Savannah River 

Ecology Laboratory & Herpetology Program, 2012). After juveniles have hatched, they remain with the 

female for up to a year or more for protection during this vulnerable life stage (National Park Service, 

2012; Savannah River Ecology Laboratory & Herpetology Program, 2012). Smaller alligators prefer 

wetlands with dense vegetation for protection and prey advantage (Savannah River Ecology Laboratory 

& Herpetology Program, 2012).

3.8.2.2.7.3 Population and Abundance

Following state and federal management of this species, alligator populations have rebounded to an 

estimated total in the millions of individuals (Savannah River Ecology Laboratory & Herpetology 

Program, 2012). The Navy is currently monitoring occurrences of American alligators at Naval Air Station 

Key West. In 2014, one American alligator (along with 21 American crocodiles and two indistinguishable 
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eye shines) was identified at the air station. During 2016 spotlight surveys (occurring in January, April, 

June, and August), one alligator was observed at Naval Air Station Key West. No nesting activity was 

observed on the Naval Air Station Key West properties. Nesting may also occur on the coastal portions 

of the air station (Mazzotti et al., 2016). 

3.8.2.2.7.4 Predator and Prey Interactions

American alligators are opportunistic carnivores. Adults eat a variety of animals, including large fish, 

turtles, snakes, birds, and small mammals. Hatchlings and smaller alligators eat insects, crayfish, snails 

and other invertebrates, small fish, and amphibians (Savannah River Ecology Laboratory & Herpetology 

Program, 2012).

Alligator eggs are often preyed upon by raccoons, opossums, skunks, feral pigs, and other terrestrial 

nest predators. Similarly, young alligators are preyed upon by raccoons, crabs, large snakes, turtles, 

birds, and even fish (Savannah River Ecology Laboratory & Herpetology Program, 2012).

3.8.2.2.7.5 Species-Specific Threats

State-level management programs, including managed harvesting, have not appeared to impact alligator 

populations. Alligators, however, appear to be sensitive to water quality parameters (e.g., salinity,

temperature, and contaminants such as heavy metals and pharmaceuticals), as well as prey availability 

(Hidalgo-Ruz et al., 2012).

3.8.2.3 Species Not Listed under the Endangered Species Act

3.8.2.3.1 Diamondback terrapin (Malaclemys terrapin)

3.8.2.3.1.1 Status and Management

The diamondback terrapin is a widely distributed species that is native to the brackish coastal tidal 

marshes of the eastern and southern United States. This includes the states of Alabama, Connecticut, 

Delaware, Florida, Georgia, Louisiana, Maryland, Massachusetts, Mississippi, New Jersey, New York, 

North Carolina, Rhode Island, South Carolina, Texas, and Virginia. Population declines of this species are 

typically local and due to crab trap mortality and vehicle strikes on land. Several states have 

laws/regulations requiring that crab pot traps be fitted with exclusion or escape mechanisms to prevent 

bycatch of terrapins. The diamondback terrapin is not ESA listed, but is state listed in Massachusetts as 

Threatened. All U.S. states within this species’ range (except New York) have designated this species as a 

Species of Greatest Conservation Need (U.S. Fish and Wildlife Service, 2013).

3.8.2.3.1.2 Habitat and Geographic Range

Typical habitat of the diamondback terrapin includes coastal swamps, estuaries, lagoons, tidal creeks, 

mangroves, and salt marshes with salinities ranging from 0 to 35 parts per thousand. Diamondback 

terrapins have salt glands around their eyes, allowing them to secrete excess salt from their blood, and 

survive in salty environments (University of Georgia, 2017). Although diamondback terrapins are found 

in brackish water, periodic access to freshwater is required for long-term health. Diamondback terrapins 

play an important role in coastal saltwater marsh ecosystems by aiding in seed dispersal, controlling

insect and snail populations, and contributing to other ecological services (e.g., removing suspended 

sediments and contaminants in water) through perpetuating eelgrass spread (Pfau & Roosenburg, 

2010).

Although diamondback terrapins are an aquatic turtle and spend the majority of their life in water, they 

do leave the water to bask and lay eggs (University of Georgia, 2017). During the cold winter months, 
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diamondbacks hibernate in the mud at the bottom of tidal creeks. Nesting females wander considerable 

distances on land before nesting. Nests are usually laid in sand dunes or scrub vegetation near the 

ocean. Eggs are typically laid in late May through August and generally take 50–80 days to hatch.

The distribution of diamondback terrapins is best described as discontinuous along the approximately 

5,000 km of coastline between Cape Cod, Massachusetts, and Corpus Christi, Texas (Pfau & Roosenburg, 

2010). Throughout this distribution, there are seven defined subspecies of the diamondback terrapin 

based primarily on differences in carapace morphology and skin coloring (Hart & Lee, 2006). The

subspecies are listed below:

 Carolina diamondback terrapin (Malaclemys terrapin centrata)

 Texas diamondback terrapin (Malaclemys terrapin littoralis)

 Ornate diamondback terrapin (Malaclemys terrapin macrospilota)

 Mississippi diamondback terrapin (Malaclemys terrapin pileata)

 Mangrove diamondback terrapin (Malaclemys terrapin rhizophorarum)

 Eastern Florida diamondback terrapin (Malaclemys terrapin tequesta)

 Northern diamondback terrapin (Malaclemys terrapin terrapin)

Despite this extensive distribution, its zone of occurrence is very linear and in places fragmented, 

resulting in a relatively small total area of occupancy (Hart & Lee, 2006).

Population Trends

Terrapins have a long history of exploitation by humans, who harvested them for food for decades 

(University of Georgia, 2017). The current population size of diamondback terrapins in the United States

is unknown, but estimated to be over 100,000 individuals. Most diamondback terrapin populations 

range from stable to declining.

3.8.2.3.1.4 Predator Prey Interactions

Diamondback terrapins feed on shrimp, clams, barnacles, crabs, mussels and other marine 

invertebrates. Juveniles prey on insects and small crustaceans. Most notably, adults feed on salt marsh 

periwinkle (Littoraria irrorata), a snail that feeds on salt marsh cord grass. By feeding on the periwinkles, 

the diamondback terrapins control the populations of periwinkles and prevent them from overgrazing 

cord grasses (U.S. Fish and Wildlife Service, 2013). Nests, hatchlings, and sometimes adults are eaten by 

raccoons, foxes, rats and many species of birds, especially crows and gulls, which significantly impacts 

juvenile population numbers.

3.8.2.3.1.5 Species-Specific Threats

The species has declined significantly from historic levels, in part due to 19th and 20th century 

harvesting as gourmet food. Harvesting of turtles and eggs is no longer a primary threat to this species.

In the states of South Carolina and Maryland, there have been significant local declines due to crab trap 

mortality and vehicle (car and boat) strikes. Additionally, a decline in the population of females is 

consistent with the increased mortality of nesting females from vehicle strikes while searching for 

nesting sites on land (U.S. Fish and Wildlife Service, 2013). Additional threats include loss of nesting 

habitat (erosion, land subsidence and shoreline hardening, residential development), nest and hatchling 

predation, and water quality degradation.
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3.8.3 ENVIRONMENTAL CONSEQUENCES

This section evaluates how, and to what degree, the activities described in Chapter 2 (Description of 

Proposed Action and Alternatives) and Appendix A (Navy Activity Descriptions) potentially impact 

reptiles known to occur within the Study Area. Tables 2.6-1 through 2.6-4 present proposed typical 

training and testing activity locations for each alternative (including number of events). General 

characteristics of all U.S. Navy stressors were introduced in Section 3.0.3.3 (Identifying Stressors for 

Analysis), and living resources’ general susceptibilities to stressors were introduced in Section 3.0.3.6 

(Biological Resource Methods). The stressors vary in intensity, frequency, duration, and location within 

the Study Area. The stressors analyzed for reptiles are:

 Acoustic (sonar and other transducers; air guns; pile driving; vessel noise; aircraft noise; and 

weapon noise) 

 Explosive (explosions in-air, explosions in-water)

 Energy (in-water electromagnetic devices; high-energy lasers

 Physical disturbance and strikes (vessels and in-water devices; military expended materials; 

seafloor devices; pile driving)

 Entanglement (wires and cables; decelerators/parachutes; biodegradable polymers) 

 Ingestion (military expended materials – munitions; military expended materials other 

than munitions)

 Secondary stressors (impacts on habitat; impacts on prey availability) 

The analysis includes consideration of the mitigation that the Navy will implement to avoid potential 

impacts on sea turtles from acoustic, explosive, and physical disturbance and strike stressors. Mitigation 

was coordinated with NMFS and the USFWS through the consultation process. Details of the Navy’s 

mitigation are provided in Chapter 5 (Mitigation).

3.8.3.1 Acoustic Stressors

The analysis of effects to reptiles follows the concepts outlined in Section 3.0.3.6.1 (Conceptual 

Framework for Assessing Effects from Acoustic and Explosive Activities). This section begins with a 

summary of relevant data regarding acoustic impacts on reptiles in Section 3.8.3.1.1 (Background). This 

is followed by an analysis of estimated impacts on reptiles due to specific Navy acoustic stressors (sonar 

and other transducers, air guns, pile driving, vessel noise, aircraft noise, and weapon noise). Additional 

explanations of the acoustic terms and sound energy concepts used in this section are found in 

Appendix D (Acoustic and Explosive Concepts). Studies of the effects of sound on aquatic reptiles are 

limited; therefore, where necessary, knowledge of impacts on other species from acoustic stressors is 

used to assess impacts on sea turtles, crocodilians, and terrapins.

3.8.3.1.1 Background

The sections below include a survey and synthesis of best-available-science published in peer-reviewed 

journals, technical reports, and other scientific sources pertinent to impacts on reptiles potentially 

resulting from Navy training and testing activities. Reptiles could be exposed to a range of impacts 

depending on the sound source and context of the exposure. Exposures to sound-producing activities 

may result in auditory or non-auditory trauma, hearing loss resulting in temporary or permanent hearing 

threshold shift, auditory masking, physiological stress, or changes in behavior.
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3.8.3.1.1.1 Injury

The high peak pressures close to some non-explosive impulsive underwater sound sources, such as air 

guns and impact pile driving, may be injurious, although there are no reported instances of injury to 

reptiles caused by these sources. A Working Group organized under the American National Standards 

Institute-Accredited Standards Committee S3, Subcommittee 1, Animal Bioacoustics, developed sound 

exposure guidelines for fish and sea turtles (Popper et al., 2014), hereafter referred to as the ANSI Sound 

Exposure Guidelines. Lacking any data on non-auditory sea turtle injuries due to non-explosive impulsive 

sounds, such as air guns and impact pile driving, the working group conservatively recommended that 

non-auditory injury could be analyzed using data from fish. The data show that fish would be resilient to 

injury to the non-explosive impulsive sound sources analyzed in this EIS/OEIS. Therefore, it is assumed 

that sea turtles, crocodilians, and terrapins would be as well. Additionally, sea turtle shells may protect 

against non-auditory injury due to exposures to high peak pressures (Popper et al., 2014), which can also 

be assumed for terrapins. 

Lacking any data on non-auditory sea turtle injuries due to sonars, the working group also estimated the 

risk to sea turtles from low-frequency sonar to be low and mid-frequency sonar to be non-existent. Due 

to similarity in hearing, it is assumed that this would be the case for crocodilians and terrapins, as well.

As discussed in Section 3.0.3.6.1 (Conceptual Framework for Assessing Effects from Acoustic and 

Explosive Activities, specifically Section 3.0.3.6.1.1, Injury), mechanisms for non-auditory injury due to 

acoustic exposure have been hypothesized for diving breath-hold animals. Acoustically induced bubble 

formation, rectified diffusion, and acoustic resonance of air cavities are considered for their similarity to 

pathologies observed in marine mammals stranded coincident with sonar exposures but were found to 

not be likely causal mechanisms (Section 3.7.3.1.1.1, Injury), and findings are applicable to reptiles. 

Nitrogen decompression due to modifications to dive behavior has never been observed in sea turtles. 

Sea turtles are thought to deal with nitrogen loads in their blood and other tissues, caused by gas 

exchange from the lungs under conditions of high ambient pressure during diving, through anatomical, 

behavioral, and physiological adaptations (Lutcavage & Lutz, 1997). Although diving sea turtles 

experience gas supersaturation, gas embolism has only been observed in sea turtles bycaught in 

fisheries (Garcia-Parraga et al., 2014). Therefore, nitrogen decompression due to changes in diving 

behavior is not considered a potential consequence to diving reptiles.

3.8.3.1.1.2 Hearing Loss and Auditory Injury

Exposure to intense sound may result in hearing loss, typically quantified as threshold shift, which 

persists after cessation of the noise exposure. Threshold shift is a loss of hearing sensitivity at an 

affected frequency of hearing. This noise-induced hearing loss may manifest as temporary threshold 

shift (TTS), if hearing thresholds recover over time, or permanent threshold shift (PTS), if hearing 

thresholds do not recover to pre-exposure thresholds. Because studies on inducing threshold shift in 

reptiles are very limited (e.g., alligator lizards; Dew et al., 1993; Henry & Mulroy, 1995), are not 

sufficient to estimate PTS and TTS onset thresholds, and have not been conducted on any of the reptiles 

present in the Study Area, auditory threshold shift in reptiles is considered to be consistent with general 

knowledge about noise-induced hearing loss described in Section 3.0.3.6.1 (Conceptual Framework for 

Assessing Effects from Acoustic and Explosive Activities).

Because there are no data on auditory effects on sea turtles, the ANSI Sound Exposure Guidelines

(Popper et al., 2014) do not include numeric sound exposure thresholds for auditory effects on sea 

turtles. Rather, the guidelines qualitatively estimate that sea turtles are less likely to incur TTS or PTS 
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with increasing distance from various sound sources. The guidelines also suggest that data from fishes 

may be more relevant than data from marine mammals when estimating impacts on sea turtles, 

because, in general, fish hearing range is more similar to the limited hearing range of sea turtles. As 

shown in Section 3.8.2.1.4.1 (Hearing and Vocalization – Sea Turtles), sea turtle hearing is most sensitive 

around 100 to 400 Hz in-water, is limited over 1 kHz, and is much less sensitive than that of any marine 

mammal. Therefore, sound exposures from most mid-frequency and all high-frequency sound sources 

are not anticipated to affect sea turtle hearing, and sea turtles are likely only susceptible to auditory 

impacts when exposed to very high levels of sound within their limited hearing range.

Crocodilians and terrapins also have a limited hearing range, as described in Sections 3.8.2.1.4.2

(Hearing and Vocalization – Crocodilians) and 3.8.2.1.4.3 (Hearing and Vocalization – Terrapins), with 

best underwater hearing in the low frequencies, below 1 kHz, suitable for detecting low-frequency 

broadband vocalizations and sounds caused by prey movement. It is assumed that crocodilian and 

terrapin susceptibility to auditory impacts would be similar to that of sea turtles.

3.8.3.1.1.3 Physiological Stress

A stress response is a suite of physiological changes meant to help an organism mitigate the impact of a 

stressor. If the magnitude and duration of the stress response is too great or too long, then it can have 

negative consequences to the animal (e.g., decreased immune function, decreased reproduction). 

Physiological stress is typically analyzed by measuring stress hormones, other biochemical markers, or 

vital signs. Physiological stress has been measured for sea turtles or crocodilians during nesting (Flower 

et al., 2015; Valverde et al., 1999), capture and handling (Flower et al., 2015; Gregory & Schmid, 2001; 

Jessop et al., 2003; Lance et al., 2004), and when caught in entanglement nets (Hoopes et al., 2000; 

Snoddy et al., 2009) and trawls (Stabenau et al., 1991). However, the stress caused by acoustic exposure 

has not been studied for reptiles. Therefore, the stress response in reptiles in the Study Area due to 

acoustic exposures is considered to be consistent with general knowledge about physiological stress 

responses described in Section 3.0.3.6.1 (Conceptual Framework for Assessing Effects from Acoustic and 

Explosive Activities).

Marine animals naturally experience stressors within their environment and as part of their life histories. 

Changing weather and ocean conditions, exposure to diseases and naturally occurring toxins, lack of 

prey availability, social interactions with members of the same species, nesting, and interactions with 

predators all contribute to stress. Anthropogenic sound-producing activities have the potential to 

provide additional stressors beyond those that naturally occur. 

Due to the limited information about acoustically induced stress responses, the Navy conservatively 

assumes in its effects analysis that any physiological response (e.g., hearing loss or injury) or significant

behavioral response is also associated with a stress response.

3.8.3.1.1.4 Masking

As described in Section 3.0.3.6.1 (Conceptual Framework for Assessing Effects from Acoustic and 

Explosive Activities), auditory masking occurs when one sound, distinguished as the “noise,” interferes 

with the detection or recognition of another sound or limits the distance over which other biologically 

relevant sounds, including those produced by prey, predators, or conspecifics, can be detected. Masking 

only occurs when the sound source is operating; therefore, direct masking effects stop immediately 

upon cessation of the sound-producing activity. Any sound above ambient noise and within an animal’s 

hearing range may potentially cause masking. 
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Compared to other marine animals, such as marine mammals, that are highly adapted to use sound in 

the marine environment, marine reptile hearing is limited to lower frequencies and is less sensitive. 

Because marine reptiles likely use their hearing to detect broadband low-frequency sounds in their

environment, the potential for masking would be limited to certain similar sound exposures. Only 

continuous human-generated sounds that have a significant low-frequency component, are not brief in 

duration, and are of sufficient received level could create a meaningful masking situation (e.g., vibratory 

pile extraction or proximate vessel noise). Other intermittent, short-duration sound sources with lowfrequency components (e.g., air guns or low-frequency sonars) would have more limited potential for 

masking depending on duty cycle. 

There is evidence that reptiles may rely primarily on senses other than hearing for interacting with their 

environment, such as vision (Narazaki et al., 2013), magnetic orientation (Avens, 2003; Putman et al., 

2015b), and scent (Shine et al., 2004). Any effect of masking may be mediated by reliance on other 

environmental inputs.

3.8.3.1.1.5 Behavioral Reactions

Behavioral responses fall into two major categories: alterations in natural behavior patterns and 

avoidance. These types of reactions are not mutually exclusive and reactions may be combinations of 

behaviors or a sequence of behaviors. As described in Section 3.0.3.6.1 (Conceptual Framework for 

Assessing Effects from Acoustic and Explosive Activities), the response of a reptile to an anthropogenic 

sound would likely depend on the frequency, duration, temporal pattern, and amplitude of the sound as 

well as the animal’s prior experience with the sound and the context in which the sound is encountered 

(i.e., what the animal is doing at the time of the exposure). Distance from the sound source and whether 

it is perceived as approaching or moving away may also affect the way a reptile responds to a sound. 

Reptiles may detect sources below 2 kHz but likely have limited hearing ability above 1 kHz. They likely 

detect most broadband sources (including air guns, pile driving, and vessel noise) and low-frequency 

sonars, so they may respond to these sources. Because auditory abilities for sea turtles and terrapins are 

poor above 1 kHz, detection and consequent reaction to any mid-frequency source is unlikely.

Crocodilians have a slightly higher hearing range, but with best sensitivity around 800 Hz, they are 

assumed to have similar auditory abilities and reactions to sources below 2 kHz.

In the ANSI Sound Exposure Guidelines (Popper et al., 2014), qualitative risk factors were developed to 

assess the potential for sea turtles to respond to various underwater sound sources. The guidelines state

that there is a low likelihood that sea turtles would respond within tens of meters of low-frequency 

sonars, and that it is highly unlikely that sea turtles would respond to mid-frequency sources. The risk 

that sea turtles would respond to other broadband sources, such as shipping, air guns, and pile driving, 

is considered high within tens of meters of the sound source, but moderate to low at farther distances.

For this analysis, it is assumed that these guidelines would also apply to crocodilians and terrapins.

Behavioral Reactions to Impulsive Sound Sources 

There are limited studies of reptile responses to sounds from impulsive sound sources, and all data 

come from sea turtles exposed to seismic air guns. These exposures consist of multiple air gun shots, 

either in close proximity or over long durations, so it is likely that observed responses may over-estimate 

responses to single or short-duration impulsive exposures. Studies of responses to air guns are used to 

inform reptile responses to other impulsive sounds (impact pile driving and some weapon noise).
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O'Hara and Wilcox (1990) attempted to create a sound barrier at the end of a canal using seismic air 

guns. They reported that loggerhead turtles kept in a 300 m by 45 m enclosure in a 10 m deep canal 

maintained a minimum standoff range of 30 m from air guns fired simultaneously at intervals of 

15 seconds, with strongest sound components within the 25–1,000 hertz frequency range. McCauley et 

al. (2000) estimated that the received sound pressure level (SPL) at which turtles avoided sound in the 

O’Hara and Wilcox (1990) experiment was 175–176 decibels referenced to 1 micropascal (dB re 1 μPa).

Moein Bartol et al. (1995) investigated the use of air guns to repel juvenile loggerhead sea turtles from 

hopper dredges. Sound frequencies of the air guns ranged from 100 to 1,000 Hz at three source SPLs: 

175, 177, and 179 dB re 1 μPa. The turtles avoided the air guns during the initial exposures (mean range 

of 24 m), but additional exposures on the same day and several days afterward did not elicit avoidance 

behavior that was statistically significant. They concluded that this was likely due to habituation.

McCauley et al. (2000) exposed a caged green and a caged loggerhead sea turtle to an approachingdeparting single air gun to gauge behavioral responses. The trials showed that above a received SPL of 

166 dB re 1 μPa, the turtles noticeably increased their swimming activity compared to nonoperational 

periods, with swimming time increasing as air gun SPLs increased during approach. Above 175 dB re 1 

μPa, behavior became more erratic, possibly indicating the turtles were in an agitated state. The authors 

noted that the point at which the turtles showed more erratic behavior and exhibited possible agitation 

would be expected to approximate the point at which active avoidance to air guns would occur for 

unrestrained turtles.

No obvious avoidance reactions by free-ranging sea turtles, such as swimming away, were observed 

during a multi-month seismic survey using air gun arrays, although fewer sea turtles were observed 

when the seismic air guns were active than when they were inactive (Weir, 2007). The author noted that 

sea state and the time of day affected both air gun operations and sea turtle surface basking behavior, 

making it difficult to draw conclusions from the data. However, DeRuiter and Doukara (2012) noted 

several possible startle or avoidance reactions to a seismic air gun array in the Mediterranean by 

loggerhead turtles that had been motionlessly basking at the water surface.

Behavioral Reactions to Sonar and Other Transducers

Studies of reptile responses to underwater non-impulsive sounds are limited. All data are from studies 

with sea turtles. Lenhardt (1994) used very low-frequency vibrations (< 100 Hz) coupled to a shallow 

tank to elicit swimming behavior responses by two loggerhead sea turtles. Watwood et al. (2016) tagged 

green sea turtles with acoustic transponders and monitored them using acoustic telemetry arrays in Port 

Canaveral, Florida. Sea turtles were monitored before, during, and after a routine pier-side submarine 

sonar test that utilized typical source levels, signals, and duty cycle. No significant long-term 

displacement was demonstrated by the sea turtles in this study. The authors note that Port Canaveral is 

an urban marine habitat and that resident sea turtles may be less likely to respond than naïve 

populations. 

3.8.3.1.1.6 Long-Term Consequences

For the reptiles present in the Study Area, long-term consequences to individuals and populations due 

to acoustic exposures have not been studied. Therefore, long-term consequences to reptiles due to 

acoustic exposures are considered following Section 3.0.3.6.1 (Conceptual Framework for Assessing 

Effects from Acoustic and Explosive Activities).
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The long-term consequences due to individual behavioral reactions and short-term (seconds to minutes) 

instances of physiological stress are especially difficult to predict because individual experience over 

time can create complex contingencies. It is more likely that any long-term consequences to an 

individual would be a result of costs accumulated over a season, year, or life stage due to multiple 

behavioral or stress responses resulting from exposures to multiple stressors over significant periods of 

time. Conversely, some reptiles may habituate to or become tolerant of repeated acoustic exposures 

over time, learning to ignore a stimulus that in the past did not accompany any overt threat. For 

example, loggerhead sea turtles exposed to air guns with a source SPL of 179 dB re 1 μPa initially 

exhibited avoidance reactions. However, they may have habituated to the sound source after multiple 

exposures since a habituation behavior was retained when exposures were separated by several days 

(Moein Bartol et al., 1995). Intermittent exposures are assumed to be less likely to have lasting 

consequences. 

3.8.3.1.2 Impacts from Sonar and Other Transducers

Sonar and other transducers emit sound waves into the water to detect objects, safely navigate, and 

communicate. Use of sonar and other transducers would typically be transient and temporary. General 

categories of sonar systems are described in Section 3.0.3.3.1 (Acoustic Stressors); only those sources 

within the hearing range of reptiles (<2 kHz) in the Study Area are considered.

Sonar-induced acoustic resonance and bubble formation phenomena are very unlikely to occur under 

realistic conditions, as discussed in Section 3.8.3.1.1.1 (Injury). Non-auditory injury (i.e., other than PTS) 

and mortality from sonar and other transducers is so unlikely as to be discountable under normal 

conditions and is therefore not considered further in this analysis. 

The most probable impacts from exposure to sonar and other transducers are PTS, TTS, behavioral 

reactions, masking, and physiological stress (Sections 3.8.3.1.1.2, Hearing Loss and Auditory Injury;

3.8.3.1.1.3, Physiological Stress; 3.8.3.1.1.4, Masking; and 3.8.3.1.1.5, Behavioral Reactions).

Activities involving sonar and other transducers would not occur in areas inhabited by the ESA-listed 

American crocodile, thus potential impacts are limited to sea turtles, alligators, and terrapins.

3.8.3.1.2.1 Methods for Analyzing Impacts from Sonar and Other Transducers

Potential impacts considered are hearing loss due to threshold shift (permanent or temporary), masking 

of other biologically relevant sounds, physiological stress, and changes in behavior. The Navy performed 

a quantitative analysis to estimate the number of times that sea turtles could be affected by sonar and 

other transducers used during Navy training and testing activities. The Navy’s quantitative analysis to 

determine impacts to sea turtles and marine mammals uses the Navy Acoustic Effects Model to produce 

initial estimates of the number of animals that may experience these effects; these estimates are further 

refined by considering animal avoidance of sound-producing activities and implementation of 

mitigation. The steps of this quantitative analysis are described in Section 3.0.1.2 (Navy’s Quantitative 

Analysis to Determine Impacts to Sea Turtles and Marine Mammals), which takes into account:

 criteria and thresholds used to predict impacts from sonar and other transducers (see below); 

 the density and spatial distribution of sea turtles; and 

 the influence of environmental parameters (e.g., temperature, depth, salinity) on sound 

propagation when estimating the received sound level on the animals.
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A further detailed explanation of this analysis is provided in the 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, 2018). Since crocodilians and terrapins have similar 

hearing range and sensitivity as sea turtles, as described in Section 3.8.2.1.4 (Hearing and Vocalization), 

it is inferred that crocodilians and terrapins would react similarly to sonar and other transducers as sea 

turtles. 

Criteria and Thresholds Used to Predict Impacts from Sonar and Other Transducers

Auditory Weighting Functions

Animals are not equally sensitive to noise at all frequencies. To capture the frequency-dependent nature 

of the effects of noise, auditory weighting functions are used. Auditory weighting functions are 

mathematical functions that adjust received sound levels to emphasize ranges of best hearing and 

de-emphasize ranges with less or no auditory sensitivity. The adjusted received sound level is referred to 

as a weighted received sound level. 

The auditory weighting function for sea turtles is shown in Figure 3.8-11. The derivation of this 

weighting function is described in the technical report Criteria and Thresholds for U.S. Navy Acoustic and 

Explosive Effects Analysis (Phase III) (U.S. Department of the Navy, 2017). The frequencies around the 

top portion of the function, where the amplitude is closest to zero, are emphasized, while the 

frequencies below and above this range (where amplitude declines) are de-emphasized, when summing 

acoustic energy received by a sea turtle.

Source: U.S. Department of the Navy (2017)

Notes: dB: decibels; kHz: kilohertz; TU: sea turtle species group

Figure 3.8-11: Auditory Weighting Function for Sea Turtles

Hearing Loss from Sonar and Other Transducers

No studies of hearing loss have been conducted on sea turtles. Therefore, sea turtle susceptibility to 

hearing loss due to an acoustic exposure is evaluated using knowledge about sea turtle hearing abilities 

in combination with non-impulsive auditory effect data from other species (marine mammals and fish). 
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This yields sea turtle exposure functions, shown in Figure 3.8-12, which are mathematical functions that 

relate the sound exposure levels (SELs) for onset of PTS or TTS to the frequency of the sonar sound 

exposure. The derivation of the sea turtle exposure functions are provided in the technical report 

Criteria and Thresholds for U.S. Navy Acoustic and Explosive Effects Analysis (Phase III) (U.S. Department 

of the Navy, 2017).

Source: U.S. Department of the Navy (2017)

Note: dB re 1 μPa2s: decibels referenced to 1 micropascal second squared; kHz: kilohertz. The solid black curve is the exposure 

function for TTS and the dashed black curve is the exposure function for PTS onset. Small dashed lines and asterisks 

indicate the SEL thresholds at the most-sensitive frequency for TTS (200 dB) and PTS (220 dB).

Figure 3.8-12: TTS and PTS Exposure Functions for Sonar and Other Transducers

Accounting for Mitigation

The Navy implements mitigation measures (described in Chapter 5, Mitigation) that would reduce the 

probability or severity of any potential impacts during activities that use sonar and other transducers, 

including the power-down or shut-down (i.e., power-off) of sonar when a sea turtle is observed in the 

mitigation zone. The mitigation zones for active sonar activities were designed to avoid the potential for 

sea turtles to be exposed to levels of sound that could result in auditory injury (i.e., PTS) from active 

sonar to the maximum extent practicable. The mitigation zones encompass the estimated ranges to 

injury (including PTS) for a given sonar exposure. Therefore, the impact analysis quantifies the potential 

for mitigation to reduce the risk of PTS. Two factors are considered when quantifying the effectiveness 

of mitigation: (1) the extent to which the type of mitigation proposed for a sound-producing activity 

(e.g., active sonar) allows for observation of the mitigation zone prior to and during the activity; and 

(2) the sightability of each species that may be present in the mitigation zone, which is determined by 

species-specific characteristics and the viewing platform. A detailed explanation of the analysis is

provided in the technical report 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, 2018).

In the quantitative analysis, consideration of mitigation measures means that, for activities where 

mitigation is feasible, some model-estimated PTS is considered mitigated to the level of TTS. The impact 
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analysis does not analyze the potential for mitigation to reduce TTS or behavioral effects, even though 

mitigation could also reduce the likelihood of these effects. In practice, mitigation also protects all 

unobserved (below the surface) animals in the vicinity, including other species, in addition to the 

observed animal. However, the analysis assumes that only animals sighted at the water surface would 

be protected by the applied mitigation. The analysis, therefore, does not capture the protection 

afforded to all marine species that may be near or within the mitigation zone.

The ability to observe the range to PTS was estimated for each training or testing event. The ability of 

Navy Lookouts to detect sea turtles in or approaching the mitigation zone is dependent on the animal’s 

presence at the surface and the characteristics of the animal that influence its sightability (such as size 

or surface active behavior). The behaviors and characteristics of some species may make them easier to 

detect. Environmental conditions under which the training or testing activity could take place are also 

considered such as the sea surface conditions, weather (e.g., fog or rain), and day versus night.

3.8.3.1.2.2 Impact Ranges for Sonar and Other Transducers

Because sea turtle hearing range is limited to a narrow range of frequencies and thresholds for auditory 

impacts are relatively high, there are very few sonar sources that could potentially result in exposures 

exceeding the sea turtle PTS and TTS thresholds. Therefore, the range to auditory effects for most 

sources, such as the representative bin of LF5, in sea turtle hearing range is zero. Ranges would be 

greater (i.e., up to tens of meters) for sonars and other transducers with higher source levels; however, 

specific ranges cannot be provided in an unclassified document.

Ranges to auditory effects are not calculated for crocodilians or terrapins. Due to similarity in hearing 

and for purposes of this analysis, crocodilians and terrapins are assumed to have similar ranges to 

auditory impacts as sea turtles. 

Presentation of Estimated Impacts from the Quantitative Analysis

The results of the analysis of potential impacts to sea turtles from sonars and other transducers are 

discussed below in Sections 3.8.3.1.2.3 (Impacts from Sonar and Other Transducers under Alternative 1) 

and 3.8.3.1.2.4 (Impacts from Sonar and Other Active Sources under Alternative 2). The detailed analysis 

of potential impacts estimated for individual species from exposure to sonar for training and testing 

activities under Alternative 1 and Alternative 2 are presented in the figures below. The figures below 

provide the estimated impacts per region, per activity, and by effect (e.g., TTS and PTS). There is a 

potential for impacts to occur anywhere within the Study Area where sound from sonar and the species 

overlap, although only Regions or Activity Categories where 0.5 percent of the impacts or greater are 

estimated to occur are graphically represented on the figures below. All (i.e., grand total) estimated 

impacts for that species are included in the bar plots, regardless of region or category. 

Note that the numbers of activities planned can vary from year-to-year. Results are presented for a 

“maximum sonar use year”. The number of hours these sonars would be operated are described in 

Section 3.0.3.3.1 (Acoustic Stressors). Potential impacts to crocodilians and terrapins are analyzed

qualitatively. 

3.8.3.1.2.3 Impacts from Sonar and Other Transducers under Alternative 1

Impacts from Sonar and Other Transducers under Alternative 1 for Training Activities

General categories and characteristics of sonar systems and the number of hours these sonars would be 

operated during training under Alternative 1 are described in Section 3.0.3.3.1 (Acoustic Stressors). 

Activities using sonars and other transducers would be conducted as described in Chapter 2 (Description 
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of Proposed Action and Alternatives) and Appendix A (Navy Activity Descriptions). Use of sonar and 

other transducers would typically be transient and temporary.

Under Alternative 1, the number of major training exercises and civilian port defense activities would 

fluctuate each year to account for the natural variation of training cycles and deployment schedules. 

Some unit-level anti-submarine warfare training requirements would be met through synthetic training 

in conjunction with other training exercises. Training activities using low-frequency sonar and other 

transducers within reptile hearing range (<2 kHz) could occur throughout the Study Area in areas 

potentially inhabited by sea turtles, alligators, and terrapins, although use would generally occur within 

Navy range complexes, on Navy testing ranges, or around inshore locations identified in Chapter 2 

(Description of Proposed Action and Alternatives). Use of low-frequency sonars during training activities 

would be greatest in the Jacksonville Range Complex and Chesapeake Bay.

The quantitative analysis, using the number of hours of sonar and other transducers for a maximum year 

of training activities under Alternative 1, predicts that no sea turtles of any species are likely to be 

exposed to the high received levels of sound from sonars or other transducers that could cause TTS or 

PTS. Only a limited number of sonars and other transducers with frequencies within the range of reptile 

hearing (<2 kHz) and high source levels have the potential to cause TTS and PTS. 

The ANSI Sound Exposure Guidelines estimate the risk of a sea turtle responding to a low-frequency 

sonar (less than 1 kHz) is low regardless of proximity to the source, and there is no risk of a sea turtle 

responding to a mid-frequency sonar (1–10 kHz) (Popper et al., 2014). A reptile could respond to sounds 

detected within its limited hearing range if it is close enough to the source. The few studies of sea turtle 

reactions to sounds, discussed in Section 3.8.3.1.1.5 (Behavioral Reactions), suggest that a behavioral 

response could consist of temporary avoidance, increased swim speed, or changes in depth, or that 

there may be no observable response. Use of sonar and other transducers would typically be transient 

and temporary, and there is no evidence to suggest that any behavioral response would persist after a 

sound exposure. It is assumed that a stress response could accompany any behavioral responses. 

Implementation of mitigation may further reduce the already low risk of auditory impacts on sea turtles. 

Depending on the sonar source, mitigation includes powering down the sonar or ceasing active sonar 

transmission if a sea turtle is observed in the mitigation zone, as discussed in Section 5.3.2 (Acoustic 

Stressors).

Although masking of biologically relevant sounds by the limited number of sonars and other transducers 

operated in reptile hearing range is possible, this may only occur in certain circumstances. Reptiles most 

likely use sound to detect nearby broadband, continuous environmental sounds, such as the sounds of 

waves crashing on the beach. The use characteristics of most low-frequency sonars, including limited 

band width, beam directionality, limited beam width, relatively low source levels, low duty cycle, and 

limited duration of use, would both greatly limit the potential for a reptile to detect these sources and 

limit the potential for masking of broadband, continuous environmental sounds. In addition, broadband 

sources within sea turtle hearing range, such as countermeasures used during anti-submarine warfare, 

would typically be used in off-shore areas and some inshore areas, but not in nearshore areas where 

detection of beaches or concentrated vessel traffic is relevant for the masking of biologically relevant 

sounds to reptiles.

Considering the above factors and the mitigation measures that would be implemented as described in 

Chapter 5 (Mitigation), long-term consequences to sea turtle individuals or populations would not be 

expected.
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The use of sonar and other transducers during training activities would not overlap with green, 

hawksbill, or leatherback turtle critical habitat around Culebra, Puerto Rico; Mona Island, Puerto Rico; 

and St. Croix Island, U.S. Virgin Islands respectively. For loggerhead turtle designated critical habitat (79 

Federal Register 39855), the use of sonar and other transducers have a pathway to impact the physical 

and biological features of the constricted migratory habitat in the mid-Atlantic and southeast regions by 

producing “noise pollution” from military activity. However, impacts, if any, on this habitat would be 

considered insignificant, with no discernible impact on the conservation function of the physical and 

biological features, and would not prevent a turtle from migrating as these activities are not continuous 

and most sources are outside of sea turtle hearing range. The physical and biological features identified 

for the nearshore reproductive, wintering, breeding, and Sargassum habitats (National Marine Fisheries 

Service, 2014b) would not be impacted by the use of sonar and other transducers during training 

activities.

It is reasonable to assume that crocodilians and terrapins use their hearing similarly to sea turtles and 

that the types of impacts would be similar to those described above for sea turtles. Within their 

respective geographic ranges, alligators and terrapins could potentially be exposed to sonar and other 

transducers in the inshore regions of the Study Area during training activities, as described in Chapter 2 

(Description of Proposed Action and Alternatives) and Appendix A (Navy Activity Descriptions). Sonar 

use is not proposed in the nearshore and inshore areas of south Florida known to be inhabited by the 

ESA-listed American crocodile or in designated American crocodile critical habitat in the Florida Bay, 

which encompasses creeks, canals, and swamps.

Pursuant to the ESA, the use of sonar and other transducers during training activities under Alternative 1 

may affect ESA-listed green, hawksbill, Kemp’s ridley, loggerhead, and leatherback turtles; and would 

have no effect on the ESA-listed American crocodile. There would be no effect on green, hawksbill, or 

leatherback turtle critical habitat or American crocodile critical habitat. The use of sonar and other 

transducers during training activities may affect loggerhead constricted migratory habitats in the 

mid-Atlantic and southeast regions. The Navy has consulted with NMFS as required by section 7(a)(2) of 

the ESA. 

Impacts from Sonar and Other Transducers under Alternative 1 for Testing Activities

General categories and characteristics of sonar systems and the number of hours these sonars would be 

operated during testing under Alternative 1 are described in Section 3.0.3.3.1 (Acoustic Stressors). 

Activities using sonars and other transducers would be conducted as described in Chapter 2 (Description 

of Proposed Action and Alternatives) and Appendix A (Navy Activity Descriptions).

Under Alternative 1, the number of testing activities would fluctuate annually. Testing activities using 

sonar and other transducers could occur throughout the Study Area, although use would generally occur 

within Navy range complexes, on Navy testing ranges, or around inshore locations identified in Chapter 

2 (Description of Proposed Action and Alternatives). In particular, low-frequency sources during testing 

activities occur in some coastal waters such as Bath, Maine, Groton, Connecticut; Newport, Rhode 

Island; the Naval Undersea Warfare Center Division, Newport Testing Range; Narragansett, Rhode 

Island; Norfolk, Virginia; Kings Bay, Georgia; Mayport, Florida; Port Canaveral, Florida; offshore of Fort 

Pierce, Florida; South Florida Ocean Measurement Facility; Naval Surface Warfare Center, Panama City 

Division Testing Range; Pascagoula, Mississippi; as well as in any of the range complexes throughout the 

Study Area. Low-frequency sources are operated more frequently under testing activities than during 

training activities. Therefore, although the general impacts from sonar and other transducers under 
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testing would be similar in severity to those described during training, there may be slightly more 

impacts under testing activities.

The quantitative analysis, using the number of hours of sonar and other transducers for a maximum year 

of testing activities, predicts that no green or hawksbill sea turtles are likely to be exposed to the high 

received levels of sound from sonars or other transducers that could cause TTS or PTS under Alternative 

1. The quantitative analysis also predicts that a small number of Kemp’s ridley, leatherback, and 

loggerhead turtles may be exposed to levels of sound from sonars or other transducers that could cause 

TTS. The locations and types of testing activities that would most likely contribute to these impacts are 

shown in Figure 3.8-13, Figure 3.8-14, and Figure 3.8-15 for Kemp’s ridley, leatherback, and loggerhead 

turtles, respectively. Most impacts are predicted to occur in the Northeast Range Complexes, with fewer 

impacts in the Jacksonville Range Complex. Fractional estimated impacts per region and activity area 

represent the probability that the number of estimated impacts by effect will occur in a certain region or 

be due to a certain activity category. 

Notes: Region and Activity bar charts show categories +/- 0.5 percent of the estimated impacts. No impacts during training are 

estimated for this species. No PTS is estimated for this species. No impacts are estimated from training. ASW: Anti-Submarine 

Warfare; RC: Range Complex.
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Figure 3.8-13: Kemp’s Ridley Turtle Impacts Estimated per Year from Sonar and Other 

Transducers Used During Training and Testing under Alternative 1

Notes: Region and Activity bar charts show categories +/- 0.5 percent of the estimated impacts. No impacts during training are 

estimated for this species. No PTS is estimated for this species. No impacts are estimated from training. ASW: Anti-Submarine 

Warfare; RC: Range Complex.

Figure 3.8-14: Leatherback Sea Turtle Impacts Estimated per Year from Sonar and Other 

Transducers Used During Training and Testing under Alternative 1
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Notes: Region and Activity bar charts show categories +/- 0.5 percent of the estimated impacts. No impacts during training are 

estimated for this species. No PTS is estimated for this species. No impacts are estimated from training. ASW: Anti-Submarine 

Warfare; RC: Range Complex.

Figure 3.8-15: Loggerhead Sea Turtle Impacts Estimated per Year from Sonar and Other 

Transducers Used During Training and Testing under Alternative 1

Only a limited number of sonars and other transducers with frequencies within the range of reptile 

hearing (<2 kHz) and high source levels have the potential to cause TTS and PTS. Any impact to hearing 

could reduce the distance over which a reptile detects environmental cues, such as the sound of waves 

or the presence of a vessel or predator. Implementation of mitigation may further reduce the already 

low risk of auditory impacts on sea turtles. Depending on the sonar source, mitigation includes powering 

down the sonar or ceasing active sonar transmission if a sea turtle is observed in the mitigation zone, 

and conducting pierside sonar testing during daylight hours at Port Canaveral, Florida and Kings Bay, 

Georgia, as discussed in Section 5.3.2 (Acoustic Stressors). 

The ANSI Sound Exposure Guidelines estimate the risk of a sea turtle responding to a low-frequency 

sonar (less than 1 kHz) is low regardless of proximity to the source, and there is no risk of a sea turtle 
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responding to a mid-frequency sonar (1–10 kHz) (Popper et al., 2014). A reptile could respond to sounds 

detected within their limited hearing range if they are close enough to the source. The few studies of 

sea turtle reactions to sounds, discussed in Section 3.8.3.1.1.5 (Behavioral Reactions), suggest that a 

behavioral response could consist of temporary avoidance, increased swim speed, or changes in depth, 

or that there may be no observable response. There is no evidence to suggest that any behavioral 

response would persist after a sound exposure. It is assumed that a stress response could accompany 

any behavioral responses or TTS.

Although masking of biologically relevant sounds by the limited number of sonars and other transducers 

operated in reptile hearing range is possible, this may only occur in certain circumstances. Reptiles most 

likely use sound to detect nearby broadband, continuous environmental sounds, such as the sounds of 

waves crashing on the beach. The use characteristics of most sonars, including limited band width, beam 

directionality, limited beam width, relatively low source levels, low duty cycle, and limited duration of 

use, would both greatly limit the potential for a sea turtle to detect these sources and limit the potential 

for masking of broadband, continuous environmental sounds. 

Considering the above factors and the mitigation measures that would be implemented as described in 

Chapter 5 (Mitigation), long-term consequences to sea turtle individuals or populations would not be 

expected.

The use of sonar and other transducers during training activities would not overlap with green, 

hawksbill, or leatherback turtle critical habitat around Culebra, Puerto Rico; Mona Island, Puerto Rico; 

and St. Croix Island, U.S. Virgin Islands respectively. For loggerhead turtle designated critical habitat, the 

use of sonar and other transducers have a pathway to impact the physical and biological features of the 

constricted migratory habitat in the mid-Atlantic and southeast regions by producing “noise pollution” 

from military activity (79 Federal Register 39855). However, impacts, if any, on this habitat would be 

considered insignificant, with no discernible impact on the conservation function of the physical and 

biological features, and would not prevent a turtle from migrating as these activities are not continuous 

and most sources are outside of sea turtle hearing range. The physical and biological features identified 

for the nearshore reproductive, wintering, breeding, and Sargassum habitats (National Marine Fisheries 

Service, 2014b) would not be impacted by the use of sonar and other transducers during testing 

activities.

It is reasonable to assume that crocodilians and terrapins use their hearing similarly to sea turtles and 

that the types of impacts would be similar to those described above for sea turtles. Within their 

respective geographic ranges, alligators and terrapins could potentially be exposed to sonar and other 

transducers in the inshore regions of the Study Area during testing activities, as described in Chapter 2 

(Description of Proposed Action and Alternatives) and Appendix A (Navy Activity Descriptions). No sonar 

use is proposed in the inshore or nearshore areas of south Florida known to be inhabited by the ESAlisted American crocodile, including designated American crocodile critical habitat in the Florida Bay, 

which encompasses creeks, canals, and swamps.

Pursuant to the ESA, the use of sonar and other transducers during testing activities under Alternative 1 

may affect ESA-listed green, hawksbill, Kemp’s ridley, leatherback, and loggerhead turtles; and would 

have no effect on the ESA-listed American crocodile. There would be no effect on green, hawksbill, or 

leatherback turtle critical habitat or American crocodile critical habitat since the use of sonar and other 

transducers during testing activities. The use of sonar and other transducers during testing activities may 

affect loggerhead constricted migratory habitats in the mid-Atlantic and southeast regions. The Navy has 

consulted with NMFS as required by section 7(a)(2) of the ESA. 
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3.8.3.1.2.4 Impacts from Sonar and Other Active Sources under Alternative 2

Impacts from Sonar and Other Transducers under Alternative 2 for Training Activities

General categories and characteristics of sonar systems and the number of hours these sonars would be 

operated during training under Alternative 2 are described in Section 3.0.3.3.1 (Acoustic Stressors). 

Activities using sonars and other transducers would be conducted as described in Chapter 2 (Description 

of Proposed Action and Alternatives) and Appendix A (Navy Activity Descriptions).

Under Alternative 2, the maximum number of major training exercises could occur every year, an 

additional major training exercise would be conducted in the Gulf of Mexico Range Complex annually, 

and only the number of civilian port defense activities would fluctuate annually. In addition, all unit level 

anti-submarine warfare tracking exercise – ship activities would be completed through individual events 

conducted at sea, rather than through leveraging other anti-submarine warfare training exercises or 

synthetically. This would result in an increase of sonar use compared to Alternative 1, including sources 

within reptile hearing range. Training activities using sonar and other transducers could occur 

throughout the Study Area, although use would generally occur within Navy range complexes, on Navy 

testing ranges, or around inshore locations identified in Chapter 2 (Description of Proposed Action and 

Alternatives). Use of sonars associated with anti-submarine warfare would be greatest in the 

Jacksonville and Virginia Capes Range Complexes. The limited number of sources within sea turtle 

hearing range would also typically be used in the areas described above. 

The quantitative analysis predicts that no sea turtles of any species are likely to be exposed to the high 

received levels of sound from sonars or other transducers that could cause TTS or PTS during a 

maximum year of training activities under Alternative 2. Although there would be an increase in sonar 

use compared to Alternative 1, the potential for and type of impacts on reptiles would be the similar. 

This is because reptiles are capable of detecting only a limited number of sonars due to their limited 

hearing range. 

The ANSI Sound Exposure Guidelines estimate the risk of a sea turtle responding to a low-frequency 

sonar (less than 1 kHz) is low regardless of proximity to the source, and there is no risk of a sea turtle 

responding to a mid-frequency sonar (1 to 10 kHz) (Popper et al., 2014). A reptile could respond to 

sounds detected within their limited hearing range if they are close enough to the source. The few 

studies of sea turtle reactions to sounds, discussed in Section 3.8.3.1.1.5 (Behavioral Reactions), suggest 

that a behavioral response could consist of temporary avoidance, increased swim speed, or changes in 

depth, or that there may be no observable response. Use of sonar and other transducers would typically 

be transient and temporary, and there is no evidence to suggest that any behavioral response would 

persist after a sound exposure. It is assumed that a stress response could accompany any behavioral 

responses. 

Implementation of mitigation may further reduce the already low risk of auditory impacts on sea turtles. 

Depending on the sonar source, mitigation includes powering down the sonar or ceasing active sonar 

transmission if a sea turtle is observed in the mitigation zone, as discussed in Section 5.3.2 (Acoustic 

Stressors).

Although masking of biologically relevant sounds by the limited number of sonars and other transducers 

operated in reptile hearing range is possible, this may only occur in certain circumstances. Reptiles most 

likely use sound to detect nearby broadband, continuous environmental sounds, such as the sounds of 

waves crashing on the beach. The use characteristics of most low-frequency sonars, including limited 

band width, beam directionality, limited beam width, relatively low source levels, low duty cycle, and 
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limited duration of use, would both greatly limit the potential for a reptile to detect these sources and 

limit the potential for masking of broadband, continuous environmental sounds.

Considering the above factors and the mitigation measures that would be implemented as described in 

Chapter 5 (Mitigation), long-term consequences to sea turtle individuals or populations would not be 

expected.

The use of sonar and other transducers during training activities would not overlap with green, 

hawksbill, or leatherback turtle critical habitat around Culebra, Puerto Rico; Mona Island, Puerto Rico; 

and St. Croix Island, U.S. Virgin Islands respectively. For loggerhead turtle designated critical habitat, the 

use of sonar and other transducers have a pathway to impact the physical and biological features of the 

constricted migratory habitat in the mid-Atlantic and southeast regions by producing “noise pollution” 

from military activity (79 Federal Register 39855). However, impacts, if any, on this habitat would be 

considered insignificant, with no discernible impact on the conservation function of the physical and 

biological features, and would not prevent a turtle from migrating as these activities are not continuous 

and most sources are outside of sea turtle hearing range. The physical and biological features of the 

nearshore reproductive, wintering, breeding, and Sargassum habitats (National Marine Fisheries 

Service, 2014b) would not be impacted by the use of sonar and other transducers during training 

activities.

It is reasonable to assume that crocodilians and terrapins use their hearing similarly to sea turtles and 

that the types of impacts would be similar to those described above for sea turtles. Within their 

respective geographic ranges, alligators and terrapins could potentially be exposed to sonar and other 

transducers in the inshore regions of the Study Area during testing activities, as described in Chapter 2 

(Description of Proposed Action and Alternatives) and Appendix A (Navy Activity Descriptions). No sonar 

use is proposed in the inshore or nearshore areas of south Florida known to be inhabited by the ESAlisted American crocodile, including designated American crocodile critical habitat in the Florida Bay, 

which encompasses creeks, canals, and swamps.

Pursuant to the ESA, the use of sonar and other transducers during training activities under Alternative 2 

may affect ESA-listed green, hawksbill, Kemp’s ridley, loggerhead, and leatherback sea turtles; and 

would have no effect on the ESA-listed American crocodile. There would be no effect on green, 

hawksbill, or leatherback turtle or American crocodile critical habitat. The use of sonar and other 

transducers during training activities may affect loggerhead constricted migratory habitats in the midAtlantic and southeast regions. 

Impacts from Sonar and Other Transducers under Alternative 2 for Testing Activities

General categories and characteristics of sonar systems and the number of hours these sonars would be 

operated during testing under Alternative 2 are described in Section 3.0.3.3.1 (Acoustic Stressors). 

Activities using sonars and other transducers would be conducted as described in Chapter 2 (Description 

of Proposed Action and Alternatives) and Appendix A (Navy Activity Descriptions).

Under Alternative 2, the maximum number of nearly all testing activities would occur every year. This 

would result in an increase of sonar use compared to Alternative 1, including sources within reptile 

hearing range. Testing activities using sonar and other transducers could occur throughout the Study 

Area, although use would generally occur within Navy range complexes, on Navy testing ranges, or 

around inshore locations identified in Chapter 2 (Description of Proposed Action and Alternatives).

The quantitative analysis predicts that no green or hawksbill sea turtles are likely to be exposed to the 

high received levels of sound from sonars or other transducers that could cause PTS or TTS during 
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testing activities under Alternative 2. The quantitative analysis also predicts that a small number of 

Kemp’s ridley, loggerhead, and leatherback turtles may be exposed to levels of sound from sonars or 

other transducers that could cause TTS during testing activities under Alternative 2. The locations and 

types of testing activities that would most likely contribute to these impacts are shown in Figure 3.8-16, 

Figure 3.8-17, and Figure 3.8-18 for Kemp’s ridley, leatherback, and loggerhead turtles, respectively. 

Most impacts are predicted to occur in the Northeast Range Complexes. Fractional estimated impacts 

per region and activity area represent the probability that the number of estimated impacts by effect 

will occur in a certain region or be due to a certain activity category. 

Notes: Region and Activity bar charts show categories +/- 0.5 percent of the estimated impacts. No impacts during training are 

estimated for this species. No PTS is estimated for this species. No impacts are estimated from training. ASW: Anti-Submarine 

Warfare; RC: Range Complex.

Figure 3.8-16: Kemp’s Ridley Turtle Impacts Estimated per Year from Sonar and Other 

Transducers Used During Training and Testing under Alternative 2
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Notes: Region and Activity bar charts show categories +/- 0.5 percent of the estimated impacts. No impacts during training are 

estimated for this species. No PTS is estimated for this species. No impacts are estimated from training. ASW: Anti-Submarine 

Warfare; RC: Range Complex.

Figure 3.8-17: Leatherback Sea Turtle Impacts Estimated per Year from Sonar and Other 

Transducers Used During Training and Testing under Alternative 2
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Notes: Region and Activity bar charts show categories +/- 0.5 percent of the estimated impacts. No impacts during training are 

estimated for this species. No PTS is estimated for this species. No impacts are estimated from training. ASW: Anti-Submarine 

Warfare; RC: Range Complex.

Figure 3.8-18: Loggerhead Sea Turtle Impacts Estimated per Year from Sonar and Other 

Transducers Used During Training and Testing under Alternative 2

Only a limited number of sonars and other transducers with frequencies within the range of reptile 

hearing (<2 kHz) and high source levels have the potential to cause TTS and PTS. Any impact to hearing 

could reduce the distance over which a reptile detects environmental cues, such as the sound of waves 

or the presence of a vessel or predator. Implementation of mitigation may further reduce the already 

low risk of auditory impacts on sea turtles. Depending on the sonar source, mitigation includes powering 

down the sonar or ceasing active sonar transmission if a sea turtle is observed in the mitigation zone, 

and conducting pierside sonar testing during daylight hours at Port Canaveral, Florida and Kings Bay, 

Georgia, as discussed in Section 5.3.2 (Acoustic Stressors). 

The ANSI Sound Exposure Guidelines estimate the risk of a sea turtle responding to a low-frequency 

sonar (less than 1 kHz) is low regardless of proximity to the source, and there is no risk of a sea turtle 
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responding to a mid-frequency sonar (1–10 kHz) (Popper et al., 2014). A reptile could respond to sounds 

detected within their limited hearing range if they are close enough to the source. The few studies of 

sea turtle reactions to sounds, discussed in Section 3.8.3.1.1.5 (Behavioral Reactions), suggest that a 

behavioral response could consist of temporary avoidance, increased swim speed, or changes in depth, 

or that there may be no observable response. There is no evidence to suggest that any behavioral 

response would persist after the sound exposure ends. It is assumed that a stress response could 

accompany any behavioral responses or TTS.

Although masking of biologically relevant sounds by the limited number of sonars and other transducers 

operated in reptile hearing range is possible, this may only occur in certain circumstances. Reptiles most 

likely use sound to detect nearby broadband, continuous environmental sounds, such as the sounds of 

waves crashing on the beach. The use characteristics of most sonars, including limited band width, beam 

directionality, limited beam width, relatively low source levels, low duty cycle, and limited duration of 

use, would both greatly limit the potential for a sea turtle to detect these sources and limit the potential 

for masking of broadband, continuous environmental sounds. 

Considering the above factors and the mitigation measures that would be implemented as described in 

Chapter 5 (Mitigation), long-term consequences to sea turtle individuals or populations would not be 

expected.

The use of sonar and other transducers during testing activities would not overlap with green, hawksbill, 

or leatherback turtle critical habitat around Culebra, Puerto Rico; Mona Island, Puerto Rico; and St. Croix 

Island, U.S. Virgin Islands, respectively. For loggerhead turtle-designated critical habitat (79 Federal 

Register 39855), the use of sonar and other transducers have a pathway to impact the physical and 

biological features of the constricted migratory habitat in the mid-Atlantic and southeast regions by 

producing “noise pollution” from military activity. However, impacts, if any, on this habitat would be 

considered insignificant, with no discernible impact on the conservation function of the physical and 

biological features, and would not prevent a turtle from migrating as these activities are not continuous 

and most sources are outside of sea turtle hearing range. The physical and biological features of the 

nearshore reproductive, wintering, breeding, and Sargassum habitats (National Marine Fisheries 

Service, 2014b) would not be impacted by the use of sonar and other transducers during testing 

activities.

It is reasonable to assume that crocodilians and terrapins use their hearing similarly to sea turtles and 

that the types of impacts would be similar to those described above for sea turtles. Within their 

respective geographic ranges, alligators and terrapins could potentially be exposed to sonar and other 

transducers in the inshore regions of the Study Area during testing activities, as described in Chapter 2 

(Description of Proposed Action and Alternatives) and Appendix A (Navy Activity Descriptions). No sonar 

use is proposed in the inshore or nearshore areas of south Florida known to be inhabited by the ESAlisted American crocodile, including designated American crocodile critical habitat in the Florida Bay, 

which encompasses creeks, canals, and swamps.

Pursuant to the ESA, the use of sonar and other transducers during testing activities under Alternative 2 

may affect ESA-listed green, hawksbill, Kemp’s ridley, leatherback, and loggerhead turtles; and would 

have no effect on the ESA-listed American crocodile. There would be no effect on green, hawksbill, or 

leatherback turtle critical habitat or American crocodile habitat. The use of sonar and other transducers 

during testing activities may affect loggerhead constricted migratory habitats in the mid-Atlantic and

southeast regions. 
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3.8.3.1.2.5 Impacts from Sonar and Other Transducers under the No Action Alternative

Under the No-Action Alternative, the Navy would not conduct the proposed training and testing 

activities in the AFTT Study Area. Various acoustic stressors (e.g., sonar and other transducers) would 

not be introduced into the marine environment. Therefore, baseline conditions of the existing 

environment would either remain unchanged or would improve slightly after cessation of ongoing

training and testing activities. 

3.8.3.1.3 Impacts from Air Guns

Air guns use bursts of pressurized air to create broadband, impulsive sounds. Any use of air guns would 

typically be transient and temporary. Section 3.0.3.3.1.2 (Air Guns) provides additional details on the use 

and acoustic characteristics of the small air guns used in these activities. Because no use of air guns is 

proposed in known crocodilian habitat, the remainder of the analysis of impacts from air guns focuses 

on sea turtles and terrapins.

3.8.3.1.3.1 Methods for Analyzing Impacts from Air Guns

Potential impacts considered are hearing loss due to threshold shift (permanent or temporary), masking 

of other biologically relevant sounds, physiological stress, and changes in behavior. The Navy’s 

quantitative analysis to determine impacts to sea turtles and marine mammals uses the Navy Acoustic 

Effects Model to produce initial estimates of the number of animals that may experience these effects; 

these estimates are further refined by considering animal avoidance of sound-producing activities and 

implementation of mitigation. The steps of this quantitative analysis are described in Section 3.0.1.2 

(Navy’s Quantitative Analysis to Determine Impacts to Sea Turtles and Marine Mammals), which takes 

into account:

 criteria and thresholds used to predict impacts from air guns (see below);

 the density and spatial distribution of sea turtle; and

 the influence of environmental parameters (e.g., temperature, depth, salinity) on sound 

propagation when estimating the received sound level on the animals 

A further detailed explanation of this analysis is provided in the 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, 2018).Since terrapins have similar hearing range and 

sensitivity as sea turtles, as described in Section 3.8.2.1.4 (Hearing and Vocalization), it is inferred that 

terrapins could react similarly to air guns as sea turtles. 

Criteria and Thresholds used to Predict Impacts on Sea Turtles from Air Guns

Auditory Weighting Functions

Animals are not equally sensitive to noise at all frequencies. To capture the frequency-dependent nature 

of the effects of noise, auditory weighting functions are used. The auditory weighting function for sea 

turtles presented above in Section 3.8.3.1.2.1 (Methods for Analyzing Impacts from Sonar and Other 

Transducers) is also used in the quantitative assessment of auditory impacts due to air guns. 

Hearing Loss from Air Guns

No studies of hearing loss have been conducted on sea turtles. Therefore, sea turtle susceptibility to 

hearing loss due to an air gun exposure is evaluated using knowledge about sea turtle hearing abilities in 

combination with auditory effect data from other species (marine mammals and fish). This yields sea 

turtle exposure functions, shown in Figure 3.8-19, which are mathematical functions that relate the SELs 
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for onset of PTS or TTS to the frequency of the underwater impulsive sound exposure. The derivation of 

the sea turtle impulsive exposure functions are provided in the technical report Criteria and Thresholds 

for U.S. Navy Acoustic and Explosive Effects Analysis (Phase III) (U.S. Department of the Navy, 2017).

Notes: kHz: kilohertz; SEL: Sound Exposure Level, dB re 1 μPa2s: decibels referenced to 1 micropascal squared second. The solid 

black curve is the exposure function for TTS onset and the dashed black curve is the exposure function for PTS onset. Small 

dashed lines and asterisks indicate the SEL thresholds and most-sensitive frequency for TTS and PTS.

Figure 3.8-19: TTS and PTS Exposure Functions for Impulsive Sounds 

For impulsive sounds, hearing loss in other species has also been observed to be related to the 

unweighted peak pressure of a received sound. Because this data does not exist for sea turtles, 

unweighted peak pressure thresholds for PTS and TTS were developed by applying relationships 

observed between impulsive peak pressure TTS thresholds and auditory sensitivity in marine mammals 

to sea turtles. This results in dual-metric hearing loss criteria for sea turtles for impulsive sound 

exposure: the SEL-based exposure functions in Figure 3.8-18 and the peak pressure thresholds in Table 

3.8-2. The derivation of the sea turtle impulsive peak pressure PTS and TTS thresholds are provided in 

the technical report Criteria and Thresholds for U.S. Navy Acoustic and Explosive Effects Analysis 

(Phase III) (U.S. Department of the Navy, 2017).

Table 3.8-2: PTS and TTS Peak Pressure Thresholds for Sea Turtles Exposed to Impulsive 

Sounds

Auditory Effect Unweighted Peak Pressure Threshold

TTS 226 dB re 1 μPa SPL peak

PTS 232 dB re 1 μPa SPL peak

Notes: dB re I μPa = decibels referenced to 1 micropascal, 

PTS: permanent threshold shift, TTS: temporary threshold shift, 

SPL: sound pressure level
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3.8.3.1.3.2 Impact Ranges for Air Guns

Ranges to the onset of PTS or TTS for the air guns used in Navy activities are shown in Table 3.8-3. The 

majority of air gun activities occur offshore and involve the use of a single shot or 10 shots. Fewer 

activities are conducted pierside and could use up to a maximum of 100 shots. The following ranges are 

based on the SEL metrics for PTS and TTS for 100 firing of an air gun, a conservative estimate of the 

number of air gun firings that could occur over a single exposure duration at a single location. Ranges 

based on the peak pressure metrics for PTS and TTS for firings of an air gun, regardless of number of 

firings, are zero meters. 

Table 3.8-3: Ranges to Permanent Threshold Shift and Temporary Threshold Shift for Sea 

Turtles Exposed to 100 Air Gun Firings 

Range (m)

PTS TTS

13 100

3.8.3.1.3.3 Impacts from Air Guns under Alternative 1

Impacts from Air Guns under Alternative 1 for Training Activities

Training activities under Alternative 1 do not include the use of air guns.

Impacts from Air Guns under Alternative 1 for Testing Activities

Characteristics of air guns and the number of times they would be operated during testing under

Alternative 1 are described in Section 3.0.3.3.1 (Acoustic Stressors). Activities using air guns would be 

conducted as described in Chapter 2 (Description of Proposed Action and Alternatives) and Appendix A 

(Navy Activity Descriptions). Under Alternative 1, small air guns (12–60 cubic inches) would be fired 

pierside at the Naval Undersea Warfare Center Division, Newport Testing Range, and at off-shore 

locations typically in the Northeast, Virginia Capes, and Gulf of Mexico Range Complexes. 

These small air guns lack large pressures that could cause non-auditory injuries. The broadband 

impulsive sounds produced by these small air guns could only cause PTS and TTS for sea turtles within a 

short distance. Considering that an air gun would be shut down if a sea turtle was sighted in the 

mitigation zone as described in Chapter 5 (Mitigation), any TTS is highly unlikely. The quantitative 

analysis, for a maximum year of air gun testing activities, predicts that no sea turtles of any species are 

likely to be exposed to the received levels of sound from air guns during testing activities, in their 

hearing range, that could cause TTS or PTS.

The working group that prepared the ANSI Sound Exposure Guidelines (Popper et al., 2014) provide 

parametric descriptors of sea turtle behavioral responses to air guns. Popper et al. (2014) estimate the 

risk of sea turtles responding to air guns is high, moderate, and low while at near (tens of meters), 

intermediate (hundreds of meters), and far (thousands of meters) distances from the source, 

respectively. Based on the few studies of sea turtle reactions to air guns, any behavioral reactions to air 

gun firings may be to increase swim speed or avoid the air gun. McCauley et al. (2000) estimated that 

sea turtles would begin to exhibit avoidance behavior when the received level of air gun firings was 

around 175 dB re 1 μPa, based on several studies of sea turtle exposures to air guns. The few studies of 

sea turtle reactions to sounds suggest that a behavioral response could consist of temporary avoidance, 

increased swim speed, or changes in depth, or that there may be no observable response. There is no 
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evidence to suggest that any behavioral response would persist after a sound exposure. It is assumed 

that a stress response could accompany any behavioral responses.

Sea turtles most likely use sound to detect nearby broadband, continuous environmental sounds, such 

as the sounds of waves crashing on the beach. Due to the low duration of an individual air gun shot, 

approximately 0.1 second, and the low duty cycle of sequential shots, the potential for masking from 

these small air guns would be low. Additionally, the pierside air gun use would only occur several times a 

year and would use a limited number of air gun shots, limiting any masking, while the use of small air 

guns in off-shore waters would not interfere with detection of sounds in shore environments. 

Considering the above factors and the mitigation measures that would be implemented as described in 

Chapter 5 (Mitigation), long-term consequences to sea turtle individuals or populations would not be 

expected.

The use of air guns during testing activities would not overlap with green, hawksbill, or leatherback 

turtle critical habitat around Culebra, Puerto Rico; Mona Island, Puerto Rico; and St. Croix Island, U.S. 

Virgin Islands, respectively. Loggerhead turtle habitat would not be impacted by air gun use during 

testing activities. 

It is reasonable to assume that terrapins use their hearing similarly to sea turtles and that the types of 

impacts on these species would be similar to impacts on sea turtles. Air guns within reptile hearing 

range are not likely to be used in nearshore locations where crocodilians could be present, however 

terrapins may be present in Newport, Rhode Island where pierside air gun activities occur. Due to the 

similarity in hearing between terrapins and sea turtles, the low frequency of air gun use, and the low 

duration of shots, impacts, if any, are assumed to parallel those described above for sea turtles. No air 

gun use is proposed in the areas known to be inhabited by alligators or the ESA-listed American 

crocodile, including designated American crocodile critical habitat in Florida Bay, which encompasses 

creeks, canals, and swamps.

Pursuant to the ESA, the use of air guns during testing activities under Alternative 1 may affect 

ESA-listed green, hawksbill, Kemp’s ridley, leatherback, and loggerhead turtles; would have no effect on 

the ESA-listed American crocodile. The use of air guns would have no effect on green, hawksbill, 

leatherback, or loggerhead turtle critical habitat or on American crocodile critical habitat. The Navy has 

consulted with NMFS as required by section 7(a)(2) of the ESA. 

3.8.3.1.3.4 Impacts from Air Guns under Alternative 2

Impacts from Air Guns under Alternative 2 for Training Activities

Training activities under Alternative 2 do not include the use of air guns.

Impacts from Air Guns under Alternative 2 for Testing Activities

The number and locations of air gun testing activities planned under Alternative 2 are identical to those 

planned under Alternative 1; therefore, the estimated impacts would be identical. Considering the 

factors described under Alternative 1 and the mitigation measures that would be implemented as 

described in Chapter 5 (Mitigation), long-term consequences to sea turtle individuals or populations 

would not be expected. It is reasonable to assume that terrapins use their hearing similarly to sea turtles 

and that the types of impacts on these species would be similar to impacts on sea turtles. Air guns

within reptile hearing range are not likely to be used in nearshore locations where crocodilians could be 
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present, however terrapins may be present in Newport, Rhode Island where pierside air gun activities 

occur. Due to the similarity in hearing between terrapins and sea turtles, the low frequency of air gun 

use, and the low duration of shots, impacts, if any, are assumed to parallel those described above for 

sea turtles. No air gun use is proposed in the areas known to be inhabited by alligators or the ESA-listed 

American crocodile, including designated American crocodile critical habitat in Florida Bay, which 

encompasses creeks, canals, and swamps.

Pursuant to the ESA, the use of air guns during testing activities under Alternative 2 may affect ESAlisted green, hawksbill, Kemp’s ridley, leatherback, and loggerhead turtles; would have no effect on the 

ESA-listed American crocodile; and would have no effect on green, hawksbill, loggerhead, or leatherback 

turtle critical habitat or on American crocodile critical habitat. 

3.8.3.1.3.5 Impacts from Air Guns under the No Action Alternative

Under the No Action Alternative, the Navy would not conduct the proposed training and testing 

activities in the AFTT Study Area. Various acoustic stressors (e.g., air guns) would not be introduced into 

the marine environment. Therefore, baseline conditions of the existing environment would either 

remain unchanged or would improve slightly after cessation of ongoing training and testing activities. 

3.8.3.1.4 Impacts from Pile Driving

Sea turtles could be exposed to sounds from impact pile driving and vibratory pile extraction during the 

construction and removal phases of the Elevated Causeway System. This training activity involves the 

use of an impact hammer to drive 24 in. steel piles into the sediment to support an elevated causeway 

to the shore and a vibratory hammer to later remove the piles that support the causeway structure. 

Section 3.0.3.3.1.3 (Pile Driving) provides additional details on pile driving activities and the noise levels 

measured from a prior elevated causeway installation and removal. 

Because no pile driving or vibratory extraction is proposed in known crocodilian or terrapin habitat, the 

remainder of the analysis of impacts from pile driving focuses on sea turtles.

3.8.3.1.4.1 Methods for Analyzing Impacts from Pile Driving

Potential impacts considered are hearing loss due to threshold shift (permanent or temporary), masking 

of other biologically relevant sounds, physiological stress, and changes in behavior. 

The Navy’s quantitative analysis to determine impacts on sea turtles and marine mammals for pile 

driving produces initial estimates of the number of animals that may experience these effects; these 

estimates are further refined by considering animal avoidance of sound-producing activities and 

implementation of mitigation. The steps of this quantitative analysis are described in Section 3.0.1.2 

(Navy’s Quantitative Analysis to Determine Impacts to Sea Turtles and Marine Mammals), which takes 

into account:

 criteria and thresholds used to predict impacts from pile driving (see below); and

 the density and spatial distribution of sea turtles.

A further detailed explanation of this analysis is provided in the technical report 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, 2018).
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Criteria and Thresholds used to Predict Impacts on Sea Turtles from Pile Driving

Auditory Weighting Functions

Animals are not equally sensitive to noise at all frequencies. To capture the frequency-dependent nature 

of the effects of noise, auditory weighting functions are used. The auditory weighting function for sea 

turtles presented above in Section 3.8.3.1.2.1 (Methods for Analyzing Impacts from Sonar and Other 

Transducers) is also used in the quantitative assessment of auditory impacts due to pile driving. 

Hearing Loss from Pile Driving

Because impact pile driving produces impulsive noise, the criteria used to assess the onset of TTS and 

PTS are identical to those used for air guns, as described in Section 3.8.3.1.3.1 (Methods for Analyzing 

Impacts from Air Guns).

Because vibratory pile extraction produces continuous, non-impulsive noise, the criteria used to assess 

the onset of TTS and PTS due to exposure to sonars are used to assess auditory impacts on sea turtles, 

as described in Section 3.8.3.1.2.1 (Methods for Analyzing Impacts from Sonar and Other Transducers). 

Modeling of Pile Driving Noise

Underwater noise effects from pile driving and vibratory pile extraction were modeled using actual 

measures of impact pile driving and vibratory removal during construction of an elevated causeway 

(Illingworth and Rodkin, 2015, 2017). A conservative estimate of spreading loss of sound in shallow 

coastal waters (i.e., transmission loss = 16.5*Log10 [radius]) was applied based on spreading loss 

observed in actual measurements. Inputs used in the model are provided in Section 3.0.3.3.1.3 (Pile 

Driving), including source levels, the number of strikes required to drive a pile and the duration of 

vibratory removal for a pile, the number of piles driven or removed per day, and the number of days of 

pile driving and removal.

3.8.3.1.4.2 Impact Ranges for Pile Driving

The ranges to the onset of TTS and PTS for sea turtles exposed to impact pile driving are shown in Table 

3.8-4. The ranges to effect are short due to sea turtles’ relatively high thresholds for any auditory 

impacts compared to the source levels of the impact pile driving conducted during Navy training. 

Table 3.8-4: Ranges to PTS and TTS Sea Turtles Exposed to Impact Pile Driving

Type of Activity PTS (m) TTS (m)

Impact Pile Driving (single pile) 2 19

Notes: PTS: permanent threshold shift, TTS: temporary threshold 

shift. Calculations for ranges to TTS and PTS assume a sound 

exposure level accumulated over a duration of one minute, after 

which time an animal is assumed to avoid the immediate area.

Because vibratory pile extraction has a low source level, it is not possible for a sea turtle to experience 

PTS or TTS, even if exposed to a full day of pile removal. 

3.8.3.1.4.3 Impacts from Pile Driving under Alternative 1

Impacts from Pile Driving under Alternative 1 for Training Activities

Characteristics of pile driving (impact and vibratory extraction) and the number of times pile driving for 

the elevated causeway system would occur during training under Alternative 1 are described in Section 

3.0.3.3.1 (Acoustic Stressors). Activities with pile driving would be conducted as described in Chapter 2 
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(Description of Proposed Action and Alternatives) and Appendix A (Navy Activity Descriptions). This 

activity would take place nearshore and within the surf zone, up to two times per year, once at Joint 

Expeditionary Base Little Creek/Fort Story, Virginia, and once at Marine Corps Base Camp Lejeune, North 

Carolina. 

Impulses from the impact hammer strikes are broadband, within the hearing range of sea turtles, and 

carry most of their energy in the lower frequencies. The quantitative analysis, for a maximum duration 

of pile driving activities during training activities, predicts that no sea turtles of any species are likely to 

be exposed to the received levels of sound, in their hearing range, that could cause TTS or PTS.

The impulse from impact pile driving can also travel through the bottom sediment, potentially disturbing 

sea turtles that may be present near the bottom. Any impacts on sea turtles may be reduced by soft 

starts. As discussed in Section 2.3.3.14 (Pile Driving Safety), as a standard operating procedure, the Navy 

performs soft starts at reduced energy during an initial set of strikes from an impact hammer. Soft starts 

may “warn” sea turtles and cause them to move away from the sound source before impact pile driving 

increases to full operating capacity. Soft starts were not considered when calculating the number of sea 

turtles that could be impacted, nor was the possibility that a sea turtle would avoid the construction 

area.

Sound produced from a vibratory hammer is broadband, continuous noise that is produced at a much 

lower level than impact driving. The quantitative analysis estimates that no sea turtles could be exposed 

to levels of vibratory pile extraction that could cause TTS or PTS. To further avoid the potential for 

impacts, the Navy will implement mitigation for pile driving that includes ceasing impact pile driving or 

vibratory pile extraction if a sea turtle is observed in the mitigation zone, as discussed in Section 5.3.2 

(Acoustic Stressors). 

The working group that prepared the ANSI Sound Exposure Guidelines (Popper et al., 2014) provide 

parametric descriptors of sea turtle behavioral responses to impact pile driving. Popper et al. (2014)

estimate the risk of sea turtles responding to impact pile driving is high, moderate, and low while at near 

(tens of meters), intermediate (hundreds of meters), and far (thousands of meters) distances from the 

source respectively. Based on prior observations of sea turtle reactions to sound, if a behavioral reaction 

were to occur, the responses could include increases in swim speed, change of position in the water 

column, or avoidance of the sound. There is no evidence to suggest that any behavioral response would 

persist beyond the sound exposure. It is assumed that a stress response could accompany any 

behavioral response or TTS.

Sea turtles most likely use sound to detect nearby broadband, continuous environmental sounds, such 

as the sounds of waves crashing on the beach. Despite the short duration of each impulse from an 

impact pile driving strike, the rate of impulses has the potential to result in some auditory masking of 

shore sounds or broadband vessel noise for sea turtles. Vibratory pile extraction is more likely than 

impact pile driving to cause masking of continuous broadband environmental sounds; however, due to 

its low source level, the masking effect would only be relevant in a small area around the vibratory pile 

extraction activity. These coastal areas tend to have high ambient noise levels due to natural (breaking 

waves) and anthropogenic sources. For both types of activities, masking would only occur during the 

brief periods of time during which pile driving or removal is actively occurring, approximately less than 

two hours per day for two weeks in any year. 
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Considering the above factors and the mitigation measures that would be implemented as described in 

Chapter 5 (Mitigation), long-term consequences to sea turtle individuals or populations would not be 

expected.

Hawksbill turtles are considered extralimital north of Florida, and would not occur near pile driving 

activities. Additionally, pile driving during training activities would not overlap with green, hawksbill, or 

leatherback turtle critical habitat around Culebra, Puerto Rico; Mona Island, Puerto Rico; and St. Croix 

Island, U.S. Virgin Islands respectively. Loggerhead turtle habitat would not be impacted by pile driving

use during training activities. No pile driving activities will occur in the areas known to be inhabited by 

the ESA-listed American crocodile, including designated American crocodile critical habitat in Florida 

Bay, which encompasses creeks, canals, and swamps.

Pursuant to the ESA, the pile driving and extraction during training under Alternative 1 may affect ESAlisted green, hawksbill, Kemp’s ridley, leatherback, and loggerhead turtles; would have no effect on the 

ESA-listed American crocodile; and would have no effect on green, hawksbill, leatherback, or loggerhead

turtle critical habitat or on American crocodile critical habitat. The Navy has consulted with NMFS as 

required by section 7(a)(2) of the ESA. 

Impacts from Pile Driving under Alternative 1 for Testing Activities

Testing activities under Alternative 1 do not include the use of pile driving (impact or vibratory). 

3.8.3.1.4.4 Impacts from Pile Driving under Alternative 2

Impacts from Pile Driving under Alternative 2 for Training Activities

Pile driving training activities planned under Alternative 2 are identical to those planned under 

Alternative 1; therefore, the estimated impacts would be identical. Considering the factors described 

under Alternative 1 and the mitigation measures that would be implemented as described in Chapter 5 

(Mitigation), long-term consequences to sea turtle individuals or populations would not be expected.

Pursuant to the ESA, the pile driving and removal during training under Alternative 2 may affect ESAlisted green, hawksbill, Kemp’s ridley, loggerhead, and leatherback sea turtles; would have no effect on 

the ESA-listed American crocodile; and would have no effect on green, hawksbill, loggerhead, or 

leatherback sea turtle critical habitat or on American crocodile critical habitat. 

Impacts from Pile Driving under Alternative 2 for Testing Activities

Testing activities under Alternative 2 do not include the use of pile driving (impact or vibratory).

3.8.3.1.4.5 Impacts from Pile Driving under the No Action Alternative

Under the No-Action Alternative, the Navy would not conduct the proposed training and testing 

activities in the AFTT Study Area. Various acoustic stressors (e.g., pile driving) would not be introduced 

into the marine environment. Therefore, baseline conditions of the existing environment would either 

remain unchanged or would improve slightly after cessation of ongoing training and testing activities.

3.8.3.1.5 Impacts from Vessel Noise 

The characteristics of noise produced by Navy vessels and their overall contribution to vessel noise in 

the Study Area are described in Section 3.0.3.3.1.4 (Vessel Noise). Navy vessels make up a very small 

percentage of the overall traffic, and, because most Navy ships are quieter than similar-sized 

commercial vessels, naval vessel noise contributes a very small portion of radiated noise in Navy 

operating areas (Mintz & Filadelfo, 2011; Mintz, 2012). Even during major training exercises, when a 
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higher number of Navy vessels are at sea, the Navy vessel contribution to overall ship radiated noise is 

very small. Navy ships make up only 20 percent of total ship traffic in the AFTT Study Area (Mintz, 2016). 

In terms of anthropogenic noise, Navy ships would contribute a correspondingly smaller amount of 

vessel noise compared to more common commercial shipping and boating (Mintz, 2012; Mintz & 

Filadelfo, 2011).

3.8.3.1.5.1 Methods for Analyzing Impacts from Vessel Noise

Potential impacts considered are masking of other biologically relevant sounds, physiological stress, and 

changes in behavior. The source levels of vessels are below the level of sound that would cause hearing 

loss for sea turtles. 

There is little information on assessing behavioral responses of sea turtles to vessels. Sea turtles have 

been both observed to respond (DeRuiter & Doukara, 2012) and not respond (Weir, 2007) during 

seismic surveys, although any reaction could have been due to the active firing of air gun arrays, ship 

noise, ship presence, or some combination thereof. Lacking data that assesses sea turtle reactions solely 

to vessel noise, the ANSI Sound Exposure Guidelines suggest that the relative risk of a sea turtle 

behaviorally responding to a continuous noise, such as vessel noise, is high when near a source (tens of 

meters), moderate when at an intermediate distance (hundreds of meters), and low at farther distances. 

These recommendations did not consider source level. While it is reasonable to assume that sea turtles 

may exhibit some behavioral response to vessels, numerous sea turtles bear scars that appear to have 

been caused by propeller cuts or collisions with vessel hulls that may have been exacerbated by a sea 

turtle surfacing reaction or lack of reaction to vessels (Hazel et al., 2007; Lutcavage et al., 1997). 

Since crocodilians and terrapins have similar hearing range and sensitivity as sea turtles, as described in 

Section 3.8.2.1.4 (Hearing and Vocalization), it is inferred that crocodilians and terrapins would react 

similarly to vessel noise as sea turtles. 

3.8.3.1.5.2 Impacts from Vessel Noise under Alternative 1

Impacts from Vessel Noise under Alternative 1 for Training Activities

Characteristics of Navy vessel noise are described in Section 3.0.3.3.1 (Acoustic Stressors). Activities with 

vessel noise would be conducted as described in Chapter 2 (Description of Proposed Action and 

Alternatives) and Appendix A (Navy Activity Descriptions). Vessel movements involve transits to and 

from ports to various locations within the Study Area, and many ongoing and proposed activities within 

the Study Area involve maneuvers by various types of surface ships, boats, and submarines (collectively 

referred to as vessels), as well as unmanned vehicles. Activities involving vessel movements occur 

intermittently and are variable in duration, ranging from a few hours up to two weeks. A study of Navy 

vessel traffic found that traffic was heaviest just offshore of Norfolk and Jacksonville, as well as along 

the coastal waters between the two ports (Mintz & Filadelfo, 2011; Mintz, 2012). 

Surface combatant ships (e.g., destroyers, guided missile cruisers, and littoral combat ships) and 

submarines especially are designed to be quiet to evade enemy detection. Reptiles exposed to these 

Navy vessels may not respond at all or exhibit brief startle dive reactions, if, for example, basking on the 

surface near a passing vessel. Even for louder vessels, such as Navy oilers, it is not clear that reptiles 

would typically exhibit any reaction other than a brief startle and avoidance reaction, if they react at all. 

Any of these short-term reactions to vessels are not likely to disrupt important behavioral patterns more 

than for a brief moment. The size and severity of these impacts would be insignificant, and not rise to 

the level of measurable impacts. Acoustic masking, especially from larger, non-combatant vessels, is 

possible. Vessels produce continuous broadband noise, with larger vessels producing sound that is 
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dominant in the lower frequencies where reptile hearing is most sensitive, as described in Section 

3.0.3.3.1.4 (Vessel Noise) (Mintz & Filadelfo, 2011; Richardson et al., 1995; Urick, 1983). Smaller vessels 

emit more energy in higher frequencies, much of which would not be detectable by reptiles. Sea turtles 

and terrapins most likely use sound to detect nearby broadband, continuous low-frequency 

environmental sounds, such as the sounds of waves crashing on the beach, so vessel noise in those 

habitats may cause more meaningful masking. However, most vessel use would be in harbors or in 

transit to offshore areas, limiting masking impacts on sea turtles in many shore areas. Crocodilians use 

low-frequency sounds for vocalization during various behaviors, and any potential for masking impacts 

would be limited to inshore environments for short durations during vessel transit. Existing high ambient 

noise levels in ports and harbors with non-Navy vessel traffic and in shipping lanes with large 

commercial vessel traffic would limit the potential for masking by naval vessels in those areas. In 

offshore areas with lower ambient noise, the duration of any masking effects in a particular location 

would depend on the time in transit by a vessel through an area. Because sea turtles and terrapins 

appear to rely on senses other than hearing for in-water foraging and navigation, any impact of 

temporary masking is likely minor or inconsequential. Hazel et al. (2007) noted in one study that green 

sea turtles did not have time to react to vessels moving at speeds of about 10 knots, but reacted 

frequently to vessels at speeds of about two knots. Detection, therefore, was suggested to be based on 

the turtle’s ability to see rather than hear an oncoming vessel.

Vessel noise during training activities would not overlap with green, hawksbill, or leatherback turtle 

critical habitat around Culebra, Puerto Rico; Mona Island, Puerto Rico; and St. Croix Island, U.S. Virgin 

Islands, respectively. For loggerhead turtle critical habitat (79 Federal Register 39855), vessel noise 

during training activities would have a pathway to impact the physical and biological features of the 

constricted migratory habitat in the mid-Atlantic and southeast regions by producing “noise pollution” 

from shipping or military activity. The impacts on this habitat would be considered insignificant with no 

discernible impact on the conservation function of the physical and biological features as activity would 

not prevent a turtle from migrating due to the transient nature of vessels. The physical and biological 

features of the nearshore reproductive, wintering, breeding, and Sargassum habitats (National Marine 

Fisheries Service, 2014b) would not be impacted by vessel noise during training activities.

It is reasonable to assume that crocodilians and terrapins use their hearing similarly to sea turtles and 

that the types of impacts would be similar to those described above for sea turtles. Within their 

respective geographic ranges, crocodilians and terrapins could potentially be exposed to vessel noise in 

the inshore regions of the Study Area during training activities, as described in Appendix A (Navy Activity 

Descriptions). Navy vessel presence would be unlikely in ESA-listed American crocodile habitat, which 

consists of shallow nearshore habitat in southern Florida; however, it is possible that American 

crocodiles could be occasionally exposed to Navy vessel noise, mostly from smaller support vessels.

Vessel noise produced during training activities would not impact critical habitat in the Florida Bay, 

which encompasses creeks, canals, and swamps.

Because impacts on individual sea turtles, crocodilians, or terrapins, if any, are expected to be minor and 

limited, no long-term consequences to individuals are expected. Accordingly, there would be no 

consequences to any sea turtle, crocodilian, or terrapin populations.

Pursuant to the ESA, vessel noise produced during training activities under Alternative 1 may affect 

ESA-listed green, hawksbill, Kemp’s ridley, leatherback, and loggerhead turtles and the ESA-listed 

American crocodile. There would be no effect on green, hawksbill, or leatherback turtle critical habitat 

or on American crocodile critical habitat. Vessel noise during training activities may affect loggerhead 
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constricted migratory habitats in the mid-Atlantic and southeast. The Navy has consulted with NMFS 

and USFWS as required by section 7(a)(2) of the ESA. 

Impacts from Vessel Noise under Alternative 1 for Testing Activities

Characteristics of Navy vessel noise are described in Section 3.0.3.3.1 (Acoustic Stressors). Activities with 

vessel noise would be conducted as described in Chapter 2 (Description of Proposed Action and 

Alternatives) and Appendix A (Navy Activity Descriptions). Testing activities under Alternative 1 include 

vessel movement during many events. Because many testing activities would use the same or similar 

vessels as Navy training events, the general locations and types of effects due to vessel noise described 

above for training would be similar for many testing activities. In addition, smaller vessels would 

typically be used on Navy testing ranges. Navy vessel noise would continue to be a minor contributor to 

overall radiated vessel noise in the exclusive economic zone.

Reptiles are likely able to detect low-frequency components of broadband continuous vessel noise 

which may elicit masking, physiological stress, or behavioral reactions, including avoidance behavior. 

The size and severity of these impacts would be insignificant, and not rise to the level of measurable 

impacts. Because impacts on individual sea turtles, crocodilians, and terrapins, if any, are expected to be 

minor and limited, no long-term consequences to individuals are expected. Accordingly, there would be 

no consequences to any sea turtle, crocodilian, or terrapin populations.

Pursuant to the ESA, vessel noise produced during testing activities under Alternative 1 may affect 

ESA-listed green, hawksbill, Kemp’s ridley, leatherback, and loggerhead turtles, and the ESA-listed 

American crocodile. There would be no effect on green, hawksbill, or leatherback turtle critical habitat 

or on American crocodile critical habitat. Vessel noise produced during testing activities may affect 

loggerhead constricted migratory habitats in the mid-Atlantic and southeast regions. The Navy has 

consulted with NMFS and USFWS as required by section 7(a)(2) of the ESA. 

3.8.3.1.5.3 Impacts from Vessel Noise under Alternative 2

Impacts from Vessel Noise under Alternative 2 for Training Activities

While there would be an increase in the amount of at-sea vessel time during training under Alternative 

2, the general locations and types of effects due to vessel noise would be the same as described in 

Alternative 1. Therefore, the general locations and types of effects due to vessel noise described above 

for training under Alternative 1 would be similar under Alternative 2. Navy vessel noise would continue 

to be a minor contributor to overall radiated vessel noise in the exclusive economic zone. 

Reptiles are likely able to detect low-frequency components of broadband continuous vessel noise 

which may elicit masking, physiological stress, or behavioral reactions, including avoidance behavior. 

The size and severity of these impacts would be insignificant, and not rise to the level of measurable 

impacts. Because impacts on individual sea turtles, crocodilians, and terrapins, if any, are expected to be 

minor and limited, no long-term consequences to individuals are expected. Accordingly, there would be 

no consequences to any sea turtle, crocodilian, or terrapin populations.

Pursuant to the ESA, vessel noise produced during training activities under Alternative 2 may affect 

ESA-listed green, hawksbill, Kemp’s ridley, leatherback, and loggerhead turtles and the ESA-listed 

American crocodile. There would be no effect on green, hawksbill, or leatherback turtle critical habitat 

or on American crocodile critical habitat. Vessel noise produced during training activities may affect 

loggerhead constricted migratory habitats in the mid-Atlantic and southeast regions. 
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Impacts from Vessel Noise under Alternative 2 for Testing Activities

As discussed in Chapter 2 (Description of Proposed Action and Alternatives), testing activities under 

Alternative 2 include vessel movement during many events. The difference in vessel noise contributed 

by testing activities under Alternative 2 compared to Alternative 1 is so small as to not be discernable. 

Therefore, the general locations and types of effects due to vessel noise described above for testing 

under Alternative 1 would be the same under Alternative 2. Navy vessel noise would continue to be a 

minor contributor to overall radiated vessel noise in the exclusive economic zone. 

Reptiles are likely able to detect low-frequency components of broadband continuous vessel noise 

which may elicit masking, physiological stress, or behavioral reactions, including avoidance behavior. 

The size and severity of these impacts would be insignificant, and not rise to the level of measurable 

impacts. Because impacts on individual sea turtles, crocodilians, and terrapins if any, are expected to be 

minor and limited, no long-term consequences to individuals are expected. Accordingly, there would be 

no consequences to any sea turtle, crocodilian, or terrapin populations.

Pursuant to the ESA, vessel noise produced during testing activities under Alternative 2 may affect 

ESA-listed green, hawksbill, Kemp’s ridley, leatherback, and loggerhead turtles and the ESA-listed 

American crocodile. There would be no effect on green, hawksbill, or leatherback turtle critical habitat 

or American crocodile critical habitat. Vessel noise produced during testing activities may affect 

loggerhead constricted migratory habitats in the mid-Atlantic and southeast regions. 

3.8.3.1.5.4 Impacts from Vessel Noise under the No Action Alternative

Under the No-Action Alternative, the Navy would not conduct the proposed training and testing 

activities in the AFTT Study Area. Various acoustic stressors (e.g., vessel noise) would not be introduced 

into the marine environment. Therefore, baseline conditions of the existing environment would either 

remain unchanged or would improve slightly after cessation of ongoing training and testing activities. 

3.8.3.1.6 Impacts from Aircraft Noise

Fixed and rotary-wing aircraft are used during a variety of training and testing activities throughout the 

Study Area. Aircraft produce extensive airborne noise from either turbofan or turbojet engines. 

Rotary-wing aircraft (helicopters) produce low-frequency sound and vibration (Pepper et al., 2003). An 

infrequent type of aircraft noise is the sonic boom, produced when the aircraft exceeds the speed of 

sound. Fixed-wing aircraft would pass quickly overhead, while rotary-wing aircraft (e.g., helicopters) may 

hover at lower altitudes for longer durations. A description of aircraft noise produced during Navy 

activities is provided in Section 3.0.3.3.1.5 (Aircraft Noise), including estimates of underwater noise 

produced by certain flight activities. Aircraft flights during training would be most concentrated within 

the offshore waters of the Virginia Capes, Navy Cherry Point, Jacksonville, and Key West Range 

Complexes. The use of aircrafts during training activities would also occur within several inshore water 

locations, but would be concentrated within the James Rivers and tributaries; Lower Chesapeake Bay; 

Kings Bay, Georgia; and Port Canaveral, Florida.

Most in-air sound would be reflected at the air-water interface. Depending on atmospheric conditions, 

in-air sound can refract upwards, limiting the sound energy that reaches the water surface. This is 

especially true for sounds produced at higher altitudes. Underwater sounds from aircraft would be 

strongest just below the surface and directly under the aircraft. Any sound that does enter the water 

only does so within a narrow cone below the sound source that would move with the aircraft. For the 

common situation of a hovering helicopter, the sound pressure level in water would be about 125 dB re 
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1 μPa for an H-60 helicopter hovering at 50 ft. For an example fixed-wing flight, the sound pressure 

underwater would be about 128 dB re 1 μPa for an F/A-18 traveling at 250 knots at 3,000 ft. altitude. 

Most air combat maneuver activities would occur at higher altitudes. Supersonic aircraft, if flying at low 

altitudes, could generate an airborne sonic boom that may be sensed by reptiles while at the surface, or 

as a low-level impulsive sound underwater.

3.8.3.1.6.1 Methods for Analyzing Impacts from Aircraft Noise

The amount of sound entering the ocean from aircraft would be very limited in duration, sound level, 

and affected area. For those reasons, impacts on sea turtles and other aquatic reptiles from aircraft 

have not been studied. Due to the low level of sound that could enter the water from aircraft, hearing 

loss is not further considered as a potential effect. Potential impacts considered are masking of other 

biologically relevant sounds, physiological stress, and changes in behavior.

There is little information with which to assess behavioral responses of reptiles to aircraft. The ANSI 

Sound Exposure Guidelines for sea turtles did not consider this acoustic stressor (Popper et al., 2014). 

For this analysis, the Navy assumes that some animals at or near the water surface may exhibit startle 

reactions to certain aircraft noise if aircraft altitude is low. This could mean a hovering helicopter, for 

which the sight of the aircraft and water turbulence could also cause a response, or a low-flying or 

super-sonic aircraft generating enough noise to be briefly detectable underwater or at the air-water 

interface. Because any fixed-wing or missile overflight would be brief, the risk of masking any sounds 

relevant to reptiles is very low.

Since crocodilians and terrapins have similar hearing range and sensitivity as sea turtles, as described in 

Section 3.8.2.1.4 (Hearing and Vocalization), it is inferred that crocodilians and terrapins would react 

similarly to aircraft noise as sea turtles.

3.8.3.1.6.2 Impacts from Aircraft Noise under Alternative 1

Impacts from Aircraft Noise under Alternative 1 for Training Activities

Characteristics of aircraft noise are described in Section 3.0.3.3.1 (Acoustic Stressors), and the number 

of training activities that include aircraft under Alternative 1 are shown in Section 3.0.3.3.4.4 (Aircraft). 

Training activities with aircraft would be conducted as described in Chapter 2 (Description of Proposed 

Action and Alternatives) and Appendix A (Navy Activity Descriptions). Aircraft noise would usually occur 

adjacent to Navy airfields, installations, and in special use airspace within Navy range complexes. 

Aircraft flights during training would be most concentrated within the Virginia Capes, Navy Cherry Point, 

Jacksonville, and Key West Range Complexes.

Reptiles may respond to both the physical presence and to the noise generated by aircraft, making it 

difficult to attribute causation to one or the other stimulus. In addition to noise produced, all low-flying 

aircraft make shadows, which can cause animals at the surface to react. Helicopters may also produce 

strong downdrafts, a vertical flow of air that becomes a surface wind, which can also affect an animal's 

behavior at or near the surface. 

In most cases, exposure of a reptile to fixed-wing aircraft presence and noise would be brief as the 

aircraft quickly passes overhead. Animals would have to be at or near the surface at the time of an 

overflight to be exposed to appreciable sound levels. Supersonic flight at sea would not be conducted 

over crocodilian or terrapin habitats, and is typically conducted at altitudes exceeding 30,000 ft., limiting 

the number of occurrences of supersonic flight being audible at the water surface. Because most 

overflight exposures from fixed-wing aircraft or transiting helicopters would be brief and aircraft noise 
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would be at low received levels, only startle reactions, if any, are expected in response to low altitude 

flights. Similarly, the brief duration of most overflight exposures would limit any potential for masking of 

relevant sounds. 

Daytime and nighttime activities involving helicopters may occur for extended periods of time, up to a 

couple of hours in some areas. During these activities, helicopters would typically transit throughout an 

area and may hover over the water. Longer activity durations and periods of time where helicopters 

hover may increase the potential for behavioral reactions, startle reactions, and physiological stress. 

Low-altitude flights of helicopters during some activities, which often occur under 100 ft. altitude, may 

elicit a stronger startle response due to the proximity of a helicopter to the water; the slower airspeed 

and longer exposure duration; and the downdraft created by a helicopter's rotor. 

Most fixed-wing aircraft and helicopter activities are transient in nature, although helicopters could also 

hover for extended periods. The likelihood that a sea turtle, crocodilian, or terrapin would occur or 

remain at the surface while an aircraft or helicopter transits directly overhead would be low. Helicopters 

that hover in a fixed location for an extended period of time could increase the potential for exposure. 

However, impacts from training and testing activities would be highly localized and concentrated in 

space and duration. 

Behavioral reactions, startle reactions, and physiological stress due to aircraft noise, including hovering 

helicopters, are likely to be brief and minor, if they occur at all. Sea turtle reactions to aircraft noise have 

not been studied like marine mammals. For marine mammals, aircraft noise would cause only small 

temporary changes in behavior. Since reptile hearing is less sensitive than marine mammals, 

conservatively, it is likely that sea turtles, crocodilians, and terrapins could exhibit temporary changes in 

behavior to aircraft noise as well. The size and severity of these impacts would be insignificant, and not 

rise to the level of measurable impacts. 

Aircraft noise during training activities would not overlap with green, hawksbill, or leatherback turtle 

critical habitat around Culebra, Puerto Rico; Mona Island, Puerto Rico; and St. Croix Island, U.S. Virgin 

Islands respectively. Loggerhead turtle critical habitat would not be affected by aircraft noise above the 

water.

It is reasonable to assume that crocodilians and terrapins use their hearing similarly to sea turtles and 

that the types of impacts would be similar to those described above for sea turtles. Within their 

respective geographic ranges, crocodilians and terrapins could potentially be exposed to aircraft noise in 

the inshore regions of the Study Area during training activities, as described in Appendix A (Navy Activity 

Descriptions). Navy aircraft presence would be unlikely in American crocodile habitat, which consists of 

shallow nearshore habitat in southern Florida; however, it is possible that American crocodiles could be 

occasionally exposed to Navy aircraft noise. Aircraft noise would not impact American crocodile critical 

habitat in Florida Bay which encompasses creeks, canals, and swamps.

Because impacts on individual sea turtles, crocodilians, or terrapins, if any, are expected to be minor and 

limited, no long-term consequences to individuals are expected. Accordingly, there would be no 

consequences to any sea turtle, crocodilian, or terrapin populations. 

Pursuant to the ESA, aircraft noise produced during training activities under Alternative 1 may affect 

ESA-listed green, hawksbill, Kemp’s ridley, leatherback, and loggerhead turtles and the ESA-listed 

American crocodile. Aircraft noise during training activities would have no effect on green, hawksbill,

leatherback, or loggerhead turtle critical habitat or American crocodile critical habitat. The Navy has 

consulted with NMFS and USFWS as required by section 7(a)(2) of the ESA.
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Impacts from Aircraft Noise under Alternative 1 for Testing Activities

Characteristics of aircraft noise are described in Section 3.0.3.3.1 (Acoustic Stressors) and the number of 

testing activities with aircraft under Alternative 1 are shown in Section 3.0.3.3.4.4 (Aircraft). Testing 

activities using aircraft would be conducted as described in Chapter 2 (Description of Proposed Action 

and Alternatives) and Appendix A (Navy Activity Descriptions). Aircraft overflights would usually occur 

adjacent to Navy airfields, installations, and in special use airspace within Navy range complexes. Testing 

activities with aircraft would be most concentrated within the offshore waters of the Northeast, Navy 

Cherry Point, Virginia Capes, and Jacksonville Range Complexes. 

Testing activities under Alternative 1 use aircraft during numerous events. Because many testing 

activities would use the same or similar aircraft as Navy training events in the same general locations,

the types of effects due to aircraft noise described above for training would be similar for many testing 

activities. Because impacts on individual reptiles, if any, are expected to be minor and limited, no longterm consequences to individuals are expected. Accordingly, there would be no consequences to any 

reptile populations. 

Pursuant to the ESA, aircraft noise produced during testing activities under Alternative 1 may affect 

ESA-listed green, hawksbill, Kemp’s ridley, leatherback, and loggerhead turtles and the ESA-listed 

American crocodile. There would be no effect on green, hawksbill, leatherback or loggerhead turtle 

critical habitat or American crocodile critical habitat. The Navy has consulted with NMFS and USFWS as 

required by section 7(a)(2) of the ESA. 

3.8.3.1.6.3 Impacts from Aircraft Noise under Alternative 2

Impacts from Aircraft Noise under Alternative 2 for Training Activities

There would be a minor increase in aircraft noise during training activities under Alternative 2 compared 

to Alternative 1; however, the types of impacts would not be discernible from those described for 

training under Alternative 1. Because impacts on individual sea turtles, crocodilians, or terrapins, if any, 

are expected to be minor and limited, no long-term consequences to individuals are expected. 

Accordingly, there would be no consequences to any sea turtle, crocodilian, or terrapin populations.

Pursuant to the ESA, aircraft noise produced during training activities under Alternative 2 may affect 

ESA-listed green, hawksbill, Kemp’s ridley, leatherback, and loggerhead turtles and the ESA-listed 

American crocodile; and would have no effect on green, hawksbill, leatherback, or loggerhead turtle 

critical habitat or on American crocodile critical habitat. 

Impacts from Aircraft Noise under Alternative 2 for Testing Activities

There would be a minor increase in aircraft noise under Alternative 2 compared to Alternative 1; 

however, the types of impacts would not be discernible from those described for testing under 

Alternative 1. Impacts on individual sea turtles, crocodilians, or terrapins, if any, are expected to be 

minor and limited, no long-term consequences to individuals are expected. Accordingly, there would be 

no consequences to any sea turtle, crocodilian, or terrapin populations.

Pursuant to the ESA, aircraft noise produced during testing activities under Alternative 2 may affect 

ESA-listed green, hawksbill, Kemp’s ridley, loggerhead, and leatherback turtles and the ESA-listed 

American crocodile. Aircraft noise produced during testing activities would have no effect on green, 

hawksbill, leatherback, or loggerhead turtle critical habitat or on American crocodile critical habitat. 
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3.8.3.1.6.4 Impacts from Aircraft Noise under the No Action Alternative

Under the No-Action Alternative, the Navy would not conduct the proposed training and testing 

activities in the AFTT Study Area. Various acoustic stressors (e.g., aircraft noise) would not be introduced 

into the marine environment. Therefore, baseline conditions of the existing environment would either 

remain unchanged or would improve slightly after cessation of ongoing training and testing activities. 

3.8.3.1.7 Impacts from Weapon Noise 

Reptiles may be exposed to sounds caused by the firing of weapons, objects in flight, and inert impact of 

non-explosive munitions on the water's surface, which are described in Section 3.0.3.3.1.6 (Weapon 

Noise). In general, these are impulsive sounds generated in close vicinity to or at the water surface, with 

the exception of items that are launched underwater. The noise generated from firing a weapon include 

muzzle blast and a crack sound due to a low amplitude shock wave generated by a supersonic projectile 

flying through the air. Most in-air sound would be reflected at the air-water interface. Underwater 

sounds would be strongest just below the surface and directly under the firing point. Any sound that 

enters the water only does so within a narrow cone below the firing point or path of the projectile. 

Vibration from the blast propagating through a ship’s hull, the sound generated by the impact of an 

object with the water surface, and the sound generated by launching an object underwater are other 

sources of impulsive sound in the water. Sound due to missile and target launches is typically at a 

maximum at initiation of the booster rocket and rapidly fades as the missile or target travels downrange. 

3.8.3.1.7.1 Methods for Analyzing Impacts from Weapon Noise

The amount of sound entering the ocean from weapon firing, projectile travel, and inert objects hitting 

the water would be very limited in duration and affected area. Sound levels could be relatively high 

directly beneath a gun blast, but even in the worst-case scenario of a naval large caliber gun fired at the 

lowest elevation angle, sound levels in the water directly below the blast (about 200 db re 1 μPa SPL 

peak; see Yagla & Stiegler, 2003) are substantially lower than necessary to cause hearing loss in a sea 

turtle. Similarly, situations in which inert objects hitting the water, even at high speeds, could 

hypothetically generate sound sufficient to cause hearing loss within a short distance would be very 

rare. Therefore, hearing loss is not further considered as a potential effect. Potential impacts considered 

are masking of other biologically relevant sounds, physiological stress, and changes in behavior.

Since crocodilians and terrapins have similar hearing range and sensitivity as sea turtles, as described in 

Section 3.8.2.1.4 (Hearing and Vocalization), it is inferred that crocodilians and terrapins would react 

similarly to weapon noise as sea turtles. 

3.8.3.1.7.2 Impacts from Weapon Noise under Alternative 1

Impacts from Weapon Noise under Alternative 1 for Training Activities

Activities using weapons and deterrents would be conducted as described in Chapter 2 (Description of 

Proposed Action and Alternatives) and Appendix A (Navy Activity Descriptions). General characteristics 

of types of weapon noise are described in Section 3.0.3.3.1.6 (Weapon Noise), and quantities and 

locations of expended non-explosive practice munitions and explosives (fragment-producing) for 

training under Alternative 1 are shown in Section 3.0.3.3.4.2 (Military Expended Materials). For 

explosive munitions, only associated firing noise is considered in the analysis of weapon noise. The noise 

produced by the detonation of explosive weapons is analyzed in Section 3.8.3.2 (Explosive Stressors).
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Weapon training would occur in the range complexes, with greatest use of most types of munitions in 

the Virginia Capes, Navy Cherry Point, and Jacksonville Range Complexes. Most activities involving 

large-caliber naval gunfire or the launching of targets, missiles, bombs, or other munitions are 

conducted more than 12 NM from shore, but could potentially occur in the Panama City OPAREA and

the Naval Surface Warfare Center Panama City Testing Range. Small- and medium-caliber weapon firing 

could occur throughout the Study Area. Only small-caliber weapons are used within inshore waters. 

Navy training activities in the inshore waters occur in several locations along the Atlantic coast as 

described in Section 3.0.3.3.4.2 (Military Expended Materials), with the highest concentration occurring 

in the James River and tributaries in Virginia. Other locations include the Lower Chesapeake Bay; Cooper 

River, South Carolina; Port Canaveral, Florida; and Narragansett, Rhode Island.

All of these sounds would be brief, lasting from less than a second for a blast or inert impact to few 

seconds for other launch and object travel sounds. Most incidents of impulsive sounds produced by 

weapon firing, launch, or inert object impacts would be single events, with the exception of gunfire 

activities. It is expected that these sounds may elicit brief startle reactions or diving, with avoidance 

being more likely with the repeated exposure to sounds during gunfire events. It is assumed that, similar 

to air gun exposures, reptile behavioral responses would cease following the exposure event and the 

risk of a corresponding, sustained stress response would be low. Similarly, exposures to impulsive noise 

caused by these activities would be so brief that risk of masking relevant sounds would be low. These 

activities would not typically occur in nearshore habitats where sea turtles may use their limited hearing 

to sense broadband, coastal sounds. Behavioral reactions, startle reactions, and physiological stress due 

to weapon noise are likely to be brief and minor, if they occur at all due, to the low probability of cooccurrence between weapon activity and sea turtle individuals.

To further avoid the potential for impacts, the Navy will implement mitigation for weapon firing noise 

that includes ceasing large-caliber gunnery activities if a sea turtle is observed in the mitigation zone, as 

discussed in Section 5.3.2 (Acoustic Stressors). Also, activities will not be initiated near concentrated 

Sargassum mats due to the possible presence of sea turtles. This further reduces the likelihood of 

impacts on hatchling and pre-recruitment juveniles of all sea turtle species and leatherback turtles of all 

age classes since these species and age classes occur in open-ocean habitat where most of these 

activities would occur. 

Considering the above factors and the mitigation measures that would be implemented as described in 

Chapter 5 (Mitigation), long-term consequences to sea turtle individuals or populations would not be 

expected. 

Weapon training would not overlap with green, hawksbill, or leatherback turtle critical habitat around 

Culebra, Puerto Rico; Mona Island, Puerto Rico; and St. Croix Island, U.S. Virgin Islands respectively. For 

loggerhead critical habitat (79 Federal Register 39855), weapon noise during training activities would 

have a pathway to impact the physical and biological features of the constricted migratory habitat in the 

mid-Atlantic and southeast regions by producing “noise pollution” from military activity. The impacts on 

this habitat would be considered insignificant, with no discernible impact on the conservation function 

of the physical and biological features as activity would not prevent a turtle from migrating, as weapon

noise is brief in nature. The physical and biological features of the nearshore reproductive, wintering, 

breeding, and Sargassum habitats (National Marine Fisheries Service, 2014b) would not be impacted by 

weapon noise during training activities.
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It is reasonable to assume that crocodilians and terrapins use their hearing similarly to sea turtles and 

that the types of impacts would be similar to those described above for sea turtles. Within their 

respective geographic ranges, crocodilians and terrapins could potentially be exposed to weapon noise 

in some inshore waters of the Study Area during training activities, as described in Appendix A (Navy 

Activity Descriptions). Activities producing weapon noise would not occur in American crocodile habitat, 

which consists of shallow nearshore habitat in southern Florida. Weapon noise would not impact 

American crocodile critical habitat in Florida Bay which encompasses creeks, canals, and swamps.

Because impacts on individual crocodilians and terrapins, if any, are expected to be minor and limited, 

long-term consequences to individuals or populations would not be expected.

Pursuant to the ESA, weapon noise produced during training activities under Alternative 1 may affect 

ESA-listed green, hawksbill, Kemp’s ridley, leatherback, and loggerhead turtles; and would have no 

effect on the ESA-listed American crocodile. There would be no effect on green, hawksbill, or 

leatherback turtle critical habitat or American crocodile habitat. Weapon noise produced during training 

activities may affect loggerhead constricted migratory habitats in the mid-Atlantic and southeast 

regions. The Navy has consulted with NMFS as required by section 7(a)(2) of the ESA. 

Impacts from Weapon Noise under Alternative 1 for Testing Activities

Activities using weapons and deterrents would be conducted as described in Chapter 2 (Description of 

Proposed Action and Alternatives) and Appendix A (Navy Activity Descriptions). General characteristics 

of types of weapon noise are described in Section 3.0.3.3.1.6 (Weapon Noise), and quantities and 

locations of expended non-explosive practice munitions and explosives (fragment-producing) for testing 

under Alternative 1 are shown in Section 3.0.3.3.4.2 (Military Expended Materials). For explosive 

munitions, only associated firing noise is considered in the analysis of weapon noise. The noise produced 

by the detonation of explosive weapons is analyzed in Section 3.8.3.2 (Explosive Stressors).

The general locations and types of effects due to weapon noise described above for training would be 

similar for many testing activities. Weapon testing would typically occur on the range complexes, with 

some activity also occurring on testing ranges. Most activities involving large-caliber naval gunfire or the 

launching of targets, missiles, bombs, or other munitions are conducted more than 12 NM from shore, 

but could potentially occur in the Panama City OPAREA and the Naval Surface Warfare Center Panama 

City Testing Range.

To further avoid the potential for impacts, the Navy will implement mitigation for weapon firing noise 

that includes ceasing large-caliber gunnery activities if a sea turtle is observed in the mitigation zone, as 

discussed in Section 5.3.2 (Acoustic Stressors). Also, activities will not be initiated near concentrated 

Sargassum mats due to the possible presence of sea turtles. This further reduces the likelihood of 

impacts on hatchling and pre-recruitment juveniles of all sea turtle species and leatherback turtles of all 

age classes since these species and age classes occur in open-ocean habitat where most of these 

activities would occur. 

Considering the above factors and the mitigation measures that would be implemented as described in 

Chapter 5 (Mitigation), long-term consequences to sea turtle individuals or populations would not be 

expected. No testing activities would use munitions in inshore waters, and thus would not overlap with 

or impact crocodilians or terrapins.

Weapon testing would not overlap with green, hawksbill, or leatherback turtle critical habitat around 

Culebra, Puerto Rico; Mona Island, Puerto Rico; and St. Croix Island, U.S. Virgin Islands respectively. For 

loggerhead critical habitat (79 Federal Register 39855), weapon noise during training activities would 
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have a pathway to impact the physical and biological features of the constricted migratory habitat in the 

mid-Atlantic and southeast regions by producing “noise pollution” from military activity. The impacts on 

this habitat would be considered insignificant, with no discernible impact on the conservation function 

of the physical and biological features as activity would not prevent a turtle from migrating, as weapon

noise is brief in nature. The physical and biological features of the nearshore reproductive, wintering, 

breeding, and Sargassum habitats (National Marine Fisheries Service, 2014b) would not be impacted by 

weapon noise during testing activities.

Activities producing weapon noise would not occur in American crocodile habitat, which consists of 

shallow nearshore habitat in southern Florida. Weapon noise would not impact American crocodile 

critical habitat in Florida Bay which encompasses creeks, canals, and swamps.

Pursuant to the ESA, weapon noise produced during testing activities under Alternative 1 may affect 

ESA-listed green, hawksbill, Kemp’s ridley, leatherback, and loggerhead turtles; and would have no 

effect on the ESA-listed American crocodile. There would be no effect on green, hawksbill, or 

leatherback sea turtle critical habitat or American crocodile critical habitat. Weapon noise produced 

during testing activities may affect loggerhead constricted migratory habitats in the mid-Atlantic and

southeast regions. The Navy has consulted with NMFS as required by section 7(a)(2) of the ESA. 

3.8.3.1.7.3 Impacts from Weapon Noise under Alternative 2 

Impacts from Weapon Noise under Alternative 2 for Training Activities

Activities using weapons and deterrents would be conducted as described in Chapter 2 (Description of 

Proposed Action and Alternatives) and Appendix A (Navy Activity Descriptions). General characteristics 

of types of weapon noise are described in Section 3.0.3.3.1.6 (Weapon Noise), and quantities and 

locations of expended non-explosive practice munitions and explosives (fragment-producing) for 

training under Alternative 2 are shown in 3.0.3.3.4.2. (Military Expended Materials). For explosive 

munitions, only associated firing noise is considered in the analysis of weapon noise. The noise produced 

by the detonation of explosive weapon is analyzed in Section 3.8.3.2 (Explosive Stressors).

There would be a minor increase in these activities under Alternative 2 compared to Alternative 1; 

however, the types of impacts and locations of impacts would be the same as those described for 

training under Alternative 1. To further avoid the potential for impacts, the Navy will implement 

mitigation for weapon firing noise that includes ceasing large-caliber gunnery activities if a sea turtle is 

observed in the mitigation zone, as discussed in Section 5.3.2 (Acoustic Stressors). Also, activities will not 

be initiated near concentrated Sargassum mats due to the possible presence of sea turtles. This further 

reduces the likelihood of impacts on hatchling and pre-recruitment juveniles of all sea turtle species and 

leatherback turtles of all age classes since these species and age classes occur in open-ocean habitat

where most of these activities would occur. Because impacts on individual sea turtles, crocodilians, and 

terrapins, if any, are expected to be minor and limited, long-term consequences to individuals or 

populations are not expected. 

Pursuant to the ESA, weapon noise produced during training activities under Alternative 2 may affect 

ESA-listed green, hawksbill, Kemp’s ridley, leatherback, and loggerhead turtles; and would have no 

effect on the ESA-listed American crocodile. There would be no effect on green, hawksbill, or 

leatherback turtle critical habitat or American crocodile critical habitat. Weapon noise produced during 

training activities may affect loggerhead constricted migratory habitats in the mid-Atlantic and

southeast regions. 
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Impacts from Weapon Noise under Alternative 2 for Testing Activities

Activities using weapon and deterrents would be conducted as described in Chapter 2 (Description of 

Proposed Action and Alternatives) and Appendix A (Navy Activity Descriptions). General characteristics 

of types of weapon noise are described in Section 3.0.3.3.1.6 (Weapon Noise), and quantities and 

locations of expended non-explosive practice munitions and explosives (fragment-producing) for testing 

under Alternative 2 are shown in 3.0.3.3.4.2. (Military Expended Materials). For explosive munitions, 

only associated firing noise is considered in the analysis of weapon noise. The noise produced by the 

detonation of explosive weapons is analyzed in Section 3.8.3.2 (Explosive Stressors).

There would be a minor increase in these activities under Alternative 2 compared to Alternative 1; 

however, the types of impacts and locations of impacts would be the same as those described for 

testing under Alternative 1. To further avoid the potential for impacts, the Navy will implement 

mitigation for weapon firing noise that includes ceasing large-caliber gunnery activities if a sea turtle is 

observed in the mitigation zone, as discussed in Section 5.3.2 (Acoustic Stressors). Also, activities will not 

be initiated near concentrated Sargassum mats due to the possible presence of sea turtles. This further 

reduces the likelihood of impacts on hatchling and pre-recruitment juveniles of all sea turtle species and 

leatherback turtles of all age classes since these species and age classes occur in open-ocean habitat 

where most of these activities would occur. No testing activities would use munitions in inshore waters, 

and thus would not overlap with or impact crocodilians or terrapins.

Because impacts on individual sea turtles, if any, are expected to be minor and limited, no long-term 

consequences to individuals are expected. Accordingly, there would be no consequences to any sea 

turtle populations. Pursuant to the ESA, weapon noise produced during testing activities under 

Alternative 2 may affect ESA-listed green, hawksbill, Kemp’s ridley, leatherback, and loggerhead turtles; 

and would have no effect on the ESA-listed American crocodile. There would be no effect on green, 

hawksbill, or leatherback turtle critical habitat or American crocodile critical habitat. Weapon noise 

produced during testing activities may affect loggerhead constricted migratory habitats in the midAtlantic and southeast regions. 

3.8.3.1.7.4 Impacts from Weapon Noise under the No Action Alternative

Under the No-Action Alternative, the Navy would not conduct the proposed training and testing 

activities in the AFTT Study Area. Various acoustic stressors (e.g., weapon noise) would not be 

introduced into the marine environment. Therefore, baseline conditions of the existing environment 

would either remain unchanged or would improve slightly after cessation of ongoing training and testing 

activities. 

3.8.3.2 Explosive Stressors

Explosions in the water or near the water surface can introduce loud, impulsive, broadband sounds into 

the marine environment. But unlike other acoustic stressors, explosions release energy at a high rate 

producing a shock wave that can be injurious and even deadly. Therefore, explosive impacts on reptiles 

are discussed separately from other acoustic stressors, even though the analysis of explosive impacts 

will rely on data for sea turtle impacts due to impulsive sound exposure where appropriate.

Explosives are usually described by their net explosive weight, which accounts for the weight and type of 

explosive material. Additional explanation of the acoustic and explosive terms and sound energy 

concepts used in this section is found in Appendix D (Acoustic and Explosives Concepts).
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This section begins with a summary of relevant data regarding explosive impacts on reptiles in Section 

3.8.3.2.1 (Background). The ways in which an explosive exposure could result in immediate effects or 

lead to long-term consequences for an animal are explained in the Section 3.0.3.6.1 (Conceptual 

Framework for Assessing Effects from Acoustic and Explosive Activities), and the analysis in this section 

follows that framework. Studies of the effects of sound and explosives on reptiles are limited; therefore, 

where necessary, knowledge of explosive impacts to other species is used to assess impacts on reptiles, 

such as sea turtles, crocodilians, and terrapins.

3.8.3.2.1 Background

The sections below include a survey and synthesis of best available science published in peer-reviewed 

journals, technical reports, and other scientific sources pertinent to impacts on reptiles potentially 

resulting from Navy training and testing activities. Reptiles could be exposed to a range of impacts 

depending on the explosive source and context of the exposure. In addition to acoustic impacts 

including temporary or permanent hearing loss, auditory masking, physiological stress, or changes in 

behavior, potential impacts from an explosive exposure can include non-lethal injury and mortality. 

3.8.3.2.1.1 Injury

Because direct studies of explosive impacts on reptiles have not been conducted, the below discussion 

of injurious effects is based on studies of other animals, generally mammals. The generalizations that 

can be made about in-water explosive injuries to other species should be applicable to reptiles, with 

consideration of the unique anatomy of sea turtles and terrapins. For example, it is unknown if the sea 

turtle shell may afford it some protection from internal injury.

If an animal is exposed to an explosive blast underwater, the likelihood of injury depends on the charge 

size, the geometry of the exposure (distance to the charge, depth of the animal and the charge), and the 

size of the animal. In general, an animal would be less susceptible to injury near the water surface 

because the pressure wave reflected from the water surface would interfere with the direct path 

pressure wave, reducing positive pressure exposure. However, rapid under-pressure caused by the 

negative surface-reflected pressure wave above an underwater detonation may create a zone of 

cavitation that may contribute to potential injury. In general, blast injury susceptibility would increase 

with depth, until normal lung collapse (due to increasing hydrostatic pressure) and increasing ambient 

pressures again reduce susceptibility. See Appendix D (Acoustic and Explosives Concepts) for an 

overview of explosive propagation and an explanation of explosive effects on gas cavities. 

Primary blast injury is injury that results from the compression of a body exposed to a blast wave. This is 

usually observed as barotrauma of gas-containing structures (e.g., lung and gut) and structural damage 

to the auditory system (Greaves et al., 1943; Office of the Surgeon General, 1991; Richmond et al., 

1973). The lungs are typically the first site to show any damage, while the solid organs (e.g., liver, spleen, 

and kidney) are more resistant to blast injury (Clark & Ward, 1943). Recoverable injuries would include 

slight lung injury, such as capillary interstitial bleeding, and contusions to the gastrointestinal tract. 

More severe injuries would significantly reduce fitness and likely cause death in the wild. Rupture of the 

lung may also introduce air into the vascular system, producing air emboli that can cause a stroke or 

heart attack by restricting oxygen delivery to critical organs. In this discussion, primary blast injury to 

auditory tissues is considered gross structural tissue injury distinct from noise-induced hearing loss, 

which is considered below in Section 3.8.3.2.1.2 (Hearing Loss). 

Data on observed injuries to sea turtles from explosions is generally limited to animals found following 

explosive removal of offshore structures (Viada et al., 2008), which can attract sea turtles for feeding 
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opportunities or shelter. Klima et al. (1988) observed a turtle mortality subsequent to an oil platform 

removal blast, although sufficient information was not available to determine the animal’s exposure. 

Klima et al. (1988) also placed small sea turtles (less than seven kilograms) at varying distances from 

piling detonations. Some of the turtles were immediately knocked unconscious or exhibited vasodilation 

over the following weeks, but others at the same exposure distance exhibited no effects. 

Incidental injuries to sea turtles due to military explosions have been documented in a few instances. In 

one incident, a single 1,200 pound (lb.) trinitrotoluene (TNT) underwater charge was detonated off 

Panama City, FL in 1981. The charge was detonated at a mid-water depth of 120 ft. Although details are 

limited, the following were recorded: at a distance of 500–700 ft., a 400 lb. sea turtle was killed; at 1,200 

ft., a 200–300 lb. sea turtle experienced “minor” injury; and at 2,000 ft. a 200–300 lb. sea turtle was not 

injured (O'Keeffe & Young, 1984). In another incident, two “immature” green sea turtles (size 

unspecified) were killed when 100-150 ft. away from detonation of 20 lb. of C-4 in a shallow water 

environment.

For this analysis, it is assumed that these types of observations would also apply to crocodilians and 

terrapins. Results from limited experimental data suggest two explosive metrics are predictive of 

explosive injury: peak pressure and impulse. 

Impulse as a Predictor of Explosive Injury

Without measurements of the explosive exposures in the above incidents, it is difficult to draw 

conclusions about what amount of explosive exposure would be injurious to aquatic reptiles. Studies of 

observed in-water explosive injuries showed that terrestrial mammals were more susceptible than 

comparably sized fish with swim bladders (Yelverton & Richmond, 1981), and that fish with swim 

bladders may have increased susceptibility to swim bladder oscillation injury depending on exposure 

geometry (Goertner, 1978; Wiley et al., 1981). Therefore, controlled tests with a variety of terrestrial 

mammals (mice, rats, dogs, pigs, sheep, and other species) are the best available data sources on actual 

injury to similar-sized animals due to underwater exposure to explosions. 

In the early 1970s, the Lovelace Foundation for Medical Education and Research conducted a series of 

tests in an artificial pond to determine the effects of underwater explosions on mammals, with the goal 

of determining safe ranges for human divers. The resulting data were summarized in two reports 

(Richmond et al., 1973; Yelverton et al., 1973). Specific physiological observations for each test animal 

are documented in Richmond et al. (1973). Gas-containing internal organs, such as lungs and intestines, 

were the principle damage sites in submerged terrestrial mammals, consistent with earlier studies of

mammal exposures to underwater explosions (Clark & Ward, 1943; Greaves et al., 1943). 

In the Lovelace studies, acoustic impulse was found to be the metric most related to degree of injury, 

and size of an animal’s gas-containing cavities was thought to play a role in blast injury susceptibility. 

The proportion of lung volume to overall body size is similar between sea turtles and terrestrial

mammals, so the magnitude of lung damage in the tests may approximate the magnitude of injury to 

sea turtles when scaled for body size. Measurements of some shallower diving sea turtles (Hochscheid 

et al., 2007) show lung to body size ratios that are larger than terrestrial animals, whereas the lung to 

body mass ratio of the deeper diving leatherback sea turtle is smaller (Lutcavage et al., 1992). The use of 

test data with smaller lung to body ratios to set injury thresholds may result in a more conservative 

estimate of potential for damaging effects (i.e., lower thresholds) for animals with larger lung to body 

ratios. 
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For these shallow exposures of small terrestrial mammals (masses ranging from 3.4 to 50 kilograms) to 

underwater detonations, Richmond et al. (1973) reported that no blast injuries were observed when 

exposures were less than 6 lb. per square in. per millisecond (psi-ms) (40 pascal-seconds [Pa-s]), no 

instances of slight lung hemorrhage occurred below 20 psi-ms (140 Pa-s), and instances of no lung 

damage were observed in some exposures at higher levels up to 40 psi-ms (280 Pa-s). An impulse of 

34 psi-ms (230 Pa-s) resulted in about 50 percent incidence of slight lung hemorrhage. About half of the 

animals had gastrointestinal tract contusions (with slight ulceration, i.e., some perforation of the

mucosal layer) at exposures of 25–27 psi-ms (170–190 Pa-s). Lung injuries were found to be slightly 

more prevalent than gastrointestinal tract injuries for the same exposure.

The Lovelace subject animals were exposed near the water surface; therefore, depth effects were not 

discernible in this data set. In addition, this data set included only small terrestrial animals, whereas 

adult reptiles may be substantially larger and have respiratory structures adapted for the high pressures 

experienced at depth. Goertner (1982) examined how lung cavity size would affect susceptibility to blast 

injury by considering both size and depth in a bubble oscillation model of the lung, which is assumed to 

be applicable to reptiles as well for this analysis. Animal depth relates to injury susceptibility in two 

ways: injury is related to the relative increase in explosive pressure over hydrostatic pressure, and lung 

collapse with depth reduces the potential for air cavity oscillatory damage. The time period over which 

an impulse must be delivered to cause damage is assumed to be related to the natural oscillation period 

of an animal’s lung, which depends on lung size. Based on a study of green sea turtles, Berkson (1967)

predicted sea turtle lung collapse would be complete around 80–160 m depth. 

Peak Pressure as a Predictor of Explosive Trauma

High instantaneous peak pressures can cause damaging tissue distortion. Goertner (1982) suggested a 

peak overpressure gastrointestinal tract injury criterion because the size of gas bubbles in the 

gastrointestinal tract are variable, and their oscillation period could be short relative to primary blast 

wave exposure duration. The potential for gastrointestinal tract injury, therefore, may not be 

adequately modeled by the single oscillation bubble methodology used to estimate lung injury due to 

impulse. Like impulse, however, high instantaneous pressures may damage many parts of the body, but 

damage to the gastrointestinal tract is used as an indicator of any peak pressure-induced injury due to 

its vulnerability.

Older military reports documenting exposure of human divers to blasts generally describe peak pressure 

exposures around 100 lb. per square inch (psi) (237 dB re 1 μPa peak) to feel like a slight pressure or 

stinging sensation on skin, with no enduring effects (Christian & Gaspin, 1974). Around 200 psi, the 

shock wave felt like a blow to the head and chest. Data from the Lovelace Foundation experiments show 

instances of gastrointestinal tract contusions after exposures up to 1,147 psi peak pressure, while 

exposures of up to 588 psi peak pressure resulted in many instances of no observed gastrointestinal 

tract effects. The lowest exposure for which slight contusions to the gastrointestinal tract were reported 

was 237 dB re 1 μPa peak. As a vulnerable gas-containing organ, the gastrointestinal tract is vulnerable 

to both high peak pressure and high impulse, which may vary to differing extents due to blast exposure 

conditions (e.g., animal depth, distance from the charge). This likely explains the range of effects seen at 

similar peak pressure exposure levels and shows the utility of considering both peak pressure and 

impulse when analyzing the potential for injury due to explosions.

The ANSI Sound Exposure Guidelines (Popper et al., 2014) recommended peak pressure guidelines for 

sea turtle injury from explosives. Lacking any direct data for sea turtles, these recommendations were 

based on fish data. Of the fish data available, the working group conservatively chose the study with the 
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lowest peak pressures associated with fish mortality to set guidelines (Hubbs & Rechnitzer, 1952), and 

did not consider the Lovelace studies discussed above.

Fragmentation

Fragments produced by exploding munitions at or near the surface may present a high-speed strike 

hazard for an animal at or near the surface. In water, however, fragmentation velocities decrease rapidly

due to drag (Swisdak & Montanaro, 1992). Because blast waves propagate efficiently through water, the 

range to injury from the blast wave would likely extend beyond the range of fragmentation risk. 

3.8.3.2.1.2 Hearing Loss

An underwater explosion produces broadband, impulsive sound that can cause noise-induced hearing 

loss, typically quantified as threshold shift, which persists after cessation of the noise exposure. This 

noise-induced hearing loss may manifest as TTS or PTS. Because studies on inducing threshold shift in 

reptiles are very limited (e.g., alligator lizards: Dew et al., 1993; Henry & Mulroy, 1995) and have not 

been conducted on any of the reptiles present in the Study Area, auditory threshold shift in reptiles is 

considered to be consistent with general knowledge about noise-induced hearing loss described in 

Section 3.0.3.6.1 (Conceptual Framework for Assessing Effects from Acoustic and Explosive Activities).

Little is known about how sea turtles or terrapins use sound in their environment. The ANSI Sound 

Exposure Guidelines (Popper et al., 2014) do not suggest numeric sound exposure thresholds for 

auditory effects on sea turtles due to the lack of data. Rather, the guidelines qualitatively advise that sea 

turtles are less likely to incur TTS or PTS with increasing distance from an explosion. The guidelines also 

suggest that data from fishes may be more relevant than data from marine mammals when estimating 

auditory impacts on sea turtles, because, in general, fish hearing range is more similar to the limited 

hearing range of sea turtles. As shown in Section 3.8.2.1.4.1 (Hearing and Vocalization – Sea Turtles), sea 

turtle hearing is most sensitive around 100–400 Hz in-water, is limited over 1 kHz, and is much less 

sensitive than that of any marine mammal. The guidelines do not advise on crocodilians or terrapins, 

however hearing is most sensitive at low frequencies in these species as discussed in Section 3.8.2.1.4 

(Hearing and Vocalization). For this analysis, it is assumed that hearing loss in crocodilians and terrapins 

would be similar to sea turtles.

3.8.3.2.1.3 Physiological Stress

A stress response is a suite of physiological changes that are meant to help an organism mitigate the 

impact of a stressor. If the magnitude and duration of the stress response is too great or too long, it can 

have negative consequences to the animal (e.g., decreased immune function, decreased reproduction). 

Physiological stress is typically analyzed by measuring stress hormones, other biochemical markers, or 

vital signs. Physiological stress has been measured for sea turtles during nesting (Flower et al., 2015; 

Valverde et al., 1999) and capture and handling (Flower et al., 2015; Gregory & Schmid, 2001), but the 

stress caused by acoustic exposure has not been studied for reptiles. Therefore, the stress response in 

reptiles in the Study Area due to acoustic exposures is considered to be consistent with general 

knowledge about physiological stress responses described in Section 3.0.3.6.1 (Conceptual Framework 

for Assessing Effects from Acoustic and Explosive Activities).

Marine animals naturally experience stressors within their environment and as part of their life histories. 

Changing weather and ocean conditions, exposure to diseases and naturally occurring toxins, lack of 

prey availability, social interactions with members of the same species, nesting, and interactions with 
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predators all contribute to stress. Anthropogenic sound-producing activities have the potential to 

provide additional stressors beyond those that naturally occur. 

Due to the limited information about acoustically induced stress responses in reptiles, the Navy 

conservatively assumes in its effect analysis that any physiological response (e.g., hearing loss or injury) 

or significant behavioral response is also associated with a stress response. 

3.8.3.2.1.4 Masking 

As described in Section 3.0.3.6.1 (Conceptual Framework for Assessing Effects from Acoustic and 

Explosive Activities), auditory masking occurs when one sound, distinguished as the “noise,” interferes 

with the detection or recognition of another sound or limits the distance over which other biologically 

relevant sounds can be detected. Masking only occurs when the sound source is operating; therefore, 

direct masking effects stop immediately upon cessation of the sound-producing activity. Any unwanted 

sound above ambient noise and within an animal’s hearing range may potentially cause masking that 

can interfere with an animal’s ability to detect, understand, or recognize biologically relevant sounds of 

interest. 

Masking occurs in all vertebrate groups and can effectively limit the distance over which an animal can 

communicate and detect biologically relevant sounds. The effect of masking has not been studied for 

marine reptiles. The potential for masking in reptiles would be limited to certain sound exposures due to 

their limited hearing range to broadband low-frequency sounds and lower sensitivity to noise in the 

marine environment. Only sounds that have a significant low-frequency component, are not of brief 

duration, and are of sufficient received level could create a meaningful masking situation. While 

explosions produce intense, broadband sounds with significant low-frequency content, these sounds are 

very brief with limited potential to mask relevant sounds.

There is evidence that reptiles may rely primarily on senses other than hearing for interacting with their 

environment, such as vision (Narazaki et al., 2013), magnetic orientation (Avens, 2003; Putman et al., 

2015b), and scent (Shine et al., 2004). Any effect of masking may be mediated by reliance on other 

environmental inputs.

3.8.3.2.1.5 Behavioral Reactions

There are no observations of behavioral reactions by aquatic reptiles to exposure to explosive sounds 

and energy. Impulsive signals, particularly at close range, have a rapid rise time and higher 

instantaneous peak pressure than other signal types, making them more likely to cause startle 

responses or avoidance responses. Although explosive sources are more energetic than air guns, the few 

studies of sea turtles’ responses to air guns may show the types of behavioral responses that sea turtles 

may have towards explosions. General research findings regarding behavioral reactions from sea turtles 

due to exposure to impulsive sounds, such as those associated with explosions, are discussed in detail in 

Behavioral Reactions to Impulsive Sound Sources under Section 3.8.3.1 (Acoustic Stressors). For this 

analysis, it is assumed that these guidelines would also apply to crocodilians and terrapins.

3.8.3.2.1.6 Long-Term Consequences

For reptiles present in the Study Area, long-term consequences to individuals and populations due to 

acoustic exposures have not been studied. Therefore, long-term consequences to reptiles due to 

explosive exposures are considered following Section 3.0.3.6.1 (Conceptual Framework for Assessing 

Effects from Acoustic and Explosive Activities).
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Long-term consequences to a population are determined by examining changes in the population 

growth rate. Physical effects that could lead to a reduction in the population growth rate include 

mortality or injury, which could remove animals from the reproductive pool, and permanent hearing 

impairment, which could impact navigation. The long-term consequences due to individual behavioral 

reactions and short-term instances of physiological stress are especially difficult to predict because 

individual experience over time can create complex contingencies. It is more likely that any long-term 

consequences to an individual would be a result of costs accumulated over a season, year, or life stage 

due to multiple behavioral or stress responses resulting from exposures to multiple stressors over 

significant periods of time. Conversely, some reptiles may habituate to or become tolerant of repeated 

acoustic exposures over time, learning to ignore a stimulus that in the past did not accompany any overt 

threat. For example, loggerhead sea turtles exposed to air guns with a source SPL of 179 dB re 1 μPa

initially exhibited avoidance reactions. However, they may have habituated to the sound source after 

multiple exposures since a habituation behavior was retained when exposures were separated by 

several days (Moein Bartol et al., 1995). More research is needed to better understand the long-term 

consequences of human-made noise on reptiles, although intermittent exposures are assumed to be 

less likely to have lasting consequences.

3.8.3.2.2 Impacts from Explosives

This section analyzes the impacts on reptiles due to in-water explosions that result from Navy training 

and testing activities, synthesizing the background information presented above. 

3.8.3.2.2.1 Methods for Analyzing Impacts from Explosives

Potential impacts considered are mortality, injury, hearing loss due to threshold shift (permanent or 

temporary), masking of other biologically relevant sounds, physiological stress, and changes in behavior. 

The Navy’s quantitative analysis to determine impacts to sea turtles and marine mammals uses the Navy 

Acoustic Effects Model to produce initial estimates of the number of animals that may experience these 

effects; these estimates are further refined by considering animal avoidance of sound-producing 

activities and implementation of mitigation. The steps of this quantitative analysis are described in 

Section 3.0.1.2 (Navy’s Quantitative Analysis to Determine Impacts to Sea Turtles and Marine 

Mammals), which takes into account:

 criteria and thresholds used to predict impacts from explosives (see below);

 the density and spatial distribution of sea turtles; and

 the influence of environmental parameters (e.g., temperature, depth, salinity) on sound 

propagation and explosive energy when estimating the received sound level and pressure on the 

animals.

A further detailed explanation of this analysis is provided in the 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, 2018).

Since crocodilians and terrapins have similar hearing range and sensitivity as sea turtles, as described in 

Section 3.8.2.1.4 (Hearing and Vocalization), it is inferred that crocodilians and terrapins would react 

similarly to explosions as sea turtles. 
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Criteria and Thresholds used to Predict Impacts from Explosives

Mortality and Injury from Explosives 

As discussed above in Section 3.8.3.2.1.1 (Injury), two metrics have been identified as predictive of 

injury: impulse and peak pressure. Peak pressure contributes to the “crack” or “stinging” sensation of a 

blast wave, compared to the “thump” associated with received impulse. Older military reports 

documenting exposure of human divers to blast exposure generally describe peak pressure exposures 

around 100 psi (237 dB re 1 μPa SPL peak) to feel like slight pressure or stinging sensation on skin, with 

no enduring effects (Christian & Gaspin, 1974).

Two sets of thresholds are provided for use in non-auditory injury assessment. The exposure thresholds 

are used to estimate the number of animals that may be affected during Navy training and testing 

activities (Table 3.8-5). The thresholds for the farthest range to effect are based on the received level at 

which 1 percent risk is predicted and are useful for assessing mitigation effectiveness. Increasing animal

mass and increasing animal depth both increase the impulse thresholds (i.e., decrease susceptibility), 

whereas smaller mass and decreased animal depth reduce the impulse thresholds (i.e., increase 

susceptibility). For impact assessment, sea turtle populations are assumed to be 5 percent adult and 95 

percent sub-adult. This adult to sub-adult population ratio is estimated from what is known about the 

population age structure for sea turtles. Sea turtles typically lay multiple clutches of 100 or more eggs 

with little parental investment and generally have low survival in early life. However, sea turtles that are 

able to survive past early life generally have high age-specific survival in later life. 

Table 3.8-5: Criteria to Quantitatively Assess Non-Auditory Injury due to Underwater 

Explosions

Impact 

Category Impact Threshold Threshold for Farthest Range to 

Effect2

Mortality1

144M

1

3

⁄

(1 +

D

10.1

)

1

6

⁄

Pa-s 103M

1

3

⁄

(1 +

D

10.1

)

1

6

⁄

Pa-s

Injury1 65.8M

1

3

⁄

(1 +

D

10.1

)

1

6

⁄

Pa-s 47.5M

1

3

⁄

(1 +

D

10.1

)

1

6

⁄

Pa-s

243 dB re 1 μPa SPL peak 237 dB re 1 μPa SPL peak

1

Impulse delivered over 20% of the estimated lung resonance period. See U.S. Department of the 

Navy (2017).

2 Threshold for 1% risk used to assess mitigation effectiveness.

Note: dB re 1 μPa = decibels referenced to 1 micropascal, SPL = sound pressure level

The derivation of these injury criteria and the species mass estimates are provided in the technical 

report Criteria and Thresholds for U.S. Navy Acoustic and Explosive Effects Analysis (Phase III) (U.S. 

Department of the Navy, 2017).

When explosive munitions (e.g., a bomb or missile) detonates, fragments of the weapon are thrown at 

high velocity from the detonation point, which can injure or kill sea turtles if they are struck. Risk of 

fragment injury reduces exponentially with distance as the fragment density is reduced. Fragments 

underwater tend to be larger than fragments produced by in-air explosions (Swisdak & Montanaro, 

1992). Underwater, the friction of the water would quickly slow these fragments to a point where they 

no longer pose a threat. On the other hand, the blast wave from an explosive detonation moves 
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efficiently through the seawater. Because the ranges to mortality and injury due to exposure to the blast 

wave are likely to far exceed the zone where fragments could injure or kill an animal, the above 

thresholds are assumed to encompass risk due to fragmentation. 

Auditory Weighting Functions

Animals are not equally sensitive to noise at all frequencies. To capture the frequency-dependent nature 

of the effects of noise, auditory weighting functions are used. Auditory weighting functions are 

mathematical functions that adjust received sound levels to emphasize ranges of best hearing and deemphasize ranges with less or no auditory sensitivity. The adjusted received sound level is referred to as 

a weighted received sound level. 

The auditory weighting function for sea turtles is shown in Figure 3.8-20. The derivation of this 

weighting function is described in the technical report Criteria and Thresholds for U.S. Navy Acoustic and 

Explosive Effects Analysis (Phase III) (U.S. Department of the Navy, 2017). The frequencies around the 

top portion of the function, where the amplitude is closest to zero, are emphasized, while the 

frequencies below and above this range (where amplitude declines) are de-emphasized, when summing 

acoustic energy received by a sea turtle.

Source: U.S. Department of the Navy (2017)

Notes: dB: decibels; kHz: kilohertz; TU: sea turtle hearing group

Figure 3.8-20: Auditory Weighting Function for Sea Turtles

Hearing Loss from Explosives

No studies of hearing loss have been conducted on sea turtles. Therefore, sea turtle susceptibility to 

hearing loss due to an acoustic exposure is evaluated using knowledge about sea turtle hearing abilities 

in combination with non-impulsive auditory effect data from other species (marine mammals and fish). 

This yields sea turtle exposure functions, shown in Figure 3.8-21, which are mathematical functions that 

relate the SELs for onset of TTS or PTS to the frequency of the sonar sound exposure. The derivation of 

the sea turtle exposure functions are provided in the technical report Criteria and Thresholds for U.S. 

Navy Acoustic and Explosive Effects Analysis (Phase III) (U.S. Department of the Navy, 2017).
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Notes: kHz: kilohertz; SEL: Sound Exposure Level, dB re 1 μPa2s = decibels referenced to 1 micropascal squared second. The 

solid black curve is the exposure function for TTS onset and the dashed black curve is the exposure function for PTS onset. 

Small dashed lines and asterisks indicate the SEL thresholds and most-sensitive frequency for TTS and PTS.

Figure 3.8-21: TTS and PTS Exposure Functions for Impulsive Sounds

For impulsive sounds, hearing loss in other species has also been observed to be related to the 

unweighted peak pressure of a received sound. Because this data does not exist for sea turtles, 

unweighted peak pressure thresholds for TTS and PTS were developed by applying relationships 

observed between impulsive peak pressure TTS thresholds and auditory sensitivity in marine mammals 

to sea turtles. This results in dual-metric hearing loss criteria for sea turtles for impulsive sound 

exposure: the SEL-based exposure functions in Figure 3.8-21 and the peak pressure thresholds in Table 

3.8-6. The derivation of the sea turtle impulsive peak pressure TTS and PTS thresholds are provided in 

the technical report Criteria and Thresholds for U.S. Navy Acoustic and Explosive Effects Analysis (Phase 

III) (U.S. Department of the Navy, 2017).

Table 3.8-6: TTS and PTS Peak Pressure Thresholds Derived for Sea Turtles Exposed to 

Impulsive Sounds

Auditory Effect Unweighted Peak Pressure Threshold

TTS 226 dB re 1 μPa SPL peak

PTS 232 dB re 1 μPa SPL peak

Notes: dB re 1 μPa = decibels referenced to 1 micropascal, 

PTS = permanent threshold shift, SPL = sound pressure level, 

TTS = temporary threshold shift

Accounting for Mitigation

The Navy implements mitigation measures (described in Chapter 5, Mitigation) during explosive 

activities, including delaying detonations when a sea turtle or marine mammal is observed in the 

mitigation zone. The mitigation zones encompass the estimated ranges to mortality for a given 
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explosive. Therefore, the impact analysis quantifies the potential for mitigation to reduce the risk of 

mortality due to exposure to explosives. Two factors are considered when quantifying the effectiveness 

of mitigation: (1) the extent to which the type of mitigation proposed for a sound-producing activity 

(e.g., active sonar) allows for observation of the mitigation zone prior to and during the activity; and 

(2) the sightability of each species that may be present in the mitigation zone, which is determined by 

species-specific characteristics and the viewing platform. A detailed explanation of the analysis is 

provided in the technical report 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, 2018).

In the quantitative analysis, consideration of mitigation measures means that, for activities where 

mitigation is feasible, model-estimated mortality is considered mitigated to the level of injury. The 

impact analysis does not analyze the potential for mitigation to reduce TTS or behavioral effects, even 

though mitigation could also reduce the likelihood of these effects. In practice, mitigation also protects 

all unobserved (below the surface) animals in the vicinity, including other species, in addition to the 

observed animal. However, the analysis assumes that only animals sighted at the water surface would 

be protected by the applied mitigation. The analysis, therefore, does not capture the protection 

afforded to all marine species that may be near or within the mitigation zone.

3.8.3.2.2.2 Impact Ranges for Explosives

Ranges to effect (see Table 3.8-7 through Table 3.8-10) were developed in the Navy Acoustic Effects 

Model based on the thresholds for TTS, PTS, injury, and mortality discussed above. 
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Table 3.8-7: Ranges to Mortality for Sea Turtles Exposed to Explosives as a Function of Animal 

Mass1

Bin

Animal Mass Intervals (kg)1,2

10 50 100 150 300

E1 3

(2–3)

0

(0–2)

0

(0–0)

0

(0–0)

0

(0–0)

E2 4

(3–4)

2

(2–3)

1

(0–2)

1

(0–2)

0

(0–0)

E3 8

(6–10)

5

(4–6)

4

(3–4)

3

(3–4)

2

(2–2)

E4 14

(0–30)

9

(0–19)

7

(0–15)

6

(4–12)

5

(3–8)

E5 13

(11–30)

8

(7–15)

7

(6–12)

6

(5–10)

4

(4–7)

E6 18

(14–50)

12

(9–30)

10

(7–23)

8

(7–19)

6

(5–13)

E7 69

(55–85)

40

(35–45)

30

(25–35)

25

(24–30)

19

(18–21)

E8 47

(0–100)

30

(0–55)

23

(0–40)

20

(0–30)

16

(9–21)

E9 32

(30–55)

23

(22–25)

19

(18–20)

17

(16–18)

13

(12–13)

E10 59

(35–190)

26

(25–40)

24

(21–35)

21

(19–35)

16

(15–25)

E11 213

(180–400)

135

(120–210)

105

(100–170)

92

(85–140)

63

(55–100)

E12 133

(50–320)

46

(30–150)

27

(25–35)

25

(25–30)

20

(19–21)

E16 931

(800–1,025)

676

(600–850)

538

(525–550)

485

(470–500)

376

(370–390)

E17 1,359

(1,025–2,025)

1,077

(900–1,275)

929

(800–1,025)

841

(750–925)

728

(675–850)

1 Ranges based on the mortality impact threshold (see Criteria and Thresholds Used to Predict Impacts from 

Explosives) in Section 3.8.3.2.2.1 (Methods for Analyzing Impacts from Explosives). 

2 Average distance (m) to mortality is depicted above the minimum and maximum distances which are in 

parentheses.
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Table 3.8-8: Ranges to Non-Auditory Injury1(in meters) for Sea Turtles Exposed to Explosives 

as a Function of Animal Mass

Bin

Animal Mass Intervals (kg)1,2

10 50 100 150 300

E1 12

(11–13)

12

(11–13)

12

(11–13)

12

(11–13)

12

(11–13)

E2 15

(15–16)

15

(15–16)

15

(15–16)

15

(15–16)

15

(15–16)

E3 25

(25–40)

25

(25–40)

25

(25–40)

25

(25–40)

25

(25–40)

E4 30

(0–65)

30

(0–55)

30

(0–55)

30

(9–55)

30

(7–55)

E5 41

(30–70)

41

(30–70)

41

(30–70)

41

(30–70)

41

(30–70)

E6 53

(40–130)

53

(40–90)

53

(40–90)

53

(40–90)

53

(40–90)

E7 166

(110–190)

94

(75–110)

92

(75–110)

92

(75–110)

92

(75–110)

E8 107

(0–230)

88

(0–130)

88

(0–130)

88

(19–130)

88

(17–130)

E9 119

(90–300)

119

(90–140)

119

(90–130)

119

(90–130)

119

(90–130)

E10 169

(90–480)

139

(90–270)

139

(90–190)

139

(90–160)

139

(90–160)

E11 436

(310–1,275)

284

(230–525)

223

(190–500)

192

(170–500)

191

(170–500)

E12 300

(140–675)

188

(140–400)

188

(140–320)

188

(140–270)

188

(140–220)

E16 1,460

(1,275–2,025)

1,146

(975–1,775)

962

(825–1,775)

888

(775–1,775)

844

(650–1,775)

E17 2,520

(1,275–4,275)

1,751

(1,275–3,025)

1,442

(1,275–3,025)

1,414

(1,025–3,025)

1,414

(1,025–3,025)

1 Ranges based on the injury impact threshold (see Criteria and Thresholds Used to Predict Impacts from 

Explosives) in Section 3.8.3.2.2.1 Methods for Analyzing Impacts from Explosives).

2 Average distance (m) to non-auditory injury is depicted above the minimum and maximum distances, which 

are in parentheses. The ranges depicted are the further of the ranges for impulse or peak pressure thresholds 

for an explosive bin and animal mass interval combination.
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Table 3.8-9: Peak Pressure Based Ranges to PTS and TTS for Sea Turtles Exposed to Explosives

Range to Effects for Explosives Bin: Sea Turtles1

Bin Source Depth (m) PTS TTS

E1 0.1 36

(30–60)

66

(50–100)

E2 0.1 44

(40–60)

70

(60–85)

E3 18.25 80

(80–110)

152

(140–230)

E4

15 111

(100–180)

220

(190–440)

19.8 101

(100–110)

198

(190–250)

198 85

(65–110)

181

(170–220)

E5 0.1 116

(75–140)

210

(100–250)

E6

0.1 144

(95–170)

257

(130–320)

30 218

(160–450)

436

(300–1,275)

E7 15 321

(250–410)

660

(500–850)

E8

0.1 243

(130–320)

403

(190–525)

45.75 334

(280–775)

696

(500–1,775)

305 250

(210–310)

508

(490–625)

E9 0.1 350

(230–400)

563

(330–750)

E10 0.1 389

(180–925)

619

(320–1,275)

E11

18.5 715

(480–2,025)

1,350

(800–3,775)

45.75 761

(525–1,775)

1,399

(925–3,525)

E12 0.1 510

(310–675)

797

(460–2,025)

E16 61 2,500

(1,275–5,775)

3,761

(1,275–9,275)

E17 61 3,097

(1,275–8,275)

4,735

(1,525–10,275)

1Average distance (m) to PTS and TTS are depicted above the minimum and maximum distances which are in 

parentheses. Values depict the maximum range produced by the peak pressure metric. 

Notes: PTS = permanent threshold shift, TTS = temporary threshold shift
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Table 3.8-10: SEL Based Ranges to PTS and TTS for Sea Turtles Exposed to Explosives

Range to Effects for Explosives: Sea Turtles1

Bin Source Depth (m) Cluster Size PTS TTS

E1 0.1

1

0

(0–0)

0

(0–0)

20 0

(0–0)

2

(2–4)

E2 0.1

1

0

(0–0)

0

(0–0)

2

0

(0–0)

0

(0–0)

E3 18.25

1

3

(3–3)

17

(16–19)

50 25

(23–25)

145

(130–220)

E4

15

1

5

(5–8)

41

(40–50)

5

13

(12–17)

99

(90–110)

19.8 2

7

(7–7)

50

(50–50)

198 2

4

(0–7)

18

(0–35)

E5 0.1 25 6

(6–14)

41

(25–160)

E6

0.1 1

2

(2–3)

11

(10–15)

30 1

16

(13–24)

129

(95–360)

E7 15 1

51

(45–55)

361

(330–390)

E8

0.1 1

6

(5–11)

60

(25–180)

45.75 1

40

(40–65)

308

(260–725)

305 1

15

(0–35)

128

(55–190)

E9 0.1 1

9

(9–20)

160

(40–350)

E10 0.1 1

15

(13–25)

207

(50–625)

E11

18.5 1

229

(170–440)

1,474

(750–4,025)

45.75 1

179

(170–260)

1,143

(700–2,775)

E12 0.1 1

25

(18–120)

367

(80–900)
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Table 3.8-10: SEL Based Ranges to PTS and TTS for Sea Turtles Exposed to Explosives

(continued)

Range to Effects for Explosives: Sea Turtles1

Bin Source Depth (m) Cluster Size PTS TTS

E16 61 1

1,059

(900–1,525)

5,257

(1,525–10,525)

E17 61 1

1,869

(1,275–2,775)

13,443

(7,775–23,275)

1Average distance (m) to PTS and TTS are depicted above the minimum and maximum distances which are in 

parentheses. Values depict the maximum range produced by the SEL metric. 

Notes: PTS = permanent threshold shift, TTS = temporary threshold shift

Presentation of Estimated Impacts from the Quantitative Analysis

The results of the analysis of potential impacts to sea turtles from explosives as described in Section 

3.8.3.2.2.1 (Methods for Analyzing Impacts from Explosives) are discussed below. Estimated numbers of 

potential impacts from the quantitative analysis for each species of sea turtle from exposure to 

explosive energy and sound for training and testing activities are presented below. The most likely 

regions and activity categories from which the impacts could occur are displayed in the figures for each 

species of sea turtle. Additionally, results of Ship Shock Trial are presented separately in the section for

impacts due to testing. There is a potential for impacts to occur anywhere within the Study Area where 

sound and energy from explosives and the species overlap, although only areas or categories where 

0.5 percent of the impact, or greater, are estimated to occur are graphically represented on the species 

specific figures below. All (i.e., grand total) estimated impacts are included in the graphics, regardless of 

region or category. 

The numbers of activities planned can vary slightly from year-to-year. Results are presented for a 

maximum explosive use year; however, during most years, explosive use would be less resulting in fewer 

potential impacts. The number of explosives used are described in Section 3.0.3.3.2 (Explosive 

Stressors). Impacts to crocodilians and terrapins are discussed qualitatively below as appropriate. 

3.8.3.2.2.3 Impacts from Explosives under Alternative 1

Impacts from Explosives under Alternative 1 for Training Activities

Activities using explosives would be conducted as described in Chapter 2 (Description of Proposed 

Action and Alternatives) and Appendix A (Navy Activity Descriptions). General characteristics, quantities, 

and net explosive weights of in-water explosives used during training under Alternative 1 are provided in 

Section 3.0.3.3.2 (Explosive Stressors). Quantities and locations of fragment-producing explosives during 

training under Alternative 1 are shown in Section 3.0.3.3.4.2 (Military Expended Materials). Under 

Alternative 1, there could be fluctuation in the amount of explosions that could occur annually, although 

potential impacts would be similar from year to year. 

Training activities involving explosions would typically be conducted in the range complexes, with 

greater occurrence in the Virginia Capes and Jacksonville Range Complexes. Activities that involve 

underwater detonations and explosive munitions typically occur more than 3 NM from shore. 

The estimated impacts on sea turtles from explosives during training activities presented in Figure 

3.8-22 through Figure 3.8-25 are for the maximum anticipated training year under Alternative 1 (for 

impact tables, see Appendix E, Acoustic Impact Tables). Under Alternative 1, it is possible that impacts 

would be slightly reduced in some years, as explosive use would fluctuate.
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Notes: Region and Activity bar charts show categories +/- 0.5 percent of the estimated impacts. Estimated impacts most years 

would be less based on fewer explosions. No injuries (non-auditory) are estimated for this species. ASW: Anti-Submarine 

Warfare; RC: Range Complex.

Figure 3.8-22: Green Turtle Impacts Estimated per Year from the Maximum Number of Explosions 

During Training and Testing under Alternative 1 (Excluding Full Ship Shock Trials)
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Notes: Region and Activity bar charts show categories +/- 0.5 percent of the estimated impacts. Estimated impacts most years 

would be less based on fewer explosions. No injuries (non-auditory) are estimated for this species. ASW: Anti-Submarine Warfare;

RC: Range Complex.

Figure 3.8-23: Kemp’s Ridley Turtle Impacts Estimated per Year from the Maximum Number of 

Explosions During Training and Testing under Alternative 1 (Excluding Full Ship Shock Trials)
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Notes: Region and Activity bar charts show categories +/- 0.5 percent of the estimated impacts. Estimated impacts most years 

would be less based on fewer explosions. No injuries (non-auditory) are estimated for this species. ASW: Anti-Submarine 

Warfare; RC: Range Complex.

Figure 3.8-24: Leatherback Turtle Impacts Estimated per Year from the Maximum Number of 

Explosions During Training and Testing under Alternative 1 (Excluding Full Ship Shock Trials)
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Notes: Region and Activity bar charts show categories +/- 0.5 percent of the estimated impacts. Estimated impacts most years 

would be less based on fewer explosions. ASW: Anti-Submarine Warfare; RC: Range Complex.

Figure 3.8-25: Loggerhead Turtle Impacts Estimated per Year from the Maximum Number of 

Explosions during Training and Testing under Alternative 1 (Excluding Full Ship Shock Trials)

As shown in the above estimates, the quantitative analysis estimates that a small number of green, 

Kemp’s ridley, leatherback, and loggerhead turtles would be exposed to levels of explosive sound and 

energy that could cause TTS and PTS, some loggerhead turtles would be injured, and no sea turtles 
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would be killed. The quantitative analysis predicts that no hawksbill sea turtles are likely to be exposed 

to the levels of explosive sound and energy that could cause TTS, PTS, or injury during training activities 

under Alternative 1. Fractional estimated impacts per region and activity area represent the probability 

that the number of estimated impacts by effect will occur in a certain region or be due to a certain 

activity category.

Threshold shifts and injuries could reduce the fitness of an individual animal, causing a reduction in 

foraging success, reproduction or increased susceptibility to predators. This reduction in fitness would 

be temporary for recoverable impacts, such as TTS. There could be long-term consequences to some 

individuals. However, no population-level impact is expected due to the low number of estimated 

injuries for any sea turtle species relative to total population size. 

As discussed in Section 5.3.3 (Explosive Stressors), procedural mitigation includes ceasing explosive 

detonations (e.g., ceasing deployment of an explosive bomb) if a sea turtle is observed in the mitigation 

zone whenever and wherever applicable activities occur. In addition to procedural mitigation, the Navy 

will implement mitigation within mitigation areas to: (1) avoid or reduce potential impacts from 

explosives on sea turtles in nearshore waters of the Navy Cherry Point Range Complex during nesting 

season (see Section 5.4.3, Mitigation Areas off the Mid-Atlantic and Southeastern United States), and 

(2) avoid or reduce potential impacts on seafloor resources throughout the Study Area (see Section 

5.4.1, Mitigation Areas for Seafloor Resources). Mitigation for seafloor resources will help the Navy 

further avoid or reduce the potential for impacts on sea turtles that shelter and feed on shallow-water 

coral reefs, live hard-bottom, artificial reefs, submerged aquatic vegetation, and shipwrecks. 

Reptile hearing is less sensitive than other marine animals (i.e., marine mammals), and the role of their 

underwater hearing is unclear. Reptiles’ limited hearing range (<2 kHz) is most likely used to detect 

nearby broadband, continuous environmental sounds, such as the sounds of waves crashing on the 

beach that may be important for identifying their habitat. Recovery from a hearing threshold shift 

begins almost immediately after the noise exposure ceases. A temporary threshold shift is expected to 

take a few minutes to a few days, depending on the severity of the initial shift, to fully recover (U.S. 

Department of the Navy, 2017). If any hearing loss remains after recovery, that remaining hearing 

threshold shift is permanent. Because explosions produce broadband sounds with low-frequency 

content, hearing loss due to explosive sound could occur across a sea turtle’s very limited hearing range, 

reducing the distance over which relevant sounds, such as beach sounds, may be detected for the 

duration of the threshold shift.

Some reptiles may behaviorally respond to the sound of an explosive. A reptile’s behavioral response to 

a single detonation or explosive cluster is expected to be limited to a short-term startle response, as the 

duration of noise from these events is very brief. Limited research and observations from air gun studies 

(see Section 3.8.3.2.2.1, Methods for Analyzing Impacts from Explosives) suggest that if sea turtles are 

exposed to repetitive impulsive sounds in close proximity, they may react by increasing swim speed, 

avoiding the source, or changing their position in the water column. There is no evidence to suggest that 

any behavioral response would persist beyond the sound exposure. Because the duration of most 

explosive events is brief, the potential for masking is low. In fact, the ANSI Sound Exposure Guidelines

(Popper et al., 2014) consider masking to not be a concern for sea turtles exposed to explosions. This 

can also be assumed for crocodilians and terrapins. 

A physiological stress response is assumed to accompany any injury, hearing loss, or behavioral reaction. 

A stress response is a suite of physiological changes that are meant to help an organism mitigate the 
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impact of a stressor. While the stress response is a normal function for an animal dealing with natural 

stressors in their environment, chronic stress responses could reduce an individual’s fitness. Due to the 

low number of estimated impacts, it is not likely that any reptile would experience repeated stress 

explosive impacts.

Considering the above factors and the mitigation measures that would be implemented as described in 

Chapter 5 (Mitigation), long-term consequences for sea turtle populations would not be expected.

The use of explosives during training activities would not overlap with green, hawksbill, or leatherback 

turtle critical habitat around Culebra, Puerto Rico; Mona Island, Puerto Rico; and St. Croix Island, U.S. 

Virgin Islands respectively. Explosives during training activities would have a pathway to impact the 

physical and biological features of the constricted migratory habitat and Sargassum habitat in the midAtlantic and southeast regions by producing “noise pollution” from military activity (79 Federal Register

39855). The impacts on these habitats would be considered insignificant with no discernible impact on 

the conservation function of the physical and biological features as activity would not prevent a turtle 

from migrating, as explosions are brief in nature.

In addition to sea turtles, crocodilians and terrapins may overlap with explosions occurring in inshore 

areas. The only training activities involving explosions that would occur in ESA-listed American crocodile

habitat involve the underwater detonation of small (2-lb.) charges in enclosed areas of Truman Harbor 

and Demolition Key in the Key West Range Complex. Alligators and terrapins may also be present in 

Truman Harbor and Demolition Key, and terrapins may be present in areas with detonations occurring in 

the inshore waters of the lower Chesapeake Bay. Impacts, if any, to crocodilians and terrapins would be 

low due to the low probability of occurrence and nature of the confined and restricted detonation 

locations. The use of explosives would not overlap with American crocodile critical habitat in Florida Bay, 

which encompasses creeks, canals, and swamps.

Pursuant to the ESA, the use of explosives during training activities under Alternative 1 may affect 

ESA-listed green, hawksbill, Kemp’s ridley, leatherback, and loggerhead turtles and the ESA-listed 

American crocodile. There would be no effect on green, hawksbill, or leatherback turtle or American 

crocodile critical habitat. The use of explosives during training activities may affect loggerhead 

constricted migratory and Sargassum habitats in the mid-Atlantic and southeast regions. The Navy has 

consulted with NMFS and USFWS as required by section 7(a)(2) of the ESA. 

Impacts from Explosives under Alternative 1 for Testing Activities

Activities using explosives would be conducted as described in Chapter 2 (Description of Proposed 

Action and Alternatives) and Appendix A (Navy Activity Descriptions). General characteristics, quantities, 

and net explosive weights of in-water explosives used during testing under Alternative 1 are provided in 

Section 3.0.3.3.2 (Explosive Stressors). Quantities and locations of fragment-producing explosives during 

testing under Alternative 1 are shown in 3.0.3.3.4.2 (Military Expended Materials). 

Under Alternative 1, the number of testing activities using explosives could fluctuate annually. Testing 

activities involving explosions would typically be conducted on range complexes and on testing ranges, 

and do not occur in inshore waters. Activities that involve underwater detonations and explosive 

munitions typically occur more than 3 NM from shore. Very few activities would be conducted in the 

Naval Undersea Warfare Center Division, Newport Testing Range, and the Naval Surface Warfare Center 

Carderock Division, South Florida Ocean Measurement Facility Testing Range.
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The estimated impacts on sea turtles from explosives during testing activities presented in Figure 3.8-22

through Figure 3.8-25 are for the maximum anticipated testing year under Alternative 1, excluding ship 

shock trials (for impact tables, see Appendix E, Acoustic Impact Tables). The estimated impacts on sea 

turtles from a small ship shock trial and a large ship shock trial are shown in Figure 3.8-26 and Figure 

3.8-27. The results shown include the impacts due to all four separate detonations that constitute a 

single full ship shock trial. Small Ship Shock Trials could take place any season within the deep offshore 

water of the Virginia Capes Range Complex or in the spring, summer, or fall within the Jacksonville 

Range Complex and would occur up to three times over a 5-year period. The Large Ship Shock Trial could 

take place in the Jacksonville Range Complex during the spring, summer, or fall and during any season 

within the deep offshore water of the Virginia Capes or Gulf of Mexico Range Complexes. The Large Ship 

Shock Trial would occur once over five years. In addition, no ship shock trials would be conducted in the 

Jacksonville Range Complex between November and April due to North Atlantic right whale calving 

season. The estimated impacts shown are the worst case for each species in any season at any of the 

possible ship shock trial locations; therefore, they over-estimate the actual potential for impacts.

Note: As shown in the estimates above, the quantitative analysis estimates that one loggerhead turtle could be killed and a 

small number of loggerhead and leatherback turtles could be injured. 

Figure 3.8-26: Estimated Impacts on Sea Turtles from a Small Ship Shock Trial under Alternative 1
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Note: As shown in the estimates above, the quantitative analysis estimates that one loggerhead turtle could be killed and a 

small number of most other sea turtle species could be injured. 

Figure 3.8-27: Estimated Impacts on Sea Turtles from a Large Ship Shock Trial under Alternative 1

As shown in the above estimates, the quantitative analysis estimates that a small number of green, 

Kemp’s ridley, loggerhead, and leatherback turtles would be exposed to levels of explosive sound and 

energy that could cause TTS and PTS, some loggerhead sea turtles would be injured, and no sea turtles 

would be killed, excluding ship shock trials. The quantitative analysis predicts that no hawksbill sea 

turtles are likely to be exposed to the levels of explosive sound and energy that could cause TTS, PTS, or 

injury during testing activities under Alternative 1, excluding ship shock trials. In Figure 3.8-22 to Figure 

3.8-25, fractional estimated impacts per region and activity area represent the probability that the 

number of estimated impacts by effect will occur in a certain region or be due to a certain activity 

category. Additionally, the quantitative analysis estimates that one loggerhead turtle could be killed 

during a small ship shock trial and one during a large ship shock trial (Figure 3.8-26 and Figure 3.8-27).

All sea turtle species present in the Study Area could be exposed to levels of explosive sound and energy 

that could cause TTS or PTS, and only Kemp’s, leatherback, or loggerhead turtles could be injured during 

small or large ship shock trials. 

Threshold shifts and injuries could affect the fitness of an individual animal, causing a reduction in 

foraging success, reproduction, or increased susceptibility to predators. This reduction in fitness would 

be temporary for recoverable impacts, such as TTS, but there could be long-term consequences to some 

individuals. However, no population-level impact would occur due to the low number of estimated 

injuries for any sea turtle species relative to total population size.

As discussed in Section 5.3.3 (Explosive Stressors), procedural mitigation includes ceasing explosive 

detonations (e.g., ceasing deployment of an explosive bomb) if a sea turtle is observed in the mitigation 
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zone whenever and wherever applicable activities occur. Navy also implements additional procedural 

mitigation during sea turtle nesting season in the Naval Surface Warfare Center, Panama City Division 

Testing Range during line charge testing events. In addition to procedural mitigation, the Navy will 

implement mitigation within mitigation areas to: (1) avoid or reduce potential impacts from explosives

on sea turtles in nearshore waters of the Navy Cherry Point Range Complex during nesting season (see 

Section 5.4.3, Mitigation Areas off the Mid-Atlantic and Southeastern United States), and (2) avoid or 

reduce potential impacts on seafloor resources throughout the Study Area (see Section 5.4.1, Mitigation 

Areas for Seafloor Resources). Mitigation for seafloor resources will help the Navy further avoid or 

reduce the potential for impacts on sea turtles that shelter and feed on shallow-water coral reefs, live 

hard-bottom, artificial reefs, submerged aquatic vegetation, and shipwrecks.

The Navy also develops detailed ship shock mitigation plans prior to conducting ship shock trials. Ship 

shock trial procedural mitigations include pre-activity observation for sea turtles and floating vegetation 

that may indicate the possible presence of sea turtles in a large mitigation zone around the ship shock 

trial location, with delay or re-location if the site is deemed environmentally unsuitable, as described in 

Section 5.3.3.11 (Ship Shock Trials). These mitigations would reduce the potential for some exposures to 

high levels of explosive sound and energy.

Reptile hearing is less sensitive than other marine animals (i.e., marine mammals), and the role of their 

underwater hearing is unclear. Reptiles’ limited hearing range (<2 kHz) is most likely used to detect 

nearby broadband, continuous environmental sounds, such as the sounds of waves crashing on the 

beach that may be important for identifying their habitat. Recovery from a hearing threshold shift 

begins almost immediately after the noise exposure ceases. A temporary threshold shift is expected to 

take a few minutes to a few days, depending on the severity of the initial shift, to fully recover. If any 

hearing loss remains after recovery, that remaining hearing threshold shift is permanent. Because 

explosions produce broadband sounds with low-frequency content, hearing loss due to explosives could 

occur across a sea turtle’s very limited hearing range, reducing the distance over which relevant sounds, 

such as beach sounds, may be detected for the duration of the threshold shift.

Some reptiles may behaviorally respond to the sound of an explosive. A reptile’s behavioral response to 

a single detonation or explosive cluster is expected to be limited to a short-term (seconds to minutes) 

startle response, as the duration of noise from these events is very brief. Limited research and 

observations from air gun studies (Section 3.8.3.2.2.1, Methods for Analyzing Impacts from Explosives) 

suggest that if sea turtles are exposed to repetitive impulsive sounds in close proximity, they may react 

by increasing swim speed, avoiding the source, or changing their position in the water column. There is 

no evidence to suggest that any behavioral response would persist beyond the sound exposure.

A physiological stress response is assumed to accompany any injury, hearing loss, or behavioral reaction. 

A stress response is a suite of physiological changes that are meant to help an organism mitigate the 

impact of a stressor. While the stress response is a normal function for an animal dealing with natural 

stressors in their environment, chronic stress responses could reduce an individual’s fitness. Due to the 

low number of estimated impacts, there is a low likelihood that a reptile would experience repeated 

stress responses due to explosive impacts. Because the duration of most explosive events is brief, the 

potential for masking is low. The ANSI Sound Exposure Guidelines (Popper et al., 2014) consider masking 

to not be a concern for sea turtles exposed to explosions.

Considering the above factors and the mitigation measures that would be implemented as described in 

Chapter 5 (Mitigation), long-term consequences for sea turtle populations would not be expected.
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The use of explosives during testing activities would not overlap with green, hawksbill, or leatherback 

turtle critical habitat around Culebra, Puerto Rico; Mona Island, Puerto Rico; and St. Croix Island, U.S. 

Virgin Islands respectively. Explosives during training activities would have a pathway to impact the 

physical and biological features of the constricted migratory habitat and Sargassum habitat in the midAtlantic and southeast regions by producing “noise pollution” from military activity (79 Federal Register

39855). The impacts on these habitats would be considered insignificant with no discernible impact on 

the conservation function of the physical and biological features as activity would not prevent a turtle 

from migrating, as explosions are brief in nature. 

Explosives would not be used in crocodilian, including the ESA-listed American crocodile, or terrapin 

habitats during testing activities. Additionally, the use of explosives would not overlap with American 

crocodile critical habitat in Florida Bay, which encompasses creeks, canals, and swamps.

Pursuant to the ESA, the use of explosives during testing activities under Alternative 1 may affect 

ESA-listed green, hawksbill, Kemp’s ridley, leatherback, and loggerhead turtles; and would have no 

effect on the ESA-listed American crocodile. There would be no effect on green, hawksbill, or 

leatherback turtle critical habitat or on American crocodile critical habitat. The use of explosives during 

testing activities may affect loggerhead constricted migratory and Sargassum habitats in the midAtlantic and southeast regions. The Navy has consulted with NMFS as required by section 7(a)(2) of the 

ESA. 

3.8.3.2.2.4 Impacts from Explosives under Alternative 2

Impacts from Explosives under Alternative 2 for Training Activities

Under Alternative 2, the maximum number of training activities could occur every year. Activities using 

explosives would be conducted as described in Chapter 2 (Description of Proposed Action and 

Alternatives) and Appendix A (Navy Activity Descriptions). General characteristics, quantities, and net 

explosive weights of in-water explosives used during training under Alternative 2 are provided in Section 

3.0.3.3.2 (Explosive Stressors). Quantities and locations of fragment-producing explosives during training 

under Alternative 2 are shown in 3.0.3.3.4.2 (Military Expended Materials).

Training activities involving explosions would typically be conducted in the range complexes, with 

greater occurrence in the Virginia Capes and Jacksonville Range complexes. Activities that involve 

underwater detonations and explosive munitions typically occur more than 3 NM from shore. 

The estimated impacts on sea turtles from explosions during a maximum year of training under 

Alternative 2 are presented in Figure 3.8-28 to Figure 3.8-31. Estimated impacts for Alternative 2 are 

identical to those described in Section 3.8.3.2.2.3 (Impacts from Explosives Under Alternative 1).
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Notes: Region and Activity bar charts show categories +/- 0.5 percent of the estimated impacts. Estimated impacts most years 

would be less based on fewer explosions. No injuries (non-auditory) are estimated for this species. ASW: Anti-Submarine 

Warfare; RC: Range Complex.

Figure 3.8-28: Green Turtle Impacts Estimated per Year from the Maximum Number of 

Explosions During Training and Testing under Alternative 2 (Excluding Full Ship Shock Trials)
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Notes: Region and Activity bar charts show categories +/- 0.5 percent of the estimated impacts. Estimated impacts most years 

would be less based on fewer explosions. No injuries (non-auditory) are estimated for this species. ASW: Anti-Submarine 

Warfare; RC: Range Complex.

Figure 3.8-29: Kemp’s Ridley Turtle Impacts Estimated per Year from the Maximum Number 

of Explosions During Training and Testing under Alternative 2 (Excluding Full Ship Shock 

Trials)
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Notes: Region and Activity bar charts show categories +/- 0.5 percent of the estimated impacts. Estimated impacts most years 

would be less based on fewer explosions. No injuries (non-auditory) are estimated for this species. ASW: Anti-Submarine 

Warfare; RC: Range Complex.

Figure 3.8-30: Leatherback Sea Turtle Impacts Estimated per Year from the Maximum Number 

of Explosions During Training and Testing under Alternative 2 (Excluding Full Ship Shock 

Trials)
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Notes: Region and Activity bar charts show categories +/- 0.5 percent of the estimated impacts. Estimated impacts most years 

would be less based on fewer explosions. ASW: Anti-Submarine Warfare; RC: Range Complex.

Figure 3.8-31: Loggerhead Sea Turtle Impacts Estimated per Year from the Maximum Number 

of Explosions During Training and Testing under Alternative 2 (Excluding Full Ship Shock 

Trials)
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As shown in the above estimates, the quantitative analysis estimates that a small number of green, 

Kemp’s ridley, leatherback, and loggerhead turtles would be exposed to levels of explosive sound and 

energy that could cause TTS and PTS, some loggerhead turtles would be injured, and no sea turtles 

would be killed. The quantitative analysis predicts that no hawksbill sea turtles are likely to be exposed 

to the levels of explosive sound and energy that could cause TTS, PTS, or injury during training activities 

under Alternative 2. Fractional estimated impacts per region and activity area represent the probability 

that the number of estimated impacts by effect will occur in a certain region or be due to a certain 

activity category.

Threshold shifts and injuries could reduce the fitness of an individual animal, causing a reduction in 

foraging success, reproduction, or increased susceptibility to predators. This reduction in fitness would 

be temporary for recoverable impacts, such as TTS, but there could be long-term consequences to some 

individuals. However, no population-level impact is expected due to the low number of estimated 

injuries for any sea turtle species relative to total population size.

As discussed in Section 5.3.3 (Explosive Stressors), procedural mitigation includes ceasing explosive 

detonations (e.g., ceasing deployment of an explosive bomb) if a sea turtle is observed in the mitigation 

zone whenever and wherever applicable activities occur. In addition to procedural mitigation, the Navy 

will implement mitigation within mitigation areas to: (1) avoid or reduce potential impacts from 

explosives on sea turtles in nearshore waters of the Navy Cherry Point Range Complex during nesting 

season (see Section 5.4.3, Mitigation Areas off the Mid-Atlantic and Southeastern United States), and (2) 

avoid or reduce potential impacts on seafloor resources throughout the Study Area (see Section 5.4.1, 

Mitigation Areas for Seafloor Resources). Mitigation for seafloor resources will help the Navy further 

avoid or reduce the potential for impacts on sea turtles that shelter and feed on shallow-water coral 

reefs, live hard-bottom, artificial reefs, submerged aquatic vegetation, and shipwrecks.

Considering the above factors and the mitigation measures that would be implemented as described in 

Chapter 5 (Mitigation), long-term consequences for sea turtle population would not be expected.

The use of explosives during training activities would not overlap with green, hawksbill, or leatherback 

turtle critical habitat around Culebra, Puerto Rico; Mona Island, Puerto Rico; and St. Croix Island, U.S. 

Virgin Islands respectively. Explosives during training activities would have a pathway to impact the 

physical and biological features of the constricted migratory habitat and Sargassum habitat in the midAtlantic and southeast regions by producing “noise pollution” from military activity (79 Federal Register

39855). The impacts on these habitats would be considered insignificant with no discernible impact on 

the conservation function of the physical and biological features as activity would not prevent a turtle 

from migrating, as explosions are brief in nature. 

In addition to sea turtles, crocodilians and terrapins may overlap with explosions occurring in inshore 

areas. The only training activities involving explosions that would occur in ESA-listed American crocodile 

habitat involves the underwater detonation of small (2-lb.) charges in enclosed areas of Truman Harbor 

and Demolition Key in the Key West Range Complex. Alligators and terrapins may also be present in 

Truman Harbor and Demolition Key, and terrapins may be present in areas with detonations occurring in 

the inshore waters of the lower Chesapeake Bay. Impacts, if any, to crocodilians and terrapins would be 

low due to the low probability of occurrence and nature of the confined and restricted detonation 

locations. The use of explosives would not overlap with American crocodile critical habitat in Florida Bay, 

which encompasses creeks, canals, and swamps.
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Pursuant to the ESA, the use of explosives during training activities under Alternative 2 may affect 

ESA-listed green, hawksbill, Kemp’s ridley, leatherback, and loggerhead sea turtles; and may affect the 

ESA-listed American crocodile. There would be no effect on green, hawksbill, or leatherback sea turtle 

critical habitat or on American crocodile critical habitat. The use of explosives during training activities 

may affect loggerhead constricted migratory and Sargassum habitats in the mid-Atlantic and southeast 

regions.

Impacts from Explosives under Alternative 2 for Testing Activities

Under Alternative 2, the maximum number of testing activities could occur every year. Activities using

explosives would be conducted as described in Chapter 2 (Description of Proposed Action and 

Alternatives) and Appendix A (Navy Activity Descriptions). General characteristics, quantities, and net 

explosive weights of in-water explosives used during testing under Alternative 2 are provided in Section 

3.0.3.3.2 (Explosive Stressors). Quantities and locations of fragment-producing explosives during testing 

under Alternative 2 are shown in 3.0.3.3.4.2 (Military Expended Materials). 

Testing activities involving explosions would typically be conducted on range complexes and on testing 

ranges, and do not occur in inshore waters. Activities that involve underwater detonations and explosive 

munitions typically occur more than 3 NM from shore. 

Annual use of explosives during testing under Alternative 2 is nearly identical to the maximum year of 

testing under Alternative 1. Therefore, estimated impacts under Alternative 2 are nearly identical to 

those described in Section 3.8.3.2.2.3 (Impacts from Explosives under Alternative 1).

The estimated impacts on sea turtles from explosives during testing activities presented in Figure 3.8-28

through Figure 3.8-31 are for the maximum anticipated testing year under Alternative 2, excluding ship 

shock trials (for impact tables, see Appendix E, Acoustic Impact Tables). The estimated impacts on sea 

turtles from a small ship shock trial are shown in Figure 3.8-32. No impacts were estimated for a large

ship shock trial. Small ship shock trials could take place any season within the deep offshore water of the 

Virginia Capes Range Complex or in the spring, summer, or fall within the Jacksonville Range Complex 

and would occur up to three times over a five-year period. In addition, no ship shock trials would be 

conducted in the Jacksonville Range Complex between November and April due to North Atlantic right 

whale calving season. The estimated impacts shown are the worst case for each species in any season at 

any of the possible ship shock trial locations; therefore, they over-estimate the actual potential for 

impacts.
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Note: As shown in the estimates above, the quantitative analysis estimates that one loggerhead turtle could be killed and a 

small number of loggerhead and leatherback turtle species could be injured. 

Figure 3.8-32: Estimated Impacts on Sea Turtles from a Small Ship Shock Trial

As shown in Figure 3.8-28 through Figure 3.8-31, the quantitative analysis estimates that a small number 

of green, Kemp’s ridley, leatherback, and loggerhead turtles would be exposed to levels of explosive 

sound and energy that could cause TTS and PTS, some loggerhead sea turtles would be injured, and no 

sea turtles would be killed, excluding ship shock trials. The quantitative analysis predicts that no 

hawksbill sea turtles are likely to be exposed to the levels of explosive sound and energy that could 

cause TTS, PTS, or injury during testing activities under Alternative 2, excluding ship shock trials. In 

Figure 3.8-28 to Figure 3.8-31, fractional estimated impacts per region and activity area represent the 

probability that the number of estimated impacts by effect will occur in a certain region or be due to a 

certain activity category. During a small ship shock trial, the quantitative analysis estimates that one 

loggerhead turtle could be killed (Figure 3.8-32). All sea turtle species present in the Study Area could be 

exposed to levels of explosive sound and energy that could cause TTS or PTS, and only leatherback or 

loggerhead turtles could be injured during a small ship shock trial. 

Threshold shifts and injuries could affect the fitness of an individual animal, causing a reduction in 

foraging success, reproduction, or increased susceptibility to predators. This reduction in fitness would 

be temporary for recoverable impacts, such as TTS, but there could be long-term consequences to some 

individuals. However, no population-level impact would occur due to the low number of estimated 

injuries for any sea turtle species relative to total population size.

As discussed in Section 5.3.3 (Explosive Stressors), procedural mitigation includes ceasing explosive 

detonations (e.g., ceasing deployment of an explosive bomb, ceasing explosive missile firing) if a sea 

turtle is observed in the mitigation zone whenever and wherever applicable activities occur. Navy also 
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implements additional procedural mitigation during sea turtle nesting season in the Naval Surface 

Warfare Center, Panama City Division Testing Range during line charge testing events. In addition to

procedural mitigation, the Navy will implement mitigation within mitigation areas to: (1) avoid or reduce 

potential impacts from explosives on sea turtles in nearshore waters of the Navy Cherry Point Range 

Complex during nesting season (see Section 5.4.3, Mitigation Areas off the Mid-Atlantic and 

Southeastern United States), and (2) avoid or reduce potential impacts on seafloor resources 

throughout the Study Area (see Section 5.4.1, Mitigation Areas for Seafloor Resources). Mitigation for 

seafloor resources will help the Navy further avoid or reduce the potential for impacts on sea turtles 

that shelter and feed on shallow-water coral reefs, live hard-bottom, artificial reefs, submerged aquatic 

vegetation, and shipwrecks.

The Navy also develops detailed ship shock mitigation plans prior to conducting ship shock trials. Ship 

shock trial procedural mitigations include pre-activity observation for sea turtles and floating vegetation 

that may indicate the possible presence of sea turtles in a large mitigation zone around the ship shock 

trial location, with delay or re-location if the site is deemed environmentally unsuitable, as described in 

Section 5.3 (Procedural Mitigation to be Implemented). These mitigations would reduce the potential 

for some exposures to high levels of explosive sound and energy.

Considering the above factors and the mitigation measures that would be implemented as described in 

Chapter 5 (Mitigation), long-term consequences for sea turtle populations would not be expected.

The use of explosives during testing activities would not overlap with green, hawksbill, or leatherback 

turtle critical habitat around Culebra, Puerto Rico; Mona Island, Puerto Rico; and St. Croix Island, U.S. 

Virgin Islands respectively. Explosives during training activities would have a pathway to impact the 

physical and biological features of the constricted migratory habitat and Sargassum habitat in the midAtlantic and southeast regions by producing “noise pollution” from military activity (79 Federal Register

39855). The impacts on these habitats would be considered insignificant with no discernible impact on 

the conservation function of the physical and biological features as activity would not prevent a turtle 

from migrating, as explosions are brief in nature. 

Explosives would not be used in crocodilian, including the ESA-listed American crocodile, or terrapin 

habitats during testing activities. The use of explosives would not overlap with American crocodile 

critical habitat in Florida Bay, which encompasses creeks, canals, and swamps.

Pursuant to the ESA, the use of explosives during testing activities under Alternative 2 may affect 

ESA-listed green, hawksbill, Kemp’s ridley, loggerhead, and leatherback turtles; and would have no 

effect on the ESA-listed American crocodile. There would be no effect on green, hawksbill, or 

leatherback turtle critical habitat or American crocodile critical habitat. The use of explosives during 

testing activities may affect loggerhead constricted migratory and Sargassum habitats in the midAtlantic and southeast regions. 

3.8.3.2.2.5 Impacts from Explosives under the No Action Alternative

Under the No-Action Alternative, the Navy would not conduct the proposed training and testing 

activities in the AFTT Study Area. Various explosive stressors would not be introduced into the marine 

environment. Therefore, baseline conditions of the existing environment would either remain 

unchanged or would improve slightly after cessation of ongoing training and testing activities.
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3.8.3.3 Energy Stressors

This section analyzes the potential impacts of energy stressors used during training and testing activities 

within the Study Area. This section includes analysis of the potential impacts of: (1) in-water 

electromagnetic devices and (2) high-energy lasers. The potential for impact from electromagnetic 

energy created by kinetic energy weapons was determined to be low and contained on the surface 

vessel (Section 3.0.3.3.3.1, In-Water Electromagnetic Devices) and, therefore, will not be analyzed in this 

section. General discussion of impacts can also be found in Section 3.0.3.6.2 (Conceptual Framework for 

Assessing Effects from Energy-Producing Activities). Because energy stressors would not occur in 

habitats used by the American crocodile, the impacts that may potentially occur from energy stressors 

are limited to sea turtles, American alligators, and as diamondback terrapins.

3.8.3.3.1 Impacts from In-Water Electromagnetic Devices

For a discussion of the types of activities that create an electromagnetic field underwater, refer to 

Appendix B (Activity Stressor Matrices), and for information on locations and the number of activities 

proposed for each alternative, see Section 3.0.3.3.3.1 (In-Water Electromagnetic Devices). The devices 

producing an electromagnetic field are towed or unmanned mine countermeasure systems. The 

electromagnetic field is produced to simulate a vessel’s magnetic field. In an actual mine-clearing 

operation, the intent is that the electromagnetic field would trigger an enemy mine designed to sense a 

vessel’s magnetic field.

Well over a century ago, electromagnetic fields were introduced into the marine environment within the 

Study Area from a wide variety of sources (e.g., power transmission cables), yet little is known about the 

potential impacts on marine life. There is consensus, however, that magnetic fields and other cues 

(e.g., visual cues), are important for sea turtle orientation and navigation (Lohmann et al., 1997; Putman 

et al., 2015b). Studies on behavioral responses to magnetic fields have been conducted on green and 

loggerhead sea turtles. Loggerheads were found to be sensitive to field intensities ranging from 0.005 to 

4,000 microteslas, and green sea turtles were found to be sensitive to field intensities from 29.3 to 

200 microteslas (Bureau of Ocean Energy Management, 2011). Because these data are the best available 

information, this analysis assumes that the responses would be similar for other sea turtle species. Sea 

turtles use geomagnetic fields to navigate at sea, and therefore changes in those fields could impact 

their movement patterns (Lohmann & Lohmann, 1996; Lohmann et al., 1997). Turtles in all life stages 

orient to the earth’s magnetic field to position themselves in oceanic currents, and directional swimming 

presumably aided by magnetic orientation has been shown to occur in some sea turtles(Christiansen et 

al., 2016; Putman & Mansfield, 2015). This helps them locate seasonal feeding and breeding grounds 

and return to their nesting sites (Lohmann & Lohmann, 1996; Lohmann et al., 1997). Experiments show 

that sea turtles can detect changes in magnetic fields, which may cause them to deviate from their 

original direction (Lohmann & Lohmann, 1996; Lohmann et al., 1997). For example, Teuten et al. (2007)

found that loggerhead hatchlings tested in a magnetic field of 52 microteslas swam eastward, and when 

the field was decreased to 43 microteslas, the hatchlings swam westward. Sea turtles also use 

nonmagnetic cues for navigation and migration, and these additional cues may compensate for 

variations in magnetic fields. Putman et al. (2015b) conducted experiments on loggerhead hatchlings 

and determined that electromagnetic fields may be more important for sea turtle navigation in areas 

that may constrain a turtle’s ability to navigate (cold temperatures or displacement from a migration 

route). The findings of this study suggest that the magnetic orientation behavior of sea turtles is closely 

associated with ocean ecology and geomagnetic environment (Putman et al., 2015b).
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Liboff (2015) determined that freshly hatched sea turtles are able to detect and use the local 

geomagnetic field as a reference point before embarking a post-hatchling migration. Liboff (2015) 

proposed that the information is transferred from the mother to the egg through some undetermined 

geomagnetic imprinting process (Liboff, 2015). Aspects of electromagnetic stressors that are applicable 

to marine organisms in general are described in Section 3.0.3.6.2 (Conceptual Framework for Assessing 

Effects from Energy-Producing Activities).

As stated in Section 3.0.3.3.3.1 (In-Water Electromagnetic Devices), the static magnetic fields generated 

by electromagnetic devices used in training and testing activities are of relatively minute strength. The 

maximum strength of the magnetic field is approximately 2,300 microteslas, with the strength of the 

field decreasing further from the device. At a distance of 4 m from the source of a 2,300-microtesla

magnetic field, the strength of the field is approximately 50 microteslas, which is within the range of the 

Earth’s magnetic field (25 to 65 microteslas). At 8 m, the strength of the field is approximately 

40 percent of the Earth’s magnetic field, and only 10 percent at 24 m away from a 2,300 microtesla

magnetic field at the source. At a distance of 200 m the magnetic field would be approximately 

0.2 microteslas (U.S. Department of the Navy, 2005), which is less than 1 percent of the strength of the 

Earth’s magnetic field. This is likely within the range of detection for sea turtle species, but at the lower 

end of the sensitivity range.

Sheridan (2010) confirmed high degrees of site fidelity among terrapins returning to natal beaches,

along with low dispersal distances, suggesting that long-distance navigation is not required of terrapins, 

and they likely rely on other environmental cues (e.g., visual cues, shoreline shape, currents). Terrapins 

and alligators, however, like other reptiles (Brothers & Lohmann, 2015; Mathis & Moore, 1988; Putman 

et al., 2015b), likely detect electromagnetic fields and can use them in some degree for orientation. For 

inshore reptiles, however, other cues are likely more important.

3.8.3.3.1.1 Impacts from In-Water Electromagnetic Devices under Alternative 1

Impacts from In-Water Electromagnetic Devices under Alternative 1 for Training Activities

As discussed in Section 3.0.3.3.3.1 (In-Water Electromagnetic Devices), offshore training activities that 

use in-water electromagnetic devices would occur within the Virginia Capes, Navy Cherry Point, 

Jacksonville, and Gulf of Mexico Range Complexes (see Table 3.0-15). In addition, training activities that 

use in-water electromagnetic devices would occur within inshore waters surrounding Boston, 

Massachusetts; Earle, New Jersey; Delaware Bay, Delaware; Hampton Roads, Virginia; Morehead City, 

North Carolina; Wilmington, North Carolina; Savannah, Georgia; Kings Bay; Georgia; Mayport, Florida; 

Port Canaveral; Florida; Tampa, Florida; Beaumont, Texas; and Corpus Christi, Texas (see Table 3.0-23) 

In-water electromagnetic devices would be used in areas potentially inhabited by sea turtles, American 

alligators, and diamondback terrapins.

Sea turtles would be potentially exposed to electromagnetic fields in offshore areas and nearshore areas 

where electromagnetic devices are used. Sea turtles are expected to be highly dispersed in offshore 

waters, and co-occurrence with training events is unlikely even in the Navy Cherry Point Range Complex 

and Virginia Capes Range Complex where the density of training activities using in-water 

electromagnetic devices is the highest. If located in the immediate area (within about 200 m) where 

electromagnetic devices are being used, adult, sub-adult, juvenile, and hatchling sea turtles of all species

could deviate from their original movements, but the extent of this disturbance is likely to be 

inconsequential because of the low likelihood of a sea turtle occurring within 200 m of the device and 

the movement through the area of both the turtle and the device. In the event that an animal is exposed 
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in these areas, a small behavioral disturbance (e.g., short disorientation) is unlikely to significantly 

impact an animal’s behavior and fitness. Repeated exposures to animals are not anticipated as these 

offshore areas do not have resident animals year round. Given the very low number of events within 

inshore waters (see Table 3.0-23), the inshore water locations of where these devices would occur, and 

species’ distribution, co-occurrence with individuals of any species is very unlikely, especially in northern 

inshore locations.

Potential impacts on sea turtles are not anticipated because any potential effects are likely limited to a 

few minor disturbances, which would be similar to natural stressors regularly occurring in the animal’s 

life cycle. The electromagnetic devices used in training activities are not expected to cause more than a 

short-term behavioral disturbance to sea turtles because of the: (1) relatively low intensity of the 

magnetic fields generated (0.2 microteslas at 200 m from the source), (2) very localized potential impact 

area, and (3) temporary duration of the activities (hours). Potential impacts of exposure to 

electromagnetic stressors are not expected to result in substantial changes in an individual’s behavior, 

growth, survival, annual reproductive success, lifetime reproductive success (fitness), or species 

recruitment, and are not expected to result in population-level impacts.

American alligators may be exposed to electromagnetic fields in inshore training locations from North 

Carolina to Texas, while diamondback terrapins may be exposed to electromagnetic fields in all inshore

training locations where electromagnetic devices are used under Alternative 1 (these locations are listed 

in Table 3.0-23). Electromagnetic fields generated by in-water training devices would likely have 

negligible effects on alligators and terrapins because of the (1) relatively low intensity of the magnetic 

fields generated (0.2 microteslas at 200 m from the source), (2) very localized potential impact area, 

(3) geography of inshore waters (e.g., mudflats, plants, islands, creeks) that likely further shield alligators 

and terrapins from electromagnetic fields, (4) temporary duration of the activities (hours), and (5) the 

reliance on other environmental cues for orientation. Potential impacts of exposure to electromagnetic 

stressors are not expected to result in substantial changes in an individual’s behavior, growth, survival, 

annual reproductive success, lifetime reproductive success (fitness), or species recruitment, and are not 

expected to result in population-level impacts for American alligators or diamondback terrapins.

Proposed training activities that use in-water electromagnetic devices would not occur in designated 

critical habitat for the green sea turtle (Culebra Island), hawksbill sea turtle (Mona Island and Monita 

Island), leatherback sea turtle (St. Croix Island), or American crocodile (Florida Bay). Navy training 

activities that expend in-water electromagnetic devices would not occur within the southeast portion of 

loggerhead critical habitat that is designated as breeding areas, but would occur in the following 

loggerhead sea turtle critical habitat year round: nearshore reproductive habitat, winter areas, 

migration corridors, and Sargassum habitat. See Section 3.8.2.2.4.1 (Status and Management) for a 

description of these habitat types and supporting physical and biological factors. In-water 

electromagnetic device use has no pathway to impact the physical and biological features identified for 

these habitats (National Marine Fisheries Service, 2014b) due to the relatively weak strength of the 

electromagnetic fields created by these activities, the localized area potentially impacted by the 

electromagnetic fields, and the temporary duration of these activities.

Pursuant to the ESA, the use of electromagnetic devices during training activities under Alternative 1

may affect ESA-listed green, hawksbill, Kemp’s ridley, leatherback, and loggerhead sea turtles; and 

would have no effect on the ESA-listed American crocodile. There would be no effect on green, 

hawksbill, leatherback, or loggerhead sea turtle critical habitat; and there would be no effect on 
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American crocodile critical habitat. The Navy has consulted with the NMFS as required by section 7(a)(2) 

of the ESA in that regard.

Impacts from In-Water Electromagnetic Devices under Alternative 1 for Testing Activities

As discussed in Section 3.0.3.3.3.1 (In-Water Electromagnetic Devices), under Alternative 1, offshore

testing activities use in-water electromagnetic devices would occur within the Virginia Capes, Navy 

Cherry Point, Jacksonville, and Gulf of Mexico Range Complexes, as well as the South Florida Ocean 

Measurement Facility, and the Naval Surface Warfare Center Panama City Testing Range (see 

Table 3.0-14). In addition, testing activities that use in-water electromagnetic devices would occur 

within inshore waters surrounding Little Creek, Virginia (see Table 3.0-15).

Only sea turtles and diamondback terrapins are analyzed for potential impacts for testing activities that 

use in-water electromagnetic devices under Alternative 1. For testing activities occurring within inshore 

waters near Little Creek, Virginia, most of the sea turtle species except the hawksbill sea turtle would be 

present. Given the limited location of where these devices would occur, and species’ distribution in the 

area, which is limited to warmer months, co-occurrence with individuals is possible but unlikely in 

certain times of the year.

Sea turtles would be potentially exposed to electromagnetic fields in offshore areas and nearshore areas 

where electromagnetic devices are used. Sea turtles are expected to be highly dispersed in offshore 

waters, and co-occurrence with testing events is unlikely within areas used for testing activities 

(e.g., Virginia Capes, Navy Cherry Point, Jacksonville, and Gulf of Mexico Range Complexes), even in 

areas where sea turtle density is likely the highest (Virginia Capes and Navy Cherry Point Range 

Complexes). If located in the immediate area (within about 200 m) where electromagnetic devices are 

being used, adult, sub-adult, juvenile, and hatchling sea turtles could deviate from their original 

movements, but the extent of this disturbance is likely to be inconsequential because of the low 

likelihood of a sea turtle occurring within 200 m of the device and the movement through the area of 

both the turtle and the device. In addition, potential impacts on sea turtles are not anticipated because 

any potential effects are likely limited to a few minor disturbances, which would be similar to natural 

stressors regularly occurring in the animal’s life cycle. The electromagnetic devices used in testing 

activities are not expected to cause more than a short-term behavioral disturbance to sea turtles 

because of the: (1) relatively low intensity of the magnetic fields generated (0.2 microteslas at 200 m 

from the source), (2) very localized potential impact area, and (3) temporary duration of the activities 

(hours). Potential impacts of exposure to electromagnetic stressors are not expected to result in 

substantial changes in an individual’s behavior, growth, survival, annual reproductive success, lifetime 

reproductive success (fitness), or species recruitment, and are not expected to result in population-level 

impacts.

Diamondback terrapins may be exposed to electromagnetic fields in inshore waters around Little Creek, 

Virginia, where electromagnetic devices are used under Alternative 1. Electromagnetic fields generated 

by in-water testing devices would likely have negligible effects on terrapins because of the (1) relatively 

low intensity of the magnetic fields generated (0.2 microteslas at 200 m from the source), (2) very 

localized potential impact area, (3) geography of inshore waters (e.g., mudflats, plants, islands, creeks) 

that likely further shield terrapins from electromagnetic fields, (4) temporary duration of the activities 

(hours), and (5) the reliance on other environmental cues for orientation. Potential impacts of exposure 

to electromagnetic stressors are not expected to result in substantial changes in an individual’s

behavior, growth, survival, annual reproductive success, lifetime reproductive success (fitness), or 
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species recruitment, and are not expected to result in population-level impacts for diamondback 

terrapins.

Proposed testing activities that use in-water electromagnetic devices would not occur in designated 

critical habitat for the green sea turtle (Culebra Island), hawksbill sea turtle (Mona Island and Monita 

Island), leatherback sea turtle (St. Croix Island), or American crocodile (Florida Bay). Navy testing 

activities that expend in-water electromagnetic devices would not occur within the southeast portion of 

loggerhead critical habitat that is designated as breeding areas, but would occur in the following 

loggerhead sea turtle critical habitat year round: nearshore reproductive habitat, winter areas, 

migration corridors, and Sargassum habitat. See Section 3.8.2.2.4.1 (Status and Management) for a 

description of these habitat types and supporting physical and biological factors. In-water 

electromagnetic device use has no pathway to impact the physical and biological features identified for 

these habitats (National Marine Fisheries Service, 2014b) due to the relatively weak strength of the 

electromagnetic fields created by these activities, the localized area potentially impacted by the 

electromagnetic fields, and the temporary duration of these activities.

Pursuant to the ESA, the use of electromagnetic devices during testing activities under Alternative 1 may 

affect ESA-listed green, hawksbill, Kemp’s ridley, leatherback, and loggerhead sea turtles; and would 

have no effect on the ESA-listed American crocodile. There would be no effect on green, hawksbill,

leatherback, or loggerhead sea turtle critical habitat. The Navy has consulted with the NMFS as required 

by section 7(a)(2) of the ESA in that regard.

3.8.3.3.1.2 Impacts from In-Water Electromagnetic Devices under Alternative 2

Impacts from In-Water Electromagnetic Devices under Alternative 2 for Training Activities

Because the locations, number of events, and potential effects associated with in-water electromagnetic 

devices would be the same under Alternatives 1 and 2, impacts experienced by sea turtles, American 

alligators, and diamondback terrapins from in-water electromagnetic devices use under Alternative 2 

are not expected to be meaningfully different than those described under Alternative 1. Therefore, 

impacts associated with training activities under Alternative 2 are the same as Alternative 1.

Proposed training activities that use in-water electromagnetic devices would not occur in designated 

critical habitat for the green sea turtle (Culebra Island), hawksbill sea turtle (Mona Island and Monita 

Island), leatherback sea turtle (St. Croix Island), or American crocodile (Florida Bay). Navy training 

activities that expend in-water electromagnetic devices would not occur within the southeast portion of 

loggerhead critical habitat that is designated as breeding areas, but would occur in the following 

loggerhead sea turtle critical habitat year round: nearshore reproductive habitat, winter areas, 

migration corridors, and Sargassum habitat. See Section 3.8.2.2.4.1 (Status and Management) for a 

description of these habitat types and supporting physical and biological factors. In-water 

electromagnetic device use has no pathway to impact the physical and biological features identified for 

these habitats (National Marine Fisheries Service, 2014b) due to the relatively weak strength of the 

electromagnetic fields created by these activities, the localized area potentially impacted by the 

electromagnetic fields, and the temporary duration of these activities.

Pursuant to the ESA, the use of electromagnetic devices during training activities under Alternative 2

may affect ESA-listed green, hawksbill, Kemp’s ridley, leatherback, and loggerhead sea turtles; and 

would have no effect on the ESA-listed American crocodile. There would be no effect on green, 
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hawksbill, leatherback, or loggerhead sea turtle critical habitat; and there would be no effect on 

American crocodile critical habitat.

Impacts from In-Water Electromagnetic Devices under Alternative 2 for Testing Activities

As discussed in Section 3.0.3.3.3.1 (In-Water Electromagnetic Devices) the locations, numbers of testing 

activities, and potential effects associated with in-water electromagnetic device use would be the same 

under Alternatives 1 and 2. Refer to Section 3.8.3.3.1.1 (Impacts from In-Water Electromagnetic Devices 

under Alternative 1) for a discussion of impacts on sea turtles and terrapins.

Proposed testing activities that use in-water electromagnetic devices would not occur in designated 

critical habitat for the green sea turtle (Culebra Island), hawksbill sea turtle (Mona Island and Monita 

Island), leatherback sea turtle (St. Croix Island), or American crocodile (Florida Bay). Navy testing 

activities that expend in-water electromagnetic devices would not occur within the southeast portion of 

loggerhead critical habitat that is designated as breeding areas, but would occur in the following 

loggerhead sea turtle critical habitat year round: nearshore reproductive habitat, winter areas, 

migration corridors, and Sargassum habitat. See Section 3.8.2.2.4.1 (Status and Management) for a 

description of these habitat types and supporting physical and biological factors. In-water 

electromagnetic device use has no pathway to impact the physical and biological features identified for 

these habitats (National Marine Fisheries Service, 2014b) due to the relatively weak strength of the 

electromagnetic fields created by these activities, the localized area potentially impacted by the 

electromagnetic fields, and the temporary duration of these activities.

Pursuant to the ESA, the use of electromagnetic devices during testing activities under Alternative 2 may 

affect ESA-listed green, hawksbill, Kemp’s ridley, leatherback, and loggerhead sea turtles; and would 

have no effect on the ESA-listed American crocodile. There would be no effect on green, hawksbill,

leatherback, or loggerhead sea turtle critical habitat; and there would be no effect on American 

crocodile critical habitat.

3.8.3.3.1.3 Impacts from In-Water Electromagnetic Devices under the No Action 

Alternative

Impacts from In-Water Electromagnetic Devices under the No Action Alternative for Training and 

Testing Activities

Under the No Action Alternative, the Navy would not conduct the proposed training and testing 

activities in the AFTT Study Area. Various energy stressors (e.g., in-water electromagnetic devices) would 

not be introduced into the marine environment. Therefore, baseline conditions of the existing 

environment would either remain unchanged or would improve slightly after cessation of ongoing 

training and testing activities.

3.8.3.3.2 Impacts from In-Air Electromagnetic Devices

The use of in-air electromagnetic devices associated with Navy training and testing activities is not 

applicable to reptiles because in-air electromagnetic energy does not penetrate the ocean, nor will use 

of these devices be close enough in proximity to sea turtle nesting locations to have an effect on these 

animals. As a result, in-air electromagnetic devices will not be analyzed further in this section.

3.8.3.3.3 Impacts from High-Energy Lasers

As discussed in Section 3.0.3.3.3.3 (Lasers), high-energy laser weapons training and testing involves the 

use of up to 30 kilowatts of directed energy as a weapon against small surface vessels and airborne 
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targets. These weapons systems are deployed from surface ships and helicopter to create small but 

critical failures in potential targets and used at short ranges from the target.

This section analyzes the potential impacts of high-energy lasers on sea turtles. As discussed in 

Section 3.0.3.3.3.3 (Lasers), high-energy laser weapons are designed to disable surface targets, 

rendering them immobile. High-energy lasers would only be used in open ocean areas for training and 

testing activities; therefore, crocodilian and terrapin species are not included in the analysis for potential 

impacts from high-energy lasers because they would not be located in areas where high-energy lasers 

would be used.

The primary concern for high-energy weapons training and testing is the potential for a sea turtle to be 

struck by a high-energy laser beam at or near the water's surface, which could result in injury or death, 

resulting from traumatic burns from the beam. 

Sea turtles could be exposed to a laser only if the beam missed the target. Should the laser strike the sea 

surface, individual sea turtles at or near the surface could be exposed. The potential for exposure to a 

high energy laser beam decreases as the water depth increases. Because laser platforms are typically 

helicopters and ships, sea turtles at sea would likely transit away or submerge in response to other 

stressors, such as ship or aircraft noise, although some sea turtles would not exhibit a response to an 

oncoming vessel or aircraft, increasing the risk of contact with the laser beam.

3.8.3.3.3.1 Impacts from High-Energy Lasers under Alternative 1

Impacts from High-Energy Lasers under Alternative 1 for Training Activities

As discussed in Section 3.0.3.3.3.3 (Lasers), high-energy laser use associated with training activities 

would occur within the Virginia Capes and Jacksonville Range Complexes. For safety reasons, high 

energy lasers would not be used in nearshore or inshore training locations. Navy training activities have 

the potential to expose sea turtles that occur within these areas to this energy stressor.

Appendix F (Military Expended Materials and Direct Strike Impact Analyses) includes a conservative 

probability estimate for a direct laser strike on a sea turtle during training activities. The analysis is 

over-predictive and conservative in that it assumes: (1) that all sea turtles would be at or near the 

surface 100 percent of the time, and would not account for the duration of time a sea turtle would be 

diving; and (2) that sea turtles are stationary, which does not account for any movement or any 

potential avoidance of the training or testing activity in response to other stressors (e.g., vessel noise). 

Loggerhead sea turtles have the highest seasonal density within these areas where high-energy lasers 

would be used; therefore, for the sake of conservatively estimating the potential for direct strike of sea 

turtles by a high-energy laser, loggerheads are used as a proxy in the modeling for estimating impacts on 

all sea turtle species within the AFTT Study Area. As shown in Appendix F (Military Expended Materials

and Direct Strike Impact Analyses) the probability for a direct strike on a sea turtle is extremely low. The 

modeling results show that 0.000008 loggerhead sea turtles would be exposed to a high-energy laser 

strike. Based on the assumptions used in the statistical probability analysis, there is a high level of 

certainty in the conclusion that no sea turtles of any species that occur in the Study Area would be 

struck by a high-energy laser. Potential impacts of exposure to high-energy lasers are not expected to 

result in substantial changes in an individual’s behavior, growth, survival, annual reproductive success, 

lifetime reproductive success (fitness), or species recruitment, and are not expected to result in 

population-level sea turtles.
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Proposed training activities that use high-energy lasers would not occur in designated critical habitat for 

the green sea turtle (Culebra Island), hawksbill sea turtle (Mona Island and Monita Island), leatherback 

sea turtle (St. Croix Island), or American crocodile (Florida Bay). Navy training activities that use highenergy lasers would not occur within the southeast portion of loggerhead critical habitat that is 

designated as breeding areas or nearshore reproductive habitats, but would occur in the following 

loggerhead turtle critical habitat year round: winter areas, migration corridors, and Sargassum habitat.

See Section 3.8.2.2.4.1 (Status and Management) for a description of these habitat types and supporting 

physical and biological factors. High-energy laser use has no pathway to impact the physical and 

biological features identified for these habitats (National Marine Fisheries Service, 2014b) due to the 

directed energy of the laser, the dissipation of energy as water depth increases, and the temporary 

duration of the activities. (National Marine Fisheries Service, 2014b)

Pursuant to the ESA, the use of high-energy lasers during training activities under Alternative 1 may 

affect ESA-listed green, hawksbill, Kemp’s ridley, leatherback, and loggerhead sea turtles; and will have 

no effect on the ESA-listed American crocodile. There would be no effect on green, hawksbill,

leatherback, or loggerhead sea turtle critical habitat; and no effect on American crocodile critical 

habitat. The Navy has consulted with the NMFS as required by section 7(a)(2) of the ESA in that regard.

Impacts from High-Energy Lasers under Alternative 1 for Testing Activities

As discussed in Section 3.0.3.3.3.3 (Lasers), high-energy laser tests would occur within the Northeast, 

Virginia Capes, Navy Cherry Point, Jacksonville, Gulf of Mexico, and Key West Range Complexes. 

High-energy laser testing activities would also be conducted within the Naval Undersea Warfare Center, 

Newport Testing Range, South Florida Ocean Measurement Facility, and the Naval Surface Warfare

Center Panama City Testing Range. Navy testing activities have the potential to expose sea turtles that 

occur within these locations to this energy stressor. The sea turtle species with the highest average 

seasonal density (loggerhead sea turtle) in the location with the greatest number of testing activities 

involving high-energy lasers under Alternative 1 (Virginia Capes Range Complex) was used in the 

probability analysis.

Appendix F (Military Expended Materials and Direct Strike Impact Analyses) includes a conservative 

probability estimate for a direct laser strike on a sea turtle during testing activities. Using the same 

methods and assumptions described above, the modeling results show that 0.000136 loggerhead sea 

turtles would be exposed to a high-energy laser strike. Based on the assumptions used in the statistical 

probability analysis, there is a high level of certainty in the conclusion that no sea turtle of any species 

that occur in the Study Area would be struck by a high-energy laser.

Proposed testing activities that use high-energy lasers would not occur in designated critical habitat for 

the green sea turtle (Culebra Island), hawksbill sea turtle (Mona Island and Monita Island), leatherback 

sea turtle (St. Croix Island), or American crocodile (Florida Bay). Navy testing activities that use highenergy lasers would not occur within nearshore reproductive habitats, but would occur in the following 

loggerhead turtle critical habitat year round: breeding areas, winter areas, migration corridors, and 

Sargassum habitat. See Section 3.8.2.2.4.1 (Status and Management) for a description of these habitat 

types and supporting physical and biological factors. High-energy laser use has no pathway to impact the 

physical and biological features identified for these habitats (National Marine Fisheries Service, 2014b)

due to the directed energy of the laser, the dissipation of energy as water depth increases, and the 

temporary duration of the activities.(National Marine Fisheries Service, 2014b)
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Pursuant to the ESA, the use of high-energy lasers during testing activities under Alternative 1 may 

affect ESA-listed green, hawksbill, Kemp’s ridley, leatherback, and loggerhead sea turtles; and will have 

no effect on the ESA-listed American crocodile. There would be no effect on green, hawksbill,

leatherback, or loggerhead sea turtle critical habitat; and no effect on American crocodile critical 

habitat. The Navy has consulted with NMFS as required by section 7(a)(2) of the ESA in that regard.

3.8.3.3.3.2 Impacts from High-Energy Lasers under Alternative 2

Impacts from High-Energy Lasers under Alternative 2 for Training Activities

The locations, number of events, and potential effects associated with high-energy lasers would be the 

same under Alternatives 1 and 2. Refer to Section 3.8.3.3.3.1 (Impacts from High-Energy Lasers under

Alternative 1) for a discussion of impacts on sea turtles. 

Proposed training activities that use high-energy lasers would not occur in designated critical habitat for 

the green sea turtle (Culebra Island), hawksbill sea turtle (Mona Island and Monita Island), leatherback 

sea turtle (St. Croix Island), or American crocodile (Florida Bay). Navy training activities that use highenergy lasers would not occur within the southeast portion of loggerhead critical habitat that is 

designated as breeding areas or nearshore reproductive habitats, but would occur in the following 

loggerhead turtle critical habitat year round: winter areas, migration corridors, and Sargassum habitat.

See Section 3.8.2.2.4.1 (Status and Management) for a description of these habitat types and supporting 

physical and biological factors. High-energy laser use has no pathway to impact the physical and 

biological features identified for these habitats (National Marine Fisheries Service, 2014b) due to the 

directed energy of the laser, the dissipation of energy as water depth increases, and the temporary 

duration of the activities.(National Marine Fisheries Service, 2014b)

Pursuant to the ESA, the use of high-energy lasers during training activities under Alternative 2 may 

affect ESA-listed green, hawksbill, Kemp’s ridley, leatherback, and loggerhead sea turtles; and will have 

no effect on the ESA-listed American crocodile. There would be no effect on green, hawksbill,

leatherback, or loggerhead sea turtle critical habitat; and no effect on American crocodile critical 

habitat.

Impacts from High-Energy Lasers under Alternative 2 for Testing Activities

The locations, number of events, and potential effects associated with high-energy laser use would be 

the same under Alternatives 1 and 2. Refer to Section 3.8.3.3.3.1 (Impacts from High-Energy Lasers 

under Alternative 1) for a discussion of impacts on sea turtles. 

Proposed testing activities that use high-energy lasers would not occur in designated critical habitat for 

the green sea turtle (Culebra Island), hawksbill sea turtle (Mona Island and Monita Island), leatherback 

sea turtle (St. Croix Island), or American crocodile (Florida Bay). Navy testing activities that use highenergy lasers would not occur within nearshore reproductive habitats, but would occur in the following 

loggerhead turtle critical habitat year round: breeding areas, winter areas, migration corridors, and 

Sargassum habitat. See Section 3.8.2.2.4.1 (Status and Management) for a description of these habitat 

types and supporting physical and biological factors. High-energy laser use has no pathway to impact the 

physical and biological features identified for these habitats (National Marine Fisheries Service, 2014b)

due to the directed energy of the laser, the dissipation of energy as water depth increases, and the 

temporary duration of the activities.(National Marine Fisheries Service, 2014b)
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Pursuant to the ESA, the use of high-energy lasers during testing activities under Alternative 2 may 

affect ESA-listed green, hawksbill, Kemp’s ridley, leatherback, and loggerhead sea turtles; and will have 

no effect on the ESA-listed American crocodile. There would be no effect on green, hawksbill,

leatherback, or loggerhead sea turtle critical habitat; and no effect on American crocodile critical 

habitat.

3.8.3.3.3.3 Impacts from High-Energy Lasers under the No Action Alternative

Impacts from High-Energy Lasers under the No Action Alternative for Training and Testing 

Activities

Under the No Action Alternative, the Navy would not conduct the proposed training or testing activities 

in the AFTT Study Area. Various energy stressors (e.g., high-energy lasers) would not be introduced into 

the marine environment. Therefore, baseline conditions of the existing environment would either 

remain unchanged or would improve slightly after cessation of ongoing training and testing activities.

3.8.3.4 Physical Disturbance and Strike Stressors

This section analyzes the potential impacts of the various types of physical disturbance and strike 

stressors used by Navy during training and testing activities within the Study Area. The physical 

disturbance and strike stressors that may impact reptiles and include: (1) Navy vessels and in-water 

devices; (2) military expended materials, including non-explosive practice munitions and fragments from 

high-explosive munitions; and (3) seafloor devices. General discussion of impacts can also be found in 

Section 3.0.3.6.3 (Conceptual Framework for Assessing Effects from Physical Disturbance or Strike).

The way a physical disturbance may affect a reptile would depend in part on the relative size of the 

object, the speed of the object, the location of the reptile in the water column, and the behavioral 

reaction of the sea turtle. It is not known at what point or through what combination of stimuli (visual, 

acoustic, or through detection in pressure changes) a reptile becomes aware of a vessel or other 

potential physical disturbances prior to reacting or being struck. 

Like marine mammals, if a reptile reacts to physical disturbance, the individual must stop its activity and 

divert its attention in response to the stressor. The energetic costs of reacting to a stressor will depend 

on the specific situation, but one can assume that the caloric requirements of a response may reduce 

the amount of energy available for other biological functions.

For sea turtles who have resident home ranges near Navy activities, the relative concentration of Navy 

vessels would cause sea turtles to respond repeatedly to the exposure. This repeated response would 

interrupt normal daily routines (e.g., foraging activities) more often than resident near-shore turtles not 

near Navy installations or in open ocean areas where Navy vessel traffic is less concentrated, though 

animals may become habituated to repeated stimuli. If a strike does occur, the cost to the individual 

could range from slight injury to death.

Diamondback terrapins may be exposed to potential physical disturbance and strike hazards in all 

inshore training and testing locations. American alligators may be exposed in all inshore training and 

testing locations along the Atlantic coast from North Carolina to Florida, and along the Gulf coast from 

Florida to Texas. As with sea turtles, impacts of any potential strike of alligators or terrapins could range 

from slight injury to death. American crocodiles are not included in the analysis for physical disturbance 

and strike stressors because of the very low likelihood of a strike. Navy vessel presence would be 

unlikely in American crocodile habitat, which consists of shallow nearshore habitat in southern Florida; 

however, it is possible that American crocodiles could be occasionally exposed to Navy vessel noise, 
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mostly from smaller support vessels (see Section 3.8.3.1.5, Impacts from Vessel Noise, for an analysis of 

acoustic stressor responses by crocodilians). Therefore, American crocodiles are not analyzed for 

potential impacts from physical disturbance and strike stressors. 

3.8.3.4.1 Impacts from Vessels and In-Water Devices

Vessels

The majority of the training and testing activities under all alternatives involve some level of vessel 

activity. For a discussion on the types of activities that use vessels see Appendix B (Activity Stressor 

Matrices). Section 3.0.3.3.4.1 (Vessels and In-Water Devices) Table 3.0-17 provides a list of 

representative vessels used in training and testing activities, along with vessel lengths and speeds used 

in training and testing activities. 

Within the AFTT Study Area, commercial traffic is heaviest in the nearshore waters, near major ports 

and in the shipping lanes along the entire United States East Coast and along the northern coast of the 

Gulf of Mexico while Navy vessel traffic is primarily concentrated between the mouth of the Chesapeake 

Bay, Virginia and Jacksonville, Florida (Mintz, 2012). An examination of vessel traffic within the AFTT 

Study Area determined that Navy vessel occurrence is two orders of magnitude lower than that of 

commercial traffic. The study also revealed that, while commercial traffic is relatively steady throughout 

the year, Navy vessel usage within the range complexes is episodic, based on specific exercises being 

conducted at different times of the year (Mintz, 2012); however, Navy vessel use within inshore waters

occurs regularly and primarily consists of high-speed small vessel movements. These high-speed vessel 

movements in near shore and inshore waters present a relatively higher risk for strike (Hazel et al., 

2007) because of the higher concentrations of sea turtles in these areas and the difficulty for vessel 

operators to avoid collisions in high-speed activities. 

Strikes of sea turtles, American alligators, and diamondback terrapin could cause permanent injury or 

death from bleeding or other trauma, paralysis and subsequent drowning, infection, or inability to feed. 

Apart from the severity of the physical strike, the likelihood and rate of recovery from a strike may be 

influenced by the animal’s age, reproductive state, and general condition. Much of what is written about 

recovery from vessel strikes is inferred from observing individuals some time after a strike. 

Numerous sea turtles bear scars that appear to have been caused by propeller cuts or collisions with 

vessel hulls (Hazel et al., 2007; Lutcavage et al., 1997). Fresh wounds on some stranded animals may 

strongly suggest a vessel strike as the cause of death. The actual incidence of recovery versus death is 

not known, given available data. Any sea turtle species found in the Study Area can occur at or near the 

surface in open ocean and coastal areas, whether feeding or periodically surfacing to breathe.

Sea turtles spend a majority of their time submerged (Renaud & Carpenter, 1994; Sasso & Witzell, 

2006), though Hazel et al. (2009) and Hazel et al. (2007) showed turtles staying within the top 3 m of 

water despite deeper water being available. Loggerhead turtles are the most abundant sea turtles found 

in the nearshore environment of the Study Area. Loggerheads, considered to be the most generalist of 

sea turtle species in terms of feeding and foraging behavior, apparently exhibit varied dive behavior that 

is linked to the quantity and quality of available resources. Leatherback turtles are more likely to feed at 

or near the surface in open ocean areas. It is important to note that leatherbacks can forage for jellyfish 

at depth but bring them to the surface to ingest (Benson et al., 2007; Fossette et al., 2007; James & 

Herman, 2001). Basking on the water’s surface is common for all species within the Study Area as a 

strategy to thermoregulate, and the reduced activity associated with basking may pose higher risks for 

sea turtle strikes because of a likely reduced capacity to avoid cues. Green, hawksbill, loggerhead, and 
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Kemp’s ridley sea turtles are more likely to forage nearshore, and although they may feed along the 

seafloor, they surface periodically to breathe while feeding and moving between near-shore habitats.

Kemp’s ridleys can spend extended periods foraging at depth, even in open ocean areas (Sasso & 

Witzell, 2006; Seney, 2016; Servis et al., 2015). 

Smaller, faster vessels that operate in nearshore waters, where green, Kemp’s ridley, loggerhead sea 

turtles can be more densely concentrated, pose a greater risk (Chaloupka et al., 2008). For example, sea 

turtle occurrence (e.g., Kemp’s ridleys and loggerheads) increases in nearshore areas within Chesapeake 

Bay from late spring to early fall, most likely due to foraging (Barco & Lockhart, 2015). Other studies 

have shown that the potential for vessel strike increases in areas important for foraging sea turtles 

(Denkinger et al., 2013). 

Vessels transiting in shallow waters to and from ports travel at slower speed and pose less risk of strikes 

to sea turtles (Hazel et al., 2007; Lutcavage et al., 1997). It should be noted that no known instances of 

vessel strikes to sea turtles by a Navy vessel have been reported for the Study Area.

The American alligator and diamondback terrapin are also subject to potential vessel strikes in inshore 

waters. The diamondback terrapin may be exposed to potential strike within all inshore training and 

testing locations, while the American alligator would be exposed to potential strike in inshore training 

and testing locations along the Atlantic coast from North Carolina to Florida, and along the Gulf Coast 

from Florida to Texas. 

American alligators may exhibit avoidance behaviors in relatively open waters in the presence of 

recreational boating traffic. Lewis et al. (2014) observed that alligators avoided open waters of the Fort 

Worth Nature Center and Refuge located on the Trinity River in Texas, at least in part due to the 

presence of recreational boaters. Based off of field observations, Lewis et al. (2014) noted that both 

motorized and non-motorized boats commonly approached alligators, which may have resulted in 

alligators avoiding the open water where detection by boaters would have been more likely. Grant and 

Lewis (2010) noted in a study on spectacled caiman (Caiman crocodilus) in the Tortuguero region of 

Costa Rica found that increasing boat traffic associated with ecotourism, recreation, and local human 

population growth increased the likelihood of boat-collision–related injuries. Spectacled caiman were 

also frequently observed avoiding boats (Grant & Lewis, 2010). Grant and Lewis (2010) also noted that 

collisions with boats were more likely to occur in relatively more narrow channels where crocodilians 

had less maneuverable space within the channel to avoid the boat, as substantiated by observations of 

American crocodile scars on tails. With American alligator population increases in recent years 

(Savannah River Ecology Laboratory & Herpetology Program, 2012) and expansion into many parts of 

their historical range (Smith et al., 2016), incidents of collisions with boats will likely increase. However, 

alligators likely exhibit avoidance behaviors both in the presence of vessels and avoid areas with high 

amounts of recreational boat traffic. 

Hearing sensitivities of terrapins have been shown to overlap with boat engine sounds. However, the 

lack of observed behavioral responses to approaching vessels can present strike risk to terrapins, 

particularly in high-density, small vessel recreation areas (Lester et al., 2012; Lester, 2013). Therefore, 

terrapins may be at relatively higher risk to potential strike compared to crocodilians where vessel traffic 

occurs, not because of an inability to hear approaching vessels, but because terrapins do not exhibit 

avoidance behaviors.
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In-Water Devices

In-water devices are generally smaller (several inches to 111 ft.) than most Navy vessels. Devices that 

could pose a collision risk to reptiles are those operated at high speeds and are unmanned. For a 

discussion on the types of activities that use in-water devices see Appendix B (Activity Stressor 

Matrices), and for information on where in-water devices are used, and how many activities would 

occur under each alternative, see Section 3.0.3.3.4.1 (Vessels and In-Water Devices).

The Navy reviewed torpedo design features and a large number of previous anti-submarine warfare 

torpedo exercises to assess the potential of torpedo strikes on marine mammals, and its conclusions are 

also relevant to reptiles. The acoustic homing programs of Navy torpedoes are sophisticated and would 

not confuse the acoustic signature of a marine mammal with a submarine/target. It is reasonable to 

assume that acoustic signatures of sea turtles would also not be confused with a submarine or target. All 

exercise torpedoes are recovered and refurbished for eventual re-use. Review of the exercise torpedo 

records indicates there has never been an impact on a sea turtle or other reptile. In thousands of 

exercises in which torpedoes were fired or in-water devices used, there have been no recorded or 

reported instances of a marine species strike from a torpedo or any other in-water device. 

Since some in-water devices are identical to support craft (typically less than 15 m in length), reptiles

could respond to the physical presence of the device similar to how they respond to the physical 

presence of a vessel. Physical disturbance from the use of in-water devices is not expected to result in 

more than a momentary behavioral response. These responses would likely include avoidance behaviors 

(swimming away or diving) and cessation of normal activities (e.g., foraging). As with an approaching 

vessel, not all sea turtles would exhibit avoidance behaviors and therefore would be at higher risk of a 

strike.

In-water devices, such as unmanned underwater vehicles, that move slowly through the water are 

highly unlikely to strike reptiles because the animal could easily avoid the object. Towed devices are 

unlikely to strike a sea turtle because of the observers on the towing platform and other standard safety 

measures employed when towing in-water devices. Reptiles that occur in areas that overlap with 

in-water device use within the Study Area may encounter in-water devices. It is possible that reptiles

may be disturbed by the presence of these activities, but any disturbance from the use of in-water 

devices is not expected to result in more than a temporary behavioral response.

3.8.3.4.1.1 Impacts from Vessels and In-Water Devices under Alternative 1

Section 3.0.3.3.4.1 (Vessels and In-Water Devices) provides estimates of relative vessel and in-water 

device use and location throughout the Study Area. Under Alternative 1 the concentration of vessel and 

in-water device use and the manner in which the Navy trains and tests would remain consistent with the 

levels and types of activity undertaken in the AFTT Study Area over the last decade. Consequently, the 

Navy does not foresee any appreciable changes in the levels, frequency, or locations where vessels have 

been used over the last decade, and therefore the level at which physical disturbance and strikes are 

expected to occur is likely to remain consistent with the previous decade.

Impacts from Vessels and In-Water Devices under Alternative 1 for Training Activities

As indicated in Section 3.0.3.3.4.1 (Vessels and In-Water Devices), most training activities involve large 

vessel movement. The potential for vessel strikes to reptiles are not associated with any specific training 

activity but rather a limited, sporadic, and accidental result of Navy ship movement within the Study 

Area, occurring in both offshore and inshore water areas. Vessel movement can be widely dispersed 
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throughout the AFTT Study Area but for the most part occurs within the established range complexes 

and is more concentrated near naval ports, piers, and range areas. Training activities that include vessel 

movements in the offshore waters of the Study Area would primarily be conducted within the Virginia 

Capes, Navy Cherry Point, and Jacksonville Range Complexes, but would also be conducted within the 

Northeast, Key West, and Gulf of Mexico Range Complexes, as well as other offshore AFTT areas. 

Offshore vessel movements would be widely dispersed throughout the Study Area, but are more 

concentrated near ports, naval installations, range complexes and testing ranges. Large vessel 

movement primarily occurs within the U.S. Exclusive Economic Zone, with the majority of the traffic 

flowing between Naval Stations Norfolk and Mayport (see Table 3.0-18).

Vessel movements associated with training activities within inshore waters would occur within or near 

Boston, Massachusetts; Groton, Connecticut; Narragansett, Rhode Island; Earle, New Jersey; Delaware 

Bay, Delaware; James River and tributaries, Virginia; York River, Virginia; the Lower Chesapeake Bay, 

Virginia; Hampton Roads, Virginia; Norfolk, Virginia; Morehead City, North Carolina; Wilmington, North 

Carolina; Cooper River, South Carolina; Savannah, Georgia; Kings Bay, Georgia; Mayport, Florida; St. 

Johns River, Florida; Port Canaveral, Florida; Tampa, Florida; St. Andrew Bay, Florida; Beaumont, Texas, 

and Corpus Christi, Texas. In addition, high-speed small vessel movements would be conducted within 

inshore waters including and surrounding Narragansett Bay, Rhode Island; James River and tributaries, 

Virginia; York River, Virginia; the Lower Chesapeake Bay; Coopers River, South Carolina; Mayport, 

Florida; St. Johns River, Florida; Port Canaveral, Florida; and St. Andrew Bay, Florida (see Table 3.0-18

through Table 3.0-20).

As discussed in Section 3.0.3.3.4.1 (Vessels and In-Water Devices), in-water devices include unmanned 

surface vehicles, unmanned underwater vehicles, and towed devices. Under Alternative 1, offshore

training activities involving the use of in-water devices would be conducted within the Northeast, 

Virginia Capes, Navy Cherry Point, Jacksonville, Key West, and Gulf of Mexico Range Complexes, the 

Naval Surface Warfare Center Panama City Testing Range, and other offshore AFTT areas. Training 

activities that use in-water devices would also occur within inshore waters including and surrounding 

Boston, Massachusetts; Earle, New Jersey; Delaware Bay, Delaware; Hampton Roads, Virginia; the Lower 

Chesapeake Bay, Virginia; James River and tributaries, Virginia; York River, Virginia; Morehead City, 

North Carolina; Wilmington, North Carolina; Savannah, Georgia; Kings Bay, Georgia; Mayport, Florida; 

Port Canaveral, Florida; Tampa, Florida; St. Andrew Bay, Florida; Beaumont, Texas; and Corpus Christi, 

Texas.

Under Alternative 1 training activities, sea turtles may be exposed to strike risk in all inshore and 

offshore areas where vessels and in-water devices would operate. American alligators may be exposed 

to vessel strike at Morehead City, North Carolina; Cooper River, South Carolina; Savannah, Georgia; 

Kings Bay, Georgia; Mayport, Florida; St. Johns River, Florida; Port Canaveral, Florida; Tampa, Florida; St. 

Andrew Bay, Florida; Beaumont, Texas, and Corpus Christi, Texas. Diamondback terrapins may be 

exposed to strike at all inshore training locations.

Under Alternative 1, sea turtle, alligator, and terrapin strikes would most likely occur where there is a 

co-location of these reptile species, especially in high densities, and with high-speed vessel and in-water 

device training activities. Over the continental shelf, sea turtles are at risk of strikes because of greater 

densities of sea turtles and more frequent vessel movements relative to the open ocean. Therefore, sea 

turtle species that occur over the continental shelf and in inshore waters (e.g., estuaries), would 

therefore have a greater potential for impacts. This suggests that loggerhead sea turtles are likely the 

most at risk of vessel interactions and in-water devices under Alternative 1 in the open ocean, as well as 
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within inshore waters where small and fast vessels conduct activities because this species is the most 

abundant in the Range Complexes and inshore waters (e.g., Lower Chesapeake Bay) that have the 

highest concentration of training activities involving vessel movement. There is not expected to be any 

predictable seasonal difference in Navy vessel use; therefore, impacts from vessels and in-water devices, 

including physical disturbance and potential for strike, would depend on each species’ seasonal patterns 

of occurrence or degree of residency in the continental shelf and inshore waters portions of the AFTT 

Study Area. As previously indicated, any physical disturbance from vessel transit and use of in-water 

devices is not expected to result in more than a momentary behavioral response; however, an actual 

strike of a reptile would likely result in permanent injury, temporary injury that weakens a sea turtle’s 

resilience to other natural and human-induced stressors, death. In-water devices have a very limited 

potential to strike a sea turtle, alligator, or terrapin because they either move slowly through the water 

column (e.g., most unmanned underwater vehicles) or are closely monitored by observers manning the 

towing platform (e.g., most towed devices).

Although the likelihood is low, a harmful interaction with a vessel or in-water device in the open ocean

cannot be discounted. In addition, more frequent vessel movements would occur in nearshore and 

inshore waters where sea turtles may congregate. Sea turtles often congregate close to shorelines 

during the breeding season, where vessel traffic is denser (Schofield et al., 2010). Activities within these 

areas present a higher likelihood of vessel strike of a sea turtle. Any of the sea turtle species found in the 

Study Area can occur at or near the surface in open-ocean and coastal areas or inshore waters, whether 

feeding, periodically surfacing to breathe, or basking (a behavior more common in cooler water and 

seasons). Leatherback turtles are more likely to feed at or near the surface in open ocean areas. Green, 

hawksbill, Kemp’s ridley, and loggerhead turtles are more likely to forage nearshore, and although they 

may feed along the seafloor, they surface periodically to breathe while feeding and moving between 

nearshore habitats. These species, except for Hawksbill turtles, are distributed widely in all offshore

portions of the Study Area.

The leatherback turtle is likely to be impacted by these activities, given its preference for open-ocean 

habitats and its feeding behavior (feed at the surface and throughout the water column) and prey (e.g., 

jellyfish). Hatchlings and pre-recruitment juveniles of all sea turtle species may also occur in open-ocean 

habitats, where they reside among Sargassum mats. Sea turtles are expected to be highly dispersed in 

deeper offshore waters and given the large area over which Navy vessels could potentially conduct 

training activities, the likelihood of co-occurrence is low, as well as the potential consequences.

Training activities that include vessel movements in the inshore waters of the Study Area occur on a 

more regular basis than the offshore activities, and often involve the vessels traveling at speeds greater 

than 10 knots (see Section 3.0.3.3.4.1, Vessels and In-Water Devices). Generally these inshore water 

activities are conducted in more confined waterways than activities occurring in the offshore waters, 

limiting maneuverability of the vessel, especially when trying to avoid a potential collision with a reptile. 

High-speed vessel movements further increase the potential risk of vessel strikes by reducing the 

available reaction time of both the animal and vessel operator to an impending strike. Hazel et al. (2007)

noted in one study that green sea turtles did not have time to react to vessels moving at speeds of about 

10 knots, but reacted frequently to vessels at speeds of about two knots. Detection, therefore, was 

suggested to be based on the turtle’s ability to see rather than hear an oncoming vessel. Boat strike has 

been identified as one of the important mortality factors in several nearshore sea turtle habitats 

worldwide. Precise data are lacking for sea turtle mortalities directly caused by vessel strikes; however, 

live and dead turtles are often found with injuries indicative of collision with a vessel hull or propeller 
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(Hazel et al., 2007; Lutcavage et al., 1997). For example, Barco et al. (2016) found that out of the 60 

fresh, dead loggerhead turtles that were examined from 2004 to 2013 in Virginia, 15 (25 percent) 

showed signs of vessel interactions. Scientists in Hawaii reported that 2.5 percent of green turtles found 

dead on the beaches between 1982 and 2003 had been killed by vessel strike (Chaloupka et al., 2008). 

Given the high amount of high-speed vessel movement hours, the inshore water locations of where 

these activities would occur (Table 3.0-20), and species’ distribution throughout the Study Area, cooccurrence with individuals of loggerhead, green, Kemp’s ridley, and leatherback turtles are very likely, 

especially in the Lower Chesapeake Bay, Virginia.

Any collision with a sea turtle would result in injury, and possible mortality, of an individual sea turtle. 

Under Alternative 1 training activities, the Navy will continue to implement procedural mitigation to 

avoid or reduce the potential for vessel and in-water device strike of sea turtles (see Section 5.3.4.1, 

Vessel Movement, and Section 5.3.4.2, Towed In-Water Devices). Within a mitigation zone of a vessel or 

in-water device, trained observers will relay sea turtle locations to the operators, who are required to 

change course (no course change would be implemented if the vessel’s safety is threatened, the vessel 

is restricted in its ability to maneuver (e.g., during launching and recovery of aircraft or landing craft, 

during towing activities, when mooring, etc.), or if the in-water device is operated autonomously. A 

mitigation zone size is not specified for sea turtles to allow flexibility based on vessel type and mission 

requirements (e.g., small boats operating in a narrow harbor).

Potential impacts of exposure to vessels may result in substantial changes in an individual’s behavior, 

growth, survival, annual reproductive success, lifetime reproductive success (fitness), or species 

recruitment. Given the number of high-speed vessel hours in the inshore water locations, and the 

density of sea turtles in the area, the possibility of a strike to an individual of any species cannot be 

discounted. Any strike at high speed is likely to result in significant injury. Potential impacts of exposure 

to vessels are not expected to result in population-level impacts for all sea turtle species.

Strike potential in inshore training locations for American alligators under Alternative 1 training activities 

would likely range from minor survivable injuries to death of individual alligators. Based on avoidance

behaviors, as shown in open water locations with motorized and non-motorized boat traffic, strike 

potential is likely reduced. Potential impacts of exposure to vessels and in-water devices may result in 

substantial changes in an individual’s behavior, growth, survival, annual reproductive success, lifetime 

reproductive success (fitness), or species recruitment. Given the number of high-speed vessel hours in 

the inshore water locations, and the density of alligators in training locations, the possibility of a strike 

to an individual alligator cannot be discounted. Any strike at high speed is likely to result in significant 

injury. Potential impacts of exposure to vessels are not expected to result in population-level impacts for 

American alligators.

Strike potential in inshore training locations for the diamondback terrapin under Alternative 1 training 

activities would likely range from major injuries (because of the relatively small body mass and body 

type of terrapins) and death. Boat strikes are a significant concern in terrapin conservation efforts 

(Lester et al., 2012; Lester, 2013). Potential impacts of exposure to vessels and in-water devices may 

result in substantial changes in an individual terrapin’s behavior, growth, survival, annual reproductive 

success, lifetime reproductive success (fitness), or species recruitment. Given the number of high-speed 

vessel hours in the inshore water locations, and the density of terrapins in training locations, the 

possibility of a strike to an individual terrapin cannot be discounted. Any strike at high speed is likely to 

result in significant injury. Potential impacts of exposure to vessels are not expected to result in 

population-level impacts for diamondback terrapins.
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Proposed training activities under Alternative 1 that use vessels and in-water devices would not occur in 

designated critical habitat for the green sea turtle (Culebra Island), hawksbill sea turtle (Mona Island and 

Monita Island), leatherback sea turtle (St. Croix Island), or American crocodile (Florida Bay). Navy 

training activities that use vessels and in-water devices would occur year round within the five critical 

habitat types for the loggerhead turtle. See Section 3.8.2.2.4.1 (Status and Management) for a 

description of these habitat types and supporting physical and biological factors. Vessels have no 

pathway to impact the physical and biological features identified for these habitats (National Marine 

Fisheries Service, 2014b). For example, training activities that use vessels and in-water devices will not 

impact the prey species found in Sargassum habitat or the nearshore habitat conditions that are 

essential for nearshore reproductive habitat.

Pursuant to the ESA, the use of vessels and in-water devices during training activities under Alternative 1 

may affect ESA-listed green, hawksbill, Kemp’s ridley, leatherback, and loggerhead sea turtles; and 

would have no effect on the American crocodile. There would be no effect on green, hawksbill, 

leatherback, or loggerhead sea turtle critical habitat; and no effect on American crocodile critical 

habitat. The Navy has consulted with NMFS as required by section 7(a)(2) of the ESA in that regard.

Impacts from Vessels and In-Water Devices under Alternative 1 for Testing Activities

As indicated in Section 3.0.3.3.4.1 (Vessels and In-Water Devices), most of the testing activities involve 

large vessel movement. However, the number of activities that involve large vessel movements for 

testing is comparatively lower than the number of training activities. In addition, testing often occurs 

jointly with a training event, so it is likely that the testing activity would be conducted from a training 

vessel. Vessel movement in conjunction with testing activities could be widely dispersed throughout the 

Study Area, but would be concentrated near naval ports, piers, range complexes, testing ranges, and 

especially off the northeast U.S. coast, off south Florida, and in the Gulf of Mexico. Specifically, offshore

testing activities that include vessels would be conducted within the Northeast, Virginia Capes, Navy 

Cherry Point, Jacksonville, Key West, and Gulf of Mexico Range Complexes, the Naval Undersea Warfare 

Center, Newport Testing Range; South Florida Ocean Measurement Facility Testing Range; Naval Surface 

Warfare Center, Panama City Division Testing Range (see Table 3.0-18). 

Propulsion testing, which sometimes include ships operating at speeds in excess of 30 knots, occur 

infrequently but may pose a higher strike risk for reptiles (and primarily sea turtles because this activity 

would be conducted in offshore waters). This activity requires some vessels to transit at high speeds to 

complete the testing activity. These activities would occur in the Northeast, Virginia Capes, Jacksonville, 

and Gulf of Mexico Range Complexes. However, there are just a few of these events proposed per year, 

so the increased risk is nominal compared to all vessel use proposed for testing activities under 

Alternative 1.

In addition, vessel movements associated with testing activities would occur within inshore waters

surrounding Bath, Massachusetts; Portsmouth, New Hampshire; Newport, Rhode Island; Groton, 

Connecticut; Little Creek, Virginia; Norfolk, Virginia; Kings Bay, Georgia; Mayport, Florida; Port 

Canaveral, Florida; and Pascagoula, Mississippi (see Table 3.0-19).

Also, as discussed in Section 3.0.3.3.4.1 (Vessels and In-Water Devices), testing activities involving the 

use of in-water devices would occur in the AFTT Study Area at any time of year. Under Alternative 1, 

testing activities involving the use of in-water devices would be conducted throughout the AFTT Study 

Area, including the Northeast, Virginia Capes, Navy Cherry Point, Jacksonville, Key West, and Gulf of 
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Mexico Range Complexes, the Naval Undersea Warfare Center, Newport Testing Range, South Florida 

Ocean Measurement Facility, and the Naval Surface Warfare Center Panama City Testing Range.

As with training activities, sea turtle, alligator, or terrapin strikes resulting from testing activities would 

most likely occur where there is a co-location of these reptile species, especially in high densities, and 

with high-speed vessel and in-water device testing activities. Over the continental shelf, sea turtles are 

at risk of strikes because of greater densities of sea turtles and more frequent vessel movements 

relative to the open ocean. Therefore, sea turtle species that occur over the continental shelf and in 

inshore waters (e.g., estuaries), would therefore have a greater potential for impacts. Loggerhead sea 

turtles are likely the most at risk of vessel interactions under Alternative 1 in the open ocean, as well as 

within inshore waters where small and fast vessels conduct activities. There is not expected to be any 

predictable seasonal difference in Navy vessel use; therefore, impacts from vessels and in-water devices, 

including physical disturbance and potential for strike, would depend on each species’ seasonal patterns 

of occurrence or degree of residency in the continental shelf portions of the AFTT Study Area. As 

previously indicated, any physical disturbance from vessel transit and use of in-water devices is not 

expected to result in more than a momentary behavioral response; however, an actual strike of a sea 

turtle would likely result in permanent injury, temporary injury that weakens a sea turtle’s resilience to 

other natural and human-induced stressors, death. Although the likelihood is low, a harmful interaction 

with a vessel or in-water device cannot be discounted during a testing activity.

Any collision with a sea turtle would result in injury, and possible mortality, of an individual sea turtle. 

Under Alternative 1 testing activities, the Navy will continue to implement procedural mitigation to 

avoid or reduce the potential for vessel and in-water device strike of sea turtles (see Section 5.3.4.1, 

Vessel Movement, and Section 5.3.4.2, Towed In-Water Devices). Within a mitigation zone of a vessel or 

in-water device, trained observers will relay sea turtle locations to the operators, who are required to 

change course (no course change would be implemented if the vessel’s safety is threatened, the vessel 

is restricted in its ability to maneuver (e.g., during launching and recovery of aircraft or landing craft, 

during towing activities, when mooring, etc.), or if the in-water device is operated autonomously. A 

mitigation zone size is not specified for sea turtles to allow flexibility based on vessel type and mission 

requirements (e.g., small boats operating in a narrow harbor).

The leatherback turtle is likely to be impacted by testing activities using vessels and in-water devices, 

given its preference for open-ocean habitats and its feeding behavior (feed at the surface and 

throughout the water column) and prey (e.g., jellyfish). Hatchlings and pre-recruitment juveniles of all 

sea turtle species may also occur in open-ocean habitats, where they reside among Sargassum mats. Sea 

turtles are expected to be highly dispersed in deeper offshore waters; given the large area over which 

Navy vessels could potentially conduct testing activities, the likelihood of co-occurrence is low, as well as 

the potential consequences.

American alligators may be exposed to vessel strike during testing activities at inshore testing locations 

in Georgia, Florida, and Mississippi. Diamondback terrapins may be exposed to strike at all inshore 

testing locations along the Atlantic and Gulf coasts.

Strike potential in inshore testing locations for American alligators under Alternative 1 testing activities 

would likely range from minor survivable injuries to death of individual alligators. Based on avoidance 

behaviors, as shown in open-water locations with motorized and non-motorized boat traffic, strike 

potential is likely reduced. Potential impacts of exposure to vessels and in-water devices may result in 

substantial changes in an individual’s behavior, growth, survival, annual reproductive success, lifetime 
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reproductive success (fitness), or species recruitment. Given the number of testing activities involving 

vessel movement in inshore locations, and the density of alligators in testing locations, the possibility of 

a strike to an individual alligator cannot be discounted. Any strike at high speed is likely to result in 

significant injury. Potential impacts of exposure to vessels are not expected to result in population-level 

impacts for American alligators.

Strike potential in inshore testing locations for the diamondback terrapin under Alternative 1 testing 

activities would likely range from major injuries (because of the relatively small body mass and body 

type of terrapins) and death. Boat strikes are a significant concern in terrapin conservation efforts 

(Lester et al., 2012; Lester, 2013). Potential impacts of exposure to vessels and in-water devices may 

result in substantial changes in an individual terrapin’s behavior, growth, survival, annual reproductive 

success, lifetime reproductive success (fitness), or species recruitment. Given the number of testing 

activities involving vessel movement in inshore locations, and the density of terrapins in testing 

locations, the possibility of a strike to an individual terrapin cannot be discounted. Any strike at high 

speed is likely to result in significant injury. Potential impacts of exposure to vessels are not expected to 

result in population-level impacts for the diamondback terrapin.

Proposed testing activities under Alternative 1 that use vessels and in-water devices would not occur in 

designated critical habitat for the green sea turtle (Culebra Island), hawksbill sea turtle (Mona Island and 

Monita Island), leatherback sea turtle (St. Croix Island), or American crocodile (Florida Bay). Navy testing 

activities that use vessels and in-water devices would occur year round within the five critical habitat 

types for the loggerhead turtle. See Section 3.8.2.2.4.1 (Status and Management) for a description of 

these habitat types and supporting physical and biological factors. Vessels have no pathway to impact 

the physical and biological features identified for these habitats (National Marine Fisheries Service, 

2014b). For example, testing activities that use vessels and in-water devices will not impact the prey 

species found in Sargassum habitat or the nearshore habitat conditions that are essential for nearshore 

reproductive habitat.

Pursuant to the ESA, the use of vessels and in-water devices during testing activities under Alternative 1 

may affect ESA-listed green, hawksbill, Kemp’s ridley, leatherback, and loggerhead sea turtles; and 

would have no effect on the American crocodile. There would be no effect on green, hawksbill, 

leatherback, or loggerhead sea turtle critical habitat; and no effect on American crocodile critical 

habitat. The Navy has consulted with NMFS as required by section 7(a)(2) of the ESA in that regard.

3.8.3.4.1.2 Impacts from Vessels and In-Water Devices under Alternative 2

Impacts from Vessels and In-Water Devices under Alternative 2 for Training Activities

As shown in Tables 3.0-18–3.0-20 the locations of offshore training activities that use vessels are the 

same under Alternatives 1 and 2. However, the number of offshore training activities involving vessel 

movement would increase by approximately 2 percent annually and 3 percent over five years under 

Alternative 2. Similarly, the locations and annual numbers of training activities that include vessels 

within inshore waters of the AFTT Study Area would be the same under Alternatives 1 and 2. Even with 

the nominal increase in training activity levels described above, Navy training activities would remain 

consistent with the levels of activity and types activities undertaken in the AFTT Study Area over the last 

decade. 

Similarly, Tables 3.0-22 and 3.0-23 show the locations of training activities within both offshore and 

inshore waters of the Study Area that use in-water devices area would be the same under Alternatives 1 
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and 2. In addition, the annual number of training activities occurring within inshore waters of the AFTT 

Study Area are identical between Alternatives 1 and 2. However, the number of offshore training 

activities that use in-water devices would increase by approximately 5 percent annually and 6 percent 

over five years (as with Alternative 1). This level of increased in-water device use would not appreciably 

change the potential for physical disturbance or strike of a sea turtle. Because the increase in activities 

under Alternative 2 over five years would be the same as with Alternative 1, impacts from training 

activities involving vessels and in-water devices under Alternative 2 would be similar to Alternative 1. 

Therefore, the analyses presented in Section 3.8.3.4.1.1 (Impacts from Vessels and In-Water Devices 

under Alternative 1) for training activities are applicable to training activities under Alternative 2.

Any collision with a sea turtle would result in injury, and possible mortality, of an individual sea turtle. 

Under Alternative 2 training activities, the Navy will continue to implement procedural mitigation to 

avoid or reduce the potential for vessel and in-water device strike of sea turtles (see Section 5.3.4.1, 

Vessel Movement, and Section 5.3.4.2, Towed In-Water Devices). Within a mitigation zone of a vessel or 

in-water device, trained observers will relay sea turtle locations to the operators, who are required to 

change course (no course change would be implemented if the vessel’s safety is threatened, the vessel 

is restricted in its ability to maneuver (e.g., during launching and recovery of aircraft or landing craft, 

during towing activities, when mooring, etc.), or if the in-water device is operated autonomously. A 

mitigation zone size is not specified for sea turtles to allow flexibility based on vessel type and mission 

requirements (e.g., small boats operating in a narrow harbor).

Strike potential in inshore training locations for American alligators under Alternative 2 training activities 

would likely range from minor survivable injuries to death of individual alligators. Based on avoidance 

behaviors, as shown in open water locations with motorized and non-motorized boat traffic, strike 

potential is likely reduced. Potential impacts of exposure to vessels and in-water devices may result in 

substantial changes in an individual’s behavior, growth, survival, annual reproductive success, lifetime 

reproductive success (fitness), or species recruitment. Given the number of high-speed vessel hours in 

the inshore water locations, and the density of alligators in training locations, the possibility of a strike 

to an individual alligator cannot be discounted. Any strike at high speed is likely to result in significant 

injury. Potential impacts of exposure to vessels are not expected to result in population-level impacts for 

American alligators.

Strike potential in inshore training locations for the diamondback terrapin under Alternative 2 training 

activities would likely range from major injuries (because of the relatively small body mass and body 

type of terrapins) and death. Boat strikes are a significant concern in terrapin conservation efforts 

(Lester et al., 2012; Lester, 2013). Potential impacts of exposure to vessels and in-water devices may 

result in substantial changes in an individual terrapin’s behavior, growth, survival, annual reproductive 

success, lifetime reproductive success (fitness), or species recruitment. Given the number of high-speed 

vessel hours in the inshore water locations, and the density of terrapins in training locations, the 

possibility of a strike to an individual terrapin cannot be discounted. Any strike at high speed is likely to 

result in significant injury. Potential impacts of exposure to vessels are not expected to result in 

population-level impacts for diamondback terrapins.

The leatherback turtle is likely to be impacted by training activities that use vessels and in-water devices, 

given its preference for open-ocean habitats and its feeding behavior (feed at the surface and 

throughout the water column) and prey (e.g., jellyfish). Hatchlings and pre-recruitment juveniles of all 

sea turtle species may also occur in open-ocean habitats, where they reside among Sargassum mats. Sea 

turtles are expected to be highly dispersed in deeper offshore waters; given the large area over which 
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Navy vessels could potentially conduct training activities, the likelihood of co-occurrence is low, as well 

as the potential consequences.

Proposed training activities under Alternative 2 that use vessels and in-water devices would not occur in 

designated critical habitat for the green sea turtle (Culebra Island), hawksbill sea turtle (Mona Island and 

Monita Island), leatherback sea turtle (St. Croix Island), or American crocodile (Florida Bay). Navy 

training activities that use vessels and in-water devices would occur year round within the five critical 

habitat types for the loggerhead turtle. See Section 3.8.2.2.4.1 (Status and Management) for a 

description of these habitat types and supporting physical and biological factors. Vessels have no 

pathway to impact the physical and biological features identified for these habitats (National Marine 

Fisheries Service, 2014b). For example, training activities that use vessels and in-water devices will not 

impact the prey species found in Sargassum habitat or the nearshore habitat conditions that are 

essential for nearshore reproductive habitat.

Pursuant to the ESA, the use of vessels and in-water devices during training activities under Alternative 2 

may affect ESA-listed green, hawksbill, Kemp’s ridley, leatherback, and loggerhead sea turtles; and 

would have no effect on the American crocodile. There would be no effect on green, hawksbill, 

leatherback, or loggerhead sea turtle critical habitat; and no effect on American crocodile critical 

habitat.

Impacts from Vessels and In-Water Devices under Alternative 2 for Testing Activities

As shown in Tables 3.0-18 through 3.0-20, the locations of testing activities within offshore and inshore 

waters that involve vessel movement would be the same under Alternatives 1 and 2. In addition, the

annual and five-year numbers of testing activities that involve vessel movements within inshore waters

of the AFTT Study Area are identical under Alternatives 1 and 2. However, the number of offshore

testing activities would increase by 0.3 percent annually and by approximately 7 percent over five years. 

As previously indicated the number of testing activities that involve vessels are much lower than the 

number of training activities. Furthermore, testing activities may be conducted simultaneously with a 

training event, using a training vessel. The proposed increase in offshore vessel use from testing 

activities under Alternative 2 would still be consistent with the levels of activity and types activities 

undertaken in the AFTT Study Area over the last decade. 

In addition, Tables 3.0-22 and 3.0-23 show the locations and annual numbers of testing activities that 

use in-water devices are the same under Alternatives 1 and 2. However, the number of testing activities 

that use in-water devices would increase approximately 11 percent over five years. This slight level of 

increased use of in-water devices does not substantially change the potential for physical disturbance or 

strike of sea turtles, crocodilians, or terrapins. Therefore, impacts from testing activities involving vessels 

and in-water devices under Alternative 2 would be similar to Alternative 1 and the analyses presented in 

Section 3.8.3.4.1.1 (Impacts from Vessels and In-Water Devices under Alternative 1) for testing activities 

are applicable to testing activities under Alternative 2.

Any collision with a sea turtle would result in injury, and possible mortality, of an individual sea turtle. 

Under Alternative 2 testing activities, the Navy will continue to implement procedural mitigation to 

avoid or reduce the potential for vessel and in-water device strike of sea turtles (see Section 5.3.4.1, 

Vessel Movement, and Section 5.3.4.2, Towed In-Water Devices). Within a mitigation zone of a vessel or 

in-water device, trained observers will relay sea turtle locations to the operators, who are required to 

change course (no course change would be implemented if the vessel’s safety is threatened, the vessel 

is restricted in its ability to maneuver (e.g., during launching and recovery of aircraft or landing craft, 
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during towing activities, when mooring, etc.), or if the in-water device is operated autonomously. A 

mitigation zone size is not specified for sea turtles to allow flexibility based on vessel type and mission 

requirements (e.g., small boats operating in a narrow harbor).

Strike potential in inshore testing locations for American alligators under Alternative 2 testing activities 

would likely range from minor survivable injuries to death of individual alligators. Based on avoidance 

behaviors, as shown in open-water locations with motorized and non-motorized boat traffic, strike 

potential is likely reduced. Potential impacts of exposure to vessels and in-water devices may result in 

substantial changes in an individual’s behavior, growth, survival, annual reproductive success, lifetime 

reproductive success (fitness), or species recruitment. Given the number of testing activities involving 

vessel movement in inshore locations, the possibility of a strike to an individual alligator cannot be 

discounted. Any strike at high speed is likely to result in significant injury. Potential impacts of exposure 

to vessels are not expected to result in population-level impacts for American alligators.

Strike potential in inshore testing locations for the diamondback terrapin under Alternative 2 testing 

activities would likely range from major injuries (because of the relatively small body mass and body 

type of terrapins) and death. Boat strikes are a significant concern in terrapin conservation efforts 

(Lester et al., 2012; Lester, 2013). Potential impacts of exposure to vessels and in-water devices may 

result in substantial changes in an individual terrapin’s behavior, growth, survival, annual reproductive 

success, lifetime reproductive success (fitness), or species recruitment. Given the number of testing 

activities involving vessel movement in inshore locations, and the density of terrapins in testing 

locations, the possibility of a strike to an individual terrapin cannot be discounted. Any strike at high 

speed is likely to result in significant injury. Potential impacts of exposure to vessels are not expected to 

result in population-level impacts for the diamondback terrapin.

The leatherback turtle is likely to be impacted by testing activities that use vessels and in-water devices, 

given its preference for open-ocean habitats and its feeding behavior (feed at the surface and 

throughout the water column) and prey (e.g., jellyfish). Hatchlings and pre-recruitment juveniles of all 

sea turtle species may also occur in open-ocean habitats, where they reside among Sargassum mats. Sea 

turtles are expected to be highly dispersed in deeper offshore waters; given the large area over which 

Navy vessels could potentially conduct testing activities, the likelihood of co-occurrence is low, as well as 

the potential consequences.

Navy testing activities that use vessels and in-water devices would occur year round within the five 

critical habitat types for the loggerhead turtle. See Section 3.8.2.2.4.1 (Status and Management) for a 

description of these habitat types and supporting physical and biological factors. Vessels have no 

pathway to impact the physical and biological features identified for these habitats (National Marine 

Fisheries Service, 2014b). For example, testing activities that use vessels and in-water devices will not 

impact the prey species found in Sargassum habitat or the nearshore habitat conditions that are 

essential for nearshore reproductive habitat.

Pursuant to the ESA, the use of vessels and in-water devices during testing activities under Alternative 2 

may affect ESA-listed green, hawksbill, Kemp’s ridley, leatherback, and loggerhead sea turtles; and 

would have no effect on the American crocodile. There would be no effect on green, hawksbill, 

leatherback, or loggerhead sea turtle critical habitat; and no effect on American crocodile critical 

habitat.
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3.8.3.4.1.3 Impacts from Vessels and In-Water Devices under the No Action Alternative

Impacts from Vessels and In-Water Devices under the No Action Alternative for Training and 

Testing Activities

Under the No Action Alternative, the Navy would not conduct the proposed training and testing 

activities in the AFTT Study Area. Various physical disturbance and strike stressors (e.g., vessels and 

in-water devices) would not be introduced into the marine environment. Therefore, baseline conditions 

of the existing environment would either remain unchanged or would improve slightly after cessation of 

ongoing training and testing activities.

3.8.3.4.2 Impacts from Aircraft and Aerial Targets

Impacts from aircraft and aerial targets are not applicable to sea turtles, crocodilians, or terrapins

because they do not occur in airborne environments and will not be analyzed further in this section. 

Refer to the Impacts from Military Expended Materials section (Section 3.8.3.4.3) for impacts from 

target fragments and the Acoustic Stressors section (Section 3.8.3.1) for potential disturbance 

from aircraft.

3.8.3.4.3 Impacts from Military Expended Materials

This section analyzes the strike potential to sea turtles from the following categories of military 

expended materials: (1) all sizes of non-explosive practice munitions; (2) fragments from high-explosive 

munitions; (3) expendable targets; and (4) expended materials other than munitions, such as sonobuoys, 

expended bathythermographs, and torpedo accessories. 

For a discussion of the types of activities that use military expended materials refer to Appendix B 

(Activity Stressor Matrices) and for a discussion on where they are used and how much of each material 

is expended under each alternative, see Section 3.0.3.3.4.2 (Military Expended Materials). As described 

in Appendix F (Military Expended Materials and Direct Strike Impact Analyses), for physical disturbance 

and strike stressors as it relates to sea turtles, impacts from fragments from high-explosive munitions 

are included in the analysis presented in Section 3.8.3.2 (Explosive Stressors), and are not considered 

further in this section. These activities would occur in offshore and inshore training and testing locations 

that overlap with all species of sea turtles, American alligators, and diamondback terrapins. Because 

military expended materials would not be used in areas that overlap with the American crocodile known 

range or critical habitat designated for this species, the American crocodile is not analyzed for potential 

impacts from military expended materials.

The primary concern is the potential for a sea turtle, American alligator, or diamondback terrapin to be 

struck with a military expended material at or near the water’s surface, which could result in injury or 

death. For sea turtles, although disturbance or strike from an item as it falls through the water column is 

possible, it is not likely because the objects generally sink through the water slowly and can be avoided 

by most sea turtles. Materials will slow in their velocity as they approach the bottom of the water and 

will likely be avoided by any juvenile or adult sea turtles (e.g., Kemp’s ridley, green, loggerhead, or 

hawksbill turtles) that happen to be in the vicinity foraging in benthic habitats. Therefore, the discussion 

of military expended materials strikes focuses on the potential of a strike at the surface of the water.

Other reptiles (such as American alligators and terrapins) could be on the water’s surface. However, 

these reptiles may respond to other types of stressors (e.g., vessel noise or visual disturbance) and flee 

the vicinity of the inshore activity, thereby reducing the potential for physical disturbance and strike.

Where inshore training and testing activities are adjacent to any terrapin rookery locations, terrapins 
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(nesting females and hatchlings) may be at higher risk of physical disturbance and strike because more 

individual terrapins would be expected to occur in inshore waters in close proximity to these locations.

American alligators are likely sensitive to approaching vessels, often demonstrating avoidance behaviors 

to both motorized and non-motorized recreational boating in lakes (Lewis et al., 2014), and are likely at 

higher risk for strike in narrow shallow channels that would restrict the movements of a fleeing alligator. 

It is unlikely that military expended materials would strike American alligators in these waters because 

materials would not be expended in small creeks and similar habitats. American alligators would be at 

higher risk for strike in more relatively open waters like rivers and estuaries where materials may be 

expended.

Diamondback terrapins likely detect approaching vessels, but do not typically exhibit avoidance 

behaviors (Lester et al., 2012; Lester, 2013); therefore, terrapins are likely at increased strike risk by 

military expended materials when transiting an open water area or foraging at the surface.

While no strike from military expended materials has ever been reported or recorded on a reptile, the 

possibility of a strike still exists. Therefore, the potential for sea turtles to be struck by military expended 

materials was evaluated using statistical probability modeling to estimate potential direct strike 

exposures to a sea turtle. American alligators and diamondback terrapins were not included in the 

model because these species occur in relatively more shallow water habitats and would likely respond 

to other stressors from inshore training and testing activities. To estimate potential direct strike 

exposures of sea turtles, a scenario was calculated using the sea turtle species with the highest average 

monthly density in areas with the highest amounts of military expended material expenditures, 

specifically Virginia Capes and Jacksonville Range Complexes (see Appendix F, Military Expended 

Materials and Direct Strike Impact Analyses). Input values include munitions data (frequency, footprint 

and type), size of the training or testing area, sea turtle density data, and size of the animal. To estimate 

the potential of military expended materials to strike a sea turtle, the impact area of all military 

expended materials was totaled over one year in the area with the highest combined amounts of 

military expended materials for the Proposed Action. Loggerhead turtles are used as a proxy for 

modeling impacts because this species has the highest seasonal density within these two areas; 

therefore, loggerhead turtles provide the most conservative estimate of potential strikes. For estimates 

of expended materials in all areas, see Section 3.0.3.3.4.2 (Military Expended Materials). The analysis of 

the potential for a sea turtle strike is influenced by the following assumptions:

 The model is two-dimensional, assumes that all sea turtles would be at or near the surface 

100 percent of the time, and does not consider any time a sea turtle would be submerged.

 The model also does not take into account the fact that most of the projectiles fired during 

training and testing activities are fired at targets, and that most projectiles hit those targets, so 

only a very small portion of those would hit the water with their maximum velocity and force.

 The model assumes the animal is stationary and does not account for any movement of the sea 

turtle or any potential avoidance of the training or testing activity.

The potential of fragments from high-explosive munitions or expended material other than munitions to 

strike a sea turtle is likely lower than for the worst-case scenario calculated above because those events 

happen with much lower frequency. Fragments may include metallic fragments from the exploded 

target, as well as from the exploded munitions.
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There is a possibility that an individual turtle at or near the surface may be struck if they are in the target 

area at the point of physical impact at the time of non-explosive munitions delivery. Expended 

munitions may strike the water surface with sufficient force to cause injury or mortality. Direct 

munitions strikes from non-explosive bombs, missiles, and rockets are potential stressors to some 

species. Some individuals at or near the surface may be struck directly if they are at the point of impact 

at the time of non-explosive practice munitions delivery. However, most missiles hit their target or are 

disabled before hitting the water. Thus, most of these missiles and aerial targets hit the water as 

fragments, which quickly dissipates their kinetic energy within a short distance of the surface.

Adult sea turtles are generally at the surface for short periods and spend most of their time submerged; 

however, hatchlings and juveniles of all sea turtle species spend more time at the surface while in ocean 

currents, and all sea turtle life stages bask on the surface. Leatherback sea turtles of all age classes are 

more likely to be foraging at or near the surface in the open ocean than other species, but the likelihood 

of being struck by a projectile remains very low because of the wide spatial distribution of leatherbacks 

relative to the point location of an activity. Furthermore, projectiles are aimed at targets, which will 

absorb the impact of the projectile. Other factors that further reduce the likelihood of a sea turtle being 

struck by an expended munition include the recovery of all non-explosive torpedoes as well as targetrelated materials that are intact after the activity. The Navy will implement mitigation (e.g., not 

conducting gunnery activities against a surface target when a specified distance from sea turtles) to 

avoid potential impacts from military expended materials on sea turtles throughout the Study Area (see 

Section 5.3, Procedural Mitigation to be Implemented).

3.8.3.4.3.1 Impacts from Military Expended Materials under Alternative 1

Impacts from Military Expended Materials under Alternative 1 for Training Activities

Training activities in offshore waters under Alternative 1 that involve military expended materials under 

the Proposed Action would occur in the Northeast, Virginia Capes, Navy Cherry Point, Jacksonville, Key 

West, Gulf of Mexico Range Complexes, and other AFTT areas. In addition, training activities that involve 

military expended materials would be conducted within inshore waters within and around Boston, 

Massachusetts; Earle, New Jersey; Delaware Bay, Delaware; Narragansett, Rhode Island; Hampton 

Roads, Virginia; James River and tributaries, Virginia; the Lower Chesapeake Bay, Virginia; Morehead 

City, North Carolina; Wilmington, North Carolina; Cooper River, South Carolina; Savannah, Georgia; 

Kings Bay, Georgia; Mayport, Florida; Port Canaveral, Florida; Tampa, Florida; Beaumont, Texas; and 

Corpus Christi, Texas (see Table 3.0-30 and Table 3.0-33). Navy training activities have the potential to 

expose all age classes of any species of sea turtle within these offshore and inshore areas to military 

expended materials.

Sea turtles are expected to be highly dispersed in offshore waters. Repeated exposures to sea turtles are 

not anticipated as these offshore areas do not have resident animals year round. Navy training activities 

involving military expended materials in the inshore waters occur in several locations along the Atlantic 

coast, but fewer types of military materials would be expended compared to the activities in the 

offshore areas (see Section 3.0.3.3.4.2, Military Expended Materials). For training activities occurring in 

inshore waters, loggerhead, green, Kemp’s ridley, and hawksbill turtles that have recruited to benthic 

foraging grounds could be present. Leatherbacks that forage at the surface in coastal and sometimes 

estuarine waters would also be present. Hatchlings of all sea turtle species would be present very briefly 

as they leave the nest, enter the water, and move to offshore areas to develop. Hatchlings would only 

be present a few months of the year between summer and fall from southern Virginia and further south.
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As stated previously, factors that further reduce the likelihood of a sea turtle being struck by an 

expended munition include the recovery of all non-explosive torpedoes as well as target-related 

materials that are intact after the activity. The Navy will implement mitigation (e.g., not conducting 

gunnery activities against a surface target when a specified distance from sea turtles) to avoid potential 

impacts from military expended materials on sea turtles throughout the Study Area. Hatchlings and prerecruitment juveniles of all sea turtle species may also occur in open-ocean habitats; however, the 

likelihood of impact is lower for these age classes due to their occurrence at or near the water surface 

by concentrated Sargassum mats. Activities will not be initiated near concentrated Sargassum mats due 

to the possible presence of sea turtles (see Section 5.3, Procedural Mitigation to be Implemented).

American alligators and diamondback terrapins would also be exposed to training activities using 

military expended materials in inshore locations. Under Alternative 1, American alligators may be 

potentially exposed to military expended materials in inshore locations in North Carolina, South 

Carolina, Georgia, Florida, and Texas, while diamondback terrapins may be exposed in all inshore 

training locations. The likelihood of a physical disturbance and strike of an American alligator and 

diamondback terrapin is low because of the relatively lower numbers of military expended materials 

that would be expended in inshore waters compared to offshore locations, and the anticipated lower 

density of alligators and terrapins in inshore training locations. However, because of the potential for 

larger concentrations of female adult terrapins at coastal rookery locations at the beginning of nesting 

season and the larger concentration of hatchlings in waters at the end of nesting season, terrapins are at 

higher risk of physical disturbance and strike of military expended materials.

The model results presented in Appendix F (Military Expended Materials and Direct Strike Impact 

Analyses) estimate loggerhead sea turtle exposures (as discussed above, as a conservative proxy for all 

sea turtles) during training activities in the Virginia Capes and Jacksonville Range Complexes. The 

loggerhead turtle was used as a proxy for all sea turtle species because this species has the highest 

offshore density estimates, which would provide the most conservative output results. Based on a 

worst-case scenario, the results indicate with a reasonable level of certainty that sea turtles would not 

be struck by non-explosive practice munitions and expended materials other than munitions. In the 

Virginia Capes Range Complex, the model estimates approximately 0.08 direct strike exposures per year. 

In the Jacksonville Range Complex, the model estimates 0.03 direct strike exposures per year. As stated 

previously, for the purposes of modeling, only Virginia Capes and Jacksonville Range Complexes were 

used because these two training areas would have the highest estimated numbers and concentrations 

of military expended materials for each alternative and would thus provide a reasonable comparison for 

all other areas with fewer expended materials.

Green, Kemp’s ridley, and loggerhead sea turtles may occur in these areas used for modeling (Virginia 

Capes and Jacksonville Range Complexes). Hawksbill turtles may also occur in the Jacksonville Range 

Complex and farther south off the U.S. Atlantic and Gulf coasts, but less frequently than the other 

species of sea turtles. Leatherback turtles are more likely to be farther offshore, in the open ocean, 

although in the summer they are known to forage in nearshore environments in inshore waters of 

Virginia and North Carolina. Military expended materials deposition would be less concentrated in the 

Gulf of Mexico because of fewer activities that would expend materials. All of these sea turtle species

may occur within the Gulf of Mexico, but Kemp’s ridley and green sea turtles are more abundant. 

Under Alternative 1, training activities could introduce exposure risk to military expended materials, but 

activities are not expected to result in substantial changes in an individual reptile’s behavior, growth, 
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survival, annual reproductive success, lifetime reproductive success (fitness), or species recruitment, and 

as such are not expected to result in population-level impacts for all sea turtle species.

Proposed training activities under Alternative 1 that use military expended materials would not occur in 

designated critical habitat for the green sea turtle (Culebra Island), hawksbill sea turtle (Mona Island and 

Monita Island), leatherback sea turtle (St. Croix Island), or American crocodile (Florida Bay). Navy 

training activities that use military expended materials would occur year round within the five critical 

habitat types for the loggerhead sea turtle. See Section 3.8.2.2.4.1 (Status and Management) for a 

description of these habitat types and supporting physical and biological factors. Military expended 

materials use has no pathway to impact the physical and biological features identified for these habitats 

(National Marine Fisheries Service, 2014b) due to some of the military expended materials being 

recovered or sinking through the water column. Military expended materials would not be expended in 

the water to the point where migratory corridors would be obstructed and would not degrade 

nearshore reproductive habitat, winter areas, breeding areas, or Sargassum habitat.

Pursuant to the ESA, activities that use military expended materials during training activities under 

Alternative 1 may affect ESA-listed green, hawksbill, Kemp’s ridley, leatherback, and loggerhead sea 

turtles; and have no effect on the American crocodile. There would be no effect on green, hawksbill, 

leatherback, or loggerhead sea turtle critical habitat; and no effect on American crocodile critical 

habitat. The Navy has consulted with NMFS as required by section 7(a)(2) of the ESA in that regard.

Impacts from Military Expended Materials under Alternative 1 for Testing Activities

Testing activities in offshore waters that involve military expended materials under the Proposed Action 

would primarily occur in the Northeast, Virginia Capes, Navy Cherry Point, Jacksonville, Key West and 

Gulf of Mexico Range Complexes within the Study Area. Other areas include the Naval Undersea 

Warfare Center, Newport Testing Range; the South Florida Ocean Measurement Facility Testing Range; 

and Naval Surface Warfare Center, Panama City Testing Range (see Table 3.0-26, Table 3.0-28, 

Table 3.0-31, and Table 3.0-34). It should be noted that military expended materials would not be 

expended in inshore waters; therefore, American crocodiles, American alligators, and diamondback 

terrapins are not analyzed for potential impacts from Alternative 1 testing activities.

Sea turtles are expected to be highly dispersed in offshore waters. Repeated exposures to sea turtles are 

not anticipated as these offshore areas do not have resident animals year round. The results presented 

in Appendix F (Military Expended Materials and Direct Strike Impact Analyses) indicate a reasonable 

level of certainty that no sea turtles would be struck by military expended materials. Based on a worstcase scenario, the results indicate with a reasonable level of certainty that sea turtles would not be 

struck by non-explosive practice munitions and expended materials other than munitions. In the Virginia 

Capes Range Complex, the model estimates approximately 0.03 direct strike exposures per year. In the 

Jacksonville Range Complex, the model estimates 0.06 direct strike exposures per year. As mentioned 

previously, the loggerhead turtle was used as a proxy for all sea turtle species because this species has 

the highest offshore density estimates, which would provide the most conservative modeling output 

results. In addition, Virginia Capes Range Complex and Jacksonville Range Complex were the only areas 

modeled because these two areas would have the highest concentration of military expended materials 

from testing activities, again providing the most conservative modeling output results.

Under Alternative 1, testing activities will introduce exposure risk to military expended materials, which 

could result in changes to a sea turtle’s behavior, growth, survival, annual reproductive success, lifetime 
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reproductive success (fitness), or species recruitment. No impacts to individual sea turtles are expected; 

therefore, no population-level effects would result from testing activities under Alternative 1.

As with training activities, factors that further reduce the likelihood of a sea turtle being struck by an 

expended munition include the recovery of all non-explosive torpedoes as well as target-related 

materials that are intact after the activity. The Navy will implement mitigation (e.g., not conducting 

gunnery activities against a surface target when a specified distance from sea turtles) to avoid potential 

impacts from military expended materials on sea turtles throughout the Study Area. Hatchlings and prerecruitment juveniles of all sea turtle species may also occur in open-ocean habitats; however, the 

likelihood of impact is lower for these age classes due to their occurrence at or near the water surface 

by concentrated Sargassum mats. Activities will not be initiated near concentrated Sargassum mats due 

to the possible presence of sea turtles (see Section 5.3, Procedural Mitigation to be Implemented).

Under Alternative 1 testing activities, release of military expended materials would not occur in critical 

habitat designations for the American Crocodile (Florida Bay), green sea turtle (Culebra Island), hawksbill 

sea turtle (Mona Island and Monita Island), or leatherback sea turtle (St. Croix Island). Navy testing 

activities that use military expended materials would occur year round within the five critical habitat 

types for the loggerhead sea turtle. See Section 3.8.2.2.4.1 (Status and Management) for a description of 

these habitat types and supporting physical and biological factors. Military expended materials use has 

no pathway to impact the physical and biological features identified for these habitats (National Marine 

Fisheries Service, 2014b) due to some of the military expended materials being recovered or sinking 

through the water column. Military expended materials would not be expended in the water to the 

point where migratory corridors would be obstructed and would not degrade nearshore reproductive 

habitat, winter areas, breeding areas, or Sargassum habitat.

Pursuant to the ESA, activities that use military expended materials during testing activities under 

Alternative 1 may affect ESA-listed green, hawksbill, Kemp’s ridley, leatherback, and loggerhead sea 

turtles; and would have no effect on the American crocodile. There would be no effect on green, 

hawksbill, leatherback, or loggerhead sea turtle critical habitat; and no effect on American crocodile 

critical habitat. The Navy has consulted with NMFS as required by section 7(a)(2) of the ESA in that 

regard.

3.8.3.4.3.2 Impacts from Military Expended Materials under Alternative 2

Impacts from Military Expended Materials under Alternative 2 for Training Activities

Although there is a slight increase in the numbers of military expended materials released during 

training activities under Alternative 2 relative to Alternative 1, probability analyses conducted for 

training activities under Alternative 2 yielded nearly identical exposures compared to Alternative 1. 

Based on a worst-case scenario, the results indicate with a reasonable level of certainty that sea turtles 

would not be struck by non-explosive practice munitions and expended materials other than munitions. 

In the Virginia Capes Range Complex, the model estimates approximately 0.066 exposures per year. In 

the Jacksonville Range Complex, the model estimates 0.040 strikes per year. These results provide a high 

level of certainty that no sea turtles would be struck by military expended materials under Alternative 2 

training activities. Hatchlings and pre-recruitment juveniles of all sea turtle species may also occur in 

open-ocean habitats; however, the likelihood of impact is lower for these age classes due to their 

occurrence at or near the water surface by concentrated Sargassum mats. Activities will not be initiated 

near concentrated Sargassum mats due to the possible presence of sea turtles (see Section 5.3,

Procedural Mitigation to be Implemented). In addition, the results indicate that fractional increases in 
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expendable targets and expended materials other than munitions proposed under Alternative 2 does 

not substantially increase the potential for direct strike to sea turtles. Therefore, the associated impacts 

on sea turtles are expected to be identical to Alternative 1 as presented in Section 3.8.3.4.3.1 (Impacts 

from Military Expended Materials under Alternative 1) for training activities.

As with Alternative 1, American alligators and diamondback terrapins would also be exposed to training 

activities using military expended materials in inshore locations. Under Alternative 2, American alligators 

may be potentially exposed to military expended materials in inshore locations in North Carolina, South 

Carolina, Georgia, Florida, and Texas, while diamondback terrapins may be exposed in all inshore 

training locations. The likelihood of a physical disturbance and strike of an American alligator and 

diamondback terrapin is low because of the relatively lower numbers of military expended materials 

that would be expended in inshore waters compared to offshore locations, and the anticipated lower 

density of alligators and terrapins in inshore training locations. However, because of the potential for 

larger concentrations of female adult terrapins at coastal rookery locations at the beginning of nesting 

season and the larger concentration of hatchlings in waters at the end of nesting season, terrapins are at 

higher risk of physical disturbance and strike of military expended materials.

Proposed training activities under Alternative 2 that use military expended materials would not occur in 

designated critical habitat for the green sea turtle (Culebra Island), hawksbill sea turtle (Mona Island and 

Monita Island), leatherback sea turtle (St. Croix Island), or American crocodile (Florida Bay). Navy 

training activities that use military expended materials would occur year round within the five critical 

habitat types for the loggerhead sea turtle. See Section 3.8.2.2.4.1 (Status and Management) for a 

description of these habitat types and supporting physical and biological factors. Military expended 

materials use has no pathway to impact the physical and biological features identified for these habitats 

(National Marine Fisheries Service, 2014b) due to some of the military expended materials being 

recovered or sinking through the water column. Military expended materials would not be expended in 

the water to the point where migratory corridors would be obstructed and would not degrade 

nearshore reproductive habitat, winter areas, breeding areas, or Sargassum habitat.

Pursuant to the ESA, activities that use military expended materials during training activities under 

Alternative 2 may affect ESA-listed green, hawksbill, Kemp’s ridley, leatherback, and loggerhead sea 

turtles; and would have no effect on the American crocodile. There would be no effect on green, 

hawksbill, leatherback, or loggerhead sea turtle critical habitat; and no effect on American crocodile 

critical habitat.

Impacts from Military Expended Materials under Alternative 2 for Testing Activities

Although there is a slight increase in the numbers of military expended materials released during testing 

activities under Alternative 2 relative to Alternative 1, probability analyses conducted for testing 

activities under Alternative 2 yielded nearly identical exposures compared to Alternative 1. Based on a 

worst-case scenario, the results indicate with a reasonable level of certainty that sea turtles would not 

be struck by non-explosive practice munitions and expended materials other than munitions. In the 

Virginia Capes Range Complex, the model estimates approximately 0.025 exposures per year. In the 

Jacksonville Range Complex, the model estimates 0.068 strikes per year. These results provide a high 

level of certainty that no sea turtles would be struck by military expended materials under Alternative 2 

training activities. In addition, the results indicate that fractional increases in expendable targets and 

expended materials other than munitions proposed under Alternative 2 does not substantially increase 

the potential for direct strike to sea turtles. Hatchlings and pre-recruitment juveniles of all sea turtle 
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species may also occur in open-ocean habitats; however, the likelihood of impact is lower for these age 

classes due to their occurrence at or near the water surface by concentrated Sargassum mats. Activities 

will not be initiated near concentrated Sargassum mats due to the possible presence of sea turtles (see 

Section 5.3, Procedural Mitigation to be Implemented). Therefore, the associated impacts on sea turtles 

are expected to be identical to Alternative 1 as presented in Section 3.8.3.4.3.1 (Impacts from Military 

Expended Materials under Alternative 1) for testing activities.

As with Alternative 1, testing activities under Alternative 2 that would use military expended materials 

would not occur in inshore waters; therefore, American crocodiles, American alligators, and 

diamondback terrapins are not analyzed for potential impacts from Alternative 2 testing activities.

Proposed testing activities under Alternative 2 that use military expended materials would not occur in 

designated critical habitat for the green sea turtle (Culebra Island), hawksbill sea turtle (Mona Island and 

Monita Island), leatherback sea turtle (St. Croix Island), or American crocodile (Florida Bay). Navy testing 

activities that use military expended materials would occur year round within the five critical habitat 

types for the loggerhead sea turtle. See Section 3.8.2.2.4.1 (Status and Management) for a description of 

these habitat types and supporting physical and biological factors. Military expended materials use has 

no pathway to impact the physical and biological features identified for these habitats (National Marine 

Fisheries Service, 2014b) due to some of the military expended materials being recovered or sinking 

through the water column. Military expended materials would not be expended in the water to the 

point where migratory corridors would be obstructed and would not degrade nearshore reproductive 

habitat, winter areas, breeding areas, or Sargassum habitat.

Pursuant to the ESA, activities that use military expended materials during testing activities under 

Alternative 2 may affect ESA-listed green, hawksbill, Kemp’s ridley, leatherback, and loggerhead sea 

turtles; and would have no effect on the American crocodile. There would be no effect on green, 

hawksbill, leatherback, or loggerhead sea turtle critical habitat; and no effect on American crocodile 

critical habitat.

3.8.3.4.3.3 Impacts from Military Expended Materials under the No Action Alternative

Impacts from Military Expended Materials under the No Action Alternative for Training and Testing 

Activities

Under the No Action Alternative, the Navy would not conduct the proposed training or testing activities 

in the AFTT Study Area. Various physical disturbance and strike stressors (e.g., military expended 

materials) would not be introduced into the marine environment. Therefore, baseline conditions of the 

existing environment would either remain unchanged or would improve slightly after cessation of 

ongoing training and testing activities.

3.8.3.4.4 Impacts from Seafloor Devices

For a discussion of the types of activities that use seafloor devices refer to Appendix B (Activity Stressor 

Matrices) and for a discussion on where they are used and how many exercises would occur under each 

alternative, see Section 3.0.3.3.4.3 (Seafloor Devices). These include items placed on, dropped on or 

moved along the seafloor such as mine shapes, anchor blocks, anchors, bottom-placed instruments, and 

bottom-crawling unmanned underwater vehicles. The likelihood of any reptile species encountering 

seafloor devices is considered low because these items are either stationary or move very slowly along 

the bottom.
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Benthic-foraging sea turtles (e.g., Kemp’s ridley, green, loggerhead, or hawksbill turtles), American 

alligators, and diamondback terrapins would most likely encounter a seafloor device, but would likely 

avoid it. In the unlikely event that a reptile is in the vicinity of a seafloor device, the slow movement and 

stationary characteristics of these devices would not be expected to physically disturb or alter natural 

behaviors of sea turtles, alligators, or terrapins. As discussed in Section 3.8.3.4.3 (Impacts from Military 

Expended Materials), objects fall through the water slowly until they rest on the seafloor and could be 

avoided by most reptiles. Therefore, these items do not pose a significant strike risk to sea turtles, 

terrapins, or alligators. The only seafloor device used during training and testing activities that has the 

potential to strike a reptile at or near the surface is an aircraft deployed mine shape, which is used 

during aerial mine laying activities. These devices are identical to non-explosive practice bombs, 

therefore the analysis of the potential impacts from those devices are covered in Section 3.8.3.4.3 

(Impacts from Military Expended Materials) and are not further analyzed in this section. 

All of the inshore training locations shown in Table 3.0-36 may potentially be inhabited by diamondback 

terrapins, while inshore training locations in North Carolina, South Carolina, Georgia, Florida, and Texas 

may be inhabited by the American alligator. Seafloor devices would not be used in American crocodile 

habitats or within critical habitat designated for this species; therefore, American crocodiles are not 

discussed further in the analysis for potential impacts of the use of seafloor devices.

3.8.3.4.4.1 Impacts from Seafloor Devices under Alternative 1

Impacts from Seafloor Devices under Alternative 1 for Training Activities

Offshore training activities that use seafloor devices under Alternative 1 would primarily occur in the 

Virginia Capes Range Complex. Other locations include Navy Cherry Point, Jacksonville, Key West, and 

Gulf of Mexico Range Complexes; and the Naval Surface Warfare Center, Panama City Testing Range

(see Table 3.0-35). In addition training activities that use seafloor devices would be conducted within 

inshore waters including and surrounding Boston, Massachusetts; Earle, New Jersey; Delaware Bay, 

Delaware; Hampton Roads, Virginia, the Lower Chesapeake Bay, Virginia; James River and tributaries, 

Virginia; York River, Virginia; Morehead City, North Carolina; Wilmington, North Carolina; Savannah, 

Georgia; Kings Bay, Georgia; Mayport, Florida; Port Canaveral, Florida; Truman Harbor, Florida; 

Demolition Key, Florida; Tampa Florida; Beaumont, Texas; and Corpus Christi, Texas (see Table 3.0-36).

For training activities occurring in the offshore waters, loggerhead, green, and hawksbill turtles may be 

impacted, especially if seafloor devices are expended in waters where the isobaths are not greater than 

the benthic foraging ability (dive depth). Adult loggerhead turtles may be found foraging in waters as 

deep as 200 m (Hochscheid, 2014). Juvenile sea turtles (e.g., green turtles) may rest and forage in waters 

as deep as approximately 30 m (Hochscheid, 2014), and hawksbill turtles have a recorded maximum dive 

depth of about 80 m. Leatherback turtles are more likely to co-occur with these offshore activities given 

their preference for open-ocean habitats and its feeding behavior (feed throughout the water column); 

therefore, this species may be exposed to a seafloor device as it is being deployed to the bottom. For 

example, leatherbacks may dive to depths greater than 1,000 m in search of prey (e.g., jellyfish) 

(Hochscheid, 2014). Animals are expected to be highly dispersed in offshore waters. Repeated exposures 

to animals are not anticipated as these offshore areas do not have resident sea turtles year round.

Navy training activities involving seafloor devices in the inshore waters occur in several locations along 

the Atlantic coast, but fewer estimated annual activities involving seafloor devices would be conducted 

compared to the activities in the offshore areas. The most training events involving seafloor devices 

would be conducted in the Lower Chesapeake Bay. Other locations include the James River and 
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Tributaries, Virginia; and Narragansett, Rhode Island. For training activities occurring in inshore waters, 

juvenile, sub-adult, and adult loggerhead, green, Kemp’s ridley, and to a lesser extent hawksbill sea 

turtles that have recruited to benthic foraging grounds would most likely be impacted. Sub-adult and 

adult leatherbacks that forage at the surface in coastal and sometimes estuarine waters would also be 

present. Based on the analysis in Section 3.8.3.4.3 (Impacts from Military Expended Materials), there is a 

reasonable level of certainty that no sea turtles would be struck by seafloor devices. The likelihood of a 

sea turtle encountering seafloor devices in benthic foraging habitats is considered low because these 

items are either stationary or move very slowly along the bottom. Seafloor devices are not likely to 

interfere with sea turtles resident to coastal or inshore waters, or engaging in migratory, reproductive, 

and feeding behaviors within the range complexes of the AFTT Study Area. Further, seafloor devices 

would mostly impact sea turtle species that are foraging in benthic habitats (e.g., Kemp’s ridley, 

loggerhead, hawksbill, and green sea turtles) or throughout the water column in deep waters (e.g., 

leatherback sea turtle). Additionally, some sea turtle species in coastal habitats can occur near the 

bottom resting. Sea turtles encountering seafloor devices would likely avoid them because of the

devices’ slow movement and visibility. Given the slow movement of seafloor devices, the effort 

expended by sea turtles to avoid them would be minimal, and any behavioral impacts would be 

temporary.

American alligators may encounter seafloor devices in inshore training locations in Morehead City, 

North Carolina; Wilmington, North Carolina; Savannah, Georgia; Kings Bay, Georgia; Mayport, Florida; 

Port Canaveral, Florida; Truman Harbor, Florida; Demolition Key, Florida; Tampa Florida; Beaumont, 

Texas; and Corpus Christi, Texas. American alligators can spend extended periods of time under water

(as much as 40 percent of the time during nighttime foraging activities, Nifong [2014]). During this 

submerged time, the potential for alligators to be struck by seafloor devices is low, as alligators would 

likely avoid seafloor devices due to their slow movement and visibility and because they do not 

resemble prey items. Given the slow movement of seafloor devices, the effort expended by alligators to 

avoid them would be minimal, and any behavioral impacts would be temporary.

Diamondback terrapins may encounter seafloor devices in all inshore training locations. Terrapins would 

likely be in estuarine benthic habitats foraging for prey items, such as shellfish (Hart & Lee, 2006; Pfau & 

Roosenburg, 2010). For the same reasons as for sea turtles and for alligators, terrapins would likely 

avoid and not be struck by seafloor devices, because these devices are slow moving and likely visible to 

diamondback terrapins in estuarine benthic habitats. Given the slow movement of seafloor devices, the 

effort expended by diamondback terrapins to avoid them would be minimal, and any behavioral impacts 

would be temporary.

Proposed training activities under Alternative 1 that use seafloor devices would not occur in designated 

critical habitat for the green sea turtle (Culebra Island), hawksbill sea turtle (Mona Island and Monita 

Island), leatherback sea turtle (St. Croix Island), or American crocodile (Florida Bay). Navy training 

activities that use seafloor devices would occur year round within the five critical habitat types for the 

loggerhead turtle. See Section 3.8.2.2.4.1 (Status and Management) for a description of these habitat 

types and supporting physical and biological factors. Seafloor devices use has no pathway to impact the 

physical and biological features identified for these habitats (National Marine Fisheries Service, 2014b)

due to the localized area potentially impacted by seafloor devices and the fact that most seafloor 

devices are recovered. Seafloor devices would not be expended in the water to the point where 

migratory corridors would be obstructed and would not degrade nearshore reproductive habitat, winter 

areas, breeding areas, or Sargassum habitat.
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Pursuant to the ESA, training activities that use seafloor devices under Alternative 1 may affect 

ESA-listed green, hawksbill, Kemp’s ridley, leatherback, and loggerhead sea turtles; and would have no 

effect on the American crocodile. There would be no effect on green, hawksbill, leatherback, or 

loggerhead sea turtle critical habitat; and no effect on American crocodile critical habitat. The Navy has 

consulted with NMFS as required by section 7(a)(2) of the ESA in that regard.

Impacts from Seafloor Devices under Alternative 1 for Testing Activities

Testing activities that involve the use of seafloor devices under Alternative 1 would occur in the 

Northeast, Virginia Capes, Navy Cherry Point, Jacksonville, Key West, and Gulf of Mexico Range 

Complexes; Naval Undersea Warfare Center, Newport Testing Range; South Florida Ocean Measurement 

Facility Testing Range; Naval Surface Warfare Center, and Panama City Testing Range (see Table 3.0-35). 

In addition, testing activities that use seafloor devices would be conducted within the inshore waters 

surrounding Little Creek, Virginia and Norfolk, Virginia. For testing activities under Alternative 1, seafloor 

devices may be deployed in habitats used by sea turtles and diamondback terrapins. Inshore locations 

proposed for use under Alternative 1 testing activities do not include habitat areas for the American 

crocodile, critical habitat for the American crocodile, or American alligator habitats; therefore, 

crocodilian species are not analyzed for impacts under Alternative 1 testing activities.

For testing activities occurring in the offshore waters, the species and age classes that may be impacted 

are juvenile and adult loggerhead, green, and hawksbill sea turtles, especially if seafloor devices are 

expended in waters where the isobaths are not greater than the benthic foraging ability (dive depth). 

The loggerhead turtle is the most abundant species in the Virginia Capes Range Complex, and adults 

may be found foraging in waters as deep as 200 m (Hochscheid, 2014). Juvenile sea turtles (e.g., green 

turtles) may rest and forage in waters as deep as approximately 30 m (Hochscheid, 2014), and hawksbill 

turtles have a recorded maximum dive depth of about 80 m. Juvenile and adult leatherback turtles are 

more likely to co-occur with these offshore activities given their preference for open-ocean habitats and 

their feeding behavior (e.g., feed throughout the water column); therefore, this species may be exposed 

to a seafloor device as it is being deployed to the bottom. For example, leatherbacks may dive to depths 

greater than 1,000 m in search of prey (e.g., jellyfish) (Hochscheid, 2014). Animals are expected to be 

highly dispersed in offshore waters. Repeated exposures to animals are not anticipated as these 

offshore areas do not have resident sea turtles year round.

Navy testing activities involving seafloor devices in the inshore waters occur at two locations along the 

Atlantic coast; Little Creek, Virginia; and Norfolk, Virginia. Only one activity involving seafloor devices is 

estimated to occur per year at each location (see Section 3.0.3.3.4.3, Seafloor Devices). For testing 

activities occurring in inshore waters, juvenile, sub-adult, and adult loggerhead, green, and Kemp’s ridley 

turtles that have recruited to benthic foraging grounds would most likely be impacted. Sub-adult and 

adult leatherbacks that forage at the surface in coastal and sometimes estuarine waters would also be 

present. Based on the analysis in Section 3.8.3.4.3 (Impacts from Military Expended Materials), there is a 

reasonable level of certainty that no sea turtles would be struck by seafloor devices. The likelihood of a 

sea turtle encountering seafloor devices in benthic foraging habitats is considered low because these 

items are either stationary or move very slowly along the bottom. Seafloor devices are not likely to 

interfere with sea turtles resident to coastal or inshore waters, or engaging in migratory, reproductive, 

and feeding behaviors within the range complexes of the AFTT Study Area. Further, seafloor devices 

would impact sea turtle species that are foraging in benthic habitats (e.g., Kemp’s ridley, loggerhead, 

hawksbill, and green sea turtles) or throughout the water column in deep waters (e.g., leatherback sea 

turtle). Additionally, some sea turtle species in coastal habitats can occur near the bottom when resting. 
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Sea turtles encountering seafloor devices would likely avoid them because of their slow movement and 

visibility. Given the slow movement of seafloor devices, the effort expended by sea turtles to avoid them 

would be minimal, and behavioral impacts would be temporary.

Diamondback terrapins may encounter seafloor devices in the testing locations of Little Creek and 

Norfolk, Virginia. Terrapins would likely be in estuarine benthic habitats foraging for prey items, such as 

shellfish (Pfau & Roosenburg, 2010). For the same reasons as for sea turtles, terrapins would likely not 

be struck by and would avoid seafloor devices, which are slow moving and likely visible to diamondback 

terrapins in estuarine benthic habitats. Given the slow movement of seafloor devices, the effort 

expended by diamondback terrapins to avoid them would be minimal, and any behavioral impacts 

would be temporary.

Proposed testing activities under Alternative 1 that use military expended materials would not occur in 

designated critical habitat for the green sea turtle (Culebra Island), hawksbill sea turtle (Mona Island and 

Monita Island), leatherback sea turtle (St. Croix Island), or American crocodile (Florida Bay). Navy testing 

activities that use seafloor devices would occur year round within the five critical habitat types for the 

loggerhead turtle. See Section 3.8.2.2.4.1 (Status and Management) for a description of these habitat 

types and supporting physical and biological factors. Seafloor devices use has no pathway to impact the 

physical and biological features identified for these habitats (National Marine Fisheries Service, 2014b)

due to the localized area potentially impacted by seafloor devices and the fact that most seafloor 

devices are recovered. Seafloor devices would not be expended in the water to the point where 

migratory corridors would be obstructed and would not degrade nearshore reproductive habitat, winter 

areas, breeding areas, or Sargassum habitat.

Pursuant to the ESA, testing activities that use seafloor devices under Alternative 1 may affect ESA-listed 

green, hawksbill, Kemp’s ridley, leatherback, and loggerhead sea turtles; and would have no effect on 

the American crocodile. There would be no effect on green, hawksbill, leatherback, or loggerhead sea 

turtle critical habitat; and no effect on American crocodile critical habitat. The Navy has consulted with 

NMFS as required by section 7(a)(2) of the ESA in that regard.

3.8.3.4.4.2 Impacts from Seafloor Devices under Alternative 2

Impacts from Seafloor Devices under Alternative 2 for Training Activities

As stated in Section 3.0.3.3.4.3 (Seafloor Devices), the locations and annual number of training activities 

that involve seafloor devices are the same under Alternatives 1 and 2. Based on the analysis in Section 

3.8.3.4.4.1 (Impacts from Seafloor Devices under Alternative 1) for training activities, there is a 

reasonable level of certainty that no reptiles would be struck by seafloor devices. 

Proposed training activities under Alternative 2 that use military expended materials would not occur in 

designated critical habitat for the green sea turtle (Culebra Island), hawksbill sea turtle (Mona Island and 

Monita Island), leatherback sea turtle (St. Croix Island), or American crocodile (Florida Bay). Navy 

training activities that use seafloor devices would occur year round within the five critical habitat types 

for the loggerhead turtle. See Section 3.8.2.2.4.1 (Status and Management) for a description of these 

habitat types and supporting physical and biological factors. Seafloor devices use has no pathway to 

impact the physical and biological features identified for these habitats (National Marine Fisheries 

Service, 2014b) due to the localized area potentially impacted by seafloor devices and the fact that most 

seafloor devices are recovered. Seafloor devices would not be expended in the water to the point where 
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migratory corridors would be obstructed and would not degrade nearshore reproductive habitat, winter 

areas, breeding areas, or Sargassum habitat.

Pursuant to the ESA, training activities that use seafloor devices under Alternative 2 may affect 

ESA-listed green, hawksbill, Kemp’s ridley, leatherback, and loggerhead sea turtles; and would have no 

effect on the American crocodile. There would be no effect on green, hawksbill, leatherback, or 

loggerhead sea turtle critical habitat; and no effect on American crocodile critical habitat.

Impacts from Seafloor Devices under Alternative 2 for Testing Activities

As stated in Section 3.0.3.3.4.3 (Seafloor Devices) the location of testing activities that use seafloor 

devices are the same under Alternatives 1 and 2; however, the number of testing activities proposed 

under Alternative 2 would increase by approximately 2 percent annually and by approximately 7 percent 

over five years. Based on the analysis in Section 3.8.3.4.3.2 (Impacts from Military Expended Materials 

under Alternative 2) for testing activities, there is a reasonable level of certainty that no reptiles would 

be struck by seafloor devices.

Proposed training activities under Alternative 2 that use military expended materials would not occur in 

designated critical habitat for the green sea turtle (Culebra Island), hawksbill sea turtle (Mona Island and 

Monita Island), leatherback sea turtle (St. Croix Island), or American crocodile (Florida Bay). Navy 

training activities that use seafloor devices would occur year round within the five critical habitat types 

for the loggerhead turtle. See Section 3.8.2.2.4.1 (Status and Management) for a description of these 

habitat types and supporting physical and biological factors. Seafloor devices use has no pathway to 

impact the physical and biological features identified for these habitats (National Marine Fisheries 

Service, 2014b) due to the localized area potentially impacted by seafloor devices and the fact that most 

seafloor devices are recovered. Seafloor devices would not be expended in the water to the point where 

migratory corridors would be obstructed and would not degrade nearshore reproductive habitat, winter 

areas, breeding areas, or Sargassum habitat.

Pursuant to the ESA, testing activities that use seafloor devices under Alternative 2 may affect ESA-listed 

green, hawksbill, Kemp’s ridley, leatherback, and loggerhead sea turtles; and would have no effect on 

the American crocodile. There would be no effect on green, hawksbill, leatherback, or loggerhead sea 

turtle critical habitat; and no effect on American crocodile critical habitat.

3.8.3.4.4.3 Impacts from Seafloor Devices under the No Action Alternative

Impacts from Seafloor Devices under the No Action Alternative for Training and Testing Activities

Under the No Action Alternative, the Navy would not conduct the proposed training or testing activities 

in the AFTT Study Area. Various physical disturbance and strike stressors (e.g., seafloor devices) would 

not be introduced into the marine environment. Therefore, baseline conditions of the existing 

environment would either remain unchanged or would improve slightly after cessation of ongoing 

training and testing activities.

3.8.3.4.5 Pile Driving

Pile driving occurs during training activities and would have no effect on reptiles because they are 

mobile and would be able to avoid the physical disturbance and strike stressors associated with pile 

driving activities. Pile driving would occur at two locations: Little Creek, Virginia; and Camp Lejeune, 

North Carolina. Pile driving would not occur during testing activities. This activity is analyzed under 
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acoustic stressors (see Section 3.8.3.1.4, Impacts from Pile Driving) for potential impacts on reptiles (sea 

turtles, alligators, and diamondback terrapins).

Proposed training activities that involve pile driving would not occur in designated critical habitat for the 

green sea turtle (Culebra Island), hawksbill sea turtle (Mona Island and Monita Island), leatherback sea 

turtle (St. Croix Island), loggerhead sea turtle (breeding areas, nearshore reproductive habitat, winter 

areas, migration corridors, or Sargassum habitat), or American crocodile (Florida Bay). 

Pursuant to the ESA, training activities that involve pile driving under Alternative 1 and Alternative 2 

would have no effect on the ESA-listed green, hawksbill, Kemp’s ridley, leatherback, and loggerhead sea 

turtles; and have no effect on the ESA-listed American crocodile. There would be no effect on green, 

hawksbill, leatherback, or loggerhead sea turtle critical habitat; and there would be no effect on 

American crocodile critical habitat.

3.8.3.5 Entanglement Stressors

This section analyzes the potential entanglement impacts of the various types of expended materials 

used by the Navy during training and testing activities within the Study Area. This analysis includes the 

potential impacts from three types of military expended materials: (1) wires and cables 

(2) decelerators/parachutes and (3) biodegradable polymers. Because expended materials that present 

entanglement risk to sea turtles are not expended in crocodilian or terrapin habitats, and because it is 

reasonable to assume that military expended materials would not drift into crocodilian or terrapin 

habitats, entanglement stressors are not analyzed for potential impacts on the American crocodile, 

American alligator, or the diamondback terrapin.

These materials could be encountered by sea turtles and if encountered, may have the potential to 

entangle sea turtles in the AFTT Study Area at the surface, in the water column, or along the seafloor.

The number and location of materials or activities that involve the use of items that may pose an 

entanglement risk are provided in Section 3.0.3.3.5 (Entanglement Stressors). General discussion of 

impacts can also be found in Section 3.0.3.6.4 (Conceptual Framework for Assessing Effects from 

Entanglement).

Risk factors for entanglement of sea turtles include animal size (and life stage), sensory capabilities, and 

foraging methods. Most entanglements discussed in the literature are attributable to sea turtle 

entrapments with fishing gear or other non-military materials that float or are suspended at the surface. 

Entanglement events are difficult to detect from land or from a boat as they may occur at considerable 

distances from shore and typically take place underwater. Juvenile turtles and hatchlings are inherently 

less likely to be detected than larger adult sea turtles. The likelihood of witnessing an entanglement 

event is therefore typically low. However, the properties and size of these military expended materials, 

as described in Section 3.0.3.3.5 (Entanglement Stressors) and Section 3.0.3.6.4 (Conceptual Framework 

for Assessing Effects from Entanglement), makes entanglement a possibility.

3.8.3.5.1 Impacts from Wires and Cables

For a discussion of the types of activities that use wires and cables see Appendix B (Activity Stressor 

Matrices). For a discussion on where they are used and how many wires and cables would be expended 

under each alternative, see Section 3.0.3.3.5.1 (Wires and Cables). A sea turtle that becomes entangled 

in nets, lines, ropes, or other foreign objects under water may suffer temporary hindrance to movement 

before it frees itself or may remain entangled. The turtle may suffer minor injuries but recover fully, or it 
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may die as a result of the entanglement. The entanglement risk to sea turtles of these items are 

discussed below. 

Some fiber optic cables used during Navy training and testing associated with remotely operated mine 

neutralization activities would be expended, although a portion may be recovered. The length of the 

expended tactical fiber would vary (up to about 3,000 m) depending on the activity. Tactical fiber has an 

8-micrometer (0.008 mm) silica core and acylate coating, and looks and feels like thin monofilament 

fishing line. Other characteristics of tactical fiber are a 242-micrometer (0.24 mm) diameter, 12-lb. 

tensile strength, and 3.4-mm bend radius (Corning Incorporated, 2005; Raytheon Company, 2015). 

Tactical fiber is relatively brittle; it readily breaks if knotted, kinked, or abraded against a sharp object. 

Deployed tactical fiber breaks if it is looped beyond its bend radius (3.4 mm) or exceeds its tensile 

strength (12 lb.). If the fiber becomes looped around an underwater object or sea turtle, it does not 

tighten unless it is under tension. Such an event would be unlikely based on its method of deployment 

and its resistance to looping after it is expended. The tactical fibers are often designed with controlled 

buoyancy to minimize the fiber's effect on vehicle movement. The tactical fiber would be suspended 

within the water column during the activity, and then be expended and sink to the seafloor (effective 

sink rate of 1.45 cm/second [Raytheon, 2015]) where it would be susceptible to abrasion and burial by 

sedimentation. Additionally, encounter rates with fiber optic cables by sea turtles are limited by the 

small number of cables that are expended.

If the isobath is greater than the maximum benthic foraging ability (dive depth) of a sea turtle, then 

these cables would not present an entanglement risk. For example, as discussed previously, 

leatherbacks may dive to depths greater than 1,000 m in search of prey (e.g., jellyfish), while other 

species (e.g., loggerheads) may forage in benthic habitats as deep as approximately 200 m, and juvenile 

sea turtles (e.g., green sea turtles) resting and foraging in waters as deep as approximately 30 m

(Hochscheid, 2014). In addition, although hatchlings would not likely be able to escape entrapment if 

entangled, but the chance of entanglement for a hatchling is very unlikely since these cables will be 

within the water column during the activity. Therefore, fiber optic cables present an entanglement risk 

to sea turtles, but it is unlikely that an entanglement event would occur and any entanglement would be 

temporary (a few seconds) before the sea turtle could resume normal activities. As noted in Section 

3.8.2.1.5 (General Threats), entanglement by fishing gear is a serious global threat to sea turtles. The 

various types of marine debris attributed to sea turtle entanglement (e.g., commercial fishing gear,

towed gear, stationary gear, or gillnets) have substantially higher (up to 500–2,000 lb.) breaking 

strengths at their “weak links.” If fiber optic cables and fragments of cables sink to the seafloor in an 

area where the bottom is calm, they would remain there undisturbed. In an area with bottom currents 

or active tidal influence, the fiber optic strands may move along the seafloor, away from the location in 

which they were expended and potentially into sea turtle benthic foraging habitats. Over time, these 

strands may become covered by sediment in most areas or colonized by attaching and encrusting 

organisms, which would further stabilize the material and reduce the potential for reintroduction as an 

entanglement risk.

Similar to tactical fibers discussed above, guidance wires may pose an entanglement threat to sea 

turtles either in the water column or after the wire has settled to the seafloor. The Navy previously 

analyzed the potential for entanglement of sea turtles by guidance wires and concluded that the 

potential for entanglement is low (U.S. Department of the Navy, 1996). These conclusions have also 

been carried forward in NMFS analyses of Navy training and testing activities (National Marine Fisheries 

Service, 2013b). The likelihood of a sea turtle encountering and becoming entangled in a guidance wire 
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depends on several factors. With the exception of a chance encounter with the guidance wire while it is 

sinking to the seafloor (at an estimated rate of 0.7 ft. per second), it is most likely that a sea turtle would 

only encounter a guidance wire once it had settled on the seafloor. Since the guidance wire will only be 

within the water column during the activity and while it sinks, the likelihood of a sea turtle encountering 

and becoming entangled within the water column is extremely low. The tensile breaking strength of the 

wire is a maximum of 40.4 lb. and can be broken by hand (Swope & McDonald, 2013) in contrast with 

the rope or lines associated with commercial fishing activities. However, it has a somewhat higher 

breaking strength than the monofilament used in the body of most commercial gillnets (typically 31 lb. 

or less). In addition, any undispensed wire would be contained in the dispensers upon impact of the 

sonobuoy or missile with the target. In addition, based on degradation times, the guidance wires would 

break down within one to two years and therefore no longer pose an entanglement risk. As with fiber 

optic cables, guidance wire fragments may move with bottom currents or active tidal influence, and 

present an enduring entanglement risk if the wires were moved into benthic foraging habitats. 

Subsequent colonization by encrusting organisms, burying by sediment, and chemical breakdown of the 

copper filament would further reduce the potential for reintroduction as an entanglement risk. The 

length of the guidance wires varies, as described in Section 3.0.3.3.5.1 (Wires and Cables), but greater 

lengths increase the likelihood that a sea turtle could become entangled. The behavior and feeding 

strategy of a species can determine whether it may encounter items on the seafloor, where guidance 

wires will most likely be available. There is potential for those species (e.g., green, hawksbill, Kemp’s 

ridley, and loggerhead) that feed on the seafloor to encounter guidance wires and potentially become 

entangled; however, the relatively few guidance wires being expended within the AFTT Study Area limits 

the potential for encounters.

Sonobuoys consist of a surface antenna and float unit and a subsurface hydrophone assembly unit. The 

two units are attached through a thin-gauge, dual-conductor, hard draw copper strand wire, which is 

then wrapped by a hollow rubber tubing or bungee in a spiral configuration. The tensile breaking 

strength of the sonobuoy wire and rubber tubing is no more than 40 lb. The length of the sonobuoy wire

is housed in a plastic canister dispenser, which remains attached upon deployment. The length of cable 

that extends out is no more than 1500 ft. and is dependent on the water depth and type of sonobuoy. 

Attached to the sonobuoy wire is a kite-drogue and damper disk stabilizing system made of non-woven 

nylon fabric. The nylon fabric is very thin and can be broken by hand. The sonobuoy wire runs through 

the stabilizing system and leads to the hydrophone components. The hydrophone components may be 

covered by thin plastic netting depending on type of sonobuoy. Each sonobuoy has a saltwater activated 

polyurethane float that inflates when the sonobuoy is submerged and keeps the sonobuoy components 

floating vertically in the water column below it. Sonobuoys remain suspended in the water column for 

no more than 30 hours, after which they sink to the seafloor. Several factors reduce the likelihood of sea 

turtle entanglement from sonobuoy components. The materials that present an entanglement risk in 

sonobuoys are weak, and if wrapped around an adult or juvenile sea turtle, would likely break soon after 

entanglement or break while bending into potentially entangling loops, although hatchlings would not 

likely be able to escape entrapment if entangled. These materials, however, are only temporarily 

buoyant and would begin sinking after use in an activity. The entanglement risk from these components 

would only occur when a sea turtle and these components were in close proximity, which is only in the 

water column. These materials would be expended in waters too deep for benthic foraging, so bottom 

foraging sea turtles would not interact with these materials once they sink. Some sonobuoy

components, once they sink to the bottom, may be transported by bottom currents or active tidal 

influence, and present an enduring entanglement risk. In the benthic environment, subsequent 
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colonization by encrusting organisms, burying by sediment, and chemical breakdown of the various 

materials would further reduce the potential for reintroduction as an entanglement risk.

3.8.3.5.1.1 Impacts from Wires and Cables under Alternative 1

Impacts from Wires and Cables under Alternative 1 for Training Activities

Training activities under Alternative 1 would expend wires and cables within the Northeast, Virginia 

Capes, Navy Cherry Point, Jacksonville, and Gulf of Mexico Range Complexes as well as other AFTT areas

(see Table 3.0-39). Wires would be expended in greatest concentration within the Jacksonville Range 

Complex which is approximately 50,090 square nautical miles (NM2) resulting in one wire per 2 NM2

throughout the entire Jacksonville Range Complex. Cables would be expended in the greatest 

concentration within the Virginia Capes Range Complex, which is approximately 27,672 square NM2. As 

a result, there would one cable per 36 NM2throughout the entire Virginia Capes Range Complex per 

year if they were expended evenly throughout the area. It should be noted that wires and cables would 

be expended in offshore deep water portions, and would not be an entanglement risk for sea turtles in 

inshore waters.

Any species of sea turtle that occurs in the Study Area could at some time encounter expended cables or 

wires. Based on the numbers and geographic locations of their use, wires and cables most likely pose a 

risk of entanglement for hatchlings and pre-recruitment juveniles of all sea turtle species, and 

leatherback turtles of all age classes. Wires and cables may pose a slight risk to juvenile, sub-adult, and 

adult loggerhead, green, and hawksbill sea turtles that have recruited to benthic foraging grounds. 

However, wires and cables from sonobuoys would be expended in waters too deep for benthic foraging, 

so bottom-foraging sea turtles (e.g., loggerhead and green turtles) would not interact with these 

materials once they sink. The sink rates of cables and wires would rule out the possibility of these 

drifting great distances into nearshore and coastal areas where juvenile, sub-adult, and adult green, 

hawksbill, Kemp’s ridley, and loggerhead sea turtles are more likely to occur and feed on the bottom. 

However, if wires and cables are expended in waters where the isobaths are not greater than the 

benthic foraging ability (dive depth), then juvenile, sub-adult, and adult loggerhead, green, and 

hawksbill sea turtles could be at risk of entanglement. For example, loggerheads may forage in benthic 

habitats as deep as approximately 200 m (Hochscheid, 2014). Hatchlings and pre-recruitment juveniles 

of all sea turtle species may also occur in open-ocean habitats; however, the likelihood of impact is 

lower for these age classes due to their occurrence at or near the water surface by concentrated 

Sargassum mats. Activities will not be initiated near concentrated Sargassum mats due to the possible 

presence of sea turtles. Training activities that use wires and cables may cause short-term or long-term 

disturbance to an individual turtle because if a sea turtle were to become entangled in a cable or wire, it 

could free itself, or the entanglement could lead to injury or death. Potential impacts of exposure to 

cable or wire may result in changes to an individual’s behavior, growth, survival, annual reproductive 

success, lifetime reproductive success (fitness), or species recruitment. However, cables and wires are 

generally expected to cause an insignificant impact to sea turtles because of (1) the physical 

characteristics of the cables and wires; (2) the behavior of the species, as sea turtles are unlikely to 

become entangled in an object that is resting on the seafloor; and (3) the low concentrations of 

expended wires and cables in the AFTT Study Area. Given the low concentration of expended wires and 

cables, and the patchy distribution of sea turtles and the wires and cables expended in the offshore 

waters throughout the Study Area, the likelihood of encountering a wire or cable and becoming 

entangled is low.
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Potential impacts of exposure to wires and cables are not expected to result in substantial changes in an 

individual’s behavior, growth, survival, annual reproductive success, lifetime reproductive success 

(fitness), or species recruitment, and as such are not expected to result in population-level impacts for 

all sea turtle species.

Proposed training activities under Alternative 1 that expend wires and cables would not occur in 

designated critical habitat for the green sea turtle (Culebra Island), hawksbill sea turtle (Mona Island and 

Monita Island), leatherback sea turtle (St. Croix Island), or American crocodile (Florida Bay). Navy 

training activities that expend wires and cables would not occur within the southeast portion of 

loggerhead critical habitat that is designated as breeding areas, but would occur in the following 

loggerhead turtle designated critical habitat year round: nearshore reproductive habitat, winter areas, 

migratory corridors, and Sargassum habitat. See Section 3.8.2.2.4.1 (Status and Management) for a 

description of these habitat types and supporting physical and biological factors. Wires and cables have 

no pathway to impact the physical and biological features identified for these habitats (National Marine 

Fisheries Service, 2014b) due to the low concentration of wires and cables that are expended, the sparse 

distribution of the wires and cables expended in the deeper offshore waters throughout the Study Area, 

the fact that the wires and cables sink upon release, and the physical properties and degradation time of 

the wires and cables.

Pursuant to the ESA, the use of wires and cables during training activities under Alternative 1 may affect 

ESA-listed green, hawksbill, Kemp’s ridley, leatherback, and loggerhead sea turtles; and would have no 

effect on the American crocodile. There would be no effect on green, hawksbill, leatherback, or 

loggerhead sea turtle critical habitat; and no effect on American crocodile critical habitat. The Navy has 

consulted with NMFS as required by section 7(a)(2) of the ESA in that regard.

Impacts from Wires and Cables under Alternative 1 for Testing Activities

As discussed in Section 3.0.3.3.5.1 (Wires and Cables), under Alternative 1 testing activities, fiber optic 

cables, guidance wires, and sonobuoy components that would pose an entanglement risk to sea turtles

would be similar to those described training activities, even though testing activities occur at a higher 

frequency and in more locations compared to training activities. Testing activities involving wires and 

cables occur at Virginia Capes Range Complex, Jacksonville Range Complex, Key West Range Complex, 

Northeast Range Complexes, Navy Cherry Point Range Complex, Gulf of Mexico Range Complex, Naval 

Undersea Warfare Center Newport Testing Range, Naval Surface Warfare Center Panama City Testing 

Range, and South Florida Ocean Measurement Facility (see Table 3.0-40). Wires would be expended 

with the greatest concentration in the Northeast Range Complexes, which account for 27,798 NM2 in 

size. If expended evenly throughout the area, there would be one wire per approximately 1 NM2. Fiber 

optic cables would be expended with greatest concentration in the Naval Surface Warfare Center, 

Panama City Testing Range, which is 7,966 NM2 in size, resulting in approximately one cable per 24 NM2

if expended evenly throughout the area.

Any species of sea turtle that occurs in the Study Area could at some time encounter expended cables or 

wires. Based on the numbers and geographic locations of their use, wires and cables most likely pose a 

risk of entanglement for hatchlings and pre-recruitment juveniles of all sea turtle species, and 

leatherback turtles of all age classes. Wires and cables may pose a slight risk to juvenile, sub-adult, and 

adult loggerhead, green, and hawksbill sea turtles that have recruited to benthic foraging grounds. 

However, wires and cables from sonobuoys would be expended in waters too deep for benthic foraging, 

so bottom-foraging sea turtles (e.g., loggerhead and green turtles) would not interact with these 
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materials once they sink. The sink rates of cables and wires would rule out the possibility of these 

drifting great distances into nearshore and coastal areas where juvenile, sub-adult, and adult green, 

hawksbill, Kemp’s ridley, and loggerhead sea turtles are more likely to occur and feed on the bottom. 

However, if wires and cables are expended in waters where the isobaths are not greater than the 

benthic foraging ability (dive depth), then juvenile, sub-adult, and adult loggerhead, green, and 

hawksbill sea turtles could be at risk of entanglement. For example, loggerheads may forage in benthic 

habitats as deep as approximately 200 meters (Hochscheid, 2014). Hatchlings and pre-recruitment 

juveniles of all sea turtle species may also occur in open-ocean habitats; however, the likelihood of 

impact is lower for these age classes due to their occurrence at or near the water surface by 

concentrated Sargassum mats. Activities will not be initiated near concentrated Sargassum mats due to 

the possible presence of sea turtles. Testing activities that use wires and cables may cause short-term or 

long-term disturbance to an individual turtle because if a sea turtle were to become entangled in a cable 

or wire, it could free itself, or the entanglement could lead to injury or death. Potential impacts of 

exposure to cable or wire may result in changes to an individual’s behavior, growth, survival, annual 

reproductive success, lifetime reproductive success (fitness), or species recruitment. However, cables 

and wires are generally expected to cause an insignificant impact to sea turtles because of (1) the 

physical characteristics of the cables and wires; (2) the behavior of the species, as sea turtles are unlikely 

to become entangled in an object that is resting on the seafloor; and (3) the low concentrations of 

expended wires and cables in the AFTT Study Area. Given the low concentration of expended wires and 

cables, and the patchy distribution of sea turtles and the wires and cables expended in the offshore 

waters throughout the Study Area, the likelihood of encountering a wire or cable and becoming 

entangled is low.

Proposed testing activities under Alternative 1 that expend wires and cables would not occur in 

designated critical habitat for the green sea turtle (Culebra Island), hawksbill sea turtle (Mona Island and 

Monita Island), leatherback sea turtle (St. Croix Island), or American crocodile (Florida Bay). Navy testing 

activities that expend wires and cables would occur year round within the five critical habitat types for 

the loggerhead turtle. See Section 3.8.2.2.4.1 (Status and Management) for a description of these 

habitat types and supporting physical and biological factors. Wires and cables have no pathway to 

impact the physical and biological features identified for these habitats (National Marine Fisheries 

Service, 2014b) due to the low concentration of wires and cables that are expended, the sparse 

distribution of the wires and cables expended in the deeper offshore waters throughout the Study Area, 

the fact that the wires and cables sink upon release, and the physical properties and degradation time of 

the wires and cables.

Pursuant to the ESA, the use of wires and cables during testing activities under Alternative 2 may affect 

ESA-listed green, hawksbill, Kemp’s ridley, leatherback, and loggerhead sea turtles; and will have no 

effect on the American crocodile. There would be no effect on green, hawksbill, leatherback, or 

loggerhead sea turtle critical habitat; and no effect on American crocodile critical habitat. The Navy has 

consulted with the NMFS as required by section 7(a)(2) of the ESA in that regard. 

3.8.3.5.1.2 Impacts from Wires and Cables under Alternative 2

Impacts from Wires and Cables under Alternative 2 for Training Activities

The locations of training activities that expend wires and cables are the same under Alternatives 1 and 2. 

Table 3.0-39 shows the number and location of wires and cables expended during proposed training 

activities. The numbers of wires and cables would be the same for Alternative 2 as for Alternative 1 
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except for increased numbers of sonobuoy wires in the Gulf of Mexico Range Complex, as well as 

increases in the number of bathythermograph wires in Virginia Capes, Navy Cherry Point, Jacksonville, 

and Gulf of Mexico Range Complexes. Overall, the number of wires (there would be no increases in the 

number of fiber optic cables) expended during training activities would increase by 2 percent annually 

and by 3 percent over five years. It should be noted that wires and cables would be expended in 

offshore deep water portions, and would not be an entanglement risk for sea turtles in inshore waters. 

Because activities under Alternative 2 occur at a similar rate and frequency relative to Alternative 1, 

entanglement stress experienced by sea turtles from guidance wires, fiber optic cables, and sonobuoy 

wires under Alternative 2 are not expected to be meaningfully different than those described under 

Alternative 1. Therefore, impacts associated with training activities under Alternative 2 are the same as 

Alternative 1.

As with Alternative 1, the use of wires and cables in training activities may cause short-term or 

long-term disturbance to an individual turtle, because if a sea turtle were to become entangled in a 

cable or wire, it could free itself or the entanglement could lead to injury or death. Potential impacts of 

exposure to cable or wire may result in changes to an individual’s behavior, growth, survival, annual 

reproductive success, lifetime reproductive success (fitness), or species recruitment. Potential impacts

of exposure to cables and wires are not expected to result in population-level impacts.

Proposed training activities under Alternative 2 that expend wires and cables would not occur in 

designated critical habitat for the green sea turtle (Culebra Island), hawksbill sea turtle (Mona Island and 

Monita Island), leatherback sea turtle (St. Croix Island), or American crocodile (Florida Bay). Navy 

training activities that expend wires and cables would not occur within the southeast portion of 

loggerhead critical habitat that is designated as breeding areas, but would occur in the following 

loggerhead turtle designated critical habitat year round: nearshore reproductive habitat, winter areas, 

migratory corridors, and Sargassum habitat. See Section 3.8.2.2.4.1 (Status and Management) for a 

description of these habitat types and supporting physical and biological factors. Wires and cables have 

no pathway to impact the physical and biological features identified for these habitats (National Marine 

Fisheries Service, 2014b) due to the low concentration of wires and cables that are expended, the sparse 

distribution of the wires and cables expended in the deeper offshore waters throughout the Study Area, 

the fact that the wires and cables sink upon release, and the physical properties and degradation time of 

the wires and cables.

Pursuant to the ESA, the use of wires and cables during training activities under Alternative 2 may affect 

ESA-listed green, hawksbill, Kemp’s ridley, leatherback, and loggerhead sea turtles; and will have no 

effect on the American crocodile. There would be no effect on green, hawksbill, leatherback, or 

loggerhead sea turtle critical habitat; and no effect on American crocodile critical habitat.

Impacts from Wires and Cables under Alternative 2 for Testing Activities

The locations of testing activities that expend wires and cables are nearly the same under Alternatives 1 

and 2. Table 3.0-40 shows the number and location of wires and cables expended during proposed 

testing activities. The numbers of wires and cables would mostly be the same for Alternative 2 as for 

Alternative 1 except for increased numbers sonobuoy wires expended in the Northeast, Virginia Capes, 

Navy Cherry Point, and Jacksonville Range Complexes. There would also be a slight increase in the 

number of fiber optic cables in Virginia Capes Range Complex and NSWC Panama City Testing Range 

under Alternative 2. Overall, the number of wires and cables expended during testing activities would 

increase by 0.6 percent annually and by 3 percent over five years. The differences in species overlap and 
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potential impacts from cables and wires on sea turtles during testing activities would not be discernible 

from those described for testing activities in Section 3.8.3.5.1.1 (Impacts from Wires and Cables under

Alternative 1). As with Alternative 1, the use of wires and cables in testing activities may cause shortterm or long-term disturbance to an individual turtle, because if a sea turtle were to become entangled 

in a cable or wire, it could free itself or the entanglement could lead to injury or death. Potential impacts

of exposure to cable or wire may result in changes to an individual’s behavior, growth, survival, annual 

reproductive success, lifetime reproductive success (fitness), or species recruitment. Potential impacts

of exposure to cables and wires are not expected to result in population-level impacts.

Proposed testing activities under Alternative 2 that expend wires and cables would not occur in 

designated critical habitat for the green sea turtle (Culebra Island), hawksbill sea turtle (Mona Island and 

Monita Island), leatherback sea turtle (St. Croix Island), or American crocodile (Florida Bay). Navy testing 

activities that expend wires and cables would occur year round within the five critical habitat types for 

the loggerhead turtle. See Section 3.8.2.2.4.1 (Status and Management) for a description of these 

habitat types and supporting physical and biological factors. Wires and cables have no pathway to 

impact the physical and biological features identified for these habitats (National Marine Fisheries 

Service, 2014b) due to the low concentration of wires and cables that are expended, the sparse 

distribution of the wires and cables expended in the deeper offshore waters throughout the Study Area, 

the fact that the wires and cables sink upon release, and the physical properties and degradation time of 

the wires and cables.

Pursuant to the ESA, the use of wires and cables during testing activities under Alternative 2 may affect 

ESA-listed green, hawksbill, Kemp’s ridley, leatherback, and loggerhead sea turtles; and will have no 

effect on the American crocodile. There would be no effect on green, hawksbill, leatherback, or 

loggerhead sea turtle critical habitat; and no effect on American crocodile critical habitat.

3.8.3.5.1.3 Impacts from Wires and Cables under the No Action Alternative

Impacts from Wires and Cables under the No Action Alternative for Training and Testing Activities

Under the No Action Alternative, the Navy would not conduct the proposed training or testing activities 

in the AFTT Study Area. Various entanglement stressors (e.g., wires and cables) would not be introduced 

into the marine environment. Therefore, baseline conditions of the existing environment would either 

remain unchanged or would improve slightly after cessation of ongoing training and testing activities.

3.8.3.5.2 Impacts from Decelerators/Parachutes

Section 3.0.3.3.5.2 (Decelerators/Parachutes) describes the types of decelerators/parachutes used 

during training and testing activities, while Section 3.0.3.3.4.2 (Military Expended Materials) provides 

the number and location of decelerators/parachutes expended during training and testing activities. 

Training and testing activities that introduce decelerators/parachutes into the water column can occur 

anywhere in the AFTT Study Area and may pose an entanglement risk to sea turtles. Potential impacts 

from decelerators/parachutes as ingestion stressors to sea turtles are discussed in Section 3.8.3.6.2.1

(Impacts from Military Expended Materials Other Than Munitions under Alternative 1).

Some aerial targets use large and extra-large decelerators/parachutes (see Section 3.0.3.3.5.2,

Decelerators/Parachutes). Large decelerators/parachutes are up to 50 ft. in diameter and extra-large 

decelerators/parachutes are up to 80 ft. in diameter. The majority of these larger-sized 

decelerators/parachutes that would be expended are the large parachutes, with a small amount of 

extra-large decelerators/parachutes being expended. The large and extra-large decelerators/parachutes 
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have long attachment cords (up to 70 ft. and 82 ft. in length, respectively), and upon water impact may 

remain at the surface for up to 5 minutes before eventually sinking to the seafloor. As previously stated, 

the rate of sinking depends upon sea conditions and the shape of the decelerator/parachute, and the 

duration of the descent would depend on the water depth. The decelerators/parachutes that are 

associated with shore-launched aerial targets have the potential to be recovered, if safety allows for it;

however, this analysis assumes the decelerators/parachutes are not recovered.

While in the water column, a sea turtle is less likely to become entangled because the 

decelerator/parachute would have to land directly on the turtle, or the turtle would have to swim into 

the decelerator/parachute or its cords before it sank. This is the case for the small and medium 

decelerators/parachutes; however, the likelihood for entanglement is higher for the large and extralarge decelerators/parachutes due to their size and the length of the attachment cords. Prior to reaching 

the seafloor, the decelerator/parachute could be carried along in a current, or snagged on a hard 

structure near the bottom. Conversely, the decelerator/parachute and associated cords could settle to 

the bottom, where they would be buried by sediment in most soft bottom areas or colonized by 

attaching and encrusting organisms, which would further stabilize the material and reduce the potential 

for reintroduction as an entanglement risk. Decelerators/parachutes or decelerator/parachute cords 

may be a risk for sea turtles to become entangled, particularly while at the surface. A sea turtle would 

have to surface to breathe or grab prey from under the decelerator/parachute and swim into the 

decelerator/parachute or its cords in order to become entangled. 

If bottom currents are present, the canopy may billow and pose an entanglement threat to sea turtles 

that feed in benthic habitats (i.e., green, Kemp’s ridley, hawksbill, and loggerhead sea turtles). Bottomfeeding sea turtles tend to forage in nearshore and coastal areas rather than offshore, where some of 

these decelerators/parachutes are used. The small and medium decelerators/parachutes would be 

expended in offshore waters too deep for benthic foraging, so bottom-foraging sea turtles would not 

interact with these materials once they sink; therefore, sea turtles are not likely to encounter small and 

medium decelerators/parachutes once they reach the seafloor. However, some of the large and extralarge decelerators/parachutes have the potential to be expended near shore, therefore posing more of 

an entanglement risk to bottom-feeding sea turtles. Hatchlings and pre-recruitment juveniles would not 

likely be able to escape entrapment if they became entangled in a decelerator/parachute at or near the 

water surface. The potential for a sea turtle to encounter an expended small or medium 

decelerator/parachute at the surface or in the water column is extremely low, and is even less probable 

at the seafloor, given the general improbability of a sea turtle being near the deployed 

decelerator/parachute, the sparse distribution of the small and medium decelerators/parachutes 

expended throughout the Study Area, as well as the patchy distribution and general behavior of sea 

turtles; therefore, potential impacts are anticipated to be insignificant. The potential for a sea turtle to 

encounter an expended large or extra-large parachute at the surface, in the water column, or on the 

seafloor is a possibility due to their size and the length of the attachment cords as well as the potentially 

concentrated distribution of these decelerators/parachutes within the nearshore waters of the Study 

Area where there is a higher concentration of some sea turtle species; therefore, potential impacts may 

be significant. Depending on how quickly the decelerator/parachute may degrade, the risk may increase 

with time if the decelerator/parachute remains intact or if underwater currents delay settling of the 

decelerator/parachute on the seafloor (where they would likely be covered by sediment and encrusted). 

Factors that may influence degradation times include exposure to ultraviolet radiation and the extent of 

physical damage of the decelerator/parachute on the water’s surface, as well as water temperature and 
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sinking depth. It should be noted that no known instances of sea turtle entanglement with a 

decelerator/parachute assembly have been reported.

3.8.3.5.2.1 Impacts from Decelerators/Parachutes under Alternative 1

Impacts from Decelerators/Parachutes under Alternative 1 for Training Activities

Training activities under the Proposed Action would expend decelerators/parachutes within the 

Northeast, Virginia Capes, Navy Cherry Point, Jacksonville, Key West, and Gulf of Mexico Range 

Complexes, along with other areas outside the Range Complexes within the AFTT Study Area. The area 

with the greatest concentration of small and medium expended decelerators/parachutes would be 

within the Jacksonville Range Complex, where one decelerator/parachute would be expended per 

2 NM2, if evenly distributed throughout the area. It should be noted that the small and medium 

decelerators/parachutes would be expended in offshore deep water portions and would not be an 

entanglement risk for sea turtles in inshore waters. The area with the greatest concentration of large 

and extra-large expended decelerators/parachutes would be within the Virginia Capes Range Complex. 

These types of decelerators/parachutes would have the potential to be expended from shore seaward. 

Any species of sea turtle that occurs in the Study Area could at some time encounter an expended 

decelerator/parachute. Based on the numbers and geographic locations of their use, decelerators/ 

parachutes and decelerator/parachute cords pose a risk of entanglement for all age classes of any sea 

turtle species. The sink rates of a small and medium decelerator/parachute assembly would rule out the 

possibility of these drifting great distances into nearshore and coastal areas where juvenile, sub-adult,

and adult green, hawksbill, Kemp’s ridley, and loggerhead sea turtles are more likely to occur and feed 

on the bottom. Although these species may feed along the seafloor, they surface periodically to breathe 

while feeding and moving between nearshore habitats. Kemp’s ridley sea turtles can spend extended 

periods foraging at depth, even in open ocean areas (Sasso & Witzell, 2006; Seney, 2016; Servis et al., 

2015). Leatherback turtles of all age classes are more likely to feed at or near the surface in open ocean 

areas, but sub-adult and adult leatherbacks may also forage at the surface and throughout the water 

column in coastal and sometimes estuarine waters. Hatchlings and pre-recruitment juveniles of all sea 

turtle species may co-occur with these activities, since these age classes occur in open-ocean habitats at 

or near the water surface and are usually affiliated with concentrated Sargassum mats. However, 

activities expending small and medium decelerators/parachutes will not be initiated near concentrated 

Sargassum mats due to the possible presence of sea turtles, further reducing the low likelihood of 

encountering an expended small or medium decelerator/parachute and entanglement risk (see Section 

5.3, Procedural Mitigation to be Implemented). 

Over the continental shelf and within nearshore waters, juveniles, sub-adults, and adults of all sea turtle 

species that have recruited to coastal foraging grounds are at risk of entanglement from the expended 

large and extra-large decelerators/parachutes because of greater densities of sea turtles and the 

potential location of these expended decelerators/parachutes (nearshore seaward). Hatchlings of all sea 

turtle species would also be present very briefly as they leave the nest, enter the water, and move to 

offshore areas to develop. Hatchlings would only be present a few months of the year between summer 

and fall from southern Virginia and further south. Green, Kemp’s ridley, and loggerhead sea turtles are 

the only species that nest as far north as Virginia. Leatherback turtles may nest as far north as North 

Carolina. Only rare nesting activity occurs in parts of Florida for the hawksbill turtle (National Marine 

Fisheries Service & U.S. Fish and Wildlife Service, 2013a). Therefore, sea turtle species that occur over 

the continental shelf and within nearshore waters would have a greater potential for impacts.
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For training activities under Alternative 1, exposure to decelerators/parachutes used in training activities 

may cause short-term or long-term disturbance to an individual turtle, because if a sea turtle were to 

become entangled in a decelerator/parachute, it could free itself, or the entanglement could lead to 

injury or death. Based on the general discussion presented above and in Section 3.0.3.3.5.2 

(Decelerators/Parachutes), small and medium decelerators/parachutes and the associated cords are 

generally expected to cause an insignificant impact to sea turtles. However, large and extra-large 

decelerators/parachutes and the associated cords have the potential to cause a significant impact to sea 

turtles. Potential impacts of exposure to decelerator/parachute may result in changes to an individual’s 

behavior, growth, survival, annual reproductive success, lifetime reproductive success (fitness), or 

species recruitment. Given the number, location and size of the decelerators/parachutes and the 

associated cords there is the potential for disturbance to sea turtles if the decelerator/parachute were 

to land directly on an animal or an animal were to swim into it before it sinks. It is possible that a benthic 

feeding sea turtle could become entangled when foraging in areas where decelerators/parachutes have 

settled on the seafloor. For example, if bottom currents are present, the canopy may temporarily billow 

and pose a greater entanglement threat.

Potential impacts of exposure to decelerators/parachutes may result in substantial changes in an 

individual’s behavior, growth, survival, annual reproductive success, lifetime reproductive success 

(fitness), or species recruitment. Given the number and location of expended large and extra-large 

decelerators/parachutes, and the density of sea turtles in the area, the possibility of entanglement 

cannot be discounted; however, potential impacts of exposure to decelerators/parachutes are not 

expected to result in population-level impacts for all sea turtle species.

Given the high amount of high-speed vessel movement hours, the inshore water locations of where 

these activities would occur, and species’ distribution throughout the Study Area, co-occurrence with 

individuals of loggerhead, green, Kemp’s ridley, and leatherback turtles are likely, especially in the 

Virginia Capes Range Complex.

Proposed training activities under Alternative 1 that use decelerators/parachutes would not occur in 

designated critical habitat for the green sea turtle (Culebra Island), hawksbill sea turtle (Mona Island and 

Monita Island), leatherback sea turtle (St. Croix Island), or American crocodile (Florida Bay). Navy 

training activities that expend decelerators/parachutes would occur year round within the five critical 

habitat types for the loggerhead turtle. See Section 3.8.2.2.4.1 (Status and Management) for a 

description of these habitat types and supporting physical and biological factors. 

Decelerators/parachutes have no pathway to impact the physical and biological features identified for 

these habitats (National Marine Fisheries Service, 2014b) due to the low concentration of 

decelerators/parachutes that are expended, the sparse distribution of the decelerators/parachutes 

expended in the deeper offshore waters throughout the Study Area, the fact that assemblies are 

designed to sink rapidly through the water column.

Pursuant to the ESA, the use of decelerators/parachutes during training activities under Alternative 1 

may affect ESA-listed green, hawksbill, Kemp’s ridley, leatherback, and loggerhead sea turtles; and will 

have no effect on the American crocodile. There would be no effect on green, hawksbill, leatherback, or 

loggerhead sea turtle critical habitat; and no effect on American crocodile critical habitat. The Navy has 

consulted with NMFS as required by section 7(a)(2) of the ESA in that regard.
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Impacts from Decelerators/Parachutes under Alternative 1 for Testing Activities

Testing activities under Alternative 1 testing activities would expend decelerators/parachutes primarily 

within the Northeast, Virginia Capes, Navy Cherry Point, Jacksonville, Key West, and Gulf of Mexico 

Range Complexes. Other locations include the Naval Undersea Warfare Center Newport Testing Range; 

South Florida Ocean Measurement Facility Testing Range; and the Naval Surface Warfare Center,

Panama City Testing Range. Small and medium decelerators/parachutes would be expended with 

greatest concentration in the Virginia Capes Range Complex; approximately one decelerator/parachute 

would be expended per 3 NM2, if evenly distributed throughout the area. It should be noted that small 

and medium decelerators/parachutes would be expended in offshore deep water portions and would 

not be an entanglement risk for sea turtles in inshore waters. The area with the greatest concentration 

of large expended decelerators/parachutes would be within the Virginia Capes Range Complex. This 

type of decelerator/parachute has the potential to be expended from shore seaward. Fewer 

decelerators/parachutes of this size will be expended during testing activities compared to training 

activities. Extra-large decelerators/parachutes would not be expended during testing activities. 

Any species of sea turtle that occurs in the Study Area could at some time encounter an expended 

decelerator/parachute. Based on the numbers and geographic locations of their use, decelerators/ 

parachutes and decelerator/parachute lines pose a risk of entanglement for all age classes of any sea 

turtle species. The sink rates of a small and medium decelerator/parachute assembly would rule out the 

possibility of these drifting great distances into nearshore and coastal areas where juvenile, sub-adult, 

and adult green, hawksbill, Kemp’s ridley, and loggerhead sea turtles are more likely to occur and feed 

on the bottom. Although these species may feed along the seafloor, they surface periodically to breathe 

while feeding and moving between nearshore habitats. Kemp’s ridley sea turtles can spend extended 

periods foraging at depth, even in open ocean areas (Sasso & Witzell, 2006; Seney, 2016; Servis et al., 

2015). Leatherback turtles of all age classes are more likely to feed at or near the surface in open ocean 

areas, but sub-adult and adult leatherbacks may also forage at the surface and throughout the water 

column in coastal and sometimes estuarine waters. Hatchlings and pre-recruitment juveniles of all sea 

turtle species may also co-occur with these activities, since these age classes occur in open-ocean 

habitats at or near the water surface and are usually affiliated with concentrated Sargassum mats. 

However, activities will not be initiated near concentrated Sargassum mats due to the possible presence 

of sea turtles, further reducing the low likelihood of encountering an expended small or medium 

decelerator/parachute and entanglement risk. 

Over the continental shelf and within nearshore waters, juveniles, sub-adults, and adults of all sea turtle 

species that have recruited to coastal foraging grounds, are at risk of entanglement from the expended 

large decelerators/parachutes because of greater densities of sea turtles and the potential location of 

these expended decelerators/parachutes (nearshore seaward). Hatchlings of all sea turtle species would 

also be present very briefly as they leave the nest, enter the water, and move to offshore areas to 

develop. Hatchlings would only be present a few months of the year between summer and fall from 

southern Virginia and further south. Green, Kemp’s ridley, and loggerhead turtles are the only species 

that nest as far north as Virginia. Leatherback turtles may nest as far north as North Carolina. Only rare 

nesting activity occurs in parts of Florida for the hawksbill turtle (National Marine Fisheries Service & 

U.S. Fish and Wildlife Service, 2013a). Therefore, sea turtle species that occur over the continental shelf

and within nearshore waters would have a greater potential for impacts.

Exposure to decelerators/parachutes used in testing activities may cause short-term or long-term 

disturbance to an individual turtle, because if a sea turtle were to become entangled in a 

decelerator/parachute, it could free itself, or the entanglement could lead to injury or death. Based on 
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the general discussion presented above, small and medium decelerators/parachutes and the associated 

cords are generally expected to cause an insignificant impact to sea turtles. Large 

decelerators/parachutes and the associated cords have the potential to cause a significant impact to sea 

turtles; however, decelerators/parachutes are not as frequently expended during testing activities, and 

therefore the likelihood of an impact is low. Potential impacts of exposure to decelerator/parachute 

may result in changes to an individual’s behavior, growth, survival, annual reproductive success, lifetime 

reproductive success (fitness), or species recruitment. Given the location and size of the 

decelerators/parachutes and the associated cords there is the potential for disturbance to sea turtles if 

the decelerator/parachute were to land directly on an animal, or an animal were to swim into it before 

it sinks, although the likelihood of this type of disturbance is low. It is possible that a benthic feeding sea 

turtle could become entangled when foraging in areas where decelerators/parachutes have settled on 

the seafloor. For example, if bottom currents are present, the canopy may temporarily billow and pose a 

greater entanglement threat. However, the potential for a sea turtle to encounter an expended 

decelerator/parachute at the surface or in the water column is low, and it is even less probable at the 

seafloor, given the general improbability of a sea turtle being near the deployed decelerator/parachute

and the distribution of sea turtles and of the decelerators/parachutes expended throughout the Study 

Area.

Based on the number of decelerators/parachutes expended under testing activities for the Proposed 

Action, the small footprint of impact, and the low likelihood of a decelerator/parachute assembly 

landing directly on a sea turtle or a sea turtle swimming directly into it, insignificant impacts on sea 

turtles are anticipated. While entanglement is a serious stressor for sea turtles from a wide range of 

debris in the ocean, decelerators/parachutes used during military testing activities are an unlikely 

source.

Potential impacts of exposure to decelerators/parachutes are not expected to result in substantial 

changes in an individual’s behavior, growth, survival, annual reproductive success, lifetime reproductive 

success (fitness), or species recruitment, and as such are not expected to result in population-level

impacts for all sea turtle species from testing activities under Alternative 1.

Proposed testing activities under Alternative 1 that use decelerators/parachutes would not occur in 

designated critical habitat for the green sea turtle (Culebra Island), hawksbill sea turtle (Mona Island and 

Monita Island), leatherback sea turtle (St. Croix Island), or American crocodile (Florida Bay). Navy testing 

activities that expend decelerators/parachutes would occur year round within the five critical habitat 

types for the loggerhead turtle. See Section 3.8.2.2.4.1 (Status and Management) for a description of 

these habitat types and supporting physical and biological factors. Decelerators/parachutes have no 

pathway to impact the physical and biological features identified for these habitats (National Marine 

Fisheries Service, 2014b) due to the low concentration of decelerators/parachutes that are expended, 

the sparse distribution of the decelerators/parachutes expended in the deeper offshore waters 

throughout the Study Area, and the fact that assemblies are designed to sink rapidly through the water 

column upon release and either break down or be encrusted with benthic organisms if settled on the 

seafloor.

Pursuant to the ESA, the use of decelerators/parachutes during testing activities under Alternative 1

may affect ESA-listed green, hawksbill, Kemp’s ridley, leatherback, and loggerhead sea turtles; and will 

have no effect on the American crocodile. There would be no effect on green, hawksbill, leatherback, or 

loggerhead sea turtle critical habitat; and no effect on American crocodile critical habitat. The Navy has 

consulted with NMFS as required by section 7(a)(2) of the ESA in that regard.
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3.8.3.5.2.2 Impacts from Decelerators/Parachutes under Alternative 2

Impacts from Decelerators/Parachutes under Alternative 2 for Training Activities

Under Alternative 2, the number of decelerators/parachutes that would be expended during training 

activities would be similar to Alternative 1 within Northeast, Virginia Capes, Navy Cherry Point, 

Jacksonville, and Key West Range Complexes, and entanglement stress experienced by sea turtles from 

decelerators/parachutes under Alternative 2 is not expected to be meaningfully different than what is

described under Alternative 1. Therefore, the impact conclusion for decelerators/parachutes under 

Alternative 2 training activities is the same as for Alternative 1. Within the Gulf of Mexico Range 

Complex, the number of parachutes would increase compared to Alternative 1; thereby exposing more 

sea turtles in open ocean habitats within the Gulf of Mexico.

Proposed training activities under Alternative 2 that use decelerators/parachutes would not occur in 

designated critical habitat for the green sea turtle (Culebra Island), hawksbill sea turtle (Mona Island and 

Monita Island), leatherback sea turtle (St. Croix Island), or American crocodile (Florida Bay). Navy testing 

activities that expend decelerators/parachutes would occur year round within the five critical habitat 

types for the loggerhead turtle. See Section 3.8.2.2.4.1 (Status and Management) for a description of 

these habitat types and supporting physical and biological factors. Decelerators/parachutes have no 

pathway to impact the physical and biological features identified for these habitats (National Marine 

Fisheries Service, 2014b) due to the low concentration of decelerators/parachutes that are expended, 

the sparse distribution of the decelerators/parachutes expended in the deeper offshore waters 

throughout the Study Area, and the fact that assemblies are designed to sink rapidly through the water 

column upon release and either break down or be encrusted with benthic organisms if settled on the 

seafloor.

Pursuant to the ESA, the use of decelerators/parachutes during training activities under Alternative 2 

may affect ESA-listed green, hawksbill, Kemp’s ridley, leatherback, and loggerhead sea turtles; and will 

have no effect on the American crocodile. There would be no effect on green, hawksbill, leatherback, or 

loggerhead sea turtle critical habitat; and no effect on American crocodile critical habitat.

Impacts from Decelerators/Parachutes under Alternative 2 for Testing Activities

The locations of testing activities that expend decelerators/parachutes are the same under Alternatives 

1 and 2. However, the total number of decelerators/parachutes expended during testing activities would 

increase by approximately 2 percent annually and by 8 percent over five years. This level of increase is 

not expected to appreciably increase the risk of entanglement to sea turtles that occur in these areas. 

Potential impacts from testing activities that expend decelerators/parachutes presented in Section

3.8.3.5.2.1 (Impacts from Decelerators/Parachutes under Alternative 1) for testing activities would be 

applicable to testing activities under Alternative 2. Therefore, the Navy anticipates that no sea turtles 

would become entangled in decelerators/parachutes.

Proposed testing activities under Alternative 2 that use decelerators/parachutes would not occur in 

designated critical habitat for the green sea turtle (Culebra Island), hawksbill sea turtle (Mona Island and 

Monita Island), leatherback sea turtle (St. Croix Island), or American crocodile (Florida Bay). Navy testing 

activities that expend decelerators/parachutes would occur year round within the five critical habitat 

types for the loggerhead turtle. See Section 3.8.2.2.4.1 (Status and Management) for a description of 

these habitat types and supporting physical and biological factors. Decelerators/parachutes have no 

pathway to impact the physical and biological features identified for these habitats (National Marine 
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Fisheries Service, 2014b) due to the low concentration of decelerators/parachutes that are expended, 

the sparse distribution of the decelerators/parachutes expended in the deeper offshore waters 

throughout the Study Area, and the fact that assemblies are designed to sink rapidly through the water 

column upon release and either break down or be encrusted with benthic organisms if settled on the 

seafloor.

Pursuant to the ESA, the use of decelerators/parachutes during testing activities under Alternative 2 

may affect ESA-listed green, hawksbill, Kemp’s ridley, leatherback, and loggerhead sea turtles; and will 

have no effect on the American crocodile. There would be no effect on green, hawksbill, leatherback, or 

loggerhead sea turtle critical habitat; and no effect on American crocodile critical habitat.

3.8.3.5.2.3 Impacts from Decelerators/parachutes under the No Action Alternative

Impacts from Decelerators/parachutes under the No Action Alternative for Training and Testing 

Activities

Under the No Action Alternative, the Navy would not conduct the proposed training or testing activities 

in the AFTT Study Area. Various entanglement stressors (e.g., decelerators/parachutes) would not be 

introduced into the marine environment. Therefore baseline conditions of the existing environment 

would either remain unchanged or would improve slightly after cessation of ongoing training and 

testing activities.

3.8.3.5.3 Impacts from Biodegradable Polymer

For a discussion of the types of activities that use biodegradable polymers see Appendix B (Activity 

Stressor Matrices) and for a discussion on where they are used and how many activities would occur 

under each alternative, see Section 3.0.3.3.5.3 (Biodegradable Polymer). Navy activities that involve 

vessel entanglement systems include the development of the biodegradable polymer and would be 

associated with testing activities in the AFTT Study Area. As indicated by its name, vessel entanglement 

systems that make use of biodegradable polymers are designed to entangle the propellers of in-water 

vessels, which would significantly slow and potentially stop the advance of the vessel. A biodegradable 

polymer is a high molecular weight polymer that degrades to smaller compounds as a result of 

microorganisms and enzymes. The rate of biodegradation could vary from hours to years and the type of 

small molecules formed during degradation can range from complex to simple products, depending on 

whether the polymers are natural or synthetic (Karlsson & Albertsson, 1998). Based on the constituents 

of the biodegradable polymer the Navy proposes to use, it is anticipated that the material will 

breakdown into small pieces within a few days to weeks. This will breakdown further and dissolve into 

the water column within weeks to a few months. The final products which are all environmentally 

benign will be dispersed quickly to undetectable concentrations. Unlike other entanglement stressors, 

biodegradable polymers only retain their strength for a relatively short period of time, therefore the 

potential for entanglement by a sea turtle would be limited. Furthermore, the longer the biodegradable 

polymer remains in the water, the weaker it becomes making it more brittle and likely to break. A sea 

turtle would have to encounter the biodegradable polymer immediately after it was expended for it to 

be a potential entanglement risk. If an animal were to encounter the polymer a few hours after it was 

expended, it is very likely that it would break easily and would no longer be an entanglement stressor.

Hatchlings, however, would not likely be able to escape entrapment if they became entangled in a 

biodegradable polymer if entanglement occurred. Biodegradable polymers would only be a risk to 

hatchlings while the biodegradable polymer retained its tensile strength. As stated above for larger life 

stages, this is likely in the timeframe of a few hours after expending, but for hatchlings, a lower tensile 
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strength would be required; therefore, the risk to hatchlings would extend over weeks. Due to the wide 

dispersion and low numbers of biodegradable polymers as well as the patchy distribution of sea turtles, 

there is a low likelihood of sea turtles, especially hatchlings, interacting with biodegradable polymers 

while they are an entanglement risk.

3.8.3.5.3.1 Impacts from Biodegradable Polymer under Alternative 1

Impacts from Biodegradable Polymer under Alternative 1 for Training Activities

Biodegradable polymers would not be used during Navy training activities under Alternative 1.

Impacts from Biodegradable Polymer under Alternative 1 for Testing Activities

Testing activities under the Proposed Action that use biodegradable polymers would be conducted 

within the Virginia Capes, Jacksonville, Key West, and Gulf of Mexico Range Complexes, as well as the 

Naval Undersea Warfare Division, Newport Testing Range. The number of testing activities involving 

biodegradable polymers conducted in these areas is relatively low, as discussed in Section 3.0.3.3.5.3 

(Biodegradable Polymer) and shown in Table 3.0-42.

Based on the geographic locations of their use and the fact that they may be expended within the 

coastal zone (3 or 9 NM from shore depending on the state), biodegradable polymers could have the 

potential to impact all age classes of all sea turtle species. Hatchlings and pre-recruitment juveniles of all 

sea turtle species, occasionally adult loggerhead turtles, and leatherback turtles of all age classes would 

most likely be impacted if biodegradable polymers were expended in offshore waters of the Virginia 

Capes, Jacksonville, Key West, and Gulf of Mexico Range Complexes, as well as the Naval Undersea 

Warfare Division, Newport Testing Range. Sea turtles are expected to be highly dispersed in offshore 

waters, and co-occurrence with testing activities is unlikely.

For testing activities that may occur within the coastal zone, juvenile, sub-adult, and adult loggerhead, 

green, Kemp’s ridley and hawksbill sea turtles that have recruited to benthic foraging grounds in coastal 

waters would most likely be impacted. Sub-adult and adult leatherbacks that forage at the surface and 

throughout the water column in coastal waters may also be impacted. Hatchlings of all sea turtle species 

would also be present very briefly as they leave the nest, enter the water, and move to offshore areas to 

develop. Hatchlings would only be present a few months of the year from southern Virginia and further 

south. Green, Kemp’s ridley, and loggerhead sea turtles are the only species that nest as far north as 

Virginia. Leatherback sea turtles may nest as far north as North Carolina. Only rare nesting activity 

occurs in parts of Florida for the hawksbill sea turtle (National Marine Fisheries Service & U.S. Fish and 

Wildlife Service, 2013a). 

No more than 30 testing events using biodegradable polymers are planned per year in the Virginia 

Capes, Jacksonville, Key West, and Gulf of Mexico Range Complexes, as well as the Naval Undersea 

Warfare Division, Newport Testing Range. Given the very low number of events and species’ 

distribution, co-occurrence with individuals of any species is very unlikely, especially in northern areas.

Based on the general discussion presented above and in Section 3.8.3.5.3 (Impacts from Biodegradable 

Polymer), biodegradable polymers are generally expected to cause a discountable impact to all sea 

turtle species. Provided the low level of activity, the concentration of these items being expended

throughout these areas is likewise considered low, which would result in a very low potential for all sea 

turtles to encounter biodegradable polymers. In addition, there is only a short duration that a sea turtle 

would be exposed to an entanglement risk due to the physical properties of the biodegradable polymer, 

further making the likelihood of entanglement extremely low. The Navy does not anticipate that any sea 

turtles would become entangled with biodegradable polymers.
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Potential impacts of exposure to biodegradable polymers are not expected to result in substantial 

changes in an individual’s behavior, growth, survival, annual reproductive success, lifetime reproductive 

success (fitness), or species recruitment, and as such are not expected to result in population-level

impacts for all sea turtle species.

Proposed testing activities under Alternative 1 that use biodegradable polymers would not occur in 

designated critical habitat for the green sea turtle (Culebra Island), hawksbill sea turtle (Mona Island and 

Monita Island), leatherback sea turtle (St. Croix Island), or American crocodile (Florida Bay). Navy testing 

activities that expend biodegradable polymers would occur year round within the five critical habitat

types for the loggerhead turtle. See Section 3.8.2.2.4.1 (Status and Management) for a description of 

these habitat types and supporting physical and biological factors. Biodegradable polymers have no 

pathway to impact the physical and biological features identified for these habitats (National Marine 

Fisheries Service, 2014b) due to the low concentration of biodegradable polymers that are expended, 

the sparse distribution of the biodegradable polymers expended throughout the Study Area, and the 

fact that biodegradable polymers are expected to degrade rapidly in water with the final products 

dispersed quickly to undetectable concentrations.

Pursuant to the ESA, the use of biodegradable polymers during testing activities under Alternative 1 may 

affect ESA-listed green, hawksbill, Kemp’s ridley, leatherback, and loggerhead sea turtles; and will have 

no effect on the American crocodile. There would be no effect on green, hawksbill, leatherback, or 

loggerhead sea turtle critical habitat; and no effect on American crocodile critical habitat. The Navy has 

consulted with NMFS as required by section 7(a)(2) of the ESA in that regard.

3.8.3.5.3.2 Impacts from Biodegradable Polymer under Alternative 2

Impacts from Biodegradable Polymer under Alternative 2 for Training Activities

Biodegradable polymers would not be used during Navy training activities under Alternative 2.

Impacts from Biodegradable Polymer under Alternative 2 for Testing Activities

The location and number of testing activities that expend biodegradable polymers under Alternative 2 

would be identical to what is proposed under Alternative 1. The analysis presented in Section 3.8.3.5.3.1 

(Impacts from Biodegradable Polymer under Alternative 1) for testing activities would also apply to 

Alternative 2.

Proposed testing activities under Alternative 2 that use biodegradable polymers would not occur in 

designated critical habitat for the green sea turtle (Culebra Island), hawksbill sea turtle (Mona Island and 

Monita Island), leatherback sea turtle (St. Croix Island), or American crocodile (Florida Bay). Navy testing 

activities that expend biodegradable polymers would occur year round within the five critical habitat 

types for the loggerhead turtle. See Section 3.8.2.2.4.1 (Status and Management) for a description of 

these habitat types and supporting physical and biological factors. Biodegradable polymers have no 

pathway to impact the physical and biological features identified for these habitats (National Marine 

Fisheries Service, 2014b) due to the low concentration of biodegradable polymers that are expended, 

the sparse distribution of the biodegradable polymers expended throughout the Study Area, and the 

fact that biodegradable polymers are expected to degrade rapidly in water with the final products 

dispersed quickly to undetectable concentrations.

Pursuant to the ESA, the use of biodegradable polymers during testing activities under Alternative 2 may 

affect ESA-listed green, hawksbill, Kemp’s ridley, leatherback, and loggerhead sea turtles; and will have 
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no effect on the American crocodile. There would be no effect on green, hawksbill, leatherback, or 

loggerhead sea turtle critical habitat; and no effect on American crocodile critical habitat.

3.8.3.5.3.3 Impacts from Biodegradable Polymer under the No Action Alternative 

Impacts from Biodegradable Polymer under the No Action Alternative for Training and Testing 

Activities

Under the No Action Alternative, the Navy would not conduct the proposed testing activities in the AFTT 

Study Area. Biodegradable polymer use is not a part of ongoing Navy activities in the Study Area and this 

entanglement stressor would not be introduced into the marine environment under the No Action 

Alternative. Therefore, no change in baseline conditions of the existing environment would occur.

3.8.3.6 Ingestion Stressors

This section analyzes the potential impacts of the various types of ingestion stressors used during 

training and testing activities within the Study Area. This analysis includes the potential impacts from the 

following types of military expended materials: non-explosive practice munitions (small- and mediumcaliber), fragments from high-explosives, fragments from targets, chaff, flare casings (including plastic 

end caps and pistons), decelerators/parachutes, and biodegradable polymers. For a discussion on the 

types of activities that use these materials refer to Appendix B (Activity Stressor Matrices) and for a 

discussion on the various types of ingestion stressors, see Section 3.0.3.3.6 (Ingestion stressors); for the 

amounts and locations of each ingestion stressor used under each alternative, see Section 3.0.3.3.4.2 

(Military Expended Materials). General discussion of impacts can also be found in Section 3.0.3.6.5 

(Conceptual Framework for Assessing Effects from Ingestion). These activities would occur in offshore 

and inshore training and testing locations that overlap with all species of sea turtles, American alligators, 

and diamondback terrapins. Because military expended materials would not be used in areas that 

overlap with the American crocodile known range or critical habitat designated for this species, the 

American crocodile is not analyzed for potential ingestion risks from expending materials during training 

or testing activities.

The potential impacts from ingesting these materials is dependent upon the probability of the animal 

encountering these items in their environment, which is primarily contingent on where the items are 

expended and how a sea turtle feeds. Sea turtles commonly mistake debris for prey, and ingestion can 

cause injury or mortality. The United Nations Environment Program estimates that approximately 6.4 

million tons of anthropogenic debris enters the marine environment every year (United Nations 

Environmental Program, 2005). Plastic is the primary type of debris found in marine and coastal 

environments, and plastics are the most common type of marine debris ingested by sea turtles (Schuyler 

et al., 2014). Sea turtles can mistake debris for prey; one study found 37 percent of dead leatherback 

turtles to have ingested various types of plastic (Mrosovsky et al., 2009), and Narazaki et al. (2013)

noted an observation of a loggerhead exhibiting hunting behavior on approach to a plastic bag, possibly 

mistaking the bag for a jelly fish. Even small amounts of plastic ingestion can cause an obstruction in a 

sea turtle’s digestive track and mortality (Bjorndal et al., 1994; Bjorndal, 1997), and hatchlings are at risk 

for ingesting small plastic fragments. Ingested plastics can also release toxins, such as bisphenol-A 

(commonly known as “BPA”) and phthalates, or absorb heavy metals from the ocean and release those 

into tissues (Fukuoka et al., 2016; Teuten et al., 2007). The risk is prolific throughout sea turtle habitats;

ingestion of expended materials by sea turtles could occur in all large marine ecosystems and open 

ocean areas and can occur at the surface, in the water column, or at the seafloor, depending on the size 

and buoyancy of the expended object and the feeding behavior of the turtle. Life stage and feeding 

preference affects the likelihood of ingestion. Turtles living in oceanic or coastal environments and 
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feeding in the open ocean or on the seafloor may encounter different types and densities of debris, and 

may therefore have different probabilities of ingesting debris. For example, floating material could be 

eaten by turtles such as leatherbacks (all age classes), and by juveniles and hatchlings of all species that 

feed at or near the water surface. It is well documented that these species and age classes are prone to 

ingesting non-prey items (Hardesty & Wilcox, 2017; Mitchelmore et al., 2017; Schuyler et al., 2014; 

Schuyler et al., 2016). Materials that sink to the seafloor pose a risk to bottom-feeding sea turtles such 

as loggerheads, Kemp’s ridleys, hawksbills, and greens. In 2014, Schuyler et al. (2014) reviewed 37 

studies of debris ingestion by sea turtles, showing that young oceanic sea turtles are more likely to 

ingest debris (particularly plastic), and that green and loggerhead turtles were significantly more likely to 

ingest debris than other sea turtle species.

The consequences of ingestion could range from temporary and inconsequential to long-term physical 

stress or even death. Ingestion of these items may not be directly lethal; however, ingestion of plastic 

and other fragments can restrict food intake and have sublethal impacts caused by reduced nutrient 

intake (McCauley & Bjorndal, 1999). Poor nutrient intake can lead to decreased growth rates, depleted 

energy, reduced reproduction, and decreased survivorship. These long-term sublethal effects may lead 

to population-level impacts, but the extent of these impacts is difficult to assess because the affected 

individuals remain at sea and the trends may only arise after several generations have passed. Schuyler 

et al. (2014) determined that most sea turtles at some point will ingest some amount of debris. 

However, military expended materials have not been documented to be ingested by sea turtles, 

although whether this is because of a lack of occurrence or an inability to distinguish military expended 

materials from other ingested items is unknown. Because bottom-feeding occurs in nearshore areas, 

materials that sink to the seafloor in the open ocean are less likely to be ingested due to their location. 

While these depths may be within the diving capabilities of most sea turtle species, especially 

leatherback turtles, bottom foraging species (i.e., greens, hawksbills, Kemp’s ridleys, and loggerheads) 

are more likely to forage in the shallower waters less than 100 m in depth. This overlaps with only a 

small portion of the depth range at which munitions are expended. However, loggerhead turtles may 

forage in benthic habitats as deep as 200 m (Hochscheid, 2014).

Rosenblatt et al. (2015) examined stomach content results collected from 960 American alligators, 

showing alligators have a diverse array of prey items (e.g., crustaceans, mollusks, fishes, amphibians, 

reptiles, mammals, birds, aquatic and terrestrial insects, and seeds), with individual alligators 

demonstrating diet specialization. Alligator populations inhabiting lakes exhibited lower specialization 

than coastal populations, likely driven by variation in habitat type and available prey types available to 

individual alligators in estuaries and other coastal habitats. Ingestion risk of non-prey items does not 

appears to be a concern while alligators are engaging in normal hunting behaviors (Nifong & Silliman, 

2017).

Diamondback terrapins would be exposed to ingestion risks within inshore training and testing locations. 

appear to be dietary generalists and opportunistic in foraging habits with a wide array of prey and 

forage items, which may increase the risk of ingestion for non-prey items. As visual predators, however, 

diamondback terrapins appear to use visual cues while foraging, showing selectivity in the prey that they 

eat (Outerbridge et al., 2017). Tulipani and Lipcius (2014) found that different age classes and sex of 

Chesapeake Bay diamondback terrapins influenced diet, with larger females consuming larger snails, 

crabs, and small amphibians and other reptiles, while smaller males and females consumed plant 

material (e.g., grass, seeds), insects, and small crustaceans. In a study of fecal samples from 42 different 

diamondback terrapins in Bermuda (the only native population of diamondback terrapins outside of the 
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United States), Outerbridge et al. (2017) found that only one sample contained non-prey items (a 

cigarette filter), with the remaining 41 samples containing natural prey and forage items. The trash item 

came from an adult female fecal sample, while samples from adult males, juveniles, and neonates 

(hatchlings) did not contain any trash items. This one study seems to indicate that consumption of 

marine debris is not a major threat for terrapins; however, large individual terrapins, particularly the 

larger females, are most at risk of ingesting non-prey items.

3.8.3.6.1 Impacts from Military Expended Material – Munitions

Many different types of explosive and non-explosive practice munitions are expended at sea during 

training and testing activities. Types of non-explosive practice munitions generally include projectiles, 

missiles, and bombs. Of these, only small- or medium-caliber projectiles would be small enough for a 

reptile to ingest in offshore and inshore waters. Small- and medium-caliber projectiles include all sizes 

up to and including 2.25 in. (57 mm) in diameter. These are solid metal munitions; therefore, even if a 

reptile did try to bite a larger munition, the munition would not break apart and be ingestible. These 

solid metal materials would quickly move through the water column and settle to the seafloor. Ingestion 

of non-explosive practice munitions is not expected to occur in the water column because the munitions 

sink quickly. 

A sea turtle would have to be undetected by Navy Lookouts (i.e., observers) prior to the commencement 

of training and testing activities (Section 5.3, Procedural Mitigation to be Implemented), be immediately 

adjacent to falling munitions, mistake sinking munitions for prey items, and react quickly enough to 

ingest the sinking material. This chain of events is highly unlikely given the Navy’s mitigation measures, 

density of animals in the study area, rapid sinking of munitions in the water column, and general 

movement speed of the animals involved. Instead, they are most likely to be encountered by species 

that forage on the bottom (i.e., loggerhead, green, Kemp’s ridley, and hawksbill sea turtles). Types of 

high-explosive munitions that can result in fragments include demolition charges, projectiles, missiles, 

and bombs. Fragments would result from fractures in the munitions casing and would vary in size 

depending on the size of the net explosive weight and munitions type; however, typical sizes of 

fragments are unknown. These solid metal materials would quickly move through the water column and 

settle to the seafloor; therefore, ingestion is not expected by most species. Fragments are primarily

encountered by species that forage on the bottom. Other munitions and munitions fragments such 

large-caliber projectiles or intact training and testing bombs are too large for loggerhead, green, Kemp’s 

ridley, and hawksbill sea turtles to consume and are made of metal so they cannot be broken up by sea 

turtles. 

In inshore waters, however, training and testing activities would expend small caliber munitions shells 

into waters, and if they overlapped with benthic foraging of sea turtles, American alligators, 

diamondback terrapins present a higher risk of ingestion.

Sublethal effects due to ingestion of munitions used in training and testing activities may cause shortterm or long-term disturbance to an individual reptiles because: (1) if a reptile were to incidentally 

ingest and swallow a metal fragment, it could potentially disrupt its feeding behavior or digestive 

processes; and (2) if the item is particularly large in proportion to the reptile ingesting it, the item could 

become permanently encapsulated by the stomach lining, with a rare chance that this could impede the 

reptile’s ability to feed or take in nutrients. Potential impacts of exposure to munitions may result in 
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changes to an individual’s behavior, growth, survival, annual reproductive success, lifetime reproductive 

success (fitness), or species recruitment. 

In open ocean environments, munitions used in training activities are generally not expected to cause 

disturbance to sea turtles because: (1) sea turtles are not expected to encounter most small- and 

medium-caliber projectiles or high-explosive fragments on the seafloor because of the depth at which 

these would be expended; and (2) in some cases, a turtle would likely pass the projectile through their 

digestive tract and expel the item without impacting the individual. For example, Schuyler et al. (2014)

noted that less than 10 percent of sea turtles (out of a sample size of 454 turtles) that ingested a wide 

range of debris suffered mortality, and 4 percent of turtles necropsied were killed by plastics ingestion 

(out of a sample size of 1,106 necropsied turtles). Because juvenile and adult green, loggerhead, Kemp’s 

ridley, and hawksbill sea turtles feed along the seafloor, they are more likely to encounter munitions of 

ingestible size that settle on the bottom than leatherbacks that primarily feed at the surface and in the 

water column. Additionally, activities will not be initiated near concentrated Sargassum mats due to the 

possible presence of sea turtles (see Section 5.3, Procedural Mitigation to be Implemented); therefore, 

the likelihood of hatchlings and pre-recruitment juveniles encountering munitions is even further 

unlikely. Furthermore, these four species typically use nearshore feeding areas, while leatherbacks are 

more likely to feed in the open ocean. Given the very low probability of a leatherback encountering and 

ingesting materials on the seafloor or water column or any other species encountering munitions in the 

water column, this analysis will focus on green, loggerhead, Kemp’s ridley, and hawksbill turtles and 

ingestible materials expended nearshore, within range complexes and testing ranges. 

A discussion of the types, numbers, and locations of activities using these devices under each alternative 

is presented in Sections 3.0.3.3.6.1 (Non-Explosive Practice Munitions) and 3.0.3.3.6.2 (Fragments from 

High-Explosive Munitions). 

3.8.3.6.1.1 Impacts from Military Expended Materials – Munitions under Alternative 1

Impacts from Military Expended Materials – Munitions under Alternative 1 for Training Activities

As provided in Tables 3.0-24, 3.0-25 and 3.0-27, offshore training activities involving non-explosive 

practice munitions and high-explosive munitions fragments would occur within the Northeast, Virginia 

Capes, Navy Cherry Point, Jacksonville, Key West, and Gulf of Mexico Range Complexes, as well as other 

AFTT areas outside of the range complexes. The Virginia Capes and Jacksonville Range Complexes have 

the highest estimated annual numbers of munitions for training activities (see Section 3.0.3.3.6.2,

Fragments from High-Explosive Munitions). In addition, training activities that expend non-explosive 

practice munitions would occur within inshore waters including and surrounding Narragansett, Rhode 

Island; James River and Tributaries, Virginia; the Lower Chesapeake Bay, Virginia; Cooper River, South 

Carolina; and Port Canaveral, Florida (see Table 3.0-33).

For training activities occurring in the offshore waters, the species and age classes that may be impacted 

are juvenile, sub-adult, and adult loggerhead, Kemp’s ridley, green, and hawksbill sea turtles, especially 

if munitions are expended in waters where the isobaths are not greater than the benthic foraging ability 

(dive depth); there is a low probability that leatherback sea turtles could be impacted. For example, 

hawksbill turtles and adult loggerheads may be found foraging in waters as deep as 80 m and 200 m, 

respectively (Hochscheid, 2014). Juvenile sea turtles (e.g., green turtles) may rest and forage in waters 

as deep as approximately 30 m (Hochscheid, 2014). Sea turtles are expected to be highly dispersed in 

offshore waters. Repeated exposures to sea turtles are not anticipated as these offshore areas do not 

have resident animals year round.
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In open ocean environments, munitions used in training activities are generally not expected to cause 

disturbance or long-term effects to individual sea turtles or their populations because (1) sea turtles are 

not expected to encounter most small- and medium-caliber projectiles or high-explosive fragments on 

the seafloor because the depth at which these would be expended precludes foraging; and (2) in the 

unexpected circumstance of a sea turtle foraging at depths greater than 200m, a turtle would likely pass 

the projectile through its digestive tract and expel the item without significantly impacting the individual 

permanently. For example, Schuyler et al. (2014) noted that less than 10 percent of sea turtles (out of a 

sample size of 454 turtles) that ingested a wide range of debris suffered mortality, and 4 percent of

turtles necropsied were killed by plastics ingestion (out of a sample size of 1,106 necropsied turtles). In 

offshore waters, the amount of non-explosive practice munitions and high-explosive munitions 

fragments that an individual sea turtle would encounter is generally low based on the patchy 

distribution of both the munitions and sea turtles.

Navy training activities involving non-explosive practice munitions in the inshore waters occur in several 

locations along the Atlantic coast, but substantially less munitions would be expended annually 

compared to the activities in the offshore areas (see Section 3.0.3.3.6.2, Fragments from High-Explosive 

Munitions). The highest concentration of munitions would be expended in the James River and 

Tributaries. Other locations include the Lower Chesapeake Bay, Virginia; Port Canaveral, Florida; and 

Narragansett Bay, Rhode Island. In inshore waters, training activities would concentrate small-caliber 

shell casings in areas that may potentially be overly benthic foraging areas (e.g., Lower Chesapeake Bay 

and Port Canaveral). Juvenile, sub-adult, and adult green, loggerhead, Kemp’s ridley, and hawksbill sea 

turtles that have recruited to benthic foraging grounds are more likely to encounter munitions of 

ingestible size that settle on the bottom since these species and age classes feed along the seafloor. 

There is a low probability that sub-adult and adult leatherbacks that forage in coastal waters could be 

impacted.

Based on the discussion presented above, the likelihood that a sea turtle would encounter and 

subsequently ingest a military expended item associated with Navy training activities in inshore waters 

and offshore waters is considered low, and munitions are generally expected to cause an insignificant 

impact to sea turtles. Adverse impacts from ingestion of military expended materials would be limited to 

the unlikely event that a sea turtle would be harmed by ingesting an item that becomes embedded in 

tissue or is too large to be passed through the digestive system. In addition, a sea turtle would not likely 

ingest every projectile it encountered. A sea turtle may attempt to ingest a projectile or fragment and 

then reject it when it realizes it is not a food item. Therefore, potential impacts of non-explosive practice 

munitions and fragments ingestion would be limited to the unlikely event in which a sea turtle might 

suffer a negative response from ingesting an item that becomes embedded in tissue or is too large to be 

passed through the digestive system. The Navy considers the likelihood of this occurring to be very low.

Potential impacts of exposure to non-explosive practice munitions and high-explosive munitions 

fragments are not expected to result in substantial changes in an individual sea turtle’s behavior, 

growth, survival, annual reproductive success, lifetime reproductive success (fitness), or species 

recruitment, and as such are not expected to result in population-level impacts for all sea turtle species.

Munitions in inshore waters would be expended in areas potentially occupied by American alligators at

Cooper River, South Carolina; and Port Canaveral, Florida. As stated above in Section 3.8.3.6 (Ingestion 

Stressors), American alligators are generalist predators, but they may specialize in specific prey items 

depending on habitat, age class of the alligator, and behaviors specific to individual alligators. In inshore 

waters, training activities would concentrate small-caliber shell casings in areas that may potentially be 
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used for benthic foraging by alligators; however, this hunting behavior is generally rare for alligators. 

There is a very low probability that American alligators foraging in estuarine habitats would encounter 

expended munitions. If an alligator did encounter expended munitions, it is unlikely that an American 

alligator would mistake munitions fragments or casings for prey items. Potential impacts of exposure to 

non-explosive practice munitions and high-explosive munitions fragments are not expected to result in 

substantial changes in an individual alligator’s behavior, growth, survival, annual reproductive success, 

lifetime reproductive success (fitness), or species recruitment, and as such are not expected to result in 

population-level impacts for the American alligator.

Munitions in inshore waters would be expended in areas potentially occupied by diamondback terrapins 

in waters surrounding Narragansett, Rhode Island; James River and Tributaries, Virginia; the Lower 

Chesapeake Bay, Virginia; Cooper River, South Carolina; and Port Canaveral, Florida. In inshore waters, 

training activities would concentrate small-caliber shell casings in estuarine areas that may potentially 

be used by terrapins while foraging for benthic prey items (e.g., crustaceans, molluscs). There is a very 

low probability that diamondback terrapins foraging in estuarine habitats would encounter expended 

munitions. Diamondback terrapins are believed to use visual cues for foraging for benthic prey; 

therefore, it is unlikely that a diamondback terrapin would mistake munitions fragments or casings for 

prey items. Potential impacts of exposure to non-explosive practice munitions and high-explosive 

munitions fragments are not expected to result in substantial changes in an individual terrapin’s

behavior, growth, survival, annual reproductive success, lifetime reproductive success (fitness), or 

species recruitment, and as such are not expected to result in population-level impacts for the 

diamondback terrapin.

Proposed training activities under Alternative 1 that expend munitions would not occur in designated 

critical habitat for the green sea turtle (Culebra Island), hawksbill sea turtle (Mona Island and Monita 

Island), leatherback sea turtle (St. Croix Island), or American crocodile (Florida Bay). Navy training 

activities that expend munitions would occur year round within the five critical habitat types for the 

loggerhead turtle. See Section 3.8.2.2.4.1 (Status and Management) for a description of these habitat 

types and supporting physical and biological factors. Munitions that pose ingestion risk have no way of 

impacting the habitat types that comprise loggerhead turtle critical habitat (National Marine Fisheries 

Service, 2014b).

Pursuant to the ESA, activities that release military expended materials-munitions during training 

activities under Alternative 1 may affect ESA-listed green, hawksbill, Kemp’s ridley, leatherback, and 

loggerhead sea turtles; and will have no effect on the American crocodile. There would be no effect on 

green, hawksbill, leatherback, or loggerhead sea turtle critical habitat; and no effect on American 

crocodile critical habitat. The Navy has consulted with NMFS as required by section 7(a)(2) of the ESA in 

that regard.

Impacts from Military Expended Materials – Munitions under Alternative 1 for Testing Activities

As provided in Tables 3.0-26 and 3.0-28, testing activities involving non-explosive practice munitions and 

high-explosive munitions fragments would be expended within the Northeast, Virginia Capes, Navy 

Cherry Point, Jacksonville, Key West, and Gulf of Mexico Range Complexes, as well as the Naval 

Undersea Warfare Center Newport Testing Range, the South Florida Ocean Measurement Facility, and 

the Naval Surface Warfare Center Panama City Testing Range. No testing activities would release 

munitions or fragments in inshore waters; therefore, only sea turtles in offshore areas are analyzed for 

potential impacts from non-explosive practice munitions and high-explosive munitions fragments under 

Alterative 1 testing activities.
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For testing activities, the species and age classes that may be impacted are juvenile, sub-adult, and adult 

loggerhead, Kemp’s ridley, green, and hawksbill sea turtles, especially if non-explosive practice

munitions and high-explosive munitions fragments are expended in waters where the isobaths are not 

greater than the benthic foraging ability (dive depth); there is a low probability that leatherback turtles 

could be impacted. For example, hawksbill turtles and adult loggerheads may be found foraging in 

waters as deep as 80 m and 200 m, respectively (Hochscheid, 2014). Juvenile sea turtles (e.g., green 

turtles) may rest and forage in waters as deep as approximately 30 m (Hochscheid, 2014). Sea turtles are 

expected to be highly dispersed in offshore waters. Repeated exposures to sea turtles are not 

anticipated as these offshore areas do not have resident animals year round.

In open ocean environments, munitions used in testing activities are generally not expected to cause 

disturbance or long-term effects to individual sea turtles or their populations because (1) sea turtles are 

not expected to encounter most small- and medium-caliber projectiles or high-explosive fragments on 

the seafloor because the depth at which these would be expended precludes foraging; and (2) in the 

unexpected circumstance of a sea turtle foraging at depths greater than 200m, a turtle would likely pass 

the projectile through its digestive tract and expel the item without significantly impacting the individual 

permanently. For example, Schuyler et al. (2014) noted that less than 10 percent of sea turtles (out of a 

sample size of 454 turtles) that ingested a wide range of debris suffered mortality, and 4 percent of

turtles necropsied were killed by plastics ingestion (out of a sample size of 1,106 necropsied turtles). In 

open ocean and nearshore waters, the amount of non-explosive practice munitions and high-explosive 

munitions fragments that an individual sea turtle would encounter is generally low based on the patchy 

distribution of both the munitions and sea turtles.

Based on the discussion presented above, the likelihood that a sea turtle would encounter and 

subsequently ingest a military expended item associated with Navy testing activities is considered low. 

Adverse impacts from ingestion of military expended materials would be limited to the unlikely event 

that a sea turtle would be harmed by ingesting an item that becomes embedded in tissue or is too large 

to be passed through the digestive system. In addition, a sea turtle would not likely ingest every 

projectile it encountered. A sea turtle may attempt to ingest a projectile or fragment and then reject it 

when it realizes it is not a food item. Therefore, potential impacts of non-explosive practice munitions 

and fragments ingestion would be limited to the unlikely event in which a sea turtle might suffer a 

negative response from ingesting an item that becomes embedded in tissue or is too large to be passed 

through the digestive system. As with the analysis for training activities, the Navy considers the potential 

for ingestion of munitions and fragments to be very low.

Potential impacts of exposure to non-explosive practice munitions and high-explosive munitions 

fragments are not expected to result in substantial changes in an individual’s behavior, growth, survival, 

annual reproductive success, lifetime reproductive success (fitness), or species recruitment, and as such 

are not expected to result in population-level impacts for all sea turtle species.

Proposed testing activities under Alternative 1 that expend munitions would not occur in designated 

critical habitat for the green sea turtle (Culebra Island), hawksbill sea turtle (Mona Island and Monita 

Island), leatherback sea turtle (St. Croix Island), or American crocodile (Florida Bay). Navy testing

activities that expend munitions would occur year round within the five critical habitat types for the 

loggerhead turtle. See Section 3.8.2.2.4.1 (Status and Management) for a description of these habitat 

types and supporting physical and biological factors. Munitions that pose ingestion risk have no way of 

impacting the habitat types that comprise loggerhead turtle critical habitat (National Marine Fisheries 

Service, 2014b).
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Pursuant to the ESA, activities that release military expended materials-munitions during testing

activities under Alternative 1 may affect ESA-listed green, hawksbill, Kemp’s ridley, leatherback, and 

loggerhead sea turtles; and will have no effect on the American crocodile. There would be no effect on 

green, hawksbill, leatherback, or loggerhead sea turtle critical habitat; and no effect on American 

crocodile critical habitat. The Navy has consulted with NMFS as required by section 7(a)(2) of the ESA in 

that regard.

3.8.3.6.1.2 Impacts from Military Expended Materials – Munitions under Alternative 2

Impacts from Military Expended Materials – Munitions under Alternative 2 for Training Activities

The locations of training activities that expend non-explosive practice munitions and high-explosive 

munition fragments are the same under Alternatives 1 and 2. In addition, the number of non-explosive 

practice munitions expended annually and over five years would be identical under Alternatives 1 and 2. 

While the annual number of high-explosive munition fragments would not change under Alternative 2, 

there would be a very slight increase (approximately 0.001 percent) over five years. This fractional 

increase does not substantially increase the risk of ingestion impacts on sea turtles. Therefore, the 

analysis presented in Section 3.8.3.6.1.1 (Impacts from Military Expended Materials - Munitions under

Alternative 1) for training activities would also apply to training activities proposed for Alternative 2.

Proposed training activities under Alternative 2 that expend munitions would not occur in designated 

critical habitat for the green sea turtle (Culebra Island), hawksbill sea turtle (Mona Island and Monita 

Island), leatherback sea turtle (St. Croix Island), or American crocodile (Florida Bay). Navy training 

activities that expend munitions would occur year round within the five critical habitat types for the 

loggerhead turtle. See Section 3.8.2.2.4.1 (Status and Management) for a description of these habitat 

types and supporting physical and biological factors. Munitions that pose ingestion risk have no way of 

impacting the habitat types that comprise loggerhead turtle critical habitat (National Marine Fisheries 

Service, 2014b).

Pursuant to the ESA, activities that release military expended materials-munitions during training 

activities under Alternative 2 may affect ESA-listed green, hawksbill, Kemp’s ridley, leatherback, and 

loggerhead sea turtles; and will have no effect on the American crocodile. There would be no effect on 

green, hawksbill, leatherback, or loggerhead sea turtle critical habitat; and no effect on American 

crocodile critical habitat.

Impacts from Military Expended Materials – Munitions under Alternative 2 for Testing Activities

The locations of testing activities that expend non-explosive practice munitions and high-explosive 

munition fragments would be identical under Alternatives 1 and 2. The numbers of non-explosive 

practice munitions (of ingestible size) during testing activities would be the same annually, but would 

increase by 2 percent over five years. In addition, the numbers of high-explosives resulting in fragments 

expended during testing activities would increase by 0.014 percent annually and by approximately 

5 percent over five years. This increased use of munition-related military expended materials would be 

fractional and would not appreciably increase the potential for adverse ingestion impacts on sea turtles. 

Therefore, the analysis presented in Section 3.8.3.6.1.1 (Impacts from Military Expended Materials -

Munitions under Alternative 1) for testing activities would also apply to testing activities proposed for 

Alternative 2.

Proposed testing activities under Alternative 2 that expend munitions would not occur in designated 

critical habitat for the green sea turtle (Culebra Island), hawksbill sea turtle (Mona Island and Monita 
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Island), leatherback sea turtle (St. Croix Island), or American crocodile (Florida Bay). Navy testing

activities that expend munitions would occur year round within the five critical habitat types for the 

loggerhead turtle. See Section 3.8.2.2.4.1 (Status and Management) for a description of these habitat 

types and supporting physical and biological factors. Munitions that pose ingestion risk have no way of 

impacting the habitat types that comprise loggerhead turtle critical habitat (National Marine Fisheries 

Service, 2014b).

Pursuant to the ESA, activities that release military expended materials-munitions during testing

activities under Alternative 2 may affect ESA-listed green, hawksbill, Kemp’s ridley, leatherback, and 

loggerhead sea turtles; and will have no effect on the American crocodile. There would be no effect on 

green, hawksbill, leatherback, or loggerhead sea turtle critical habitat; and no effect on American 

crocodile critical habitat. The Navy has consulted with NMFS as required by section 7(a)(2) of the ESA in 

that regard.

3.8.3.6.1.3 Impacts from Military Expended Materials-Munitions under the No Action 

Alternative

Impacts from Military Expended Materials-Munitions under the No Action Alternative for Training 

and Testing Activities

Under the No Action Alternative, the Navy would not conduct the proposed training or testing activities 

in the AFTT Study Area. Various ingestion stressors (e.g., military expended materials-munitions) would 

not be introduced into the marine environment. Therefore, baseline conditions of the existing 

environment would either remain unchanged or would improve slightly after cessation of ongoing 

training and testing activities.

3.8.3.6.2 Impacts from Military Expended Materials Other Than Munitions

Several different types of materials other than munitions are expended during training and testing 

activities in the AFTT Study Area. The following military expended materials other than munitions have 

the potential to be ingested by reptiles:

 target-related materials

 chaff (including fibers and end caps)

 flares (including end caps and compression pads/pistons)

 decelerators/parachutes (cloth, nylon, and metal weights)

 biodegradable polymer

Target-Related Materials 

At-sea targets are usually remotely operated airborne, surface, or subsurface traveling units, most of 

which are designed to be recovered for reuse. If they are severely damaged or displaced, targets may 

sink before they can be retrieved. Expendable targets include air-launched decoys, marine markers 

(smoke floats), cardboard boxes, and 10-ft. diameter red balloons tethered by a sea anchor. Most target 

fragments would sink quickly in the sea. Floating material, such as Styrofoam, may be lost from target 

boats and remain at the surface for some time; however, during target recovery, personnel would 

collect as much floating debris and Styrofoam as possible. Sea turtles would be exposed to potential 

ingestion risk of target-related materials where these items are expended in offshore and inshore 

waters. American alligators may be exposed to target-related materials (specifically, marine markers) in 

waters near Port Canaveral, Florida, while diamondback terrapins may be exposed to target-related 
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materials at Narragansett, Rhode Island; James River and tributaries, Virginia; York River, Virginia; and 

Lower Chesapeake Bay, Virginia (see Table 3.0-33).

Chaff

Chaff would only be expended over offshore areas; therefore, only sea turtles are analyzed for potential 

impacts of ingesting chaff. Chaff is an electronic countermeasure designed to reflect radar waves and 

obscure aircraft, vessels, and other equipment from radar tracking sources. Chaff is composed of an 

aluminum alloy coating on glass fibers of silicon dioxide (U.S. Air Force, 1997). It is released or dispensed 

in cartridges or projectiles that contain millions of chaff fibers. When deployed, a diffuse cloud of fibers 

undetectable to the human eye is formed. Chaff is a very light material that can remain suspended in air 

anywhere from 10 minutes to 10 hours and can travel considerable distances from its release point, 

depending on prevailing atmospheric conditions (Arfsten et al., 2002; U.S. Air Force, 1997). Doppler 

radar has tracked chaff plumes containing approximately 900 grams (g) of chaff drifting 200 mi. from the 

point of release, with the plume covering greater than 400 cubic miles (1,667 cubic kilometers) (Arfsten 

et al., 2002).

The chaff concentrations that sea turtles could be exposed to following release of multiple cartridges 

(e.g., following a single day of training) are difficult to accurately estimate because it depends on several 

unknown factors. First, specific release points are not recorded and tend to be random, and chaff 

dispersion in air depends on prevailing atmospheric conditions. After falling from the air, chaff fibers 

would be expected to float on the sea surface for some period, depending on wave and wind action. The 

fibers would be dispersed further by sea currents as they float and slowly sink toward the bottom. Chaff 

concentrations in benthic habitats following release of a single cartridge would be lower than the values 

noted in this section, based on dispersion by currents and the enormous dilution capacity of the 

receiving waters.

Several literature reviews and controlled experiments have indicated that chaff poses little risk, except 

at concentrations substantially higher than those that could reasonably occur from military training 

(Arfsten et al., 2002; U.S. Air Force, 1997). Nonetheless, some sea turtle species within the Study Area 

could be exposed to chaff through direct body contact and ingestion. Chemical alteration of water and 

sediment from decomposing chaff fibers is not expected to result in exposure. Based on the dispersion 

characteristics of chaff, it is likely that sea turtles would occasionally come in direct contact with chaff 

fibers while at the water’s surface and while submerged, but such contact would be inconsequential. 

Chaff is similar to fine human hair (U.S. Air Force, 1997). Because of the flexibility and softness of chaff, 

external contact would not be expected to impact most wildlife (U.S. Air Force, 1997) and the fibers 

would quickly wash off shortly after contact. Given the properties of chaff, skin irritation is not expected 

to be a problem (U.S. Air Force, 1997). Arfsten et al. (2002) reviewed the potential effects of chaff 

inhalation on humans, livestock, and animals and concluded that the fibers are too large to be inhaled 

into the lung. The fibers are predicted to be deposited in the nose, mouth, or trachea and are either 

swallowed or expelled; however, these reviews did not specifically consider sea turtles.

Although chaff fibers are too small for sea turtles to confuse with prey and forage, there is some 

potential for chaff to be incidentally ingested along with other prey items, particularly if the chaff 

attaches to other floating marine debris. If ingested, chaff is not expected to impact sea turtles due to 

the low concentration that would be ingested and the small size of the fibers. While no similar studies to 

those discussed in Section 3.0.3.3.6.3 (Military Expended Materials Other Than Munitions) on the 

impacts of chaff have been conducted on sea turtles, they are also not likely to be impacted by 

incidental ingestion of chaff fibers. For instance, some sea turtles ingest spicules (small spines within the 
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structure of a sponge) in the course of eating the sponges, without harm to their digestive system. Since 

chaff fibers are of similar composition and size as these spicules (U.S. Department of the Navy, 1999), 

ingestion of chaff should be inconsequential for sea turtles.

Chaff cartridge plastic end caps and pistons would also be released into the marine environment, where 

they would persist for long periods and could be ingested by sea turtles while initially floating on the 

surface and sinking through the water column. Chaff end caps and pistons would eventually sink in 

saltwater to the seafloor (Spargo, 2007), which reduces the likelihood of ingestion by sea turtles at the 

surface or in the water column. However, bottom-feeding sea turtles, such as green, hawksbill, Kemp’s 

ridley, and loggerhead turtles, would be at increased risk if these items were deposited in potential 

benthic feeding areas and before these items would be encrusted or buried.

Flares 

Flares and components of flares (e.g., o-rings, compression pads, plastic pistons) would be introduced in 

offshore areas and one inshore location (James River and tributaries, Virginia). Therefore, these items 

are analyzed for potential ingestion risk for sea turtles and diamondback terrapins. Flares are designed 

to burn completely. The only material that would enter the water would be a small, round, plastic 

compression pad or piston (0.45 to 4.1 g depending on flare type). The flare pads and pistons float in sea 

water.

An extensive literature review and controlled experiments conducted by the United States Air Force 

demonstrated that self-protection flare use poses little risk to the environment or animals (U.S. Air 

Force, 1997). For sea turtles and diamondback terrapins, these types of flares are large enough to not be 

considered an ingestion hazard. Nonetheless, sea turtles within the vicinity of flares could be exposed to 

light generated by the flares. Compression pads/pistons, o-rings and endcaps from flares would have the 

same impact on sea turtles and terrapins in inshore waters as discussed under chaff cartridges. It is 

unlikely that sea turtles or terrapins would be exposed to any chemicals that produce either flames or 

smoke since these components are consumed in their entirety during the burning process. Animals are 

unlikely to approach or get close enough to the flame to be exposed to any chemical components.

Decelerators/Parachutes 

Decelerators/parachutes would only be expended in offshore waters; therefore, these items are only 

analyzed as potential ingestion risks for sea turtles. 

As noted previously in Section 3.0.3.3.5.2 (Decelerators/Parachutes), decelerators/parachutes are 

classified into four different categories based on size: small, medium, large, and extra-large. The 

majority of expended decelerators/parachutes are in the small category. Decelerators/parachutes in the 

three remaining size categories (medium – up to 19 ft. in diameter, large – between 30 and 50 ft. in 

diameter, and extra-large – up to 80 ft.in diameter) are likely too big to be mistaken for prey items and 

ingested by a sea turtle. 

The majority of decelerators/parachutes are weighted and by design must sink below the surface within 

five minutes of contact with the water. Once on the seafloor, decelerators/parachutes become flattened 

(Environmental Sciences Group, 2005). Ingestion of a small decelerator/parachute by a sea turtle at the 

surface or within the water column would be unlikely, since the decelerator/parachute would not be 

available for very long before it sinks. Once on the seafloor, if bottom currents are present, the canopy 

may temporarily billow and be available for potential ingestion by sea turtles with bottom-feeding 

habits.
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Ingestion of a decelerator/parachute by a sea turtle at the surface or within the water column would be 

unlikely, since the decelerator/parachute would not be available for very long before it sinks. Once on 

the seafloor, if bottom currents are present, the canopy may temporarily billow and be available for 

potential ingestion by a sea turtle feeding on or near the seafloor. Conversely, the decelerator/ 

parachute could be buried by sediment in most soft bottom areas or colonized by attaching and 

encrusting organisms, which would further stabilize the material and reduce the potential for an 

ingestion risk. Some decelerators/parachutes may be too large to be a potential prey item for certain 

age classes (e.g., hatchlings and pre-recruitment juveniles), although degradation of the decelerator/ 

parachute may create smaller items that are potentially ingestible. The majority of these items (from 

sonobuoys), however, would be expended in deep offshore waters. Bottom-feeding sea turtles (e.g., 

green, hawksbill, Kemp’s ridley, and loggerhead turtles) tend to forage in nearshore and coastal areas 

rather than offshore, where the majority of these decelerators/parachutes are used. Since these 

materials would most likely be expended in offshore waters too deep for benthic foraging, it would be 

unlikely for bottom foraging sea turtles to interact with these materials once they sink; therefore, 

unlikely that sea turtles would encounter decelerators/parachutes once they reach the seafloor.

Biodegradable Polymer

Biodegradable polymers would only be expended in offshore waters; therefore, these items are only 

analyzed as potential ingestion risks for sea turtles. As stated in Section 3.0.3.3.5.3 (Biodegradable 

Polymer) based on the constituents of the biodegradable polymer, it is anticipated that the material will 

breakdown into small pieces within a few days to weeks. The small pieces will breakdown further and 

dissolve into the water column within weeks to a few months and could potentially be incidentally 

ingested by sea turtles. Because the final products of the breakdown are all environmentally benign, the 

Navy does not expect the use biodegradable polymer to be an ingestion stressor for sea turtles; 

therefore, is not analyzed further.

3.8.3.6.2.1 Impacts from Military Expended Materials Other Than Munitions under

Alternative 1

Impacts from Military Expended Materials Other Than Munitions under Alternative 1 for Training 

Activities

As presented in Section 3.0.3.3.6 (Ingestion Stressors) and Section 3.0.3.3.4.2 (Military Expended 

Materials), military expended materials other than munitions would be expended during offshore

training activities within the Northeast, Virginia Capes, Navy Cherry Point, Jacksonville, Key West, and 

Gulf of Mexico Range Complexes as well as other areas outside the range complexes. In addition, 

training activities that expend other materials would occur within inshore waters including and 

surrounding Narragansett, Rhode Island; James River and tributaries, Virginia; York River, Virginia; Lower 

Chesapeake Bay, Virginia; and Port Canaveral, Florida.

Target-related material, chaff, flares, and decelerators/parachutes (and their subcomponents) have the 

potential to be ingested by a sea turtle, American alligator, or diamondback terrapin, although that is 

considered unlikely since most of these materials would quickly drop through the water column, settle 

on the seafloor, or in the case of biodegradable polymers, rapidly decay and not present an ingestion 

hazard. Some Styrofoam, plastic endcaps, chaff, and other small items may float for some time before 

sinking. 
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While the smaller items discussed here may pose a hazard to reptiles, as discussed for non-explosive 

practice munitions ingestion, the impacts of ingesting these forms of expended materials on reptiles

would be minor because of the following factors:

 the limited geographic area where materials other than munitions are expended during a given 

event 

 the limited period of time these military expended materials would remain in the water column 

 the unlikely chance that a sea turtle might encounter and swallow these items on the seafloor, 

particularly given that many of these items would be expended over deep, offshore waters

 the limited types of military expended materials that would be expended in inshore waters

where benthic feeding may occur in higher concentrations that overlap with activities

 the ability of reptiles to reject and not swallow non-food items incidentally ingested.

For sea turtles, the impacts of ingesting military expended materials other than munitions would be 

limited to cases where an individual sea turtle might eat an indigestible item too large to be passed 

through the gut. The sea turtle would not be preferentially attracted to these military expended 

materials, with the possible exception of decelerators/parachutes that may appear similar to the prey of 

some sea turtle species and life stages that feed on jellyfish and similar organisms. Post-hatchling

loggerhead turtles have been found to feed on jellyfish and zooplankton (Browlow et al., 2016; 

Burkholder et al., 2004; Carr & Meylan, 1980; Richardson & McGillivary, 1991), and post-hatchling green 

turtles have been found to feed on comb jellies and gelatinous eggs (Salmon et al., 2004; Salmon et al., 

2016). Late juvenile hawksbill turtles and Kemp’s ridley turtles may also prey on jellyfish (Bjorndal, 1997; 

Frick et al., 1999; Marquez, 1994; Seney, 2016). Leatherback turtles predominately prey upon jellyfish

(Wallace et al., 2015).

For the most part, these military expended materials would most likely only be incidentally ingested by 

individuals feeding on the bottom in the precise location where these items were deposited. Military 

expended materials other than munitions that would remain floating on the surface are too small to 

pose a risk of intestinal blockage to any sea turtle that happened to encounter it. Because leatherbacks 

of all age classes, and hatchlings and juveniles of green, hawksbill, Kemp’s ridley, and loggerhead sea 

turtles are more likely to feed at or near the surface in the open ocean, they are more likely to 

encounter materials at the surface than other age classes of sea turtles that primarily feed along the 

seafloor. For example, the non-munitions material that floats in the water, such as flare pads and 

pistons, as well as some target-related materials that may not be recovered (e.g., Styrofoam) may pose 

an ingestion risk for these age classes and species given their feeding behavior and prey choice. Though 

green, hawksbill, Kemp’s ridley, and loggerhead sea turtles are bottom-feeding species that generally 

recruit to and feed in nearshore waters once they reach the juvenile stage, they may occur in the open 

ocean during migrations.

For training activities occurring in the offshore waters, the species and age classes that have the 

potential to be impacted are hatchlings and pre-recruitment juveniles of all sea turtle species, and 

leatherback turtles of all age classes. Hatchlings and pre-recruitment juveniles of all sea turtle species 

may also occur in open-ocean habitats and be exposed to these activities; however, the likelihood of 

impact is lower for these age classes due to their occurrence at or near the water surface by 

concentrated Sargassum mats. Activities will not be initiated near concentrated Sargassum mats due to 

the possible presence of sea turtles (see Section 5.3, Procedural Mitigation to be Implemented). Nonmunitions materials, with the exception of decelerators/parachutes since they are expended in deeper 
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offshore waters, may pose a slight risk to juvenile, sub-adult, and adult loggerhead, green, and hawksbill 

turtles that have recruited to benthic foraging grounds, especially if non-munitions materials are 

expended in waters where the isobaths are not greater than the benthic foraging ability (dive depth), 

then these age classes and species could be at risk of potentially ingesting non-munitions materials. For 

example, hawksbills and loggerheads may forage in benthic habitats as deep as approximately 80 m and 

200 m, respectively (Hochscheid, 2014). Juvenile sea turtles (e.g., green turtles) may rest and forage in 

waters as deep as approximately 30 m (Hochscheid, 2014). Sea turtles are expected to be highly 

dispersed in offshore waters. Repeated exposures to sea turtles are not anticipated as these offshore 

areas do not have resident animals year round. In offshore waters, the amount of military expended 

materials other than munitions that an individual sea turtle would encounter is generally low based on 

the patchy distribution of both the non-munitions and sea turtles.

Navy training activities involving military expended materials other than munitions in the inshore waters 

occur in several locations along the Atlantic coast, but fewer types of military materials (e.g., flares and 

target related materials) would be expended compared to the activities in the offshore areas (see Table 

3.0-33). As stated above, target-related materials are recovered to the maximum extent practical, 

thereby decreasing the potential for ingestion by sea turtles. The highest concentration of nonmunitions materials would be expended in the James River and tributaries in Virginia. Other locations 

include Boston, Massachusetts; Lower Chesapeake Bay, Virginia; Moorehead City, North Carolina; and 

Port Canaveral, Florida. For training activities occurring in inshore waters, juvenile, sub-adult, and adult 

loggerhead, green, Kemp’s ridley, and hawksbill sea turtles that have recruited to benthic foraging 

grounds may be impacted. Sub-adult and adult leatherbacks that forage at the surface in coastal and 

sometimes estuarine waters may also be impacted. Most of the non-munitions materials expended in 

inshore waters consist of flares (see Table 3.0-33). Since the only material that would enter the water 

after the flare has burned would be small pads and pistons that float, this decreases the potential for 

ingestion by juvenile, sub-adult, and adult green, hawksbill, Kemp’s ridley, and loggerhead turtles that 

feed on the bottom.

Based on the discussion presented above and in Section 3.8.3.6.2 (Impacts from Military Expended 

Materials Other Than Munitions), the likelihood that a sea turtle would encounter and subsequently 

ingest a non-munitions item associated with Navy training activities is considered low, and nonmunitions are generally expected to cause an insignificant impact to sea turtles. Sublethal impacts due 

to ingestion of military expended materials other than munitions used in training activities may cause 

short-term or long-term disturbance to an individual turtle because (1) if a sea turtle were to incidentally 

ingest and swallow a decelerator/parachute, target fragment, chaff or flare component, it could 

potentially disrupt its feeding behavior or digestive processes; and (2) if the item is particularly large in 

proportion to the turtle ingesting it, the item could become permanently encapsulated by the stomach 

lining, with a rare chance that this could impede the turtle’s ability to feed or take in nutrients. Potential 

impacts of exposure to these items may result in changes to an individual’s behavior, growth, survival, 

annual reproductive success, lifetime reproductive success (fitness), or species recruitment. However, 

decelerators/parachutes, target fragments, chaff, and flare components used in training activities are 

generally not expected to cause disturbance to sea turtles because (1) leatherbacks are more likely to 

forage further offshore than within range complexes, and other sea turtles (e.g., juvenile, sub-adult, and 

adult green, hawksbill, Kemp’s ridley, and loggerhead turtles) primarily forage on the bottom in 

nearshore areas; (2) in some cases, a turtle would likely pass the item through its digestive tract and 

expel the item without impacting the individual permanently; and (3) chaff, if ingested, would occur in 

very low concentration and is similar to spicules, which sea turtles (species and life stages such as adult 
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loggerheads that consume sponges and other organisms containing spicules) ingest without harm. For 

example, Schuyler et al. (2014) noted that less than 10 percent of sea turtles (out of a sample size of 454 

turtles) that ingested a wide range of debris suffered mortality, and 4 percent of turtles necropsied were 

killed by plastics ingestion (out of a sample size of 1,106 necropsied turtles). 

Potential impacts of exposure to non-munitions materials are not expected to result in substantial 

changes in an individual’s behavior, growth, survival, annual reproductive success, lifetime reproductive 

success (fitness), or species recruitment, and as such are not expected to result in population-level

impacts for all sea turtle species.

American alligators would be exposed to potential ingestion risks of other materials expended at Port 

Canaveral, Florida. As stated above in Section 3.8.3.6 (Ingestion Stressors), American alligators are 

generalist predators, but may specialize in specific prey items depending on habitat, age class of the 

alligator, and behaviors specific to individual alligators. In inshore waters at Port Canaveral, Florida, 

marine markers would be the only other type of military expended material released. Marine markers 

would likely float on the water’s surface or wash ashore in alligator habitats; however, potential 

ingestion of marine markers should be considered very low because these items do not resemble prey. 

In addition, there is a very low probability that American alligators foraging in estuarine habitats would 

encounter expended marine markers. Potential impacts of exposure to marine markers are not 

expected to result in substantial changes in an individual alligator’s behavior, growth, survival, annual 

reproductive success, lifetime reproductive success (fitness), or species recruitment, and as such are not 

expected to result in population-level impacts for the American alligator.

Other materials expended in inshore waters would be released in areas potentially occupied by 

diamondback terrapins in waters surrounding Narragansett, Rhode Island; James River and tributaries, 

Virginia; York River, Virginia; Lower Chesapeake Bay, Virginia; and Port Canaveral, Florida. In inshore 

waters, training activities would concentrate other materials in estuarine areas that may potentially be 

used by terrapins while foraging for benthic prey items (e.g., crustaceans, molluscs) once expended 

materials sink, or when floating on the surface or suspended in the water column. There is a very low 

probability that diamondback terrapins foraging in estuarine habitats would encounter expended 

materials. Diamondback terrapins are believed to use visual cues for foraging for prey items; therefore, 

it is unlikely that a diamondback terrapin would mistake other materials for prey items. Potential 

impacts of exposure to other materials are not expected to result in substantial changes in an individual 

terrapin’s behavior, growth, survival, annual reproductive success, lifetime reproductive success 

(fitness), or species recruitment, and as such are not expected to result in population-level impacts for 

the diamondback terrapin.

Proposed training activities under Alternative 1 that expend potentially ingestible non-munitions 

materials would not occur in designated critical habitat for the green sea turtle (Culebra Island), 

hawksbill sea turtle (Mona Island and Monita Island), leatherback sea turtle (St. Croix Island), or 

American crocodile (Florida Bay). Navy training activities would expend potentially ingestible nonmunitions materials year round within the five critical habitat types for the loggerhead turtle. See 

Section 3.8.2.2.4.1 (Status and Management) for a description of these habitat types and supporting 

physical and biological factors. Ingestion stressors introduced by military expended materials other than 

munitions have no way of impacting the physical and biological features that comprise loggerhead turtle 

critical habitat (National Marine Fisheries Service, 2014b).
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Pursuant to the ESA, training activities that expend potentially ingestible non-munitions materials under 

Alternative 1 may affect ESA-listed green, hawksbill, Kemp’s ridley, leatherback, and loggerhead sea 

turtles; and would have no effect the American crocodile. There would be no effect on green, hawksbill, 

leatherback, or loggerhead sea turtle critical habitat; and no effect on American crocodile critical 

habitat. The Navy has consulted with NMFS as required by section 7(a)(2) of the ESA in that regard.

Impacts from Military Expended Materials Other Than Munitions under Alternative 1 for Testing 

Activities

As presented in Section 3.0.3.3.6 (Ingestion Stressors) and Section 3.0.3.3.4.2 (Military Expended 

Materials), military expended materials other than munitions would be expended during testing 

activities within the Northeast, Virginia Capes, Navy Cherry Point, Jacksonville, Gulf of Mexico, and Key 

West Range Complexes, as well as the Naval Undersea Warfare Center, Division Newport Testing Range; 

South Florida Ocean Measurement Facility Testing Range; and Naval Surface Warfare Center, Panama 

City Division Testing Range. The Virginia Capes and Jacksonville Range Complexes have the highest 

estimated numbers of non-munitions materials per year for testing activities. Testing activities using 

military expended materials other than munitions would not occur in inshore waters. Therefore, only 

sea turtles in offshore areas are analyzed for potential impacts from ingestion of other materials under 

Alternative 1 testing activities.

Target-related material, chaff, flares, and decelerators/parachutes (and their subcomponents) have the 

potential to be ingested by a sea turtle, although that is considered unlikely since most of these 

materials would quickly drop through the water column, settle on the seafloor, or in the case of 

biodegradable polymers, rapidly decay and not present an ingestion hazard. Some Styrofoam, plastic 

endcaps, chaff, and other small items may float for some time before sinking. 

While the smaller items discussed here may pose a hazard to sea turtles, as discussed for non-explosive 

practice munitions ingestion, the impacts of ingesting these forms of expended materials on sea turtles 

would be minor because of the following factors:

 the limited geographic area where materials other than munitions are expended during a 

given event 

 the limited period of time these military expended materials would remain in the water column 

 the unlikely chance that a sea turtle might encounter and swallow these items on the seafloor, 

particularly given that many of these items would be expended over deep, offshore waters

The impacts of ingesting military expended materials other than munitions would be limited to cases 

where an individual sea turtle might eat an indigestible item too large to be passed through the gut. The 

sea turtle would not be preferentially attracted to these military expended materials, with the possible 

exception of decelerators/parachutes that may appear similar to the prey of some sea turtle species and 

life stages that feed on jellyfish and similar organisms. Post-hatchling loggerhead turtles have been 

found to feed on jellyfish and zooplankton (Browlow et al., 2016; Burkholder et al., 2004; Carr & Meylan, 

1980; Richardson & McGillivary, 1991), and post-hatchling green turtles have been found to feed on 

comb jellies and gelatinous eggs (Salmon et al., 2004; Salmon et al., 2016). Late juvenile hawksbill turtles 

and Kemp’s ridley turtles may also prey on jellyfish (Bjorndal, 1997; Frick et al., 1999; Marquez, 1994; 

Seney, 2016). Leatherback turtles predominately prey upon jellyfish (Wallace et al., 2015).

For the most part, these military expended materials would most likely only be incidentally ingested by 

individuals feeding on the bottom in the precise location where these items were deposited. Military 
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expended materials other than munitions that would remain floating on the surface are too small to 

pose a risk of intestinal blockage to any sea turtle that happened to encounter it. Because leatherbacks 

of all age classes, and hatchlings and juveniles of green, hawksbill, Kemp’s ridley, and loggerhead turtles 

are more likely to feed at or near the surface in the open ocean, they are more likely to encounter 

materials at the surface than other age classes of sea turtles that primarily feed along the seafloor. For 

example, the non-munitions material that floats in the water such as flare pads and pistons as well as 

some target-related materials that may not be recovered (e.g., Styrofoam) may pose an ingestion risk 

for these age classes and species given their feeding behavior and prey choice. Though green, hawksbill, 

Kemp’s ridley, and loggerhead sea turtles are bottom-feeding species that generally recruit to and feed 

in nearshore waters once they reach the juvenile stage, they may occur in the open ocean during 

migrations.

For testing activities occurring in the offshore waters, the species and age classes that have the potential 

to be impacted are hatchlings and pre-recruitment juveniles of all sea turtle species, and leatherback 

turtles of all age classes. Hatchlings and pre-recruitment juveniles of all sea turtle species may also occur 

in open-ocean habitats and be exposed to these activities; however, the likelihood of impact is lower for 

these age classes due to their occurrence at or near the water surface by concentrated Sargassum mats. 

Activities will not be initiated near concentrated Sargassum mats due to the possible presence of sea 

turtles (see Section 5.3, Procedural Mitigation to be Implemented). Non-munitions materials, with the 

exception of decelerators/parachutes since they are expended in deeper offshore waters, may pose a 

slight risk to juvenile, sub-adult, and adult loggerhead, green, and hawksbill turtles that have recruited 

to benthic foraging grounds, especially if non-munitions materials are expended in waters where the 

isobaths are not greater than the benthic foraging ability (dive depth), then these age classes and 

species could be at risk of potentially ingesting non-munitions materials. For example, hawksbills and 

loggerheads may forage in benthic habitats as deep as approximately 80 m and 200 m, respectively 

(Hochscheid, 2014). Juvenile sea turtles (e.g., green turtles) may rest and forage in waters as deep as 

approximately 30 m (Hochscheid, 2014). Sea turtles are expected to be highly dispersed in offshore 

waters. Repeated exposures to sea turtles are not anticipated as these offshore areas do not have 

resident animals year round. In offshore waters, the amount of military expended materials other than 

munitions that an individual sea turtle would encounter is generally low based on the patchy 

distribution of both the non-munitions and sea turtles.

Based on the discussion presented above and in Section 3.8.3.6.2 (Impacts from Military Expended 

Materials Other Than Munitions), the likelihood that a sea turtle would encounter and subsequently 

ingest a non-munitions item associated with Navy training activities is considered low, and nonmunitions are generally expected to cause an insignificant impact to sea turtles. Sublethal impacts due 

to ingestion of military expended materials other than munitions used in training activities may cause 

short-term or long-term disturbance to an individual turtle because (1) if a sea turtle were to incidentally 

ingest and swallow a decelerator/parachute, target fragment, chaff or flare component, it could 

potentially disrupt its feeding behavior or digestive processes; and (2) if the item is particularly large in 

proportion to the turtle ingesting it, the item could become permanently encapsulated by the stomach 

lining, with a rare chance that this could impede the turtle’s ability to feed or take in nutrients. Potential 

impacts of exposure to these items may result in changes to an individual’s behavior, growth, survival, 

annual reproductive success, lifetime reproductive success (fitness), or species recruitment. However, 

decelerators/parachutes, target fragments, chaff, and flare components used in training activities are 

generally not expected to cause disturbance to sea turtles because (1) leatherbacks are more likely to 

forage further offshore than within range complexes, and other sea turtles (e.g., juvenile, sub-adult, and 
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adult green, hawksbill, Kemp’s ridley, and loggerhead turtles) primarily forage on the bottom in 

nearshore areas; (2) in some cases, a turtle would likely pass the item through its digestive tract and 

expel the item without impacting the individual permanently; and (3) chaff, if ingested, would occur in 

very low concentration and is similar to spicules, which sea turtles (species and life stages such as adult 

loggerheads that consume sponges and other organisms containing spicules) ingest without harm. For 

example, Schuyler et al. (2014) noted that less than 10 percent of sea turtles (out of a sample size of 454 

turtles) that ingested a wide range of debris suffered mortality, and 4 percent of turtles necropsied were 

killed by plastics ingestion (out of a sample size of 1,106 necropsied turtles). 

Potential impacts of exposure to non-munitions materials are not expected to result in substantial 

changes in an individual’s behavior, growth, survival, annual reproductive success, lifetime reproductive 

success (fitness), or species recruitment, and as such are not expected to result in population-level

impacts for all sea turtle species.

Proposed testing activities under Alternative 1 that expend potentially ingestible non-munitions 

materials would not occur in designated critical habitat for the green sea turtle (Culebra Island), 

hawksbill sea turtle (Mona Island and Monita Island), leatherback sea turtle (St. Croix Island), or 

American crocodile (Florida Bay). Navy testing activities would expend potentially ingestible nonmunitions materials year round within the five critical habitat types for the loggerhead turtle. See 

Section 3.8.2.2.4.1 (Status and Management) for a description of these habitat types and supporting 

physical and biological factors. Ingestion stressors introduced by military expended materials other than 

munitions have no way of impacting the physical and biological features that comprise loggerhead turtle 

critical habitat (National Marine Fisheries Service, 2014b).

Pursuant to the ESA, testing activities that expend potentially ingestible non-munitions materials under 

Alternative 1 may affect ESA-listed green, hawksbill, Kemp’s ridley, leatherback, and loggerhead sea 

turtles; and would have no effect the American crocodile. There would be no effect on green, hawksbill, 

leatherback, or loggerhead sea turtle critical habitat; and no effect on American crocodile critical 

habitat. The Navy has consulted with NMFS as required by section 7(a)(2) of the ESA in that regard.

3.8.3.6.2.2 Impacts from Military Expended Materials Other Than Munitions under

Alternative 2

Impacts from Military Expended Materials Other Than Munitions under Alternative 2 for Training 

Activities

As presented in Section 3.0.3.3.6 (Ingestion Stressors), and Section 3.0.3.3.4.2 (Military Expended 

Materials), the locations of training activities that expend military expended materials other than 

munitions would be identical under Alternatives 1 and 2. However, the total number of military 

expended materials other than munitions released throughout these locations would increase by 

0.2 percent annually and by 0.2 percent over five years. The fractional increase in amount of military 

expended materials other than munitions would not substantially increase the potential for sea turtles 

to ingest these items. Therefore, the analysis presented in Section 3.8.3.6.2.1 (Impacts from Military 

Expended Materials Other Than Munitions under Alternative 1) for training activities would also apply to 

training activities proposed under Alternative 2 for sea turtles, American alligators, and diamondback 

terrapins.

Proposed training activities under Alternative 2 that expend potentially ingestible non-munitions 

materials would not occur in designated critical habitat for the green sea turtle (Culebra Island), 

hawksbill sea turtle (Mona Island and Monita Island), leatherback sea turtle (St. Croix Island), or 
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American crocodile (Florida Bay). Navy training activities would expend potentially ingestible nonmunitions materials year round within the five critical habitat types for the loggerhead turtle. See 

Section 3.8.2.2.4.1 (Status and Management) for a description of these habitat types and supporting 

physical and biological factors. Ingestion stressors introduced by military expended materials other than 

munitions have no way of impacting the physical and biological features that comprise loggerhead turtle 

critical habitat (National Marine Fisheries Service, 2014b).

Pursuant to the ESA, training activities that expend potentially ingestible non-munitions materials under 

Alternative 2 may affect ESA-listed green, hawksbill, Kemp’s ridley, leatherback, and loggerhead sea 

turtles; and would have no effect the American crocodile. There would be no effect on green, hawksbill, 

leatherback, or loggerhead sea turtle critical habitat; and no effect on American crocodile critical 

habitat.

Impacts from Military Expended Materials-Other Than Munitions under Alternative 2 for Testing 

Activities

As presented in Section 3.0.3.3.6 (Ingestion Stressors) and Section 3.0.3.3.4.2 (Military Expended 

Materials), the locations of testing activities that expend military expended materials other than 

munitions would be identical under Alternatives 1 and 2. However, the number of military expended 

materials other than munitions throughout these locations would increase by approximately 0.3 percent 

annually and by 1.2 percent over five years. The fractional increase in the amount of military expended 

materials other than munitions would not appreciably increase the potential for sea turtles to ingest 

these items. Therefore, the analysis presented in Section 3.8.3.6.2.1 (Impacts from Military Expended 

Materials Other Than Munitions under Alternative 1) for testing activities would also apply to testing 

activities proposed under Alternative 2.

Proposed testing activities under Alternative 2 that expend potentially ingestible non-munitions 

materials would not occur in designated critical habitat for the green sea turtle (Culebra Island), 

hawksbill sea turtle (Mona Island and Monita Island), leatherback sea turtle (St. Croix Island), or 

American crocodile (Florida Bay). Navy testing activities would expend potentially ingestible nonmunitions materials year round within the five critical habitat types for the loggerhead sea turtle. See 

Section 3.8.2.2.4.1 (Status and Management) for a description of these habitat types and supporting 

physical and biological factors. Ingestion stressors introduced by military expended materials other than 

munitions have no way of impacting the physical and biological features that comprise loggerhead turtle 

critical habitat (National Marine Fisheries Service, 2014b).

Pursuant to the ESA, testing activities that expend potentially ingestible non-munitions materials under 

Alternative 2 may affect ESA-listed green, hawksbill, Kemp’s ridley, leatherback, and loggerhead sea 

turtles; and would have no effect the American crocodile. There would be no effect on green, hawksbill, 

leatherback, or loggerhead sea turtle critical habitat; and no effect on American crocodile critical 

habitat.

3.8.3.6.2.3 Impacts from Military Expended Materials Other Than Munitions under the No

Action Alternative

Impacts from Military Expended Materials Other Than Munitions under the No Action Alternative 

for Training and Testing Activities

Under the No Action Alternative, the Navy would not conduct the proposed training or testing activities 

in the AFTT Study Area. Various ingestion stressors (e.g., military expended materials other than 

munitions) would not be introduced into the marine environment. Therefore, baseline conditions of the 
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existing environment would either remain unchanged or would improve slightly after cessation of 

ongoing training and testing activities.

3.8.3.7 Secondary Stressors

This section analyzes potential impacts on sea turtles, crocodilians, and terrapins exposed to stressors 

indirectly through impacts on their habitat (sediment or water quality) or prey availability. For the 

purposes of this analysis, indirect impacts on reptiles via sediment or water quality that do not require 

trophic transfer (e.g., bioaccumulation) in order to be observed are considered here. Bioaccumulation 

considered previously in this document in the analysis of fishes (Section 3.6), invertebrates (Section 3.4), 

and marine habitats (Section 3.5) indicated minimal to no impacts on potential prey species of sea 

turtles, crocodilians, or terrapins. It is important to note that the terms “indirect” and “secondary” do 

not imply reduced severity of environmental consequences but instead describe how the impact may 

occur in an organism. The potential for impacts from all of these secondary stressors are discussed 

below.

Stressors from Navy training and testing activities that could pose indirect impacts on sea turtles via 

habitat or prey include: (1) explosives, (2) explosive byproducts and unexploded munitions, (3) metals, 

and (4) chemicals. Stressors from Navy training and testing activities that could pose indirect impacts on

crocodilians or terrapins via habitat or prey include metals from training and testing activities in inshore 

waters. Analyses of the potential impacts on sediment and water quality are discussed in Section 3.2

(Sediments and Water Quality). 

Explosives 

As it pertains to sea turtles, underwater explosions could impact other species in the food web, 

including prey species that sea turtles feed upon and disrupt ecological relationships and conditions that 

would lead to decreased availability of forage. The impacts of explosions would differ depending on the 

type of prey species in the area of the blast. As described in Chapter 2 (Description of Proposed Action 

and Alternatives), Table 2.6-1 through Table 2.6-4, training and testing activities resulting in underwater 

explosions will occur in the Study Area. 

In addition to the physical effects of an underwater blast (e.g., injury or mortality from the blast 

pressure wave), prey might have behavioral reactions to underwater sound. For instance, prey species 

might exhibit a strong startle reaction to detonations that might include swimming to the surface or 

scattering away from the source. This startle and flight response is the most common secondary defense 

among animals (Mather, 2004). The abundance of prey species near the detonation point could be 

diminished for a short period before being repopulated by animals from adjacent waters (Berglind et al., 

2009; Craig, 2001). Many sea turtle prey items, such as jellyfish, sponges, and molluscs have limited 

mobility and ability to react to pressure waves; therefore, mobile prey species for sea turtles would be 

less affected because of their ability to respond to other stressors preceding an underwater blast (e.g., 

vessel noise or visual cues). Any of these scenarios would be temporary, only occurring during activities 

involving explosives, and no lasting effect on prey availability or the pelagic food web would be 

expected. For example, if prey were removed from an area resulting from a stressor introduced by a 

training or testing activity, prey species would be expected to recolonize or recruit rapidly in the area 

because there would be little or no permanent change to the habitat.

The Navy will implement mitigation (e.g., not conducting gunnery activities within a specified distance of 

shallow-water coral reefs) to avoid potential impacts from explosives and physical disturbance and strike 

stressors on seafloor resources in mitigation areas throughout the Study Area (see Section 5.4.1, 
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Mitigation Areas for Seafloor Resources). This mitigation will consequently help avoid or reduce

potential impacts from explosives on sea turtle prey species that inhabit shallow-water coral reefs, live 

hard bottom, artificial reefs, submerged aquatic vegetation, and shipwrecks.

Explosion Byproducts and Unexploded Munitions 

High-order explosions consume most of the explosive material, creating typical combustion products. In 

the case of Royal Demolition Explosive, also known as cyclonite and hexogen, 98 percent of the 

byproducts are common seawater constituents, and the remainder is rapidly diluted below threshold 

effect level (Section 3.2, Sediments and Water Quality). Explosion byproducts associated with high-order 

detonations present no indirect stressors to sea turtles through sediment or water. Furthermore, most 

explosions occur in depths exceeding that which normally support seagrass beds and coral reefs, areas 

that are commonly used by green and hawksbill sea turtles, respectively. For example, most detonations 

would occur in waters greater than 200 ft. in depth, and greater than 3 NM from shore, although mine 

warfare, demolition, and some testing detonations would occur in shallow water close to shore. These 

low-order detonations and unexploded munitions present elevated likelihood of secondary impacts on 

sea turtles. 

Deposition of undetonated explosive materials into the marine environment can be reasonably well 

estimated by the known failure and low-order detonation rates of high-explosives (Section 3.2, 

Sediments and Water Quality, Table 3.2-7). While it is remotely possible for sea turtles to come into 

contact with an undetonated explosive, to have contact with unexploded materials in the sediment or 

water, and or to ingest unexploded materials in sediments, it is very unlikely.

Indirect impacts of explosives and unexploded munitions to sea turtles via sediment contamination is 

possible only if a sea turtle ingested the sediment. Degradation of explosives proceeds through several 

pathways, as discussed in Section 3.2.3.1 (Explosives and Explosives Byproducts). Degradation products 

of Royal Demolition Explosive are not toxic to marine organisms at realistic exposure levels (Rosen & 

Lotufo, 2010). Relatively low solubility of most explosives and their degradation products means that 

concentrations of these contaminants in the marine environment are relatively low and readily diluted. 

Furthermore, while explosives and their degradation products were detectable in marine sediment 

approximately 6 to 12 in. away from degrading munitions, the concentrations of these compounds were 

not statistically distinguishable from background beyond 3 to 6 ft. from the degrading munitions 

(Section 3.2.3.1, Explosives and Explosives Byproducts). Taken together, it is possible that sea turtles 

could be exposed to degrading explosives, but it would be within a very small radius of the explosive 

(1 to 6 ft.). Juvenile, sub-adult, and adult green, hawksbill, Kemp’s ridley, and loggerhead sea turtles are 

the only age classes and species in the Study Area that might routinely ingest sediments while bottom 

feeding; however, feeding would most likely not occur in deep water areas (greater than 100 m) where 

unexploded materials are more likely to occur.

A series of studies of a World War II munitions disposal site off Hawaii have demonstrated only minimal 

concentrations of degradation products were detected in the adjacent sediments and that there was no 

detectable uptake in sampled organisms living on or in proximity to the site (Briggs et al., 2016; Edwards 

et al., 2016; Hawaii Undersea Military Munitions Assessment, 2010; Kelley et al., 2016; Koide et al., 

2016).A series of research efforts focused on World War II underwater munitions disposal sites in Hawaii 

(Briggs et al., 2016; Edwards et al., 2016; Hawaii Undersea Military Munitions Assessment, 2010; Kelley 

et al., 2016; Koide et al., 2016) and an intensively used live fire range in the Mariana Islands Smith and 

Marx (2016) provide information in regard to the impacts of undetonated materials and unexploded 
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munitions on marine life. Section 3.2.3.1 (Explosives and Explosives Byproducts) and Section 3.2.3.3

(Metals) contains a summary of this literature which investigated water and sediment quality impacts, 

on a localized scale, from munitions ocean disposal sites and ocean disposed dredge spoils sites. 

Findings from these studies indicate that there were no adverse impacts on the local ecology from the 

presence of degrading munitions and there was no bioaccumulation of munitions-related chemicals in 

local marine species. 

The island of Farallon De Medinilla (in the Mariana Islands) has been used as a target area since 1971. 

Between 1997 and 2012, there were 14 underwater scientific survey investigations around the island 

providing a long-term look at potential impacts on the marine life from training and testing involving the 

use of munitions (Smith & Marx, 2016). Munitions use has included high-explosive rounds from gunfire, 

high-explosives bombs by Navy aircraft and U.S. Air Force B-52s, in addition to the expenditure of inert 

rounds and non-explosive practice bombs. Marine life assessed during these surveys included algae, 

corals, benthic invertebrates, sharks, rays, and bony fishes, and sea turtles. The investigators found no 

evidence over the 16-year period, that the condition of the biological resources had been adversely 

impacted to a significant degree by the training activities (Smith & Marx, 2016). Furthermore, they 

found that the health, abundance, and biomass of fishes, corals and other marine resources were 

comparable to or superior to those in similar habitats at other locations within the Mariana Archipelago. 

These findings are consistent with other assessments such as that done for the Potomac River Test 

Range at Dahlgren, Virginia which was established in 1918 and is the nation’s largest fully instrumented, 

over-the-water gun-firing range. Munitions tested at Naval Surface Warfare Center, Dahlgren have 

included rounds from small-caliber guns up to the Navy’s largest (16-in. guns), bombs, rockets, mortars, 

grenades, mines, depth charges, and torpedoes (U.S. Department of the Navy, 2013). Results from the 

assessment indicate that munitions expended at Naval Surface Warfare Center, Dahlgren have not 

contributed to significant concentrations of metals to the Potomac River water and sediments given 

those contributions are orders of magnitude less than concentrations already present in the Potomac 

River from natural and manmade sources (U.S. Department of the Navy, 2013). 

The concentration of munitions/explosions, expended material, or devices in any one location in the 

AFTT Study Area would be a small fraction of that from a World War II dump site, or a target island used 

for 45 years, or a water range in a river used for almost 100 years. Based on findings from much more 

intensively used locations, the water quality effects from the use of munitions, expended material, or 

devices resulting from any of the proposed actions would be negligible by comparison. As a result, 

explosion by‐products and unexploded munitions would have no meaningful effect on water quality and 

would therefore not constitute a secondary indirect stressor for sea turtles.

Metals 

Metals are introduced into seawater and sediments as a result of training and testing activities involving 

ship hulks, targets, munitions, and other military expended materials (Section 3.2.3.3, Metals)

(Environmental Sciences Group, 2005). Some metals bioaccumulate and physiological impacts begin to 

occur only after several trophic transfers concentrate the toxic metals (Section 3.5, Habitats, and 

Chapter 4, Cumulative Impacts). Evidence from a number of studies (Briggs et al., 2016; Koide et al., 

2016) indicate metal contamination is very localized and that bioaccumulation resulting from munitions 

cannot be demonstrated. Specifically, in sampled marine life living on or around munitions on the 

seafloor, metal concentrations could not be definitively linked to the munitions since comparison of 

metals in sediment next to munitions show relatively little difference in comparison to other “clean” 
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marine sediments used as a control/reference (Koide et al., 2015). Research has demonstrated that 

some smaller marine organisms are attracted to metal munitions as a hard substrate for colonization or 

as shelter (Smith & Marx, 2016). Although this would likely increase prey availability for some benthic 

foraging sea turtles that feed on molluscs (e.g., loggerheads), the relatively low density of metals 

deposited by training and testing activities compared to concentrated dump and range sites would not 

likely substantively benefit sea turtles. Inshore waters, which would receive small-caliber shells from 

training activities have the potential to be deposited in substrates in estuaries used by some sea turtles 

(in particular Kemp’s ridley, loggerhead, and green sea turtles), crocodilians, and terrapins; and riverine 

habitats where crocodilians and terrapins would be expected to occur. As with other studies discussed 

above, leaching of metals contained in shell casings would be expected to be localized in sediments with 

little opportunity for bioaccumulation into the food web that would impact crocodilian species or 

terrapins.

Chemicals 

Several Navy training and testing activities introduce chemicals into the marine environment that are 

potentially harmful in higher concentrations; however, rapid dilution would occur and toxic 

concentrations are unlikely to be encountered. Chemicals introduced are principally from flares and 

propellants for missiles and torpedoes. Properly functioning flares, missiles, and torpedoes combust 

most of their propellants, leaving benign or readily diluted soluble combustion byproducts 

(e.g., hydrogen cyanide). Operational failures may allow propellants and their degradation products to 

be released into the marine environment. Flares and missile that operationally fail may release 

perchlorate, which is highly soluble in water, persistent, and impacts metabolic processes in many plants 

and animals if in sufficient concentration. Such concentrations are not likely to persist in the ocean. 

Research has demonstrated that perchlorate did not bioconcentrate or bioaccumulate, which was 

consistent with the expectations for a water soluble compound (Furin et al., 2013). Perchlorate from 

failed expendable items is therefore unlikely to compromise water quality to that point that it would act 

as a secondary stressor to sea turtles. It should also be noted that chemicals in the marine environment 

as a result of Navy training and testing activities would not occur in isolation and are typically associated 

with military expended materials that release the chemicals while in operation. Because sea turtles’

avoidance of an expended flare, missile, or torpedo in the water is almost certain (because of other ques 

such as visual and noise disturbance), it would further reduce the potential for introduced chemicals to 

act as a secondary stressor. Avoidance is likely because expending these items would be accompanied 

by other visual ques or noise disturbances.

3.8.3.7.1 Impacts on Habitat

As presented above in Section 3.8.3.7 (Secondary Stressors), Navy activities that introduce explosive 

byproducts and unexploded munitions, metals, and chemicals into the marine environment have not 

demonstrated long-term impacts on sediment and water quality. Explosive byproducts and unexploded 

munitions from ongoing Navy activities have not resulted in water quality impacts, and the likelihood of 

sea turtles, crocodilians, or terrapins being in contact with sediments contaminated from degrading 

explosives is low, given the small radius of impact around the location of the explosive. Furthermore, 

there is no evidence of bioconcentration or bioaccumulation of chemicals introduced by Navy activities 

that would alter water quality to an extent that would result in overall habitat degradation for sea 

turtles, crocodilians, or terrapins.

As stated previously, most detonations would occur in waters greater than 200 ft. in depth, and greater 

than 3 NM from shore, although mine warfare, demolition, and some testing detonations would occur in 
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shallow water close to shore. In deep waters, explosions would not likely remove habitat for sea turtles 

because the explosion would not be on or proximate to the sea floor. These habitats include corals, 

seagrass beds, and other benthic habitats that are used by juvenile and adult sea turtle species, e.g., 

green and hawksbill turtles. Metals are introduced into the water and sediments from multiple types of 

military expended materials. Available research indicates metal contamination is very localized and that 

bioaccumulation resulting from munitions would not occur. Several Navy training and testing activities 

introduce chemicals into the marine environment that are potentially harmful in concentration; 

however, through rapid dilution, toxic concentrations are unlikely to be encountered by sea turtles, 

crocodilians, and terrapins. In near shore waters, explosions would typically occur in the same locations, 

limiting the removal of habitat to previously disturbed areas. Therefore, habitat loss from training and 

testing activities that use explosions would not substantially remove habitats available to sea turtles, 

crocodilians, or terrapins and not impact individuals or populations.

Secondary stressors from Navy training and testing activities in the Study Area are not expected to result 

in substantial changes in an individual’s behavior, growth, survival, annual reproductive success, lifetime 

reproductive success (fitness), or species recruitment, and as such are not expected to result in 

population-level impacts for all sea turtle species, crocodilians, and terrapins.

Proposed training and testing activities that would introduce secondary stressors (potentially impacting 

habitats) would not occur in designated critical habitat for the green sea turtle (Culebra Island), 

hawksbill sea turtle (Mona Island and Monita Island), leatherback sea turtle (St. Croix Island), or 

American crocodile (Florida Bay). Navy training and testing activities would introduce secondary 

stressors (that may impact habitats) year round within the five critical habitat types for the loggerhead 

turtle. See Section 3.8.2.2.4.1 (Status and Management) for a description of these habitat types and 

supporting physical and biological factors. In nearshore waters, explosions would typically occur in the 

same locations, limiting the removal of habitat to previously disturbed areas. In offshore areas where 

most explosions would occur, the Navy would not initiate activities near concentrated Sargassum mats 

(see Section 5.3, Procedural Mitigation to be Implemented); therefore, developmental habitat for 

hatchlings and pre-recruitment juveniles of all sea turtle species would not be affected. Explosion 

byproducts, metals, and chemicals from training and testing activities, as discussed above, induce very 

localized or short-term impacts to water quality within the water column. Activities that introduce 

secondary stressors would occur over wide areas and in sufficiently low frequency as to not impact the 

physical and biological features that comprise loggerhead critical habitat.

Pursuant to the ESA, Navy training and testing activities would introduce secondary stressors with 

potential impacts on habitats that may affect ESA-listed green, hawksbill, Kemp’s ridley, leatherback, 

and loggerhead sea turtles; and would have no effect on the American crocodile. There would be no 

effect on green, hawksbill, leatherback, or loggerhead sea turtle critical habitat; and no effect on 

American crocodile critical habitat. The Navy has consulted with NMFS as required by section 7(a)(2) of 

the ESA in that regard, for training and testing activities described under Alternative 1.

3.8.3.7.2 Impacts on Prey Availability

As presented above in Section 3.8.3.7 (Secondary Stressors), Navy activities that introduce explosives, 

metals, and chemicals into the marine environment have not demonstrated long-term impacts on prey 

availability for sea turtles, crocodilians, or terrapins. Bioaccumulation of metals from munitions in prey 

species has not been demonstrated and no effects to prey availability from metals and chemicals are 

known to occur. Bioaccumulation of metals from munitions in prey species has not been demonstrated,
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and no effects to prey availability from metals and chemicals are known to occur. In-water explosions 

have the potential to injure or kill prey species that reptiles feed on within a small area affected by the 

blast; however, impacts would not substantially impact prey availability for sea turtles. Training and 

testing activities in the Study Area would be unlikely to impact coral reefs (a direct or indirect source of 

prey and forage items for juvenile, sub-adult, and adult hawksbill turtles) because the Navy implements 

measures within mitigation areas for shallow-water coral reefs. Also, activities are not initiated near 

concentrated Sargassum mats, where hatchlings and pre-recruitment juvenile sea turtle prey is found, 

due to the possible presence of sea turtles (see Section 5.3, Procedural Mitigation to be Implemented).

These mitigation measures would continue under both Alternative 1 and Alternative 2. Activities that 

involve the use of explosives typically occur at depths that exceed areas that support seagrass beds for 

foraging juvenile, sub-adult, and adult green turtles. For inshore training and testing activities, impacts 

on prey availability for crocodilians and terrapins, if they occurred, would not likely be measureable 

because of the types of activities that would occur in inshore training and testing locations, and because 

of the generalist diet of crocodilians and terrapins.

Secondary stressors from Navy training and testing activities in the Study Area that may influence prey 

availability are not expected to result in substantial changes in an individual’s behavior, growth, survival, 

annual reproductive success, lifetime reproductive success (fitness), or species recruitment, and as such 

are not expected to result in population-level impacts for all sea turtle species, crocodilians, or terrapins.

Proposed training and testing activities that would introduce secondary stressors (potentially impacting 

prey availability) would not occur in designated critical habitat for the green sea turtle (Culebra Island), 

hawksbill sea turtle (Mona Island and Monita Island), leatherback sea turtle (St. Croix Island), or 

American crocodile (Florida Bay). Navy training and testing activities would introduce secondary 

stressors (that may influence prey availability) year round within the five critical habitat types for the 

loggerhead turtle. See Section 3.8.2.2.4.1 (Status and Management) for a description of these habitat 

types and supporting physical and biological factors. In nearshore waters, explosions would typically 

occur in the same locations, limiting the removal of habitat to previously disturbed areas. In offshore 

areas where most explosions would occur, the Navy would not initiate activities near concentrated 

Sargassum mats (see Section 5.3, Procedural Mitigation to be Implemented); therefore, developmental 

habitat for hatchlings and pre-recruitment juveniles of all sea turtle species would not be affected. 

Explosion byproducts, metals, and chemicals from training and testing activities, as discussed above, 

induce very localized or short-term impacts to water quality within the water column. Activities that 

introduce secondary stressors would occur over wide areas and in sufficiently low frequency as to not 

impact the physical and biological features that comprise loggerhead critical habitat.

Pursuant to the ESA, Navy training and testing activities would introduce secondary stressors influencing 

prey availability that may affect ESA-listed green, hawksbill, Kemp’s ridley, leatherback, and loggerhead 

sea turtles; and would have no effect on the American crocodile. There would be no effect on green, 

hawksbill, leatherback, or loggerhead sea turtle critical habitat; and no effect on American crocodile 

critical habitat. The Navy has consulted with NMFS as required by section 7(a)(2) of the ESA in that 

regard, for training and testing activities described under Alternative 1.

3.8.4 SUMMARY OF POTENTIAL IMPACTS ON REPTILES

3.8.4.1 Combined Impacts of All Stressors under Alternative 1

As described in Section 3.0.3.5 (Resource-Specific Impacts Analysis for Multiple Stressors), this section 

evaluates the potential for combined impacts of all the stressors from the proposed action. The analysis 
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and conclusions for the potential impacts from each of the individual stressors are discussed in Sections

3.8.3.1 (Acoustic Stressors) through 3.8.3.6 (Ingestion Stressors) and, for ESA-listed species, summarized 

in Section 3.8.4.4 (Endangered Species Act Determinations). Stressors associated with Navy training and 

testing activities do not typically occur in isolation but rather occur in some combination. For example, 

mine neutralization activities include elements of acoustic, physical disturbance and strike, 

entanglement, ingestion, and secondary stressors that are all coincident in space and time. An analysis 

of the combined impacts of all stressors considers the potential consequences of additive stressors and 

synergistic stressors, as described below. This analysis makes the reasonable assumption that the 

majority of exposures to stressors are non-lethal, and instead focuses on consequences potentially 

impacting sea turtle, crocodilian, or terrapin fitness (e.g., physiology, behavior, reproductive potential).

Additive Stressors–There are generally two ways that a sea turtle, crocodilian, or terrapin could be 

exposed to multiple additive stressors. The first would be if an animal were exposed to multiple sources 

of stress from a single event or activity within a single testing or training event (e.g., a mine warfare 

event may include the use of a sound source and a vessel). For crocodilians and terrapins, multiple 

additive stressors would likely be limited to vessel transits in shallow waters and sound sources, or for 

American alligators and terrapins, weapons firing noise and vessels; because of the limited number of 

additive stressors that crocodilians and terrapins would likely experience, only sea turtles are addressed 

further in this section. 

The potential for a combination of these impacts from a single activity would depend on the range to 

effects of each of the stressors and the response or lack of response to that stressor. Most of the 

activities proposed under Alternative 1 generally involve the use of moving platforms (e.g., ships, 

torpedoes, and aircraft) that may produce one or more stressors; therefore, it is likely that if a sea turtle 

were within the potential impact range of those activities, it may be impacted by multiple stressors 

simultaneously. Individual stressors that would otherwise have minimal to no impact, may combine to 

have a measurable response. However, due to the wide dispersion of stressors, speed of the platforms, 

general dynamic movement of many training and testing activities, and behavioral avoidance exhibited 

by sea turtles, it is very unlikely that a sea turtle would remain in the potential impact range of multiple 

sources or sequential exercises. Exposure to multiple stressors is more likely to occur at an instrumented 

range where training and testing using multiple platforms may be concentrated during a particular 

event, or in inshore waters where sea turtles reside. In such cases involving a relatively small area on an 

instrumented range, a behavioral reaction resulting in avoidance of the immediate vicinity of the activity 

would reduce the likelihood of exposure to additional stressors. Nevertheless, the majority of the 

proposed activities in offshore areas are unit-level training and small testing activities which are 

conducted in the open ocean. Unit level exercises occur over a small spatial scale (one to a few square 

miles) and with few participants (usually one or two vessels) or short duration (the order of a few hours 

or less). In inshore waters, however, exposure to multiple stressors is likely because of the close 

proximity of stressors and higher numbers of sea turtles.

Secondly, a sea turtle could be exposed to multiple training and testing activities over the course of its 

life, however, training and testing activities are generally separated in space and time in such a way that 

it would be unlikely that any individual sea turtle would be exposed to stressors from multiple activities 

within a short timeframe. However, sea turtles with a home range intersecting an area of concentrated 

Navy activity have elevated exposure risks relative to sea turtles that simply transit the area through a 

migratory corridor. This limited potential for exposure of individuals is not anticipated to impact 

populations.
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Synergistic Stressors–Multiple stressors may also have synergistic effects. For example, sea turtles that 

react to a sound source (behavioral response) or experience injury from acoustic stressors could be 

more susceptible to physical strike and disturbance stressors via a decreased ability to detect and avoid 

threats. Sea turtles that experience behavioral and physiological consequences of ingestion stressors 

could be more susceptible to entanglement and physical strike stressors via malnourishment and 

disorientation. Similarly, sea turtles that may be weakened by disease (e.g., fibropapillomatosis) or other 

factors that are not associated with Navy training and testing activities may be more susceptible to 

stressors analyzed in this EIS/OEIS. These interactions are speculative, and without data on the 

combination of multiple Navy stressors, the synergistic impacts from the combination of Navy stressors 

are difficult to predict in any meaningful way. Research and monitoring efforts have included before, 

during, and after-event observations and surveys, data collection through conducting long-term studies 

in areas of Navy activity, occurrence surveys over large geographic areas, biopsy of animals occurring in 

areas of Navy activity, and tagging studies where animals are exposed to Navy stressors. These efforts 

are intended to contribute to the overall understanding of what impacts may be occurring overall to 

animals in these areas. 

Crocodilians and terrapins in inshore training and testing locations may experience a smaller array of 

additive and synergistic stressors relative to sea turtles in offshore locations. However, the stressors that 

could simultaneously occur or quickly follow each other may contribute to major risk factors for these 

species. For example, a major risk factor for crocodilians and terrapins is recreational boating, which 

may present the same risk factors as small boat movements associated with military training and testing 

activities. How crocodilians and terrapins may be at higher risk from other synergistic stressors is 

speculative. As with sea turtles, the additive and synergistic stressor impacts on crocodilians and 

terrapins from the combination of Navy stressors is difficult to predict in any meaningful way.

3.8.4.2 Combined Impacts of All Stressors under Alternative 2

Training and testing activities proposed under Alternative 2 would be an increase over what is proposed 

for Alternative 1. However, this increase is not expected to substantially increase the potential for 

impacts over what is analyzed for Alternative 1. The analysis presented in Section 3.8.4.1 (Combined 

Impacts of All Stressors under Alternative 1) would similarly apply to Alternative 2. The combined 

impacts of all stressors for training and testing activities under Alternative 2 are not expected to have 

deleterious impacts on the fitness of any individuals or long-term consequences to populations of sea 

turtles, crocodilians, or terrapins.

3.8.4.3 Combined Impacts of All Stressors under the No Action Alternative

Under the No Action Alternative, the Navy would not conduct the proposed training and testing 

activities in the AFTT Study Area. Various stressors would not be introduced into the marine 

environment, and there would be no combined impact of multiple stressors on sea turtles, crocodilians, 

or terrapins. Therefore, baseline conditions of the existing environment would either remain unchanged 

or would improve slightly after cessation of ongoing training and testing activities.

3.8.5 ENDANGERED SPECIES ACT DETERMINATIONS

Administration of ESA obligations associated with sea turtles are shared between NMFS and USFWS, 

depending on life stage and specific location of the sea turtle. NMFS has jurisdiction over sea turtles in 

the marine environment, and USFWS has jurisdiction over sea turtles on land. The Navy has consulted

with NMFS on its determination of effect on the potential impacts of the Proposed Action. Because no 

activities analyzed in this EIS/OEIS occur on land within sea turtle nesting areas, consultation with 
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USFWS is not required for sea turtles. American crocodiles are managed under the jurisdiction of 

USFWS; therefore, the Navy has consulted with USFWS for the proposed activities considered in this 

EIS/OEIS as required by section 7(a)(2) of the ESA.

Pursuant to the ESA, the Navy has concluded training and testing activities may affect the green sea 

turtle, hawksbill sea turtle, Kemp’s ridley sea turtle, loggerhead sea turtle, leatherback sea turtle, and 

American crocodile. The Navy has also concluded that training and testing activities may affect 

designated critical habitat for the loggerhead sea turtle; and have no effect on designated critical habitat 

for the green sea turtle, hawksbill sea turtle, leatherback sea turtle, and American crocodile. The Navy 

has consulted with NMFS and USFWS as required by section 7(a)(2) of the ESA in that regard. The Navy’s 

summary of effects determinations for each ESA-listed species is shown in Table 3.8-11. NMFS and 

USFWS concurred with all Navy determinations on their respective species.
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Table 3.8-11: Summary of ESA-Effects Determinations for Reptiles (Alternative 1)

Species Designation 

Unit

Effect Determinations by Stressor

Acoustic

Explosives EnergyPhysical Disturbance and 

Strike Entanglement Ingestion

Sonar and Other TransducersAir GunsPile DrivingVessel NoiseAircraft NoiseWeapons NoiseExplosivesIn-water Electromagnetic DevicesHigh-energy LasersVessels In-water DevicesMilitary Expended MaterialsSeafloor DevicesWires and CablesDecelerators/ParachutesBiodegradable PolymerMilitary Expended Materials -MunitionsMilitary Expended Materials -Other Than Munitions

Training Activities

American 

crocodile

Throughout 

range

NE N/A NE NLAA NLAA NE NLAA NE NE NE NE NE NE NE NE N/A NE NE

Critical habitat NE N/A NE NE NE NE NE NE NE NE NE NE NE NE NE N/A NE NE

Green turtle

North Atlantic 

DPS NLAA N/A NLAA NLAA NLAA NLAA LAA NLAA NLAA LAA NLAA NLAA NLAA NLAA LAA N/A NLAA NLAA

Critical habitat NE N/A NE NE NE NE NE NE NE NE NE NE NE NE NE N/A NE NE

Hawksbill 

turtle

Throughout 

range

NLAA N/A NLAA NLAA NLAA NLAA LAA NLAA NLAA LAA NLAA NLAA NLAA NLAA NLAA N/A NLAA NLAA

Critical habitat NE N/A NE NE NE NE NE NE NE NE NE NE NE NE NE N/A NE NE

Kemp’s 

ridley turtle 

Throughout 

range

NLAA N/A NLAA NLAA NLAA NLAA LAA NLAA NLAA LAA NLAA NLAA NLAA NLAA LAA N/A NLAA NLAA

Leatherback 

turtle

Throughout 

range

NLAA N/A NLAA NLAA NLAA NLAA LAA NLAA NLAA LAA NLAA NLAA NLAA NLAA LAA N/A NLAA NLAA

Critical habitat NE N/A NE NE NE NE NE NE NE NE NE NE NE NE NE N/A NE NE

Loggerhead 

turtle

NW Atlantic 

Ocean DPS

NLAA N/A LAA NLAA NLAA NLAA LAA NLAA NLAA LAA NLAA NLAA NLAA NLAA LAA N/A NLAA NLAA

Critical habitat NLAA N/A NE NLAA NE NLAA NLAA NE NE NE NE NE NE NE NE N/A NE NE
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Table 3.8-11: Summary of ESA-Effects Determinations for Reptiles (Alternative 1) (continued)

Species Designation 

Unit

Effect Determinations by Stressor

Acoustic

Explosives EnergyPhysical Disturbance and 

Strike Entanglement Ingestion

Sonar and Other TransducersAir GunsPile DrivingVessel NoiseAircraft NoiseWeapons NoiseExplosivesIn-water Electromagnetic DevicesHigh-energy LasersVesselsIn-water DevicesMilitary Expended MaterialsSeafloor DevicesWires and CablesDecelerators/ParachutesBiodegradable PolymerMilitary Expended Materials -MunitionsMilitary Expended Materials -Other Than Munitions

Testing Activities

American 

crocodile

Throughout 

range

NE NE N/A NLAA NLAA NE NE NE NE NE NE NE NE NE NE NE NE NE

Critical habitat NE NE N/A NE NE NE NE NE NE NE NE NE NE NE NE NE NE NE

Green turtle

North Atlantic 

DPS NLAA NLAA N/A NLAA NLAA NLAA LAA NLAA NLAA LAA NLAA NLAA NLAA NLAA NLAA NLAA NLAA NLAA

Critical habitat NE NE N/A NE NE NE NE NE NE NE NE NE NE NE NE NE NE NE

Hawksbill 

turtle

Throughout 

range

NLAA NLAA N/A NLAA NLAA NLAA LAA NLAA NLAA LAA NLAA NLAA NLAA NLAA NLAA NLAA NLAA NLAA

Critical habitat NE NE N/A NE NE NE NE NE NE NE NE NE NE NE NE NE NE NE

Kemp’s 

ridley turtle 

Throughout 

range

LAA NLAA N/A NLAA NLAA NLAA LAA NLAA NLAA LAA NLAA NLAA NLAA NLAA NLAA NLAA NLAA NLAA

Leatherback 

turtle

Throughout 

range

LAA NLAA N/A NLAA NLAA NLAA LAA NLAA NLAA LAA NLAA NLAA NLAA NLAA NLAA NLAA NLAA NLAA

Critical habitat NE NE N/A NE NE NE NE NE NE NE NE NE NE NE NE NE NE NE

Loggerhead 

turtle

NW Atlantic 

Ocean DPS LAA LAA N/A NLAA NLAA NLAA LAA NLAA NLAA LAA NLAA NLAA NLAA NLAA NLAA NLAA NLAA NLAA

Critical habitat NLAA NE N/A NLAA NE NLAA NLAA NE NE NE NE NE NE NE NE NE NE NE

Note: NW = Northwest; DPS = Distinct Population Segment; NE = no effect; NLAA = may effect, not likely to adversely affect; LAA = may effect, likely to adversely affect; N/A = not applicable, activity related to 

the stressor does not occur during specified training or testing events (e.g., there are no testing activities that involve the use of pile driving).
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3.8 References

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Table of Contents

Final 

Environmental Impact Statement/Overseas Environmental Impact Statement 

Atlantic Fleet Training and Testing

TABLE OF CONTENTS

3.9 Birds and Bats.............................................................................................. 3.9-1

3.9.1 Introduction ........................................................................................................3.9-2

3.9.2 Affected Environment.........................................................................................3.9-3

3.9.2.1 General Background ...........................................................................3.9-3

3.9.2.2 Endangered Species Act-Listed Species............................................3.9-14

3.9.2.3 Species Not Listed Under the Endangered Species Act....................3.9-31

3.9.3 Environmental Consequences ..........................................................................3.9-49

3.9.3.1 Acoustic Stressors.............................................................................3.9-50

3.9.3.2 Explosive Stressors............................................................................3.9-80

3.9.3.3 Energy Stressors................................................................................3.9-88

3.9.3.4 Physical Disturbance and Strike Stressors........................................3.9-96

3.9.3.5 Entanglement Stressors..................................................................3.9-110

3.9.3.6 Ingestion Stressors..........................................................................3.9-115

3.9.3.7 Secondary Stressors........................................................................3.9-122

3.9.4 Summary of Potential Impacts on Birds and Bats...........................................3.9-124

3.9.4.1 Combined Impacts of All Stressors Under Alternative 1 ................3.9-124

3.9.4.2 Combined Impacts of All Stressors Under Alternative 2 ................3.9-125

3.9.4.3 Combined Impacts of All Stressors Under the No Action 

Alternative......................................................................................3.9-125

3.9.5 Endangered Species Act Determinations........................................................3.9-125

3.9.6 Migratory Bird Treaty Act Determinations.....................................................3.9-125

List of Figures 

Figure 3.9-1: Critical Habitat Areas for Piping Plover in and Adjacent to the Atlantic Coastal 

Portions of the Study Area.......................................................................................................3.9-18

Figure 3.9-2: Critical Habitat Areas for Piping Plover in and Adjacent to the Eastern Gulf of 

Mexico Coastal Portions of the Study Area .............................................................................3.9-19

Figure 3.9-3: Critical Habitat Areas for Piping Plover in and Adjacent to the Western Gulf of 

Mexico Coastal Portions of the Study Area .............................................................................3.9-20
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Table of Contents

List of Tables

Table 3.9-1: Endangered Species Act-List Bird and Bat Species in the Study Area...............................3.9-14

Table 3.9-2: Major Taxonomic Groups of Birds in the Study Area .......................................................3.9-32

Table 3.9-3: Bats Known or Expected to Occur in the Study Area........................................................3.9-41

Table 3.9-4: Birds of Conservation Concern that Occur within the Study Area....................................3.9-47

Table 3.9-5: Range to No Blast Injury for Birds and Bats Exposed to Aerial Explosives .......................3.9-82

Table 3.9-6: Bird Effect Determinations for Training and Testing Activities Under the 

Proposed Action.....................................................................................................................3.9-127

Table 3.9-7: Bat Effect Determinations for Training and Testing Activities under the 

Proposed Action.....................................................................................................................3.9-129
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3.9 Birds and Bats

3.9 BIRDS AND BATS

BIRDS AND BATS SYNOPSIS

The United States Department of the Navy (Navy) considered all potential stressors that birds and 

bats could potentially be exposed to from the Proposed Action. The following conclusions have been 

reached for the Preferred Alternative (Alternative 1):

 Acoustics: Navy training and testing activities have the potential to expose birds and bats to a 

variety of acoustic stressors. The exposure to underwater sounds by birds depends on the 

species and foraging method. Pursuit divers may remain underwater for minutes, increasing 

the chance of underwater sound exposure. The exposure to in-air sounds by birds and bats 

depends on the activity (in flight or on the water surface) and the proximity to the sound 

source. Because birds are less susceptible to both temporary and permanent threshold shift 

than mammals, unless very close to an intense sound source, responses by birds to acoustic 

stressors would likely be limited to short-term behavioral responses. Some birds may be 

temporarily displaced and there may be temporary increases in stress levels. Although 

individual birds may be impacted, population level impacts are not expected. Unlike other 

mammals, bats are not susceptible to temporary and permanent threshold shifts. Bats may 

be temporarily displaced during foraging, but would return shortly after the training or testing 

is complete. Although individual bats may be impacted, population level impacts are not 

expected.

 Explosives: Navy training and testing activities have the potential to expose birds and bats to 

explosions in the water, near the water surface, and in air. Sounds generated by most small

underwater explosions are unlikely to disturb birds and bats above the water surface. 

However, if a detonation is sufficiently large or is near the water surface, birds and bats above 

the pressure released at the air-water interface could be injured or killed. Detonations in air 

could injure birds and bats while either in flight or at the water surface; however, detonations 

in air during anti-air warfare training and testing would typically occur at much higher 

altitudes where seabirds, migrating birds, and bats are less likely to be present. Detonations 

may attract birds to possible fish kills, which could cause bird mortalities or injuries if there 

are multiple detonations in a single event. An explosive detonation would likely cause a 

startle reaction, as the exposure would be brief and any reactions are expected to be shortterm. Although a few individuals may experience long-term impacts and potential mortality, 

population-level impacts are not expected.

 Energy: The impact of energy stressors on birds and bats is expected to be negligible based on 

(1) the limited geographic area in which they are used, (2) the rare chance that an individual 

bird or bat would be exposed to these devices in use, and (3) the tendency of birds and bats 

to temporarily avoid areas of activity when and where the devices are in use. The impacts of 

energy stressors would be limited to individual cases where a bird or bat might become 

temporarily disoriented and change flight direction, or be injured. Although a small number of 

individuals may be impacted, the impact at the population level would be negligible.

Continued on the next page...
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3.9 Birds and Bats

3.9.1 INTRODUCTION

This chapter provides the analysis of potential impacts on birds and bats found in the Atlantic Fleet 

Training and Testing (AFTT) Study Area (Study Area). This section provides an introduction to the species 

that occur in the Study Area.

The affected environment provides the context for evaluating the effects of the Navy training and 

testing activities to birds and bats. Because birds occur throughout the Study Area along shorelines, on 

the surface of the water, in water column and shallow bottom habitats, and are airborne over these 

habitats, Navy activities within these habitats could potentially impact many individuals and species, 

Continued from the previous page...

BIRDS AND BATS SYNOPSIS

 Physical Disturbance and Strikes: There is the potential for individual birds to be injured or 

killed by physical disturbance and strikes during training and testing. However, there would 

not be long-term species or population level impacts due to the vast area over which training 

and testing activities occur and the small size of birds and their ability to flee disturbance. 

Impacts to bats would be similar to, but less than, those described for birds since bat 

occurrence in the Study Area is relatively scant compared to birds and because bats are most 

active from dusk through dawn.

 Entanglement: Entanglement stressors have the potential to impact birds. However, the 

likelihood is low because the relatively small quantities of materials that could cause 

entanglement would be dispersed over very wide areas, often in locations or depth zones 

outside the range or foraging abilities of most birds. A small number of individuals may be 

impacted, but no effects at the population level would be expected. The possibility that an 

individual of an ESA-listed bird species would become entangled is remote due to their rarity 

and limited overlap with Navy activities. Since bats considered in this analysis do not occur in 

the water column and rarely occur at the water surface in the Study Area, few, if any, impacts 

to bats are anticipated from entanglement stressors.

 Ingestion: It is possible that persistent expended materials could be accidentally ingested by 

birds while they were foraging for natural prey items, though the probability of this event is 

low as (1) foraging depths of diving birds is generally restricted to the surface of the water or 

shallow depths, (2) the material is unlikely to be mistaken for prey, and (3) most of the 

material remains at or near the sea surface for a short length of time. No population-level 

effect to any bird species would be anticipated. Since bats considered in this analysis do not 

occur in the water column and rarely feed at the water surface in the Study Area, few, if any, 

impacts to bats are anticipated from ingestion stressors.

 Secondary: There would be relatively localized, temporary impacts from water quality 

(turbidity) which may alter foraging conditions, but no impacts on prey availability. Since bats 

considered in this analysis do not occur in the water column and rarely occur at the water 

surface in the Study Area, few, if any, impacts to bats are anticipated from secondary 

stressors.
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3.9 Birds and Bats

including members of diverse taxonomic groups, Endangered Species Act (ESA)-listed species, species 

protected under the Migratory Bird Treaty Act, and U.S. Fish and Wildlife Service (USFWS) Birds of 

Conservation Concern. Since bats also occur throughout the Study Area along shorelines, on or near the 

surface of the water, and are airborne over these habitats, Navy activities could affect bats in a similar 

manner. Any such impact, however, would be smaller than that to birds since bats are much less 

abundant in the Study Area compared to birds. 

The following sections include Section 3.9.2 (Affected Environment), which provides a description of 

baseline conditions and brief introduction to the species and major taxonomic groups that occur in the 

Study Area; Section 3.9.3 (Environmental Consequences); and Section 3.9.4 (Summary of Potential 

Impacts on Birds and Bats). Throughout this chapter, particular consideration is given to ESA-listed 

species, species protected under the Migratory Bird Treaty Act, and the USFWS Birds of Conservation 

Concern.

3.9.2 AFFECTED ENVIRONMENT

Three subsections are included in this section. General background information is given in Section

3.9.2.1 (General Background), which provides brief summaries of group size, habitat use, dive behavior, 

hearing and vocalization, and threats that affect or have the potential to affect natural communities of 

birds or bats within the Study Area. Protected species listed under the ESA are described in Section

3.9.2.2 (Endangered Species Act-Listed Species). Section 3.9.2.3 (Species Not Listed Under the 

Endangered Species Act) describes birds and bats not listed under the ESA, including major taxonomic 

groups and migratory birds protected under the Migratory Bird Treaty Act.

3.9.2.1 General Background

There are at least 160 species of birds that regularly occur in the Study Area (Sibley, 2014). Most of 

these are waterbirds – birds that live in marine, estuarine, and freshwater habitats. Waterbirds include 

seabirds, wading birds, shorebirds, and waterfowl, as described in more detail below. The remainder of 

species that may be regularly encountered in the Study Area are landbirds that are coastal resident 

species that live on land but forage in the adjacent coastal and inshore waters. Many more species 

(primarily songbirds) are neotropical migrants that occur briefly during transit between breeding areas 

in eastern North America and wintering areas in Central and South America and the Caribbean. TransGulf migrants [birds that fly 600 miles across the Gulf of Mexico between the Yucatan Peninsula and the 

U.S. Gulf Coast (Texas to Florida)], passing through the Study Area, include at least 73 species of 

landbirds (Shackelford et al., 2005).

Seabirds – birds that forage primarily on the open ocean – are of particular interest as the group of birds 

with the broadest distribution and exposure to Navy activities in the Study Area. Seabirds are a diverse 

group that are adapted to living in marine environments (Enticott & Tipling, 1997) and use coastal 

(nearshore) waters, offshore waters (continental shelf), or open ocean areas (Harrison, 1983). There are 

many biological, physical, and behavioral adaptations that are different for seabirds than for terrestrial 

birds. Seabirds typically live longer, breed later in life, and produce fewer young than other bird species

(Onley & Scofield, 2007). The feeding habits of seabirds are related to their individual physical 

characteristics, such as body mass, bill shape, and wing area (Hertel & Ballance, 1999). Some seabirds 

look for food (forage) on the sea surface, whereas others dive to variable depths to obtain prey (Burger, 

2001). Many seabirds spend most of their lives at sea and come to land only to breed, nest, and 

occasionally rest (Schreiber & Chovan, 1986). Most species nest in groups (colonies) on the ground of 

coastal areas or oceanic islands, where breeding colonies number from a few individuals to thousands. 
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3.9 Birds and Bats

However, some species of seabirds and many other waterbird species are distributed nesters, and some 

are cavity nesters. Typical bird behavior to be encountered within the Study Area would include 

breeding, foraging, roosting, and migration. Beaches and wetlands within or bordering the Study Area 

may also be used as molting grounds by some species. 

Additional information on the biology, life history, and conservation of bird species, including speciesspecific descriptions, is available from the websites of these sources:

 USFWS Migratory Bird Program and Endangered Species Program

 Birdlife International

 International Union for Conservation of Nature and Natural Resources Red List of Threatened 

Species

 National Audubon Society

 The Waterbird Society

 Department of Defense’s (DoD) Partners in Flight

 Birds of North America

Bats include resident and migratory, hibernating and non-hibernating species (National Park Service, 

2017a). Although all bats are terrestrial, many bat species occur in coastal (nearshore) waters, offshore 

waters (continental shelf), or open ocean areas while migrating or foraging and will use islands, ships, 

and other offshore structures as opportunistic or deliberate stopover sites for resting or roosting 

(Constantine, 2003; Cryan & Brown, 2007; Pelletier et al., 2013; Thompson et al., 2015; U.S. Department 

of Energy, 2016). While bats are typically nocturnal, there are anecdotal accounts of migratory tree bats 

(Lasiurus and Lasionycteris spp.) traveling during autumn migration in diurnal flocks (Hatch et al., 2013).

In North America, bats almost exclusively use echolocation to navigate and feed on insects (Kunz, 2017).

Additional information on the biology, life history, and conservation of bat species is available from the 

websites of these sources: 

 International Union for Conservation of Nature Red List of Threatened Species

 Bat Conservation International

 North American Bat Monitoring Program

 North American Bat Conservation Alliance

 North American Society for Bat Research

The following sections contain additional information on group size, habitat use, dive behavior, hearing 

and vocalization, and general threats for birds and bats in the Study Area.

3.9.2.1.1 Group Size

A variety of bird group sizes and diversity of species may be encountered throughout the Study Area, 

ranging from the solitary migration of an individual bird to thousands of birds in single-species and 

mixed-species flocks. Depending on season, location, and time of day, the number of birds observed 

(group size) will vary and will likely fluctuate from year to year. During spring and fall periods, diurnal 

and nocturnal migrants would likely occur in large groups as they migrate over open water. Many 

waterbirds migrate in very small groups or pairs, and then can be found in large groups at stopover 

areas and wintering grounds (Elphick, 2007). 
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3.9 Birds and Bats

Avian radar studies at sea show nocturnal migrants as well as seabirds moving across open oceans in 

large numbers (Desholm et al., 2006; Gauthreaux & Belser, 2003). During the nesting and breeding 

season, pelagic seabirds could be encountered in large groups following the currents and upwellings in 

pursuit of prey (Sibley, 2014). In the nearshore environments, terns, gulls, shorebirds, and plovers may 

occur in large groups while in their breeding and feeding areas.

Many bird species forage in large groups on shoaling fish or on concentrations of molluscs attached to 

the seafloor. Water temperatures, currents, upwellings, wind direction, and ocean floor topography can 

all influence when, where, and how many seabirds forage, and patterns of distribution and abundance 

vary from year to year (Elphick, 2007; Fauchald et al., 2002).

Depending on season, location, and time of day, the number of bats observed (group size) in the Study 

Area will vary and will likely fluctuate from year to year, ranging from solitary migration or foraging of an 

individual bat to single-species flocks (Constantine, 2003; Pelletier et al., 2013; U.S. Department of 

Energy, 2016). Bats flying over the ocean and other parts of the Study Area would most likely occur as 

single or a small number of individuals. No communal roosts or other large concentrations of bats are 

known within the Study Area.

3.9.2.1.2 Habitat Use

The Study Area includes portions of three major bird migration routes or flyways (Elphick, 2007)

(Shackelford et al., 2005): the Atlantic, Mississippi, and Central flyways. The Atlantic Flyway includes an 

oceanic route which passes directly over the Atlantic Ocean from Labrador and Nova Scotia to the Lesser 

Antilles and mainland South America; and a coastal route that follows the coast between New England 

and Florida and continues across the Caribbean to South America. Over water routes used by many 

species to cross the Gulf of Mexico between mainland Mexico and the Gulf coast from Florida to Texas

encompass the Mississippi Flyway and part of the Central Flyway. These routes overlap all of the large 

marine ecosystems detailed in Section 3.0.2.1 (Biogeographic Classifications). Many migratory song- and 

shorebirds fly close to the coastline of the Atlantic Flyway, although large numbers of seabirds and a few 

species of shore- and songbirds follow the oceanic flyway further offshore (throughout this section, 

offshore refers to areas beyond the immediate nearshore coastal areas both within and outside of the 

continental shelf). The largest numbers of neotropical migrants fly across the Gulf of Mexico at the 

southern end of the Mississippi Flyway (Elphick, 2007; Shackelford et al., 2005).

Birds forage in a variety of habitats such as coastal wetlands, estuaries, kelp beds, lagoons, and in the 

intertidal zone, as well as nearshore (immediately adjacent to the coastline) in shallower waters, and on 

the open ocean where they catch prey near or at the ocean surface. When and where birds occur is 

highly dependent on environmental factors and life stage and varies with prey location and time of year. 

Due to the uneven distribution of prey within the marine environment, some seabirds must fly long 

distances to obtain food. Other species like neotropical migrants must fly across open water twice a year 

to reach their wintering or breeding grounds in the search for food (Elphick, 2007; Shackelford et al., 

2005).

Within the Study Area, species diversity of foraging seabirds is higher in the southern and lower in the 

northern portions of the Study Area (Karpouzi et al., 2007). Though the northern temperate regions 

have low species diversity, seabird densities and the amount of prey consumed are greater, due to 

overall higher productivity of northern waters (Karpouzi et al., 2007). Species particularly abundant in 

the northwest Atlantic include breeding auks in west Greenland; breeding Leach’s storm-petrels 

(Oceanodroma leucorhoa) and northern gannets (Morus bassanus) in Newfoundland; and nonbreeding 
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shearwaters and sea ducks in Eastern Newfoundland, Labrador, Gulf of St Lawrence, Scotian Shelf, and 

Gulf of Maine to Cape Hatteras (Barrett et al., 2006). Most seabirds forage in offshore waters over the 

continental shelves of North America (Karpouzi et al., 2007).

Bats are wide-ranging, occurring on many islands and every continent except for Antarctica. The vast 

majority of bat species occur in tropical regions; of the more than 1,100 species known world-wide, 44 

species occur in the United States and Canada (Kunz, 2017). While all bats are terrestrial, numerous 

studies have shown that many species will forage within or migrate over marine environments, 

sometimes at considerable distances from shore. Hatch et al. (2013), for example, reported that 

offshore bats observed were located between 16.9 and 41.9 kilometers (km) from shore (with an 

average distance of 30 km) and that historic observations ranged from 2.9 to 1,950 km offshore (with an 

average distance of 103.6 km). Several North American bats have been found on Bermuda, located 

approximately 670 miles (mi.) (1,078 km) from the coast of the U.S. (Constantine, 2003; Pelletier et al., 

2013). Thompson et al. (2015) reported a large flock of little brown bats (Myotis lucifugus) roosting on a 

ship and buoys approximately 68 mi. (110 km) off the coast of Maine during optimal summertime 

conditions, with warm air and no wind. While resident bats occur in marine environments, migratory 

bats – particularly long-distance migratory bats – are the most likely species to be observed in the Study 

Area (Bureau of Ocean Energy Management, 2013; Pelletier et al., 2013; U.S. Department of Energy, 

2016). One study found that the eastern red bat (Lasiurus borealis) (73% of all occurrences) and hoary 

bat (Lasiurus cinereus) (22% of all occurrences) were the most likely species to be detected at buoy 

monitoring sites (U.S. Department of Energy, 2016), perhaps because they prefer open areas (Tetra Tech 

Inc, 2016d). Occurrence in a given area over the open ocean, however, is infrequent and seasonal, 

occurring most frequently during summer, particularly when the air is warm, the humidity is high, the 

wind speed is low, and when near forested land (Ahlén et al., 2009; Bureau of Ocean Energy 

Management, 2013; Johnson et al., 2011; U.S. Department of Energy, 2016). 

Several studies have shown that bats typically fly close to the water’s surface (e.g., lower than 10 meters

[m] above sea level) when flying over water (Pelletier et al., 2013). However, many of these studies have 

had a limited ability to detect bats migrating at higher altitudes. Aerial surveys for bats, using highdefinition video cameras mounted on a small aircraft at 610 m, off the Mid-Atlantic coast, revealed that, 

“of the six bats observed during aerial surveys for which flight height was estimable, all six were at 

altitudes over 100 m above sea level and five of the six were over 200 m” above sea level (Hatch et al. 

(2013). 

3.9.2.1.3 Dive Behavior

Many of the seabird species found in the Study Area will dive, skim, or grasp prey at the water’s surface 

or within the upper portion (1 to 2 m) of the water column (Cook et al., 2011; Jiménez et al., 2012). 

However, numerous seabirds, including various species of diving ducks, cormorants, and alcids (the 

family that includes murres, auks, auklets, and puffins) feed on the bottom at depths greater than 100 

feet (ft.) (Cook et al., 2011; Ehrlich et al., 1988). Some seabirds are aerial plunge-divers in which they 

dive from above the surface and make generally shallow dives into the water column after prey (e.g., 

terns, gannets). Others are considered surface divers where they plunge directly from the surface 

underwater after prey (e.g., puffins, loons). Most diving species tend to catch the majority of their prey 

near the surface of the water column or on the bottom in shallow water (e.g., clams, mussels, and other 

invertebrates) (Cook et al., 2011). Dive durations are correlated with depth and range from a few 

seconds in shallow divers to several minutes in alcids (Ponganis, 2015). Petrels forage both night and 

day; they capture prey by resting on the water surface and dipping their bill and by aerial pursuit of 
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flying fish (International Union for Conservation of Nature and Natural Resources, 2010b). More specific 

diving information in regard to species and taxonomic groups is provided in Sections 3.9.2.2.1 (Bermuda 

Petrel [Pterodroma cahow]) through 3.9.2.3.1.11 (Neotropical Migrant Songbirds, Thrushes, Allies, 

Cuckoos, Swifts, and Owls [Orders Passeriformes, Cuculiformes, and Apodiformes]).

While no bat species will dive into water, one bat species (the Mexican bulldog bat, or fishing bat 

[Noctilio leporinus]) primarily eats fish caught with its relatively large feet and long, sharp claws near the 

water’s surface. Though this species does occur in Mexico, Puerto Rico, and the the U.S. Virgin Islands, it 

would be an infrequent visitor to the Study Area. (Jones et al., 1973; Placer, 1998). In a study of bat 

occurrence over water in the seas around Scandinavia, Ahlén et al. (2009) reported that both migrant 

and resident bats foraged over the sea in areas with an abundance of insects in the air and crustaceans 

in the surface waters. While it is expected that bats forage in a similar manner in the Study Area, it is 

also expected that such occurrence is infrequent and seasonal for the reasons described in 

Section 3.9.2.1 (General Background), above.

3.9.2.1.4 Hearing and Vocalization

Birds

Although hearing range and sensitivity has been measured for many land birds, little is known of seabird 

hearing. The majority of the published literature on bird hearing focuses on terrestrial birds and their 

ability to hear in air. A review of 32 terrestrial and marine species indicates that birds generally have 

greatest hearing sensitivity between 1 and 4 kilohertz (kHz) (Beason, 2004; Dooling, 2002). Very few can 

hear below 20 hertz (Hz), most have an upper frequency hearing limit of 10 kHz, and none exhibit 

hearing at frequencies higher than 15 kHz (Dooling, 2002; Dooling & Popper, 2000). Hearing capabilities 

have been studied for only a few seabirds (Beason, 2004; Beuter et al., 1986; Crowell et al., 2015; 

Johansen et al., 2016; Thiessen, 1958; Wever et al., 1969); these studies show that seabird hearing 

ranges and sensitivity in air are consistent with what is known about bird hearing in general.

Auditory abilities have been measured in ten diving bird species in-air using electrophysiological 

techniques (Crowell et al., 2015). All species tested had the best hearing sensitivity from 1 to 3 kHz. The 

red-throated loon (Gavia stellata) and northern gannet (Morus bassanus) (both non-duck species) had 

the highest thresholds of the diving birds while the lesser scaup (Aythya affinis) and ruddy duck (Oxyura 

jamaicensis) (both duck species) had the lowest thresholds (Crowell et al., 2015). Auditory sensitivity 

varied amongst the species tested, spanning over 30 dB in the frequency range of best hearing. While 

electrophysiological techniques provide insight into hearing abilities, auditory sensitivity is more 

accurately obtained using behavioral techniques. Crowell (2016) used behavioral methods to obtain an 

in-air audiogram of the lesser scaup. Best hearing frequency range in air was similar to other birds, with 

best sensitivity of 14 dB re 20 μPa at 2.86 kHz. Maxwell et al. (2017) obtained the behavioral in-air 

audiogram of a great cormorant (Phalacrocorax carbo) and the most sensitive hearing was 18 dB re 20 

μPa at 2 kHz. 

Crowell et al. (2015) also compared the vocalizations of the same ten diving bird species to the region of 

highest sensitivity of in-air hearing. Of the birds studied, vocalizations of only eight species were 

obtained due to the relatively silent nature of two of the species. The peak frequency of the 

vocalizations of seven of the eight species fell within the range of highest sensitivity of in-air hearing. 

Crowell et al. (2015) suggested that the colonial nesters tested had relatively reduced hearing sensitivity 

because they relied on individually distinctive vocalizations over short ranges. Additionally, Crowell et al. 
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(2015) observed that the species with more sensitive hearing were those associated with freshwater 

habitats, which are quieter compared to marine habitats with wind and wave noise.

Although important to seabirds in air, it is unknown if seabirds use hearing or vocalizations underwater 

for foraging, communication, predator avoidance or navigation (Crowell, 2016; Dooling & Therrien, 

2012). Some scientists suggest that birds must rely on vision rather than hearing while underwater 

(Hetherington, 2008), while others suggest birds must rely on an alternative sense in order to coordinate 

cooperative foraging and foraging in low light conditions (e.g., night, depth) (Dooling & Therrien, 2012). 

There is little known about the hearing abilities of birds underwater (Dooling & Therrien, 2012). In air, 

the size of the bird is usually correlated with the sensitivity to sound (Johansen et al., 2016); for 

example, songbirds tend to be more sensitive to higher frequencies and larger non-songbirds tend to be 

more sensitive to lower frequencies (Dooling & Popper, 2000). Two studies have tested the ability of a 

single diving bird, a great cormorant (Phalacrocorax carbo sinensis), to respond to underwater sounds 

(Hansen et al., 2017; Johansen et al., 2016). These studies suggests that the cormorant’s hearing in air is 

less sensitive than birds of similar size; and the hearing capabilities in water are better than what would 

be expected for a purely in-air adapted ear (Johansen et al., 2016). The frequency range of best hearing 

underwater was observed to be narrower than the frequency range of best hearing in air, with greatest 

sensitivity underwater observed around 2 kHz (about 71 dB re 1 μPa based on behavioral responses)

(Hansen et al., 2017). Although results were not sufficient to be used to generate an audiogram, 

Therrien (2014) also examined underwater hearing sensitivity of long-tailed ducks (Clangula hyemalis) 

by examining behavioral responses. The research showed that auditory thresholds at frequencies within 

the expected range of best sensitivity (1, 2, and 2.86 kHz) are expected to be between 77 and 127 dB re 

1 μPa.

Diving birds may not hear as well underwater, compared to other (non-avian) species, based on 

adaptations to protect their ears from pressure changes (Dooling & Therrien, 2012). Because 

reproduction and communication with conspecifics occurs in air, adaptations for diving may have 

evolved to protect in-air hearing ability and may contribute to reduced sensitivity underwater 

(Hetherington, 2008). There are many anatomical adaptations in diving birds that may reduce sensitivity 

both in air and underwater. Anatomical ear adaptations are not well investigated, but include cavernous 

tissue in the meatus and middle ear that may fill with blood during dives to compensate for increased 

pressure on the tympanum, active muscular control of the meatus to prevent water entering the ear, 

and interlocking feathers to create a waterproof outer covering (Crowell et al., 2015; Rijke, 1970; Sade 

et al., 2008). The northern gannet, a plunge diver, has unique adaptations to hitting the water at high 

speeds, including additional air spaces in the head and neck to cushion the impact and a thicker 

tympanic membrane than similar sized birds (Crowell et al., 2015). All these adaptions could explain the 

measured higher thresholds of diving birds.

Bats

The hearing range of insect-eating bats in North America is 10 – 100 kHz. The most sensitive frequency 

band is 20 – 50 kHz, where bats can detect sounds at approximately 20 dB re 20 μPa (Bohn et al., 2006; 

Koay et al., 1997)Bats are generally unable to hear frequencies below 500 Hz. While hearing is the 

primary sense used by echolocating bats to forage and avoid obstacles, they use a combination of 

auditory and visual landmark recognition (Denzinger & Schnitzler, 2013; Gonzalez-Terrazas et al., 2016; 

Jensen et al., 2005; Schnitzler et al., 2003), magneto-reception (Holland et al., 2006; Holland et al., 2008; 

Wang et al., 2007), and spatial memory for long-distance navigation (Barchi et al., 2013; Ulanovsky & 

Moss, 2008, 2011; William & Williams, 1970; Williams et al., 1966).
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The variety of vocalizations produced by bats can be separated into two general categories: ultrasonic 

echolocation sounds and communication sounds. Echolocation is used while foraging, in which bats 

listen for received echoes from insect targets. Sound detection levels are somewhat dependent on 

ambient noise, and bats increase the loudness of their calls when they encounter noise (Hage et al., 

2013; Hotchkin & Parks, 2013; Luo & Wiegrebe, 2016). Echolocating bats have also been shown to 

passively listen for prey-generated sounds in the 2 – 14 kHz range when foraging (Kalko & Schnitzler, 

1998; Razak et al., 1999). Call frequency and duration varies with habitat, food source, and social 

situation. Ultrasonic echolocation sound types vary by species (Denzinger & Schnitzler, 2013; Siemers & 

Schnitzler, 2004), and the duration of each call can range from 0.5 – 20 ms (Ulanovsky & Moss, 2008). 

Outgoing echolocation beams produced by bats are directional and are analogous to a searchlight in 

that it illuminates or ‘ensonifies’ objects when it is aimed at them (Moss et al., 2011). Insect targets can 

be identified from a maximum range of approximately 25 m using echoes in the 25 – 30 kHz frequency 

spectra (Stilz & Schnitzler, 2012). The big brown bat (E. fuscus) is the most-studied North American bat 

species and is a good representative insect-eating species that produces different types of echolocation 

calls depending on whether it is hunting in a dense forest or an open space (Moss et al., 2011). This 

species produces broadband ultrasonic echolocation sounds in the 22 – 105 kHz range. 

Communication sounds produced by bats are typically lower in frequency than echolocation calls, 

although some bats use ultrasonic vocalizations for communication (Smotherman et al., 2016).

Echolocation sounds may also contain socially relevant information (Kazial & Masters, 2004; Masters et 

al., 1995). Vocal communication in bats is restricted to short ranges because high-frequency sounds 

dampen very quickly in air. However, research suggests that hoary bats (Lasiurus cinereus) and silverhaired bats (Lasionycteris noctivagans) are not likely to socially communicate on migration routes

(Baerwald & Barclay, 2016).

3.9.2.1.5 General Threats

Approximately half of the 346 species of seabirds that depend on ocean habitats are declining (Crowell 

et al., 2015). Seabirds are some of the most threatened marine animals in the world, with 29 percent of 

species at risk of extinction (Spatz et al., 2014). Threats to bird populations in the Study Area include 

human-caused stressors (including incidental mortality) from interactions with commercial and 

recreational fishing gear, predation and competition by introduced species, disturbance and degradation 

of nesting areas by humans and domesticated animals, noise pollution from construction and other 

human activities, nocturnal collisions with power lines and artificial lights, collisions with aircraft, and 

pollution, such as that from oil spills and plastic debris (Anderson et al., 2007; Burkett et al., 2003; 

California Department of Fish and Game, 2010; Carter & Kuletz, 1995; Carter et al., 2005; Clavero et al., 

2009; International Union for Conservation of Nature and Natural Resources, 2010b; North American 

Bird Conservation Initiative & U.S. Committee, 2010; Onley & Scofield, 2007; Piatt & Naslund, 1995; U.S. 

Fish and Wildlife Service, 2005, 2008b; Waugh et al., 2012; Weimerskirch, 2004). Disease, volcanic 

eruptions, storms, and harmful algal blooms are also threats to birds (Anderson et al., 2007; Jessup et 

al., 2009; North American Bird Conservation Initiative U.S. Committee, 2009; U.S. Fish and Wildlife 

Service, 2005).

Beach-nesting birds are vulnerable to disturbance from people, pets, and off road vehicles that may 

inadvertently destroy or disturb nests (North American Bird Conservation Initiative U.S. Committee, 

2009). Feral species (primarily cats [Felis catus] and rats [Rattus spp.], occasionally pigs [Sus scrofa], and 

cattle [Bos taurus]) may destroy nesting colonies. Seabirds are especially vulnerable to feral species on 

islands where nests and populations have been devastated through predation or habitat destruction. 
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Invasive plants can also eliminate nesting habitat on beaches (Clavero et al., 2009; North American Bird 

Conservation Initiative U.S. Committee, 2009).

Lighting on boats and on offshore oil and gas platforms has also contributed to bird fatalities in open

ocean environments when birds are attracted to these lights, usually in inclement weather conditions

(Merkel & Johansen, 2011). Recent studies have looked at different lighting systems and how they may 

impact migrating songbirds (Poot et al., 2008). Land-based lighting has been linked to episodes of 

“fallout” (grounding) involving seabirds, especially petrels, and ship-based lighting could have similar 

effects (Rodríguez et al., 2017).

Large-scale wind energy development in offshore areas has the potential to affect bird populations 

through 1) displacement from favored foraging habitats, especially to species that forage in deeper, 

offshore waters; and 2) mortality to species that tend to fly within the rotor swept zones of large wind 

turbines (approximately 20 m and 200 m from the surface) (Williams et al., 2015).

Natural causes of seabird and shorebird population declines include disease, storms, and harmful algal 

blooms, although human activities are also associated with harmful algal blooms (Jessup et al., 2009; 

North American Bird Conservation Initiative U.S. Committee, 2009; Onley & Scofield, 2007). In addition, 

seabird distribution, abundance, breeding, and other behaviors are influenced by cyclical environmental 

events, such as the El Niño Southern Oscillation and Pacific Decadal Oscillation in the Pacific Ocean 

(Congdon et al., 2007; Vandenbosch, 2000).

The primary threats to bats include disease (discussed in Section 3.9.2.1.5.3, Disease and Parasites), 

climate change (discussed in Section 3.9.2.1.5.5, Climate Change), commercial industries, especially 

wind energy development (discussed in Section 3.9.2.1.5.2, Commercial Industries), and habitat loss and 

fragmentation.

3.9.2.1.5.1 Water Quality

Spills of oil and other petroleum products pose a risk to seabirds and shorebirds through direct 

contamination and destruction of nesting, roosting, and foraging habitats (U.S. Environmental 

Protection Agency, 1999). Estimates of bird mortality caused by the BP Deepwater Horizon oil spill in the 

Gulf of Mexico during 2010 are that approximately 200,000 birds were killed in the offshore area and 

approximately 700,000 killed along the coastline during the 103-day duration of the spill (Haney et al., 

2014a, 2014b). Additional mortality occurred subsequently but has not been estimated.

3.9.2.1.5.2 Commercial Industries

A recent review of reported bycatch estimates suggests that at least 400,000 birds die in gillnets each 

year (Zydelis et al., 2013). Commercial fisheries are considered the most serious threat to the world’s 

seabirds, while invasive species are the most pervasive – affecting the largest number of species; other 

threats include pollution, hunting, trapping, energy production, and mining (BirdLife International, 

2012).

Large-scale offshore wind development may occur in highly productive areas of the Atlantic Seaboard 

and impact bird populations 1) by displacing some species from their preferred foraging habitats and 

migration routes; 2) increasing the mortality of species that fly within the rotor-swept zones of large 

turbines individuals (Williams et al., 2015).

Wind turbines may attract bats directly (e.g., there is evidence that bats perceive smooth wind turbine 

surfaces to be water) (McAlexander, 2013) or indirectly (e.g., by attracting insects) (Pelletier et al., 
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2013), where they may be injured or killed by collision with a wind turbine’s blade or by barotrauma (a 

sudden drop in pressure that a bat encounters when flying near the rotating blade). Bats are also known 

to roost on wind turbines, including offshore wind turbines (Ahlén et al., 2009). 

3.9.2.1.5.3 Disease and Parasites

Avian diseases can cause chronic population declines, dramatic die-offs or reductions in the 

reproductive success and survival of individual birds. They can even cause extinctions. Certain avian 

diseases appear to be spreading to populations previously unaffected, including to species already 

threatened by other factors. Examples include avian botulism, cholera, Erysipelothrix rhusiopathiae, 

West Nile virus and Mycoplasmal conjunctivitis. A brief description of each follows.

Avian botulism is a bacterial disease that is arguably the most important disease of migratory birds 

world-wide, affecting millions of birds. Avian cholera and (Erysipelothrix rhusiopathidae) are two 

bacterial diseases that caused considerable declines of Indian yellow-nosed albatross (Thalassarche 

carteri) on Amsterdam Island (French Southern Territories). These two diseases may have spread to 

nearby colonies of sooty albatross (Phoebetria fusca) and Amsterdam albatross (Diomedea 

amsterdamensis) with a world population of approximately 130 birds. Avian cholera has also devastated 

the population of Cape cormorant (Phalacrocorax capensis) in Western Cape Province, South Africa, 

killing approximately 13,000 individuals between May and October 2002. The West Nile Virus, a largely 

mosquito-borne viral disease (causing both bird and human mortalities), has established itself over 

much of eastern United States since 1999, spreading to Latin America and the Caribbean. American crow 

(Corvus brachyrhynchos) and other corvid species have shown very high levels of mortality from this 

disease but remains relatively stable across its range. Mycoplasmal conjunctivitis, as the disease is 

commonly called, is caused by a unique strain of (Mycoplasmal gallisepticum), a parasitic bacterium 

previously known to infect only poultry. This infectious disease has recently caused a significant decline 

in the introduced population of house finch (Carpodacus mexicanus) in eastern North America, and has 

started to spread to the native population of this species in western North America (BirdLife 

International, 2008c).

White-nose syndrome, caused by a white fungus, (Pseudogymnoascus destructans) was first discovered 

in North America in a cave in New York in 2006. Since then, the disease has spread to seven bat species 

in 32 states and 5 Canadian provinces. The disease has killed at least 5.7 million bats, caused precipitous 

declines in populations of cave-hibernating bat species in the northeast region, and led to the federal 

listing of the northern long-eared bat as threatened under the ESA. From its original detection in New 

York, the disease has spread widely throughout the New England states and the interior of the eastern 

United States (U.S. Geological Survey, 2018). On average, 96 percent of new white-nose syndrome

counties in any single year were within 150 miles of a county that was fungus or white-nose syndromepositive during the prior year. The fungus is generally present for a year or two before symptoms of 

white-nose syndrome appear and mortality of bats begins to occur (U.S. Fish and Wildlife Service, 

2016a). It is thought that half of America’s bats are at risk to the disease (Bat Conservation International, 

2017). The most common bats affected by white-nose syndrome are little brown bats, followed by the 

federally threatened northern long-eared bats and the federally endangered Indiana bat (Myotis 

sodalis). Some small-footed bats (Myotis leibii), tri-colored bats (Perimyotis subflavus) and big brown 

bats have also been affected (Yates, 2015). 

Surveys at several sites in the Gulf of Maine from 2009-2014 detected a decline in the amount of Myotis

species relative to that of other species, primarily in 2012 and 2013. At one site, overall activity levels 
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declined from 294 passes per night (with activity during 97% of nights) in 2012 to 6.4 passes per night 

(with activity during 37% of nights) in 2014 (U.S. Department of Energy, 2016). 

The little brown bat has had one of the highest mortality rates from white-nose syndrome and is 

estimated to have had a population decrease of 91 percent in the east. Big brown bats are less affected 

by white-nose syndrome and red bats, hoary bats, and silver-haired bats are migrators rather than 

hibernators, which allow them to avoid hibernacula that harbor this fungus (Hayman et al., 2016; Tetra 

Tech Inc, 2016a).

3.9.2.1.5.4 Invasive Species

Significant threats to seabirds occur on islands, which is where seabirds breed, including predation and 

habitat disturbance from invasive alien species such as rats, cats and pigs. Ground-nesting seabirds are 

particularly vulnerable to these threats, and invasive predators on islands have been the primary cause 

of global seabird declines, extirpations, and local extinctions (Spatz et al., 2014). However, in many 

cases, effective island conservation can mitigate these threats.

3.9.2.1.5.5 Climate Change

In the long term, global climate change could be the greatest threat to seabirds (North American Bird 

Conservation Initiative & U.S. Committee, 2010). Climate change impacts include changes in air and sea 

temperatures, precipitation, the frequency and intensity of storms, pH level of sea water, and sea level.

These changes could impact the timing of migration and overall marine productivity, which could in turn 

have an impact on the food resources, distribution, and reproductive success of seabirds at critical times 

in their life cycles (Aebischer et al., 1990; Congdon et al., 2007; Davoren et al., 2012).

Open ocean seabird species are particularly vulnerable to climate change due to their low reproductive 

rates, their use of islands for nesting, and their reliance on a highly variable marine system (North 

American Bird Conservation Initiative & U.S. Committee, 2010). Coastal birds are vulnerable to climate 

change due to rising sea levels, which are expected to impact foraging and nesting habitat quality and 

quantity by flooding or fragmenting habitats such as barrier islands, beaches, and mudflats (North 

American Bird Conservation Initiative & U.S. Committee, 2010).

Climate change could impact bats at all stages in their annual cycle. U.S. Fish and Wildlife Service 

(2016a), for example, writes:

“The unique life history traits of bats and their susceptibility to local temperature, humidity, and 

precipitation patterns make them an early warning system for effects of climate change in 

regional ecosystems. Climate influences food availability, timing of hibernation, frequency and 

duration of torpor, rate of energy expenditure, reproduction, and rates of juvenile bat 

development. Climate change may lead to warmer winters, which could lead to a shorter 

hibernation period, increased winter activity, and reduced reliance on the relatively stable 

temperatures of underground hibernation sites. An earlier spring would presumably result in a 

shorter hibernation period and the earlier appearance of foraging bats. An earlier emergence 

from hibernation may have no detrimental effect on populations if sufficient food is available; 

however, predicting future insect population dynamics and distributions is complex. Alterations 

in precipitation, stream flow, and soil moisture could alter insect populations and, therefore, 

food availability for bats.”

Additionally, altered seasonal ambient temperatures and precipitation patterns could also shift the 

range of some species and alter water and roost availability (U.S. Fish and Wildlife Service, 2016a), and 
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extreme weather events have led to large die-offs (Mistry & Moreno-Valdez, 2008). Bat populations are 

particularly susceptible to such large die-offs due to their low reproductive rates (Bogan, 2016). Climate 

change will also change prey detection ability of echolocating bats, with some species gaining a greater 

ability to detect prey and others having a reduced ability to detect prey species (Luo et al., 2013).

3.9.2.1.5.6 Marine Debris

Marine debris is any persistent solid material that is manufactured or processed and directly or 

indirectly, intentionally or unintentionally, disposed of or abandoned into the marine environment or 

the Great Lakes (National Oceanic and Atmospheric Administration, 2016). Marine debris is a growing 

environmental concern. With the rapid increase in global plastics production and the resulting large 

volume of litter that enters the marine environment, determining the consequences of this debris on 

marine fauna, including seabirds and ocean health has now become a critical environmental priority, 

particularly for threatened and endangered species (Wilcox et al., 2016).

Plastic debris is abundant and pervasive in the world oceans and, because of its durability, is continuing 

to increase. The ingestion of plastics by seabirds such as albatrosses and shearwaters occurs with high 

frequency and is of particular concern because of impacts on body condition and the transmission of 

toxic chemicals, both of which affect mortality and reproduction. The rates of plastic ingestion by 

seabirds are closely related to the concentrations of plastics in different areas of the ocean due to waste 

discharges and ocean currents, and are increasing (Kain et al., 2016; Wilcox et al., 2015). 

The impacts from entanglement of marine species in marine debris are clearly profound, and in many 

cases entanglements appear to be increasing despite efforts over four decades to reduce the threat. 

Many coastal states have undertaken certain efforts to reduce entanglement rates through marine

debris clean-up measures and installed fishing line recycle centers at boat landings in part due to 

entanglement of seabirds and other marine species.

Fishing related gear, balloons and plastic bags were estimated to pose the greatest entanglement risk to 

marine fauna. In contrast, experts identified a broader suite of items of concern for ingestion, with 

plastic bags and plastic utensils ranked as the greatest threats. Entanglement and ingestion affected a 

similar range of taxa, although entanglement was rated as slightly worse because it is more likely to be 

lethal. Contamination was scored the lowest in terms of impact, affecting a smaller portion of the taxa 

and being rated as having solely non-lethal impacts (Wilcox et al., 2016).

There are likely other species from other regions of the U.S. that suffer injury or death from being 

entangled in marine debris, but are not widely recognized or reported. Most of the literature describes 

entanglement of marine species from Alaska, California, Puget Sound, and Florida. However, the MidAtlantic and Gulf of Mexico regions of the U.S. are lacking in reports of marine debris entanglement. 

Similarly, reports of marine debris entanglement on seabirds are limited to a few papers (National 

Oceanic and Atmospheric Administration, 2016). This review reported entanglement in marine debris in 

the U.S. of 44 species of seabirds. The majority of cases revolve around entanglement in abandoned, lost 

or otherwise discarded fishing gear and to a lesser degree other plastic debris.

More general information about marine debris along the southeast Atlantic coast concluded the vast 

majority of marine debris was either land-based (38 percent), general-source debris (42 percent), or 

ocean-based (20 percent) recreational and commercial sources (Ribic et al., 2010); no items of military 

origin were differentiated.
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3.9.2.2 Endangered Species Act-Listed Species

There are four species of birds and two species of bats listed as endangered or threatened under the 

ESA that occur in the Study Area (U.S. Fish and Wildlife Service, 2015a). One ESA-listed species, the 

piping plover (Charadrius melodus), has critical habitat that is described in greater detail in Section

3.9.2.2.2.1 (Status and Management). The status, presence, and occurrence of ESA-listed bird and bat

species in the Study Area are discussed further below.

Table 3.9-1: Endangered Species Act-List Bird and Bat Species in the Study Area

Species Name and Regulatory Status Presence in the Study Area1

Common 

Name

Scientific 

Name ESA Status

Open Ocean 

Area

Large Marine 

Ecosystem Inshore Waters

Bermuda 

Petrel

Pterodroma 

cahow Endangered

North 

Atlantic Gyre 

(nesting), 

Gulf Stream

NewfoundlandLabrador Shelf, Scotian 

Shelf, Northeast 

U.S. Continental Shelf,

Southeast 

U.S. Continental Shelf

None

Roseate 

Tern2

Sterna

dougallii

dougallii

Endangered

Threatened

North 

Atlantic 

Gyre,

Gulf Stream

Scotian Shelf (nesting), 

Northeast 

U.S. Continental Shelf 

(nesting), Southeast 

U.S. Continental Shelf, 

Gulf of Mexico

(nesting), Caribbean 

Sea (nesting)

Sandy Hook Bay (Earle, NJ); 

Lower Chesapeake Bay 

(Hampton Roads, VA); Beaufort 

Inlet Channel (Morehead City, 

NC); Cape Fear River 

(Wilmington, NC); St. Andrew 

Bay (Panama City, FL); Sabine 

Lake (Beaumont, TX); Corpus 

Christi Bay (Corpus Christi, TX)

Piping 

Plover

Charadrius 

melodus Threatened None

NewfoundlandLabrador Shelf, Scotian 

Shelf, Northeast 

U.S. Continental Shelf, 

Southeast 

U.S. Continental Shelf, 

Gulf of Mexico, 

Caribbean Sea

Sandy Hook Bay (Earle, NJ); 

Lower Chesapeake Bay 

(Hampton Roads, VA); Beaufort 

Inlet Channel (Morehead City, 

NC); Cape Fear River 

(Wilmington, NC); St. Mary's 

River Inlet (St. Mary's, GA); St. 

Johns River and Fort George 

River Inlets (Jacksonville, FL); St. 

Andrew Bay (Panama City, FL); 

Sabine Lake (Beaumont, TX); 

Corpus Christi Bay (Corpus 

Christi, TX)

Red Knot Calidris 

canutus rufa Threatened

North 

Atlantic 

Gyre, 

Gulf Stream

Northeast 

U.S. Continental Shelf, 

Southeast 

U.S. Continental Shelf, 

Gulf of Mexico, 

Caribbean Sea

Sandy Hook Bay (Earle, NJ); 

Lower Chesapeake Bay 

(Hampton Roads, VA); Beaufort 

Inlet Channel (Morehead City, 

NC); Cape Fear River 

(Wilmington, NC); St. Andrew 

Bay (Panama City, FL); Sabine 

Lake (Beaumont, TX); Corpus 

Christi Bay (Corpus Christi, TX)
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Table 3.9-1: Endangered Species Act-List Bird and Bat Species in the Study Area (continued)

Species Name and Regulatory Status Presence in the Study Area1

Common 

Name

Scientific 

Name ESA Status

Open Ocean 

Area

Large Marine 

Ecosystem Inshore Waters

Indiana 

bat Myotis sodalis Endangered None

Northeast 

U.S. Continental Shelf, 

Southeast 

U.S. Continental Shelf

Sandy Hook Bay (Earle, NJ); 

Lower Chesapeake Bay 

(Hampton Roads, VA)

Northern 

long-eared 

bat

Myotis 

septentrionalis Threatened None

Scotian Shelf

(roosting), Northeast

U.S. Continental Shelf

(roosting), Southeast 

U.S. Continental Shelf

Sandy Hook Bay (Earle, NJ); 

Lower Chesapeake Bay 

(Hampton Roads, VA); Cape 

Fear River (Wilmington, NC)

1Presence in the Study Area indicates open ocean areas (North Atlantic Gyre, Gulf Stream, and Labrador Current) and coastal waters of 

large marine ecosystems (West Greenland Shelf, Newfoundland-Labrador Shelf, Scotian Shelf, Northeast U.S. Continental Shelf, 

Southeast U.S. Continental Shelf, Gulf of Mexico, and Caribbean Sea) in which the species are found. Open ocean areas and coastal 

waters where breeding occurs are indicated as (nesting).

2The roseate tern is listed as endangered under the ESA along the Atlantic coast south to North Carolina, Canada (Newfoundland, Nova 

Scotia, Quebec), and Bermuda. It is listed as threatened under the ESA in the Western Hemisphere and adjacent oceans, including 

Florida, Puerto Rico, and the Virgin Islands.

Source: (U.S. Fish and Wildlife Service, 2015a), for ESA Status.

Note: The abbreviations in the table are defined as follows—DE: Delaware; FL: Florida; GA: Georgia; NC: North Carolina; NJ: New Jersey; 

TX: Texas; VA: Virginia; ESA: Endangered Species Act, Gulf of Mexico: Gulf of Mexico.

The federally endangered Florida bonneted bat (Eumops floridanus) occurs in southern Florida and is 

thought to be the rarest bat in the world (Florida Fish and Wildlife Conservation Commission, 2017b). 

However, it is not expected to occur in the Study Area as it primarily forages over freshwater ponds, 

streams, and wetlands (U.S. Fish and Wildlife Service, 2013a). The nearest occurrence of the federally 

endangered gray bat (Myotis grisescens) to the Study Area is one county in Florida’s panhandle that is 

adjacent to Alabama and Georgia and is also not expected to occur in the Study Area (Florida Fish and 

Wildlife Conservation Commission, 2017c). The Mexican Long-nosed bat (Leptonycteris nivalis) and the 

lesser long-nosed bat (Leptonycteris curasoae) migrate through Central Mexico (from the Pacific Coast 

to Gulf of Mexico) to the southwest U.S. (International Union for Conservation of Nature, 2017; National 

Park Service, 2017b). Therefore, some individuals may migrate over the western-most portions of the 

Gulf of Mexico but the chances they would interact with Navy training activities is discountable. As such, 

these four species will not be discussed further.

3.9.2.2.1 Bermuda Petrel (Pterodroma cahow)

3.9.2.2.1.1 Status and Management

The USFWS listed the Bermuda petrel as endangered under the ESA in 1970. There is no designated 

critical habitat for this seabird species. This extremely rare seabird nests only on Bermuda in the Atlantic 

Ocean (White, 2004). The Bermuda petrel was thought to be extinct for about three decades until its 

existence was confirmed in the mid-1900s. In 1951, 18 pairs of the Bermuda petrel (commonly referred 

to as “cahow”) were rediscovered breeding on a group of four rocky islets in Castle Harbor, Bermuda. An 

intensive recovery and management program followed, which included removing predators, such as rats

(Murphy & Mowbray, 1951), and adapting nest burrow entrances with baffles and artificial burrows to 

prevent nest site competition with the white-tailed tropicbird (Phaethon lepturus) (Murphy & Mowbray, 

1951). Efforts to establish a new breeding colony in the higher areas of Nonsuch Island Nature Reserve 
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have been slow but promising (Dobson & Madeiros, 2009). The total population is estimated as 

approximately 250-275 individuals with 71 breeding pairs in 2005, 96 breeding pairs in 2009 (Dobson & 

Madeiros, 2009), and 101 breeding pairs in 2012 (U.S. Fish and Wildlife Service, 2013c).

3.9.2.2.1.2 Habitat and Geographic Range

The Bermuda petrel is a pelagic species and spends most of its life at sea, except during the breeding 

season from January to June where it comes ashore to breed. Breeding occurs outside the Study Area, 

exclusively in Bermuda on five small islets off Nonsuch Island in the North Atlantic Gyre (National 

Audubon Society, 2005). Available islet nesting habitat is limited to 2.4 acres (ac) (0.97 hectares [ha]), 

which is occupied by a varying number of breeding pairs each year (BirdLife International, 2008a). 

During the breeding season, the Bermuda petrel arrives and leaves the island only at night to avoid 

predation (Wurster & Wingate, 1968). During the breeding season, the Bermuda petrel nests in colonies, 

but is otherwise solitary (Onley & Scofield, 2007). Due to its solitary behavior the Bermuda petrel is

unlikely to approach ships (Enticott & Tipling, 1997; Onley & Scofield, 2007). More specific nest density 

or colony size information was not found.

Open Ocean Areas. In the nonbreeding season (June–December) (Brooke, 2004), the species migrates 

from the breeding grounds in Bermuda to foraging routes over much of the Atlantic Ocean, including 

waters of the North Atlantic Gyre and the Gulf Stream (includes off-shelf portions of the Virginia Capes

and Navy Cherry Point Range Complexes) (Lee & Mackin, 2008; National Audubon Society, 2005; Onley 

& Scofield, 2007). However, dispersal and at-sea distribution are generally poorly known (Brooke, 2004; 

Onley & Scofield, 2007). One additional migration route was recorded into the northeast Atlantic, off the 

coast of southwestern Ireland (Dobson & Madeiros, 2009). 

Southeast U.S. Continental Shelf Large Marine Ecosystem. First reported off North Carolina’s Outer 

Banks in April 1983 (Lee, 1987), today the species regularly occurs off the North Carolina coast (National 

Audubon Society, 2005; White, 2004). 

Newfoundland-Labrador Shelf, Scotian Shelf, and Northeast U.S. Continental Shelf Large Marine 

Ecosystems. Recent data recorded during the nonbreeding season documented western routes to the 

Gulf Stream and northern movements to the Bay of Fundy, into the Gulf of St. Lawrence, and over the 

Grand Banks. An additional route was recorded off the coast of southwestern Ireland (Madeiros, 2009).

3.9.2.2.1.3 Population Trends

The Bermuda petrel is an extremely rare seabird that is slowly but steadily increasing: 18 pairs were 

recorded in the year 1951; 70 pairs raising 40 young were recorded in 2003; 71 pairs raising 35 young 

were recorded in 2005 (International Union for Conservation of Nature and Natural Resources, 2010a). 

The reproductive output between 2000 to 2001 and 2007 to 2008 ranged from 29 to 40 fledglings per 

year (Madeiros et al., 2012). Conservation efforts continue and the species is recovering in number, with 

the population estimated at 250-275, with 101 breeding pairs as of 2012 (U.S. Fish and Wildlife Service, 

2013c). The number of chicks successfully fledged per nesting season has also increased, reaching 52 in

2010 (Dobson, 2010) and 57 in 2012 (U.S. Fish and Wildlife Service, 2013c).

3.9.2.2.1.4 Predator and Prey Interactions

Bermuda petrels feed mostly on squid, but their diet also consists of shrimp and small fish (National 

Audubon Society, 2005). Specific information on the feeding behavior of Bermuda petrels is lacking, but 

petrels of the genus Pterodroma often land on the ocean surface where they scavenge or grab prey; 
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they also feed on the wing (while flying), where they are able to catch flying fish (Onley & Scofield, 

2007). 

Maximum dive depths for several species of Pterodroma petrels in New Zealand were determined from 

depth gauges that were attached to individual birds and recovered after varying lengths of time during 

which the birds were foraging at sea (Taylor, 2008). Mean maximum dive depths ranged from 1.1 to 4.7 

m, with a maximum depth recorded of 23 meters. Maximum dive depths were similarly determined for 

the Providence petrel (Pterodroma solandri), an Australian species, and found to average 2.9 m (Bester 

et al., 2011). It is reasonable to conclude that in addition to feeding at the surface, petrels of the genus 

Pterodroma, (probably including the Bermuda petrel) frequently engage in surface plunging or pursuit 

diving to reach prey several meters below the surface. No data are available on submergence times, but 

to reach these depths presumably requires a petrel to be underwater for roughly 5-10 seconds.

3.9.2.2.1.5 Species-Specific Threats

Current threats to this species include habitat loss; competition for nest sites with the white-tailed 

tropicbird (Dobson & Madeiros, 2009); egg failure from contaminants (Brooke, 2004; Wurster & 

Wingate, 1968); light pollution from a nearby Bermuda airport; sea level rise; and increasing frequency 

and magnitude of tropical storms and hurricanes, which destroy nests through erosion, wave damage, 

and flooding (BirdLife International, 2008a, 2008b; Dobson & Madeiros, 2009; Madeiros et al., 2012; U.S. 

Fish and Wildlife Service, 2013c).

3.9.2.2.2 Piping Plover (Charadrius melodus)

The piping plover is divided into two subspecies of plovers. The piping plovers that breed on the Atlantic 

coast of the United States and Canada belong to the Atlantic subspecies C. melodus (U.S. Fish and 

Wildlife Service, 2009b) and occur within the Study Area.

3.9.2.2.2.1 Status and Management

The USFWS listed the Atlantic coast piping plover population as threatened under the ESA in 1985 and 

has instituted a recovery plan for this shorebird species (U.S. Fish and Wildlife Service, 1996). In 2001 

and 2002, critical habitat was designated for the Great Lakes breeding population and Northern Great 

Plains breeding population, and for all three breeding populations while on their wintering grounds. 

Critical habitat for wintering plovers has been designated in coastal areas near or within the Study Area 

as shown in Figure 3.9-1, Figure 3.9-2, and Figure 3.9-3.

The USFWS designated 137 areas along the coasts of North Carolina, South Carolina, Georgia, Florida, 

Alabama, Mississippi, Louisiana, and Texas as critical habitat for wintering populations. This critical 

habitat includes 1,798.3 mi. (2,891.7 km) of mapped shoreline and 165,211 ac (66,881 ha) of mapped 

area along the gulf and Atlantic coasts and along interior bays, inlets, and lagoons (Federal Register

66[132]: 36038-36086, July 10, 2001). In 2008 and 2009, the USFWS updated designated critical habitat 

for wintering piping plover populations in North Carolina and Texas, adding 2,043 ac (827 ha) in North 

Carolina and 139,029 ac (56,263 ha) along the Gulf Coast of Texas (Federal Register 73[204]: 62816-

62841, October 21, 2008; and Federal Register 74 [95]: 23476-23600, May 19, 2009, respectively). Any 

critical habitat located above the mean high tide line is outside the Study Area, as described in Section 

3.0.2 (Ecological Characterization of the Study Area).
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Notes: AFTT: Atlantic Fleet Training and Testing; OPAREA: operating area; SINKEX: ship sinking exercise; VACAPES: Virginia Capes.

Figure 3.9-1: Critical Habitat Areas for Piping Plover in and Adjacent to the Atlantic Coastal Portions of the Study Area
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Notes: AFTT: Atlantic Fleet Training and Testing; OPAREA: operating area; SINKEX: ship sinking exercise.

Figure 3.9-2: Critical Habitat Areas for Piping Plover in and Adjacent to the Eastern Gulf of Mexico Coastal Portions of the Study Area
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Notes: AFTT: Atlantic Fleet Training and Testing; OPAREA: operating area; SINKEX: ship sinking exercise.

Figure 3.9-3: Critical Habitat Areas for Piping Plover in and Adjacent to the Western Gulf of Mexico Coastal Portions of the Study Area
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The 2004 National Defense Authorization Act allows military installations to be excluded from critical 

habitat designation for endangered species under the ESA provided that the installation’s Integrated 

Natural Resource Management Plan affords (1) a benefit to the species; (2) certainty that the 

management plan will be implemented; and (3) certainty that the conservation effort will be effective. 

On Navy installations where piping plovers breed or overwinter, the Navy is exempt from critical habitat 

designations.

3.9.2.2.2.2 Habitat and Geographic Range

In the Study Area, the Atlantic breeding population of piping plovers nest and breed on coastal beaches 

from southern Maine to North Carolina and are primarily an inhabitant of sandy shorelines in the 

Northeast and Southeast U.S. Continental Shelf Large Marine Ecosystems (Haig & Elliott-Smith, 2004; 

O'Brien et al., 2006). Piping plovers nest above the mean high tide line (outside the Study Area) on 

coastal beaches, sand flats at the ends of sandpits and barrier islands, gently sloping foredunes (dunes

parallel to the shoreline), blowout areas behind primary dunes, and washover areas cut into or between 

dunes (U.S. Fish and Wildlife Service, 1996). Individuals migrate through and winter in coastal areas of 

the United States from North Carolina to Texas and portions of Yucatan in Mexico and the Caribbean

(U.S. Fish and Wildlife Service, 2009b). Different breeding populations tend to occur in different coastal 

wintering areas, although there is some overlap (Gratto-Trevor et al., 2012). In winter, the species is 

only found in coastal areas in habitats that include mudflats and dredge spoil areas and, most 

commonly, sandflats (Gratto-Trevor et al., 2012; O'Brien et al., 2006). Plovers appear to prefer sandflats 

adjacent to inlets or passes, sandy mudflats along spits (beaches formed by currents), and overwash 

areas as foraging habitats. Piping plover migration routes overlap with breeding and wintering habitats. 

Southeast U.S. Continental Shelf Large Marine Ecosystem. Recovery results from birds banded 

during the breeding season indicate that most Atlantic coast breeders winter along the southern Atlantic 

coast from North Carolina to Florida, although some birds have been reported to winter in Texas

(Gratto-Trevor et al., 2012) Evidence suggests that most of the Great Lakes population winters south 

along the Atlantic coast. Both spring and fall migration routes are believed to follow the Atlantic coast

(Gratto-Trevor et al., 2012).

Gulf of Mexico Large Marine Ecosystem. Evidence suggests that most of the threatened Northern 

Plains population winters on the Gulf Coast (Gratto-Trevor et al., 2012).

Caribbean Sea Large Marine Ecosystem. Islands in the Caribbean, the Bahamas and West Indies, 

serve as important wintering habitat (U.S. Geological Survey, 2007).

3.9.2.2.2.3 Population Trends

A 1991 international census documented 5,482 piping plovers and a decade later in 2001 the population 

estimate was 5,945 piping plovers (Haig & Elliott-Smith, 2004). The current population has been 

estimated to be approximately 8,100 individuals (BirdLife International, 2016). Coastal Atlantic United 

States populations have trended upward since listing, though some areas’ breeding populations are 

remaining at depressed levels and showing little or no increase in size. Since its 1985 listing, the Atlantic 

coast population estimate has increased from 790 pairs to an estimated 1,849 pairs in 2008, and the 

United States portion of the population has almost tripled, from approximately 550 pairs to an 

estimated 1,596 pairs (U.S. Fish and Wildlife Service, 2009c). Between 1989 and 2008, the largest 

population increase occurred in New England (245 percent), followed by New York–New Jersey 

(74 percent). Overall population growth was tempered by rapid declines in the Southern and Eastern 

Canada recovery units; the eastern Canada population decreased 21 percent (2002–2005), and the 
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population in the southern half of the Southern recovery unit declined 68 percent (1995–2001) (U.S. Fish 

and Wildlife Service, 2009c). Also, the Maine population declined 64 percent, from 66 pairs in the year 

2002 to 24 pairs in 2008, mostly due to loss of habitat from spring storms and dune stabilization 

projects. More recently, numbers have declined, with 3,973 piping plovers observed during the winter 

census of the 2011 International Piping Plover Census, with Texas having by far the largest number of 

any state (2,145), and more than 1,000 piping plovers discovered wintering in the Bahamas (ElliottSmith et al., 2015). The 2011 breeding census resulted in an estimated breeding population of at least 

5,723 birds, 75 percent of which were in the United States, with a breeding population of 1,476 pairs in 

the Atlantic coastal states (Elliott-Smith et al., 2015). Though the abundance of the Atlantic coast plovers 

has reduced near-term extinction threats, geographic variation in population growth and sensitivity to 

survival and productivity are cause for continuing conservation concern (U.S. Fish and Wildlife Service, 

2009c).

3.9.2.2.2.4 Predator and Prey Interactions

Feeding habitats of breeding piping plovers include intertidal portions of ocean beaches, washover 

areas, mudflats, sandflats, wrack lines (line of deposited seaweed on the beach), shorelines of coastal 

ponds, lagoons, and salt marshes (Gratto-Trevor et al., 2012; U.S. Fish and Wildlife Service, 1996). They 

hunt visually using a start-and-stop running method, gleaning and probing the substrate for a variety of 

small invertebrates (marine worms, crustaceans, molluscs, insects, and the eggs and larvae of many 

marine invertebrates) (Maslo et al., 2012; U.S. Fish and Wildlife Service, 1996). Foraging occurs 

throughout the day and at night.

Piping plovers are preyed upon by various species. These predators, such as crows, gulls, raptors, 

raccoons, foxes, skunks, and domestic and feral cats, are often associated with developed beaches and 

have been identified as a substantial source of mortality for piping plover eggs and chicks (U.S. Fish and 

Wildlife Service, 2009b; Winter & Wallace, 2006).

3.9.2.2.2.5 Species-Specific Threats

The localized declines of the Atlantic coast piping plover population is attributed to habitat loss and 

degradation and increased predator populations in coastal environments (U.S. Fish and Wildlife Service, 

1996). Excessive disturbance may cause the parents to flee the nest, exposing eggs or chicks to the hot 

sun or predators. High disturbance levels around nest sites can also result in the abandonment of nests 

and, ultimately, decreased breeding success (Cohen & Gratto-Trevor, 2011). Causing parents or juveniles 

to flush while foraging may stress juveniles enough to negatively influence critical growth and 

development. Few areas used by wintering piping plovers are free of human disturbance, and nearly 

50 percent have leashed and unleashed dog presence (U.S. Fish and Wildlife Service, 2009b).

Along the Atlantic coast, commercial, residential, and recreational development have decreased the 

amount of coastal habitat available for piping plovers. Trends show continued loss and degradation of 

habitat in migration and wintering areas due to sand placement projects, inlet stabilization, sand mining, 

erosion prevention structures (groins, seawalls, and revetments, exotic and invasive vegetation, and 

wrack removal) (U.S. Fish and Wildlife Service, 2009b). Unusual events, such as hurricanes, can impact 

hundreds of young-of-the-year and adults. Storms can also, over time, positively impact local piping 

plover populations by leveling dunes and creating suitable nesting habitat (U.S. Fish and Wildlife Service, 

1996). Beach development and stabilization activities, dredging, recreational activities, and pollution are 

factors that impact the plover population on wintering grounds (U.S. Fish and Wildlife Service, 1996). 

There are also unknown sources of mortality experienced during migration or on the wintering grounds
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(Calvert et al., 2006; Root et al., 1992). Recent data suggest that lighting on vessels and on offshore oil 

and gas platforms may cause mortality and could help explain some of these unknown mortality events

(Merkel & Johansen, 2011). New potential threats include wind turbine development projects which 

introduce the possibility of collision, disturbance, and displacement of plovers (Burger et al., 2011). 

Another threat is climate change resulting in sea level rise that would directly impact Atlantic coast 

piping plovers breeding and wintering habitat (U.S. Fish and Wildlife Service, 2009b).

3.9.2.2.3 Roseate Tern (Sterna dougallii)

Five subspecies of the roseate tern have been described, though some taxonomic designations are 

uncertain: S. d. dougallii in the North Atlantic, Europe, and the Caribbean; S. d. korustes in India, Sri 

Lanka, and Burma; S. d. gracilis in Australia and Indonesia; and S. d.arideensis on the Seychelles Islands

(Cornell Lab of Ornithology, 2014). All subspecies are similar in appearance to S. d. dougallii, with slight 

differences in wing length and bill color. The North Atlantic and Caribbean population of S. d. dougallii is 

the subspecies that occurs within the Study Area (U.S. Fish and Wildlife Service, 2010a).

3.9.2.2.3.1 Status and Management

In the year 1987, the USFWS listed the roseate tern as endangered under the ESA along the Atlantic 

coast of the United States (Maine to North Carolina); in Canadian provinces of Newfoundland, Nova 

Scotia, and Quebec, as well as in Bermuda (U.S. Fish and Wildlife Service, 2010c). The species is listed as 

threatened under the ESA in the Western Hemisphere, including Florida, Puerto Rico, and the Virgin 

Islands (U.S. Fish and Wildlife Service, 2010c). No critical habitat has been designated for this species in 

the United States. In the year 2006, Canada designated critical habitat for the species (U.S. Fish and 

Wildlife Service, 2010a). Recovery and management plans have been implemented to protect breeding 

colonies, foraging areas, and wintering grounds (Cornell Lab of Ornithology, 2014). The plans intend to 

increase breeding population size, distribution, and productivity by maintaining, expanding, and 

enhancing nesting habitat (U.S. Fish and Wildlife Service, 1998). Recovery and management methods 

include posting nesting areas with signs and fencing, discouraging and controlling competing gull 

species, managing vegetation to enhance nesting habitat, and attempting to attract individuals to 

historically occupied sites (U.S. Fish and Wildlife Service, 1998).

3.9.2.2.3.2 Habitat and Geographic Range

Roseate terns arrive at their breeding grounds in late April and early May (early to mid-May in the 

Caribbean population) and spend approximately 2 weeks feeding before they occupy nesting grounds

(U.S. Fish and Wildlife Service, 1998). Northeastern roseate terns migrate in late August and early 

September, traveling in groups through the eastern Caribbean and along the north coast of South 

America to wintering grounds along the northern and eastern South American coast (Cornell Lab of 

Ornithology, 2014; Kirkham & Nettleship, 1987; National Audubon Society, 2017; U.S. Fish and Wildlife 

Service, 1998, 2010a). The migratory pathway of Caribbean birds is not known, but the route is almost 

certain to be 2,000 to 4,000 km (1,243 to 2,485 mi.) shorter than the route taken by the northeastern

population (U.S. Fish and Wildlife Service, 2010a).

Roseate terns are colonial breeders. The North Atlantic populations are known to nest on a limited 

number of small islands off New York and Massachusetts, while the Caribbean population similarly nests 

in Puerto Rico, the Dry Tortugas, and the Florida Keys, as well as other non-U.S. affiliated Caribbean 

islands (Cornell Lab of Ornithology, 2014). They nest on islands near or under cover, such as vegetation, 

rocks, driftwood, and even human-made objects. They have also been documented nesting on sand 

dunes found at the end of barrier beaches (U.S. Fish and Wildlife Service, 1998). North American roseate 
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terns use moderately to heavily vegetated sites for nesting (Burger & Gochfeld, 1988). Unlike the 

northeastern population, Caribbean roseate tern nests are exposed. Nests are near vegetation or rocks, 

on open sandy beaches, narrow rock ledges close to the water line, or among coral rubble (U.S. Fish and 

Wildlife Service, 1993). 

Open Ocean. Within the Study Area, North American roseate terns occur within open ocean areas (Gulf 

Stream and North Atlantic Gyre) more often during migration and staging for migration than during 

winter or the breeding season. Between May and September, small numbers of common and roseate 

terns are widely distributed at sea, southeast of Cape Cod and throughout the Gulf of Maine, east to the 

southeast edge of Georges Bank. Flocks of terns, including roseate terns, have been observed resting on 

the sea. Such occurrences at sea are typically associated with the occurrence of predatory fish (e.g., 

tuna) that drive prey species to the surface (U.S. Fish and Wildlife Service, 2010a). 

Northeast U.S. Continental Shelf Large Marine Ecosystem. Most breeding North American roseate 

terns occur in this large marine ecosystem from late April/early May to late August/early September

(Table 3.9-1). Approximately 80 percent of the northeast population breeds at two large colonies on 

Great Gull Island, New York; and Bird Island, Massachusetts; with the remaining percentage breeding at 

15–20 smaller colonies in Canada and the United States (Connecticut, Massachusetts, Maine, and New 

York) (Cornell Lab of Ornithology, 2014). Sand flats and beaches of southeastern Massachusetts, 

particularly along outer Cape Cod and nearshore islands provide important roosting and loafing habitats 

during fall staging. The Nantucket Shoal between the Massachusetts mainland and the islands of 

Martha’s Vineyard and Nantucket is a particularly important foraging area for the entire northeastern 

population (U.S. Fish and Wildlife Service, 2010a).

Southeast U.S. Continental Shelf, Gulf of Mexico, and Caribbean Sea Large Marine Ecosystems.

Wintering North American roseate terns occur along the southeast Atlantic and gulf coasts (U.S. Fish and 

Wildlife Service, 2010c). The Caribbean population of roseate tern breeds from the Florida Keys through 

the West Indies to islands off Central America and northern South America (U.S. Fish and Wildlife 

Service, 1993). Within the Study Area, the Gulf of Mexico and Caribbean Sea Large Marine Ecosystems 

contain the population in the Florida Keys and Dry Tortugas, and Puerto Rico.

3.9.2.2.3.3 Population Trends

The estimated global population of roseate terns is approximately 70,000 to 82,000 (BirdLife 

International, 2010). They are a widespread species that breed on every continent except Antarctica, 

with populations in the Indian Ocean, Caribbean, Australasian, European, African, and North American 

regions (Gochfeld, 1983). Approximately 3,200 pairs are estimated in the northeast U.S. population, with 

an additional 75 pairs in Canada and 250 pairs in Florida (Cornell Lab of Ornithology, 2014). Within the 

Caribbean population, approximately 1,000 pairs occur in Puerto Rico, with an estimated 500 to 2,300 

pairs in the U.S. Virgin Islands (Cornell Lab of Ornithology, 2014). The roseate tern experienced drastic 

declines in the late nineteenth century due to commercial hunting of feathers for the millinery (hatmaking) industry (U.S. Fish and Wildlife Service, 1998), as well as humans seeking eggs for food (Kirkham 

& Nettleship, 1987). Populations again showed decline in the 1940s and 1970s as the geographic range 

and the number of breeding colonies decreased (U.S. Fish and Wildlife Service, 1998). 

Groups of roseate terns can be small due to their limited population size and limited nesting habitat in 

North America. In the northeast, breeding colonies of roseate terns range from 2 to more than 

1,000 pairs, depending on breeding colony location (U.S. Fish and Wildlife Service, 1998). After chicks 

fledge from their breeding colonies, terns tend to congregate in large numbers at post-breeding staging 
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areas to build up energy reserves for their seasonal fall migration to South America (U.S. Fish and 

Wildlife Service, 2010a). Northeastern roseate terns are always mixed with gulls and other species of 

terns, while populations in the Caribbean and the Seychelles Islands are known to form single-species 

colonies (Cornell Lab of Ornithology, 2014). Duffy (1986) found that roseate terns foraging in smaller 

flocks experienced higher survival rates, while in larger groups they were often out-competed by 

common terns.

3.9.2.2.3.4 Predator and Prey Interactions

The roseate tern is a coastal species that forages for small schooling fishes over shallow waters around 

bays, channels, sandbars, shoals, and reefs (Cornell Lab of Ornithology, 2014; Nisbet & Spendelow, 

1999). They are also known to forage out over deeper waters than other tern species (Olsen & Larsson, 

1995). Local commutes of up to 16 mi. (25 km) from nesting grounds to dependable foraging sites have 

been documented (Nisbet & Spendelow, 1999). Roseate terns generally concentrate in areas where prey 

is available close to the surface, driven there either by water movements or larger predatory fish. 

Roseate terns are specialized aerial plunge-divers that often completely submerge themselves when 

seizing fish (U.S. Fish and Wildlife Service, 2010c). Roseate terns tend to plunge from heights above the 

water’s surface ranging from 3 to 20 ft., although plunges from greater than 39 ft. have been observed

(Cornell Lab of Ornithology, 2014). Roseate terns do not plunge deep into the water column, usually less 

than 3 feet. Given the shallow depth of dives, submergence times of roughly 1-2 seconds can be 

anticipated. Roseate terns will often fly into the wind and hover (a behavior known as “kiting”) with 

rapid wingbeats and then, with accelerated flapping, aerial plunge into the water (Kaufman, 1990; U.S. 

Fish and Wildlife Service, 1998). Prey species are herring, mackerel, anchovies, and sand eels (Cornell 

Lab of Ornithology, 2014). 

Roseate tern eggs and young are preyed upon by hermit and land crabs, ants, snakes, other birds (e.g., 

hawks, owls, gulls, and some shorebirds), and mammals such as rats and feral cats (U.S. Fish and Wildlife 

Service, 1993).

3.9.2.2.3.5 Species-Specific Threats

Roseate tern population declines have been attributed to commercial hunting and egg collection, 

habitat loss and disturbance, organochlorine contamination, predation, and competition from gulls (U.S. 

Fish and Wildlife Service, 1998). These threats, combined with the small number of breeding sites used 

by the species, warranted the listing of the species (Nisbet & Spendelow, 1999). Roseate terns are 

sensitive to disturbance on their nesting grounds, and many suitable nesting sites have been lost or 

abandoned due to the expansion of recreational, residential, and commercial use (Gochfeld, 1983). 

Beach erosion and the expansion of gull populations have also displaced roseate terns from suitable 

nesting habitat (Cornell Lab of Ornithology, 2014). Roseate terns are vulnerable to predation and 

flooding because they nest on the ground, often in low-lying areas (Gochfeld, 1983). Storms and 

prolonged periods of cold, wet weather also impact nest success (U.S. Fish and Wildlife Service, 1993). 

Climate change and sea level rise may exacerbate erosion of nesting grounds and could result in more 

severe or more frequent storms, which could disturb these habitats and result in reduced survival of 

adults, eggs, chicks, and fledglings (U.S. Fish and Wildlife Service, 2010a). Starvation is likely a greater 

cause of death during the winter in areas such as the southern Caribbean where nutrients are relatively 

poor (Gochfeld, 1983). Although little is known about roseate tern ecology during migration and 

wintering periods, one major cause of death is believed to be humans hunting this species on its 

wintering grounds (outside the United States) (Cornell Lab of Ornithology, 2014). Emerging potential 
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threats include wind turbine development projects which introduce the possibility of collision, 

disturbance, and displacement of this species during the breeding and migratory seasons (Burger et al., 

2011).

3.9.2.2.4 Red Knot (Calidris canatus rufa)

Red knots are found on the Atlantic coast of the United States and Canada. They belong to the 

subspecies C. canutus rufa (Cornell Lab of Ornithology, 2013). This subspecies of red knot, referred to as 

the rufa red knot, is listed as threatened under the ESA.

3.9.2.2.4.1 Status and Management

Four petitions to emergency list the red knot have been submitted since 2004, and in December of 2014, 

the USFWS listed the red knot as threatened under the ESA (Federal Register 79[238]: 73706-73748, 

December 11, 2014). Currently there is no designated critical habitat for the red knot, nor are there any 

developed conservation plans available from the USFWS. The five-year goal highlighted in the species 

action plan is to stabilize and improve the conservation status of the species through increasing habitat 

protection, reducing disturbance, and protecting key resources at migration and wintering sites (Cornell 

Lab of Ornithology, 2013). The Western Hemisphere Shorebird Reserve Network has established an 

international network of wetlands in an effort to protect important sites used by shorebirds, including 

the red knot (Tsipoura & Burger, 1999). Additionally, efforts to develop protection for Delaware Bay, an 

important migration staging area for red knots, are underway by the Western Hemisphere Shorebird 

Reserve Network (Cornell Lab of Ornithology, 2013).

3.9.2.2.4.2 Habitat and Geographic Range

The species breeds on the central Canadian arctic tundra but migrates down and winters along the 

Atlantic and gulf coasts from southern New England to Florida, and as far south as South America

(Cornell Lab of Ornithology, 2013). Red knots will briefly use important stopover areas such as the 

Delaware Bay to forage before returning to their breeding grounds each year. An interior red knot 

population winters in Texas and Louisiana and migrates through the west and midwest to central 

Canada. 

Open Ocean Areas. Red knots migrate some of the longest distances known for birds, with many 

individuals annually flying more than 9,300 mi. (15,000 km) (Cornell Lab of Ornithology, 2013), during 

which they may cross over each of the open ocean areas in the Study Area. However, outside of 

migration they are typically found in nearshore habitats along coastlines. Fall migration peaks in August 

with birds flying south along the Atlantic coast to major wintering grounds on the coasts of Argentina 

and southern Chile (Cornell Lab of Ornithology, 2013).

Northeast U.S. Continental Shelf Large Marine Ecosystem. During migration stopovers, the red knot 

uses marine habitats and generally prefers coastal, sandy habitats near tidal bays, inlets, and estuaries 

for foraging (Cornell Lab of Ornithology, 2013). Red knots migrate in large flocks and stop over at the 

same coastal sites along the Atlantic coast during spring migration to feed on eggs of horseshoe crabs 

(Limulus polyphemus). In particular, Delaware Bay is one of the largest known spring (mid-May to early 

June) stopover sites for this species (Federal Register 71[176]: 53756-53835, September 12, 2006) (Clark 

et al., 1993). Up to 80 percent of the entire estimated red knot population has been observed at once in 

the Delaware Bay during spring migration, leading to the area being designated as the first hemispheric 

site in the Western Hemisphere Shorebird Reserve Network (Clark et al., 1993; Niles et al., 2008; 

Tsipoura & Burger, 1999). 
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Southeast U.S. Continental Shelf and Gulf of Mexico Large Marine Ecosystems. During fall and spring 

migration and winter months, red knots occur in nearshore coastal habitats, along the Atlantic and gulf 

coasts from southern New England to Florida and into the Gulf of Mexico (Cornell Lab of Ornithology, 

2013). The Virginia Atlantic barrier islands are a second major stopover location, with red knot peak 

counts between 5,500 and 9,100 birds since 1995 (Niles et al., 2008). They primarily occur in intertidal 

surf-zone habitats, particularly near coastal inlets, estuaries, and bays.

3.9.2.2.4.3 Population Trends

The red knot population was previously estimated at 100,000 to 150,000 individuals in the 1980s (Niles 

et al., 2008). However, annual aerial and ground surveys of Delaware Bay show fluctuation but generally 

a downward trend. Population surveys during the stopover period in the spring of 1998 at Delaware Bay 

estimated 50,000 red knots. In 2004, the same survey was repeated and the estimated population was 

substantially lower at 18,000 (Niles et al., 2008). Surveys of red knots at both migration stopover sites 

and wintering grounds continually show substantial population declines in recent decades (Federal 

Register 71[176]: 53756-53835, September 12, 2006). For example, surveys during the mid-1980s of 

wintering red knot populations in South America (Argentina and Chile) provided an estimate of 

67,500 individuals (Niles et al., 2008); but according to the USFWS, since 2005, numbers have been 

under 20,000 birds, and dipped below 10,000 in 2011. Studies from 1994 to 2002 also show decreased 

annual adult survival rates related to these population declines (Niles et al., 2008).

3.9.2.2.4.4 Predator and Prey Interactions

Red knots forage by surface pecking and probing for intertidal invertebrates and various species of 

mussels and other molluscs (Cornell Lab of Ornithology, 2013). During spring migration, a major food 

source for red knots are horseshoe crab eggs; millions of which can be found in the Delaware Bay during 

the second half of May (Botton et al., 1994). Red knot migration coincides with the horseshoe crabs 

laying their eggs, allowing birds to restore their fat reserves to continue their northward migration to 

their breeding grounds in the arctic (Cornell Lab of Ornithology, 2013; Tsipoura & Burger, 1999).

Outside of the breeding grounds, red knot predators include peregrine falcon (Falco peregrinus), merlin 

(Falco columbarius), northern harrier (Circus cyaneus), short-eared owl (Asio flammeus), great blackbacked gull (Larus marinus), and accipiters (Accipiter spp.) (Niles et al., 2008). Predators on breeding 

grounds include arctic fox (Alopex lagopus), long-tailed jaeger (Stercorarius longicaudus), and parasitic 

jaeger (Stercorarius parasiticus) (Piersma et al., 1993).

3.9.2.2.4.5 Species-Specific Threats

The red knot is threatened under the ESA mainly by habitat loss and degradation of foraging resources 

such as reduction of horseshoe crab populations (U.S. Fish and Wildlife Service, 2010b). Horseshoe crabs 

are harvested for their blood for biomedical research and their eggs for bait in the conch and eel fishing 

industries; consequently, the reduction in the amount of horseshoe crab eggs available for red knots, 

especially in Delaware Bay, is believed to be the cause of lower weight gain in red knots during 

migratory stopovers and contributing to lower adult survival (Niles et al., 2008). Beach erosion, shoreline 

protection and stabilization projects, human disturbance, limited food resources, oil spills, red tides, 

hunting, and severe weather all threaten the stability of the population (Niles et al., 2008; U.S. Fish and 

Wildlife Service, 2010b). Because large percentages of the entire population gather at single sites during 

migration (i.e., Delaware Bay) and winter, the species is especially vulnerable to loss of key resources at 

these sites (Clark et al., 1993; Cornell Lab of Ornithology, 2013; Niles et al., 2008).
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3.9.2.2.5 Indiana Bat (Myotis sodalis)

3.9.2.2.5.1 Status and Management

The Indiana bat was originally listed as in danger of extinction under the Endangered Species 

Preservation Act of 1966 and is currently listed as endangered under the ESA. In 2009, its recovery 

priority was changed from 8 (meaning that the species has a moderate degree of threat and high 

recovery potential) to 5 (meaning that the species has a high degree of threat and a low recovery 

potential) due to the emergence and poor understanding of white-nose syndrome (U.S. Fish and Wildlife 

Service, 2009a). Critical habitat was designated for the species in 1976 (Federal Register 41[187]: 41914-

41916, September 24, 1976). Eleven caves and two mines in six states (Illinois, Indiana, Kentucky, 

Missouri, Tennessee, and West Virginia) were listed as critical habitat. Significant information gaps 

remain regarding the species’ ecology that hinder sound decision-making on how best to manage and 

protect the species (U.S. Fish and Wildlife Service, 2007).

3.9.2.2.5.2 Habitat and Geographic Range

Indiana bats hibernate, typically beginning in mid-October (in northern areas) or by the end of 

November (in southern areas) and ending by early May (for females) or mid-May (for males), with 

female peak emergence in mid-April and male peak emergence early May. It is thought that spring 

migration, which may occur either immediately upon emergence or a few days after emergence, may 

cause higher mortality due to low fat reserves and food supplies. Large numbers of Indiana bats 

complete their migration in mid-May, and fall migration begins during the first two weeks of August 

(U.S. Fish and Wildlife Service, 2007). 

Extent hibernacula are patchily distributed northeast-southwest from Vermont to Tennessee, and eastwest from Tennessee to Arkansas. Between 1995 and 2005, 281 hibernacula were active for at least one 

year. Of these, only one county (in Connecticut) containing one Priority 4 (i.e., lowest priority) 

hibernacula was located along the eastern coast of the U.S., and only one county (in New Jersey) 

containing two Priority 3 (i.e., second-lowest priority) hibernacula are adjacent to a county located along 

the eastern coast of the U.S. (U.S. Fish and Wildlife Service, 2007). 

Extent maternity colonies are generally more clustered, located along the borders of Iowa, Missouri, and 

Illinois as well as throughout Indiana and southern Michigan, with scattered colonies in the northeastern 

U.S. None of the 269 extent maternity colonies are located in a county along the coast, and only 6 

colonies (all in New Jersey) are located adjacent to a county along the coast (U.S. Fish and Wildlife 

Service, 2007). 

Based on the description provided above, the Indiana bat is expected to occur in portions of the Study 

Area (refer to Table 3.9-1) infrequently, during summer months.

3.9.2.2.5.3 Population Trends

Estimates of prehistoric Indiana bat populations, based on paleontological evidence, range from 1.7 

million to 9-13 million. One analysis of bone deposits at Bat Cave, Kentucky, in Mammoth Cave National 

Park, revealed an estimated 300,000 Indiana bats had died during a single flood event; it is uncertain 

whether this catastrophic population loss occurred during prehistoric times or during a large flood in 

1937 that devastated much of the Ohio River valley (U.S. Fish and Wildlife Service, 2007). 

When the Indiana bat was originally listed, its rangewide population was estimated at approximately 

880,000. In 1983, when the first recovery plan was completed and approved, the rangewide population 

was estimated at about 550,000. Despite the acquisition and protection of over 35 caves and mines by 
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government agencies or private conservation organizations, the rangewide Indiana bat population was 

estimated at 353,000 bats in 1997 (U.S. Fish and Wildlife Service, 2009a). These earlier estimates are 

considered low, however, due to discoveries of new hibernaculums. For example, one hibernaculum 

was discovered in Missouri in 2012 that contained a minimum of 123,000 bats when partially surveyed 

in January 2013 and over 167,000 bats when more completely surveyed in January 2015. Based on 

earlier accounts of very large numbers of unidentified bats using this hibernaculum for decades, the U.S. 

Fish and Wildlife Service decided to add the same number of bats as was found in 2015 (i.e., 167,000) to 

each previous biennium total for Missouri through 1981. Based on the best available data for the 

species, the U.S. Fish and Wildlife Service currently estimates that approximately 635,000 bats occurred 

rangewide in 2007 and that the population fell to approximately 524,000 in 2015 (U.S. Fish and Wildlife 

Service, 2015b).

3.9.2.2.5.4 Predator and Prey Interactions

Indiana bats feed on flying insects, with only a very small amount of spiders (presumably ballooning 

individuals) included in the diet. Four orders of insects contribute most to the diet: Coleoptera, Diptera, 

Lepidoptera, and Trichoptera. Terrestrial-based prey (moths and beetles) were more common in 

southern studies, whereas aquatic-based insects (flies and caddisflies) dominated in the north. It is 

presumed that this difference indicates southern bats foraged more in upland habitats, and northern 

bats hunted more in wetlands or above streams and ponds. Indiana bats are also known to consume 

other flying insects such as Hymenopterans (winged ants) and Asiatic oak weevils (Cyrtepistomus 

castaneus) when opportunistically available (U.S. Fish and Wildlife Service, 2007). 

3.9.2.2.5.5 Species-Specific Threats

Threats to the Indiana bat vary during its annual cycle. Within the last 10 years, white-nose syndrome

emerged as a significant threat as it as it causes precipitous declines in populations of cave-hibernating 

bat species (see Section 3.9.2.1.5.3, Disease and Parasites). Other threats at the hibernacula include 

modifications to caves, mines, and surrounding areas that change airflow and alter the microclimate 

within the hibernacula. Human disturbance and vandalism pose significant threats during hibernation 

through direct mortality and by inducing arousal and consequent depletion of fat reserves. Natural 

catastrophes can also have a significant effect during winter because of the concentration of individuals 

in a relatively few sites. During summer months, possible threats relate to the loss and degradation of 

forested habitat. Migration pathways and swarming sites may also be affected by habitat loss and 

degradation (U.S. Fish and Wildlife Service, 2007).

3.9.2.2.6 Northern Long-eared Bat (Myotis septentrionalis)

3.9.2.2.6.1 Status and Management

The northern long-eared bat was listed as threatened under the ESA on 4 May 2015. It occurs in 37 

states, the District of Columbia, and 13 Canadian provinces (U.S. Fish and Wildlife Service, 2016a). The 

USFWS has determined that designating wintering habitat as critical habitat for the species would likely 

increase the threat of vandalism, disturbance, or the spread of white-nose syndrome. Furthermore, the 

USFWS has determined there are no areas within the summer habitat that meet the definition of critical 

habitat (U.S. Fish and Wildlife Service, 2016b). In January 2016, the USFWS established a white-nose 

syndrome zone under Rule 4(d) of the ESA. Incidental take of the northern long-eared bat is only 

allowed outside of the white-nose syndrome zone. The boundary of this zone is updated monthly as 

new data are collected and is available online at the U.S. Fish and Wildlife Service’s Midwest Region 

website. As of May 2017, the white-nose syndrome zone included a vast majority of the northern long-
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eared bat’s range and virtually the entire extent of its range along the east coast (Section 3.9.2.2.1.2, 

Habitat and Geographic Range) (U.S. Fish and Wildlife Service, 2017b). 

3.9.2.2.6.2 Habitat and Geographic Range

Hibernation generally occurs from October through April, depending on the local climate. Suitable 

habitat for hibernation includes caves and cave-like structures (e.g., abandoned or active mines, railroad 

tunnels). The spring migration period typically runs from mid-March to mid-May. Suitable summer 

habitat for the northern long-eared bat consists of a wide variety of forested and wooded habitats as 

well as linear features such as fence rows, riparian forests, and other wooded corridors with variable 

amounts of canopy closure. Mature forests are an important habitat type for foraging northern longeared bats (U.S. Fish and Wildlife Service, 2016a).

Unlike the true long-distance migratory bats (Lasiurus spp. and Lasionycteris spp.), the northern longeared bat does not undertake long-distance migrations between summer and winter ranges but will 

make shorter distance movements between summer roosts and winter hibernacula (Yates, 2015). 

Within the United States, its range extends along the eastern coast from Canada to northeastern North 

Carolina, with additional small patches along the coast of southern North Carolina and southern South 

Carolina (U.S. Fish and Wildlife Service, 2017a, 2017b). Within the Study Area, northern long-eared bats 

are most likely to occur off the coast of the Northeastern United States and Canada (U.S. Department of 

Energy, 2016).

In a literature review, Pelletier et al. (2013) report that northern long-eared bats were found along the 

coastline or offshore on islands at:

 Kejimkujik National Park, Brier Island, and Bon Portage Island in Nova Scotia, Canada. Nova 

Scotia is a peninsula that is separated from the mainland to the south by 30 to 50 mi. of water. 

Brier Island and Bon Portage Island are separated from Nova Scotia by approximately 8 mi. and 

about 2 mi., respectively. Observed during summer months.

 Bay of Fundy National Park, New Brunswick, Canada, in summer to early fall.

 Martha’s Vineyard, Massachusetts, approximately 4 mi. from mainland, during mist-netting 

surveys from April through October.

 Mount Desert Island, Maine (2 mi. off the coast), between May and September.

In addition, U.S. Department of Energy (2016) reports that ongoing mist-netting surveys at coastal sites 

in the northeast have also indicated relatively high numbers of northern long-eared bats post the 

introduction of white-nose syndrome compared to other, non-coastal areas in the northeast.

Northern long-eared bats have been detected during surveys at a variety of Navy installations along the 

eastern coast. These installations include:

 Naval Computer and Telecommunications Area Master Station Atlantic Detachment Cutler, 

located on the coast in Cutler, Maine, near the border with Canada. Data suggests there were 

likely some long-distance migratory tree-roosting bats spending the summer residency period at

the installation and that other long-distance migratory bats moved through the Installation 

during the fall (Tetra Tech Inc, 2014). However, no northern long-eared bats were detected at 

the Installation in surveys by Yates (2015).
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 Naval Weapons Station Earle in Colts Neck, New Jersey, where northern long-eared bats were 

present and roosting at the installation. The survey report authors note that the “presence of a 

sustained population of northern long-eared bats on Naval Weapons Station Earle is a testament 

to the amount of preferred habitat, contiguous forest, that the installation is able to provide 

compared to the surrounding areas.”

 Naval Weapons Station Yorktown and Naval Supply Center Cheatham Annex in Williamsburg, 

Virginia (Tetra Tech Inc, 2017b). One bat was detected during the 2016 surveys, and a juvenile 

was detected during 2014 surveys. The authors report that the presence of the juvenile 

“suggests that there may be successful Northern long-eared bat maternity colonies in the area.”

 Two installations along the coast in Virginia Beach, Virginia:

o Joint Expeditionary Base Fort Story (Tetra Tech Inc, 2016a). 

o Naval Air Station Oceana Dam Neck Annex (Tetra Tech Inc, 2016b).

In addition to the above, although no northern long-eared bats were detected at Naval Air Station 

Oceana in Virginia Beach, Virginia, they were detected near the installation in 2014 and 2015, and there 

is suitable habitat available on the installation (Tetra Tech Inc, 2016c).

3.9.2.2.6.3 Population Trends

The U.S. Fish and Wildlife Service (2016c) estimated the rangewide northern long-eared bat population 

at over 6.5 million adults. The Midwest supports 43% of the total population, followed by the Southern 

range (38%), the Eastern range (17%), and the Western range (2%). Arkansas and Minnesota are the two 

states with the largest populations, with approximately 863,850 (13%) and 829,890 (13%) adults, 

respectively. In areas affected by white-nose syndrome, however, the population is likely overestimated 

as (1) there is a clear downward trend in these areas, (2) most data are at least a year old, and (3) three 

years of occupancy data were used.

3.9.2.2.6.4 Predator and Prey Interactions

The northern long-eared bat has a diverse diet including moths, flies, leafhoppers, caddisflies, and 

beetles, and its diet differs geographically and seasonally. It forages using both hawking (catching prey in 

flight) and gleaning (picking motionless insects from vegetation and water surfaces) behaviors (U.S. Fish 

and Wildlife Service, 2016a, 2017a). Lepidopterans (moths) and coleopterans (beetles) are the most 

common insects found in northern long-eared bat diets, although arachnids are also a common prey 

item. Most foraging occurs above the understory, 1 to 3 m above the ground, but under the canopy on 

forested hillsides and ridges, rather than along riparian areas. 

3.9.2.2.6.5 Species-Specific Threats

The northern long-eared bat is one of the species of bats most impacted by white-nose syndrome (see 

Section 3.9.2.1.5.3, Disease and Parasites), which has caused declines of 90 to 100% where the disease 

has been found and is the primary factor supporting the endangered species status determination. 

Declines in the numbers of northern long-eared bats are expected to continue as white-nose syndrome

extends across the species’ range (U.S. Fish and Wildlife Service, 2016a).

3.9.2.3 Species Not Listed Under the Endangered Species Act

At least 160 species of birds, and at least 24 species of bats, are found within the Study Area that are not 

listed under the ESA. The major groups of birds are described in Section 3.9.2.3.1 (Major Groups), and 
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Section 3.9.2.3.3 (Migratory Birds) describes species that are protected and of conservation concern 

under the Migratory Bird Treaty Act. Section 3.9.2.3.2 (Bats) describes the bats that are known or are 

expected to occur in the Study Area.

3.9.2.3.1 Major Bird Groups

There are 11 major taxonomic groups of birds represented in the Study Area Table 3.9-2. These birds 

may be found in the air, at the water’s surface, or in the water column of the Study Area. The vertical 

distribution descriptions in Table 3.9-2 provide a representative description of the taxonomic group; 

however, due to variations in species behavior, these descriptions may not apply to all species within 

each group. Distribution in the water column is indicative of a species known to dive under the surface 

of the water (for example, during foraging). More detailed species descriptions, including diving 

behavior, are provided in Sections 3.9.2.3.1.1 (Geese, Swans, Dabbling, and Diving Ducks [Order 

Anseriformes]) through 3.9.2.3.1.11 (Neotropical Migrant Songbirds, Thrushes, Allies, Cuckoos, Swifts, 

and Owls [Orders Passeriformes, Cuculiformes, and Apodiformes]).

All 11 major taxonomic groups of birds in the Study Area occur in open ocean areas (Labrador Current, 

North Atlantic Gyre, Gulf Stream) or coastal waters of large marine ecosystems (West Greenland Shelf, 

Newfoundland-Labrador Shelf, Scotian Shelf, Northeast U.S. Continental Shelf, Southeast 

U.S. Continental Shelf, Gulf of Mexico, Caribbean Sea), as shown in Table 3.9-2 Refer to Figure 3.0-1 for a 

map of open ocean areas and large marine ecosystems in the Study Area.

Table 3.9-2: Major Taxonomic Groups of Birds in the Study Area

Major Bird Groups Vertical Distribution in the Study Area

Common Name

(Taxonomic Group) Description

Open Ocean 

Areas

Large 

Marine 

Ecosystem

Inshore 

Waters

Geese, swans, dabbling and 

diving ducks 

(Order Anseriformes)

Diverse group of birds that 

inhabit shallow waters, coastal 

areas, and deeper waters. Feed 

at the surface by dabbling or by 

diving in deeper water. Often 

occur in large flocks.

Airborne, 

surface, 

water 

column

Airborne, 

surface, 

water 

column

Airborne, 

surface, 

water 

column

Loons

(Order Gaviiformes)

Duck-like, fish-eating birds that 

capture prey by diving and 

underwater pursuit.

Airborne, 

surface, 

water 

column

Airborne, 

surface, 

water 

column

Airborne, 

surface, 

water 

column

Grebes

(Order Podicipediformes)

Small diving birds, duck-like.

May occur in small groups.

Airborne, 

surface, 

water 

column

Airborne, 

surface, 

water 

column

Airborne, 

surface, 

water 

column
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Table 3.9-2: Major Taxonomic Groups of Birds in the Study Area (continued)

Major Bird Groups Vertical Distribution in the Study Area

Common Name

(Taxonomic Group) Description

Open Ocean 

Areas

Large 

Marine 

Ecosystem

Inshore 

Waters

Albatrosses, fulmars, petrels, 

shearwaters, and stormpetrels 

(Order Procellariiformes)

Group of largely pelagic 

seabirds. Fly nearly continuously 

when at sea. Soar low over the 

water surface to find prey. Some 

species dive below the surface.

Airborne, 

surface, 

water 

column

Airborne, 

surface, 

water 

column

Airborne, 

surface, 

water 

column

Boobies, gannets, 

cormorants, anhingas, and 

frigatebirds

(Order Suliformes)

Diverse group of large, fisheating seabirds with four toes 

joined by webbing. Often occur 

in large flocks near high 

concentrations of bait fish.

Airborne, 

surface, 

water 

column

Airborne, 

surface, 

water 

column

Airborne, 

surface, 

water 

column

Tropicbirds (Order 

Phaethontiformes)

Oceanic birds, found far 

offshore, over warm water and 

are often seen resting on the 

water. Flight is high and steady 

and they plunge into water to 

catch fish.

Airborne, 

surface, 

water 

column

Airborne, 

surface, 

water 

column

Airborne, 

surface, 

water 

column

Pelicans, herons, egrets, Ibis, 

and spoonbills 

(Order Pelecaniformes)

Large wading birds with daggerlike, down-curved, or spoonshaped bills used to capture prey 

in water or mud.

None

Airborne, 

surface, 

water 

column

Airborne, 

surface, 

water 

column

Flamingos 

(Order Phoenicopteriformes)

Large, wading birds with unique 

angled bill to filter invertebrates 

from water or mud.

None Airborne, 

surface

Airborne, 

surface

Osprey, bald eagles, 

peregrine falcons 

(Orders Accipitriformes, and 

Falconiformes)

Large raptors that inhabit 

habitats with open water, 

including coastal areas. Feed on 

fish, waterfowl, or other 

mammals. Migrate and forage 

over open water.

None Airborne, 

surface

Airborne, 

surface 

Osprey, bald eagles, 

peregrine falcons 

(Orders Accipitriformes, and 

Falconiformes)

Large raptors that inhabit 

habitats with open water, 

including coastal areas. Feed on 

fish, waterfowl, or other 

mammals. Migrate and forage 

over open water.

None Airborne, 

surface

Airborne, 

surface 

Shorebirds, phalaropes, gulls, 

noddies, terns, skua, jaegers, 

and alcids (Order 

Charadriiformes)

Diverse group of small to 

medium-sized shorebirds, 

seabirds and allies inhabiting 

coastal, nearshore, and open 

ocean waters

Airborne, 

surface, 

water 

column

Airborne, 

surface, 

water 

column

Airborne, 

surface, 

water 

column
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Table 3.9-2: Major Taxonomic Groups of Birds in the Study Area (continued)

Major Bird Groups Vertical Distribution in the Study Area

Common Name

(Taxonomic Group) Description

Open Ocean 

Areas

Large 

Marine 

Ecosystem

Inshore 

Waters

Neotropical Migrant 

Songbirds, Warblers, 

Thrushes, Cuckoos, Owls, 

Swifts, and Allies 

(Orders Passeriformes 

Cuculiformes, Strigiformes, 

and Apodiformes)

Largest and most diverse group 

of birds in North America, 

primarily occur in coastal, and 

inland areas, but occur in large 

numbers over the open ocean 

(particularly over the Gulf of 

Mexico) during annual spring 

and fall migration periods.

Airborne Airborne Airborne

Sources: American Ornithologists' Union (2017), Sibley (2014) for major bird taxonomic groups.

3.9.2.3.1.1 Geese, Swans, Dabbling and Diving Ducks (Order Anseriformes)

There are 50 species of swans, geese, and dabbling, diving, and seaducks in the family Anatidae in North 

America. No birds from this group are considered Birds of Conservation Concern (U.S. Fish and Wildlife 

Service, 2008b). Birds from this group range from dabbling ducks found in coastal bays, estuaries, and 

lagoons to more open water ducks found in deeper water environments. Twenty-three of these species 

are diving ducks that inhabit nearshore or offshore waters of the Study Area (Sibley, 2014). Eiders, 

scoters, long-tailed duck (Clangula hyemalis), and harlequin duck (Histrionicus histrionicus) are seaducks 

that winter in nearshore ocean waters. All these species can be found in deeper water where they dive 

to forage (Sibley, 2014), some also forage on the ocean bottom in shallow water. Most diving duck 

species dive down to depths up to 33 ft. (10 m) but long-tailed ducks have been reported to dive down 

to depths up to 218 ft. (66 m) with a dive time of around 35 seconds (Sibley, 2014). Some inshore shark 

species, as well as alligators and crocodiles, prey on ducks on the surface of the water (Ehrlich et al., 

1988). 

Seaducks and some diving ducks (e.g., scaups) breed inland but winter in large numbers in the Atlantic 

coastal waters of the Study Area and dive to the bottom, feeding primarily on benthic invertebrates. The 

harlequin duck is small and agile and prefers very turbulent water such as freshwater streams during the 

breeding season. Their winter habitat includes coastal intertidal areas, but they roost at night on open 

water farther offshore (greater than 0.6 mi. [1 kilometer]) (Robertson & Goudie, 1999). The long-tailed 

duck winters in small groups in shallow ocean habitat. 

Representative species that can be found in coastal bays, estuaries, and lagoons include geese (e.g., 

Canada goose [Branta tellate], brant [Branta bernicla]); swans (e.g., trumpeter swan [Cygnus 

buccinators], tundra swan [Cygnus columbianus]); dabbling ducks (e.g., mallard [Anas platyrhynchos], 

gadwall [Anas strepera], mottled duck [Anas fulvigula], American black duck [Anas rubripes], American 

wigeon [Anas tellate], northern shoveler [Anas clypeata], blue-winged teal [Anas discors], and greenwinged teal [Anas crecca]); diving ducks (e.g., redhead [Aythyatellate], bufflehead [Bucephala albeola], 

common goldeneye [Bucephala clangula], and red-breasted merganser [Mergus serrator]); eiders (e.g., 

common eider [Somateria mollissima], king eider [Somateria spectabilis]); and scoters (e.g., surf scoter 

[Melanitta perspicillata], black scoter [Melanitta tellate]) (American Ornithologists' Union, 1998).
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3.9.2.3.1.2 Loons (Order Gaviiformes)

There are five species of loons in the family Gaviidae in North America (American Ornithologists' Union, 

1998), three of which occur in the Study Area. The common loon (G. immer) and the red-throated loon 

(G. stellata) are Birds of Conservation Concern (U.S. Fish and Wildlife Service, 2008b). Loons are medium 

to large fish-eating birds that capture prey by diving underwater (Sibley, 2014). Loons can dive down to 

250 ft. (76 m) with an average dive time of 40 seconds (Sibley, 2014). Loons move ashore only to breed, 

and all loon species nest on banks of inland ponds or lakes, requiring specific habitat features such as 

undeveloped shoreline and nest sites that have steep drop offs so they can approach their nest from 

underwater (Cornell Lab of Ornithology, 2009). For example, common loons spend their time in both 

freshwater and saltwater environments but prefer to nest on islands where the shoreline is not 

developed. Most loons need about 100 ft. (30.5 m) of room to take off, so size is another habitat feature 

that is important for nesting areas. During migration, loons fly high above land or water in loose groups 

or singly. They winter in coastal, nearshore, or open water marine habitats (Sibley, 2014). For example, 

the Pacific loon (G. pacifica) prefers deep water and is found on the open ocean and in bays. The redthroated loon, a representative species within the Study Area, has a circumpolar distribution, breeds in 

high latitudes on remote ponds, and winters along the Atlantic and Pacific coasts (American 

Ornithologists' Union, 1998).

3.9.2.3.1.3 Grebes (Order Podicipediformes)

There are seven species of grebes in the family Podicipedidae in North America (American 

Ornithologists' Union, 1998). Two of these species, the pied-billed grebe (Podilymbus podiceps) and 

horned grebe (Podiceps auritus) are Birds of Conservation Concern (U.S. Fish and Wildlife Service, 

2008b). Grebes can be found in a variety of aquatic habitats ranging from seasonally flooded scrubland 

and roadside ditches to deep lakes and coastal bays. Most grebe species winter in open waters while 

preferring marshy, vegetated habitats during the summer months (Sibley, 2014). Grebes forage by 

diving for small aquatic animals such as insects, fish, and crustaceans in the water column. For example, 

horned grebes can dive for up to 3 minutes and travel 500 ft. underwater, where they are sometimes 

preyed upon by sharks and orcas (Ehrlich et al., 1988). Grebes tend to escape predators by diving or 

sinking, leaving only the head exposed, rather than taking flight. All grebe species build floating nests in 

marshes and winter on the ocean and nearshore coastal areas (Sibley, 2014).

3.9.2.3.1.4 Albatrosses, Fulmars, Petrels, Shearwaters, and Storm-Petrels (Order 

Procellariiformes)

Procellariiformes is a large order of open ocean seabirds that are divided into four families: 

Diomedeidae (albatrosses), Procellariidae (petrels and shearwaters), Hydrobatidae (storm-petrels), and 

Pelecanoididae (diving petrels) (Enticott & Tipling, 1997; Onley & Scofield, 2007). This order includes 

species that are generally long-lived, breed once a year, and lay only one egg; thus, they have a low 

reproductive output. One of these species is listed as endangered under the ESA (Section 3.9.2.2.1, 

Bermuda Petrel [Pterodroma cahow]) (U.S. Fish and Wildlife Service, 2010d) and four are Birds of 

Conservation Concern as shown in (U.S. Fish and Wildlife Service, 2008b).

Many seabirds spend most of their lives at sea and come to land only to breed, nest, and occasionally 

roost (Schreiber & Chovan, 1986). Colonial breeding is believed to have evolved in response to the 

limited availability of relatively predator-free nesting habitats and distance to foraging sites from 

breeding grounds (Siegel-Causey & Kharitonov, 1990). Benefits of colonial breeding include increased 
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detection of predators and decreased chance of predation of young while parent birds are foraging 

away from the nest (Gill, 1995).

Seabirds can be found in high numbers resting on the water surface in flocks where prey is concentrated

(Enticott & Tipling, 1997). Some species are found around fishing boats, where they often feed on 

bycatch and may become injured from longline gear (Enticott & Tipling, 1997; Onley & Scofield, 2007). 

Also, because of their pelagic nature, this group is preyed on by some pelagic shark species (Ehrlich et 

al., 1988). Oceanic fronts (gradients in current speed, temperature, salinity, density, and enhanced 

circulation) attract seabirds due to increased foraging opportunities. For example, the at-sea distribution 

of some seabirds is associated with oceanic fronts, which support increased numbers of prey and 

provide favorable foraging conditions (Bost et al., 2009). 

There are 20 species of Procellariiformes in North America, with 13 species representing two familiesthe storm-petrels and petrels and shearwaters (American Ornithologists' Union, 1998)-occurring within 

the Study Area. Most of the petrel species in the Study Area are not considered part of the diving petrels 

and forage along the surface of the ocean. Petrels are colonial nesters and tend to nest on remote 

islands uninhabited by people.

Storm-petrels pick prey off the surface while foraging. Most breed in natural holes/cryptic burrows and 

visit their colonies only at night (Enticott & Tipling, 1997; Onley & Scofield, 2007). Fulmarine petrels, 

such as the northern fulmar (Fulmarus glacialis) and the black-capped petrel (Pterodroma hasitata), 

feed by landing on the sea and grabbing prey near the surface. Most fulmarine petrels nest in burrows 

or on cliff ledges and visit nests by day (Enticott & Tipling, 1997; Onley & Scofield, 2007). Gadfly petrels 

are generally species of the Pterodroma genus and are long-winged, fast flying, and highly pelagic. They 

feed on the wing and land on the sea (Onley & Scofield, 2007). Some gadfly petrels nest in burrows or 

crevices and visit colonies at night (Enticott & Tipling, 1997; Onley & Scofield, 2007). 

Shearwaters are small- to medium-sized and dive to varying depths for prey (Onley & Scofield, 2007). 

For example, Cory’s shearwater (Calonectris diomedea) rarely dives to 16 ft. (5 m) below the surface, 

while sooty (Puffinus griseus) and short-tailed shearwaters (Puffinus tenuirostris) can reach depths of 

230 ft. (70 m), swimming underwater with half-open wings (Enticott & Tipling, 1997; Onley & Scofield, 

2007). Greater shearwaters in the South Atlantic Ocean have been reported to dive down to 62 ft. (19 

m) and as long as 40 s in a single dive. However, the majority of their dives were less than 6.6 ft. (2 m)

(Ronconi et al., 2010).

3.9.2.3.1.5 Boobies, Gannets, Cormorants, and Frigatebirds (Order Suliformes)

The Suliformes order is a diverse group of large seabirds including anhingas, gannets, boobies, 

cormorants, and frigatebirds. This order is composed of 16 species in 4 families—12 species 

representing 2 families that occur within the Study Area. Four of these species are considered Birds of 

Conservation Concern (U.S. Fish and Wildlife Service, 2008b). Species of concern within the Study Area 

include the brown booby (Sula leucogaster), masked booby (Sula dactylatra), great cormorant 

(Phalacrocorax carbo), and magnificent frigatebird (Fregata magnificens) (American Ornithologists' 

Union, 1998).

Suliformes are less pelagic than the Procellariiformes, although some of these species such as 

frigatebirds are pelagic. Most species are colonial, feed on fish, and use a variety of breeding habitats 

including trees and bushes (but not burrows). Breeding strategies vary among species, with some being 

long-lived and having low breeding success, while others have higher annual breeding success, but 

higher annual adult death (Enticott & Tipling, 1997; Onley & Scofield, 2007). 
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Cormorants are voracious predators on inshore fishes and have been implicated as a major threat to the 

recovery efforts of Atlantic salmon in the Gulf of Maine where they feed on juvenile salmon (smolts) 

leaving the estuaries (Fay et al., 2006; National Marine Fisheries Service & U.S. Fish and Wildlife Service, 

2005). Their offshore foraging range is limited by their need for undisturbed, dry nocturnal roosting sites

(Shields et al., 2002). 

Boobies and gannets are large seabirds that plunge from the air to capture their prey. Filling similar 

niches, boobies inhabit warmer areas and gannets colder regions. Boobies and gannets often nest on 

islands in colonies, with gannets nesting on cliffs (BirdLife International, 2012) and boobies generally on 

the ground if predators allow (Pratt et al., 1987). They forage offshore in large flocks at night, often 

feeding on squid.

Like tropicbirds and pelicans, members of this group all have webbed feet and eight toes, and all have a 

throat sac, called a gular sac (Brown & Harshman, 2008). This sac is highly developed and visible in 

pelicans and frigatebirds but is also readily apparent in boobies and cormorants. Pelicans use the sac to 

trap fish, frigatebirds use it as a mating display and to feed on fish, squid, and similar marine life

(Dearborn et al., 2001), and cormorants and boobies utilize the sac for heat regulation. These birds nest 

in colonies, but individual birds are monogamous (Brown & Harshman, 2008).

3.9.2.3.1.6 Tropicbirds (Order Phaethontiformes)

Tropicbirds are medium-sized seabirds, predominately white with black patterning on the back, wings, 

and face. They have thick, pointed bills that are red or orange in color that are slightly decurved. Their 

most notable feature is the extremely long and narrow central tail feathers, which can be 11 to 22 

inches (in.) long. Their wingspans average around 3 feet. Superficially, tropicbirds resemble terns. 

Tropicbirds are highly pelagic foragers in tropical and subtropical oceans, coming to land mainly to breed 

(Sibley, 2014). Tropicbirds are plunge-divers that feed on fish and could occur as rare visitors offshore in 

the Study Area in the Gulf of Mexico, Caribbean Sea, and Southeast U.S. Continental Shelf Large Marine 

Ecosystems, and in the Gulf Stream and North Atlantic Gyre Open Ocean Areas (Sibley, 2014). No birds 

from this group are considered Birds of Conservation Concern (U.S. Fish and Wildlife Service, 2008b).

3.9.2.3.1.7 Pelicans, Herons, Egrets, Ibis, and Spoonbills (Order Pelecaniformes)

Pelecaniformes is a large group composed of long-legged, large billed species that includes pelicans, 

herons, egrets, ibis, and spoonbills. However, with the exception of two species of pelicans (described 

below), they are inhabitants of freshwater marshes and are unlikely to occur in the Study Area. Five of 

these species (roseate spoonbill, reddish egret, snowy egret, American bittern, and least bittern) are 

Birds of Conservation Concern as shown in Table 3.9-4 (U.S. Fish and Wildlife Service, 2008b).

The brown pelican (Pelecanus occidentalis) primarily occurs in shallow (less than 150 ft. [46 m]) warm 

coastal marine and estuarine environments, as well as offshore where they forage primarily on fish by 

head first plunge-diving. Most plunge-diving is limited to 3.5 to 6.5 ft. (1 to 2 m) within the water 

column. Foraging occurs within 12 mi. (20 km) of nesting islands during the breeding season, and up to 

47 mi. (75 km) offshore during the nonbreeding season (Shields et al., 2002). American white pelicans 

(Pelecanus erythrorhynchos) are found in shallow coastal bays, inlets, and estuaries that support forage 

fish (Knopf & Evans, 2004). Flocks forage cooperatively, swimming and encircling fish as a coordinated 

group or driving them into shallows, where they are caught with synchronized bill dipping (Enticott & 

Tipling, 1997; Onley & Scofield, 2007).
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3.9.2.3.1.8 Flamingos (Order Phoenicopteriformes)

Flamingos are gregarious (social) wading birds in the genus Phoenicopterus, and the only genus in the 

family Phoenicopteridae. The American flamingo (P. ruber) species is found in the Study Area. The 

distribution range of the flamingo is extremely large and includes many Caribbean and South American 

countries. However, their occurrence in the United States is limited to the southern tip of Florida 

(Everglades National Park) (Sibley, 2014; Stevens & Pickett, 1994).

These wading birds forage in intertidal areas by rhythmically swinging their bills from side to side and 

filtering small organisms out of the mud (Sibley, 2014). Though most of their life cycle is spent along 

coastal areas, migration over offshore areas does occur (Elphick, 2007). They forage in shallow water, 

swinging their bill from side to side and filtering small organisms out of the mud (Sibley, 2014).

3.9.2.3.1.9 Osprey, Bald Eagles, Kites and Falcons (Orders Accipitriformes and 

Falconiformes)

Accipitriformes is a large group consisting of 60 species in three families (American Ornithologists' 

Union, 1998). This order generally has broad wings well-suited for soaring. Falconiformes include 9 

North American species that, with the exception of the caracara (Caracara cheriway), are fast flying 

predators with pointed wings and a streamline body shape (Sibley, 2014). Members of both orders hunt 

by day and feed on a variety of prey, including fish, small mammals, reptiles, and carrion. Species that 

are likely to occur within the Study Area include the osprey (Pandion haliaetus), bald eagle (Haliaeetus 

leucocephalus), peregrine falcon (Falco peregrinus), and swallow-tailed kite (Elanoides forficatus). The 

bald eagle, peregrine falcon, and swallow-tailed kite are Birds of Conservation Concern. 

Ospreys live near slow-moving waters of coastal, nearshore, and freshwater environments in many parts 

of the Study Area. They are plunge feeders but also have the ability to capture prey with their feet while 

keeping their head above water. Fish make up a large portion of their diet, and therefore, their vision is 

well adapted to detecting underwater objects from 33–131 ft. (10–40 m) above water (Poole et al., 

2002). Ospreys migrate from northern latitudes to southern latitudes twice a year and cross bodies of 

open ocean to reach their destinations (Lott, 2006).

Bald eagles nest, forage, and winter along the Atlantic coast especially in the Chesapeake Bay region.

Bald eagles also occur throughout Florida, although no bald eagle sightings have been recorded at Port 

Canaveral in 27 years (Federal Emergency Management Agency, 2012; Florida Fish and Wildlife 

Conservation Commission, 2017a). Bald eagles have steadily increased since the ban on DDT from 60 

pairs in the 1970s to 646 in 2001. The Chesapeake Bay is very important to bald eagles because it is a 

convergence point for all three geographically distinct populations (northeast, southeast, and 

Chesapeake Bay) and has played an important part in their recovery (Watts et al., 2007). Bald eagles are

opportunistic feeders that generally prefer fish over other food types (Buehler, 2000). Adults are known 

to scavenge prey items, pirate food from other species, and capture prey such as ducks from the water’s 

surface. 

Swallow-tailed kites breed in the southeastern United States but winter in South America, making longdistance migrations each year between wintering and breeding grounds. Studies in Florida show 

swallow-tailed kites feed on various animals in the following proportions: frogs (53 percent), birds 

(30 percent), and reptiles (11 percent) and the remaining prey were insects (Meyer et al., 2004).

Most peregrine falcons occur throughout the nearshore and coastal portions of the Study Area, 

particularly near barrier islands and mudflats during the winter months. Some peregrine falcons migrate 
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along the coast, cross bodies of water such as the Gulf of Mexico, and occur offshore of the Atlantic 

coast to reach their wintering/breeding territories on a yearly basis (Lott, 2006). They can reach 

altitudes up to 12,000 ft. (Cornell Lab of Ornithology, 2011). Peregrine falcons feed mostly on other 

birds, including shorebirds, ducks, grebes, gulls, and petrels. They occasionally feed on fish while in 

coastal habitats (Cornell Lab of Ornithology, 2011).

3.9.2.3.1.10 Shorebirds, Phalaropes, Gulls, Noddies, Terns, Skimmers, Skuas, Jaegers, 

and Alcids (Order Charadriiformes)

Shorebirds are small, generally long-legged coastal birds, many of which forage below the high tide in 

the surf zone by picking and probing for small aquatic prey (Sibley, 2014). Shorebirds undergo some of 

the longest distance migrations known for birds, for example, the red knot annually migrates more than 

9,300 mi. (U.S. Fish and Wildlife Service, 2005). Though most of their life cycle is spent in coastal areas, 

shorebird migration over open ocean does occur (Elphick, 2007). Although taxonomically grouped 

among some shorebirds, two species of phalaropes in the family Scolopacidae that occur within the 

Study Area are functionally seabirds, spending the nonbreeding months out on the open ocean. For 

example, the red-necked phalarope (Phalaropus lobatus) spends up to 9 months at sea, gathering in 

small flocks at upwellings and convergence zones, foraging on zooplankton and other small aquatic 

animals that rise to the surface (Rubega et al., 2000). The red phalarope ranges farthest from shore, 

spending 11 months at sea feeding on small invertebrates (Cornell Lab of Ornithology, 2002).

The Charadriiformes include shorebirds, phalaropes, gulls, noddies, terns, skimmers, skuas, jaegers, and 

alcids (Cornell Lab of Ornithology, 2009). There are 81 species from this diverse group that occur within 

the Study Area ranging from small shorebirds to large pelagic seabirds. Two endangered species under 

the ESA belong to this group, the roseate tern and piping plover (U.S. Fish and Wildlife Service, 2010a). 

Nineteen species from this group are Birds of Conservation Concern (U.S. Fish and Wildlife Service, 

2008b). Some species in this order are highly pelagic (e.g., jaegers, skuas, alcids), whereas others are 

more coastal or nearshore species (e.g., shorebirds, gulls).

Skuas and jaegers are oceanic birds that come to land only to nest. On the nesting grounds they prey on 

lemmings, small birds, and other animals; in other seasons they pirate much of their food from other 

seabirds by chasing them and forcing them to relinquish captured prey (Sibley, 2014). Representative 

species from this group include: semipalmated plover (Charadrius semipalmatus), great skua 

(Stercorarius skua), long-tailed jaeger (Stercorarius longicaudus), sooty tern (Onychoprion fuscatus), 

brown noddy (Anous stolidus), dovekie (Alle alle), common murre (Uria aalge), razorbill (Alca torda), 

long-billed murrelet (Brachyramphus perdix), Atlantic puffin (Fratercula arctica), and red phalarope 

(Phalaropus fulicarius). 

Noddies are tropical tern-like seabirds found foraging over warm, open ocean waters where they feed 

by swooping or dipping along the surface. Brown noddies breed in colonies on islands, islets, and rocky 

outcrops in warm seas. They only lay one egg a year and build their nests in trees, shrubs, cliffs, and 

manmade structures (Sibley, 2014).

Terns are generally more marine or pelagic than gulls, though some tern species do occur more 

commonly within coastal areas (e.g., least terns). Terns roost and nest in large groups on shorelines, and 

feed on small fish by plunge-diving head first from the air into the water, often beginning from a 

hovering position. They feed closer to shore when raising young during the nesting season, but venture 

farther offshore for longer periods after young have fledged (Sibley, 2014). In the North Atlantic, Gulf 
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Stream eddies attract foraging seabirds such as the sooty tern and bridled tern (Onychoprion 

anaethetus) (Bost et al., 2009).

Alcids or auks (family Alcidae), are small oceanic species that inhabit cold Northern Hemisphere seas, 

rarely wandering south into the tropics (Pratt et al., 1987). They come to land only to breed (Enticott & 

Tipling, 1997) and nest colonially in crevices or burrows. Alcids do not undergo long-distance foraging 

trips but form feeding aggregations in areas where food is concentrated, though they do not form tight 

flocks (Enticott & Tipling, 1997). All alcids use their wings to dive underwater where they feed on fishes 

and invertebrates. Auks are pursuit divers and are entirely wing-propelled rather than foot-propelled, as 

are loons and grebes, for example. Atlantic puffins can dive between 135 to 224 ft. (41 and 68 m) for 

periods of up to 1 minute (Burger & Simpson, 1986). 

The Charadriiformes influence the distribution and abundance of invertebrates, and indirectly algae, in 

rocky intertidal communities of New England (Ellis et al., 2007). Gulls are one particular group that can 

be found over land, along the coast, in nearshore, and offshore environments. The great black-backed 

gull (Larus marinus) and the herring gull (Larus argentatus) are dominant predators along the rocky 

shores throughout the North Atlantic. They forage while walking, swimming, or flying, sometimes 

dipping into the water and sometimes plunge-diving (National Audubon Society, 2015). They often feed 

on crabs, sea urchins, and mussels in the rocky intertidal habitat; once a prey item is caught, the gull will 

fly up and drop it on rocks below to break it open.

3.9.2.3.1.11 Neotropical Migrant Songbirds, Thrushes, Cuckoos, Swifts, Owls, and

Allies (Orders Passeriformes, Cuculiformes, Apodiformes and Strigiformes)

There are 185 bird species in the orders Passeriformes, Cuculiformes, Apodiformes, and Strigiformes

that are considered nocturnal migrants and neotropical migrants with a potential to occur in the Study 

Area. Twenty-one of these species are Birds of Conservation Concern as shown in Table 3.9-4 (U.S. Fish 

and Wildlife Service, 2008b). Most of these species are nocturnal migrants and take advantage of 

favorable weather conditions to migrate (Kerlinger, 2009). Oceans are typically an obstacle for this 

group of birds because most songbirds cannot swim, or even rest on the water’s surface. Migrants tend 

to avoid large water crossings and follow land to the extent possible. Migration has a substantial risk to 

birds, ranging from mass mortality events due to inclement weather events (Newton, 2007) and other 

mortality events associated with lighting of vessels (Merkel & Johansen, 2011) and oil and gas platforms

(Poot et al., 2008). In the Gulf of Mexico, long-distance migrants are commonly found stopping over and 

resting on oil and gas platforms as well as on small boats and vessels. Most neotropical migrants, 

especially warblers and thrushes from the family Parulidae and family Turdidae, cross water at some 

point twice a year to reach their wintering and breeding grounds. For example, the Bicknell’s thrush 

(Cartharus bicknelli) breeds in mountainous forests of New England and migrates across open oceans in 

the fall to reach their wintering grounds in the Caribbean. 

Aerial insect feeders such as swifts and predatory birds such as owls may feed opportunistically during 

migration across the ocean (Elphick, 2007), but the vast majority of bird species in this diverse group do 

not feed within the Study Area.

3.9.2.3.2 Bats

At least 24 species of bats are known or expected to occur in the Study Area (Table 3.9-3), either during 

migration or foraging. Additional bat species are known to occur in areas near, or adjacent to, the Study 

Area. For example, the Mexican Long-tongued bat (Choeronycteris mexicana) migrates through Central 

Mexico but avoids the Gulf of Mexico coastline, with the exception of a small area in northeastern most 
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3.9 Birds and Bats

Mexico on the border of southernmost Texas (National Park Service, 2017b). Manning et al. (2008) list 

33 bats that occur in Texas, Jones et al. (1973) list 44 bat species from Mexico’s Yucatan Peninsula, and 

Placer (1998) states that at least 21 bat species are known to occur in Jamaica. Many of these bat 

species are included in Table 3.9-3; those that are not included are expected either to not occur in the 

Study Area or to occur very infrequently, while foraging on insects or crustaceans seasonally, during 

relatively brief periods of the summer when the air is warm, the humidity is high, the wind speed is low, 

and when near forested land (Ahlén et al., 2009; Bureau of Ocean Energy Management, 2013; Johnson 

et al., 2011; U.S. Department of Energy, 2016). Given these highly restrictive circumstances and the 

dispersed nature of Navy training activities, the chance that any bat species not listed in Table 3.9-3

would interact with Navy training activities is discountable. 

As shown in Table 3.9-3, the range of some of the bat species within the Study Area is highly limited 

(e.g., to Puerto Rico), whereas the range of other bat species includes the vast portions of the Study 

Area. Most of these bat species are insectivorous, but some are frugivores (i.e., are fruit-eating), and 

one (the Mexican bulldog bat, discussed in Section 3.9.2.1.3, Dive Behavior) eats fish. In addition, some 

insectivorous bats are suspected to also eat crustaceans (Ahlén et al., 2009; Hatch et al., 2013). 

Table 3.9-3: Bats Known or Expected to Occur in the Study Area

Bat Species Presence in the Study Area

Common 

Name Scientific Name

Open Ocean 

Areas2

Large Marine 

Ecosystem2Inshore Waters

Jamaican fruit 

bat1 Artibeus jamaicensis North Atlantic Gyre Caribbean Sea, Gulf of Mexico

Antillean 

fruit-eating 

bat1

Brachyphylla 

cavernarum

North Atlantic Gyre Caribbean Sea

Big brown bat Eptesicus fuscus Gulf Stream, North 

Atlantic Gyre

Northeast 

U.S. Continental 

Shelf, Southeast 

U.S. Continental 

Shelf, Caribbean 

Sea, Gulf of 

Mexico

Sandy Hook Bay (Earle, NJ); 

Lower Chesapeake Bay 

(Hampton Roads, VA); 

Beaufort Inlet Channel 

(Morehead City, NC); Onslow 

Beach (Camp Lejeune, NC); 

Cape Fear River (Wilmington, 

NC); Seminole Beach 

(Jacksonville, FL); St. Andrew 

Bay (Panama City, FL); Sabine 

Lake (Beaumont, TX); Corpus 

Christi Bay (Corpus Christi, 

TX); 

Brown flower 

bat

Erophylla 

bombifrons None Caribbean Sea
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Table 3.9-3: Bats Known or Expected to Occur in the Study Area (continued)

Bat Species Presence in the Study Area

Common 

Name Scientific Name

Open Ocean 

Areas2

Large Marine 

Ecosystem2Inshore Waters

Silver-haired 

bat1

Lasionycteris 

noctivagans

Gulf Stream, North 

Atlantic Gyre

Scotian Shelf, 

Northeast 

U.S. Continental 

Shelf, Southeast 

U.S. Continental 

Shelf, Caribbean 

Sea, Gulf of 

Mexico

Sandy Hook Bay (Earle, NJ); 

Lower Chesapeake Bay 

(Hampton Roads, VA); 

Beaufort Inlet Channel 

(Morehead City, NC); Onslow 

Beach (Camp Lejeune, NC); 

Cape Fear River (Wilmington, 

NC)

Eastern red 

bat1

Lasiurus borealis Gulf Stream, North 

Atlantic Gyre

Scotian Shelf, 

Northeast 

U.S. Continental 

Shelf, Southeast 

U.S. Continental 

Shelf, Caribbean 

Sea, Gulf of 

Mexico

Sandy Hook Bay (Earle, NJ); 

Lower Chesapeake Bay 

(Hampton Roads, VA); 

Beaufort Inlet Channel 

(Morehead City, NC); Onslow 

Beach (Camp Lejeune, NC); 

Cape Fear River (Wilmington, 

NC); Seminole Beach 

(Jacksonville, FL); St. Andrew 

Bay (Panama City, FL); Sabine 

Lake (Beaumont, TX); Corpus 

Christi Bay (Corpus Christi, 

TX); Puerto Rico; U.S. Virgin 

Islands

Hoary bat1Lasiurus cinereus

Labrador Current, 

Gulf Stream, North 

Atlantic Gyre

NewfoundlandLabrador Shelf, 

Scotian Shelf, 

Northeast 

U.S. Continental 

Shelf, Southeast 

U.S. Continental 

Shelf, Caribbean 

Sea, Gulf of 

Mexico

Sandy Hook Bay (Earle, NJ); 

Lower Chesapeake Bay 

(Hampton Roads, VA); 

Beaufort Inlet Channel 

(Morehead City, NC); Onslow 

Beach (Camp Lejeune, NC); 

Cape Fear River (Wilmington, 

NC); Seminole Beach 

(Jacksonville, FL); St. Andrew 

Bay (Panama City, FL); Sabine 

Lake (Beaumont, TX); Corpus 

Christi Bay (Corpus Christi, 

TX); Puerto Rico; U.S. Virgin 

Islands
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Table 3.9-3: Bats Known or Expected to Occur in the Study Area (continued)

Bat Species Presence in the Study Area

Common 

Name Scientific Name

Open Ocean 

Areas2

Large Marine 

Ecosystem2Inshore Waters

Northern 

yellow bat Lasiurus intermedius None

Northeast 

U.S. Continental 

Shelf, Southeast 

U.S. Continental 

Shelf, Caribbean 

Sea, Gulf of 

Mexico

Sandy Hook Bay (Earle, NJ); 

Lower Chesapeake Bay 

(Hampton Roads, VA); 

Beaufort Inlet Channel 

(Morehead City, NC); Onslow 

Beach (Camp Lejeune, NC); 

Cape Fear River (Wilmington, 

NC); Seminole Beach 

(Jacksonville, FL); St. Andrew 

Bay (Panama City, FL); Sabine 

Lake (Beaumont, TX); Corpus 

Christi Bay (Corpus Christi, TX)

Minor red 

bat1

Lasiurus minor None Caribbean Sea Puerto Rico

Seminole bat1Lasiurus seminolus Gulf Stream, North 

Atlantic Gyre

Northeast 

U.S. Continental 

Shelf, Southeast 

U.S. Continental 

Shelf, Caribbean 

Sea, Gulf of 

Mexico

Lower Chesapeake Bay 

(Hampton Roads, VA); 

Beaufort Inlet Channel 

(Morehead City, NC); Onslow 

Beach (Camp Lejeune, NC); 

Cape Fear River (Wilmington, 

NC); Seminole Beach 

(Jacksonville, FL); St. Andrew 

Bay (Panama City, FL); Sabine 

Lake (Beaumont, TX)

Pallas's 

mastiff bat or 

Pallas's freetailed bat

Molossus molossus North Atlantic Gyre

Southeast U.S. 

Continental Shelf, 

Caribbean Sea, 

Gulf of Mexico

Leach's single 

leaf bat1

Monophyllus 

redmani None Caribbean Sea

Antillean

ghostfaced

bat1

Mormoops 

blainvillei None Caribbean Sea

Ghostfaced

bat

Mormoops 

megalophylla None Caribbean Sea, Gulf of Mexico

Corpus Christi Bay (Corpus 

Christi, TX)

Southeastern 

myotis bat

Myotis

austroriparius None

Southeast 

U.S. Continental 

Shelf, Caribbean 

Sea, Gulf of 

Mexico

Onslow Beach (Camp Lejeune, 

NC); Cape Fear River 

(Wilmington, NC); Seminole 

Beach (Jacksonville, FL); St. 

Andrew Bay (Panama City, FL)

Eastern smallfooted bat Myotis leibii None

Northeast 

U.S. Continental 

Shelf

Sandy Hook Bay (Earle, NJ)
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Table 3.9-3: Bats Known or Expected to Occur in the Study Area (continued)

Bat Species Presence in the Study Area

Common 

Name Scientific Name

Open Ocean 

Areas2

Large Marine 

Ecosystem2Inshore Waters

Little brown 

bat Myotis lucifugus Gulf Stream

NewfoundlandLabrador Shelf, 

Scotian Shelf, 

Northeast 

U.S. Continental 

Shelf, Southeast 

U.S. Continental 

Shelf, Gulf of 

Mexico

Sandy Hook Bay (Earle, NJ); 

Lower Chesapeake Bay 

(Hampton Roads, VA);

Seminole Beach (Jacksonville, 

FL); St. Andrew Bay (Panama 

City, FL)

Evening bat Nycticeius humeralis None

Northeast 

U.S. Continental 

Shelf, Southeast 

U.S. Continental 

Shelf, Caribbean 

Sea, Gulf of 

Mexico

Lower Chesapeake Bay 

(Hampton Roads, VA); 

Beaufort Inlet Channel 

(Morehead City, NC); Onslow 

Beach (Camp Lejeune, NC); 

Cape Fear River (Wilmington, 

NC); Seminole Beach 

(Jacksonville, FL); St. Andrew 

Bay (Panama City, FL); Sabine 

Lake (Beaumont, TX); Corpus 

Christi Bay (Corpus Christi, TX)

Mexican freetailed bat Tadarida brasiliensis Gulf Stream, North 

Atlantic Gyre

Southeast 

U.S. Continental 

Shelf, Caribbean 

Sea, Gulf of 

Mexico

Seminole Beach (Jacksonville, 

FL); St. Andrew Bay (Panama 

City, FL); Sabine Lake 

(Beaumont, TX); Corpus 

Christi Bay (Corpus Christi, 

TX), Puerto Rico; U.S. Virgin 

Islands

Mexican 

bulldog bat or 

greater 

bulldog bat

Noctilio leporinus None Caribbean Sea, 

Gulf of Mexico

Rafinesque's 

big-eared bat Plecotus rafinesquii None

Northeast 

U.S. Continental 

Shelf, Southeast 

U.S. Continental 

Shelf, Caribbean 

Sea, Gulf of 

Mexico

Beaufort Inlet Channel 

(Morehead City, NC); Onslow 

Beach (Camp Lejeune, NC); 

Cape Fear River (Wilmington, 

NC); Seminole Beach 

(Jacksonville, FL); St. Andrew 

Bay (Panama City, FL); Sabine 

Lake (Beaumont, TX)

Parnell's 

moustached 

bat

Pteronotus parnellii None Caribbean Sea
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Table 3.9-3: Bats Known or Expected to Occur in the Study Area (continued)

Bat Species Presence in the Study Area

Common 

Name Scientific Name

Open Ocean 

Areas2

Large Marine 

Ecosystem2Inshore Waters

Sooty 

moustached 

bats

Pteronotus 

quadridens None Caribbean Sea

Red fruit bat Stenoderma rufum None Caribbean Sea

1Has also been reported on Bermuda during the migration season (Pelletier et al., 2013).

Bold font indicates the species migrates long distances. 

Sources: (Constantine, 2003; International Union for Conservation of Nature, 2017; Placer, 1998; Tetra Tech Inc, 2016e).

In temperate North America, most species that roost in trees, such as hoary bats, migrate south for 

winter when insects become scarce. In the fall, hundreds of hoary bats from across the United States

gather along the coasts and in northern Mexico. Mexican free-tailed bats that roost in Carlsbad 

Caverns during the summer also migrate to Mexico over winter (National Park Service, 2017a).

The Navy has performed bat surveys (both mist-netting and passive acoustic surveys) at several 

installations along the eastern coast of the United States. Results of these surveys are described below. 

Since echolocation calls for eastern red bats and Seminole bats are indistinguishable from each other, 

survey results combine these two species. In addition, it typically is not possible to identify specific 

species from passive acoustic survey recordings of Myotis species, and occasionally it is not possible to 

make a determination more specific than “high frequency call.”

 Cutler, Maine:

o All seven bat species expected to occur in Maine that are not federally listed are known 

to occur at Naval Support Activity Cutler: little brown bat, eastern small-footed bat, tricolored bat, silver-haired bat, big brown bat, eastern red bat, and hoary bat (Tetra Tech 

Inc, 2014). 

o Little brown bats were the most frequently detected species and occurred across the 

installation at all acoustic sites during the 2013 survey. Eastern red bat was the second 

most common species recorded at the Installation, and occurred across all sites. Silverhaired bats and the eastern red bat are known to be active from late April through midOctober, big brown bats from late March through early October, and hoary bats from 

early May through early October.

o The installation provides the local bat community with habitat from the late spring to 

late fall. The data also suggests that bats are utilizing habitat and traveling closer to the 

coast within forested and edge habitats.

o The occurrence of migratory bat species during the summer season indicates that longdistance migratory tree-roosting bats spent the summer residency period at the 

installation. Data also suggests that long-distance migrants move through the

installation during the fall. 

 Colts Neck, New Jersey

o Baseline bat survey at NWS Earle acoustically documented activity of eight different bat 

species, including big brown bat, eastern red bat, hoary bat, silver-haired bat, little 
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brown bat, eastern small-footed bat, northern long-eared bat, and tri-colored bat. Mistnet surveys further confirmed the presence of big brown bats, eastern red bat, and 

northern long-eared bat (Tetra Tech Inc, 2016d).

 Norfolk and Portsmouth, Virginia:

o At Naval Station Norfolk and Naval Supply Center Craney Island Fuel Terminal at Norfolk 

and Portsmouth, Virginia, mist-netting surveys captured eastern red bats (Lasiurus 

borealis). Approximately 75% of acoustic detections were identified as eastern red 

bats/Seminole bats; the remainder were mostly designated as “high frequency” bats. 

Manual review of all tri-colored bat passes were determined to not contain enough 

detail to accurately identify to species (Tetra Tech Inc, 2017a).

 Virginia Beach, Virginia:

o Surveys at Naval Air Station Oceana in Virginia Beach, Virginia detected nine bat species 

not listed under the ESA: Rafinesque's big-eared bat, big brown bat, eastern 

red/seminole bat, hoary bat, silver-haired bat, southeastern bat, little brown bat, 

evening bat, and tri-colored bat (Tetra Tech Inc, 2016c). Big brown bats were the most 

commonly recorded, accounting for 50 percent of the total calls, followed by silverhaired bats (24 percent), eastern red bats/Seminole bats (11 percent), hoary bats (4 

percent), and Myotis sp. bats (4 percent). Species with 2 percent or less of the total calls 

were little brown bats, southeastern bats, Rafinesque’s big-eared bats, evening bats, tricolored bats, and high frequency bats. 

o Surveys at JEB Fort Story on the coast acoustically documented activity of at least ten 

different species of bats including Rafinesque’s big-eared bat, big brown bat, eastern 

red/Seminole bat, hoary bat, silver-haired bat, southeastern myotis, little brown bat, 

northern long-eared bat, evening bat, and tri-colored bat. Eastern red bats, however,

are very common and Seminole bats only occur occasionally in Virginia. The overall

activity rate at JEB Fort Story was the highest detected at the four Navy bases surveyed 

in Virginia (Tetra Tech Inc, 2016a).

3.9.2.3.3 Migratory Birds

A variety of bird species would be encountered in the Study Area including those listed under the 

Migratory Bird Treaty Act (U.S. Fish and Wildlife Service, 2010d). The Migratory Bird Treaty Act 

established federal responsibilities for protecting nearly all migratory species of birds, eggs, and nests. 

Migratory bird means any bird, whatever its origin and whether or not raised in captivity, which belongs 

to a species listed in Section 10.13 of the Migratory Bird Treaty Act, or which is a mutation or a hybrid of 

any such species, including any part, nest, or egg of any such bird, or any product, whether or not 

manufactured, which consists, or is composed in whole or part, of any such bird or any part, nest, or egg 

thereof. Bird migration is defined as the periodic seasonal movement of birds from one geographic 

region to another, typically coinciding with available food supplies or breeding seasons. Under the 

Migratory Bird Treaty Act regulations applicable to military readiness activities (50 Code of Federal 

Regulations [CFR] Part 21), the USFWS has promulgated a rule that authorizes the incidental take of 

migratory birds provided they do not result in a significant impact to a population of a migratory seabird 

species. Of the 1,026 species protected under the Migratory Bird Treaty Act (U.S. Fish and Wildlife 

Service, 2013b), over 100 species occur in the Study Area. These species are not analyzed individually, 

but rather are grouped based on taxonomic or behavioral similarities based on the stressor that is being 
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3.9 Birds and Bats

analyzed. Conclusions of potential impacts on species protected under the Migratory Bird Treaty Act are 

presented at the conclusion of each stressor subsection as well as in Section 3.9.4 (Summary of Potential 

Impacts on Birds).

Birds of Conservation Concern are species, subspecies, and populations of migratory birds that the 

USFWS determined to be the highest priority for conservation actions (U.S. Fish and Wildlife Service, 

2008b). The purpose of the Birds of Conservation Concern list is to prevent or remove the need for 

additional ESA bird listings by implementing proactive management and conservation actions needed to 

conserve these species. Of the speciesthat occur within the Study Area, 62 are considered Birds of 

Conservation Concern (Table 3.9-4). With the exception of the black-capped petrel, a species that is

under review and could be proposed for listing under the ESA in the near future (see below), and the

bald eagle, these species are not analyzed individually, but rather are grouped by taxonomic or 

behavioral similarities based on the stressor being analyzed.

Table 3.9-4: Birds of Conservation Concern that Occur within the Study Area

Order/Family Common Name Scientific Name

Order Gaviiformes

Family Gaviidae

Common loon Gavia immer

Red-throated loon Gavia stellata

Order Podicipediformes

Family Podicipedidae

Horned grebe Podiceps auritus

Pied billed grebe Podilymbus podiceps

Order Procellariiformes

Family Procellariidae

Audubon’s shearwater Puffinus lherminieri

Black-capped petrel Pterodroma hasitata

Greater shearwater Puffinus gravis

Family Hydrobatidae

Band-rumped storm petrel Oceanodroma castro

Order Sulifromes

Family Sulidae

Brown booby Sula leucogaster

Masked booby Sula dactylatra

Family Phalacrocoracidae

Great cormorant Phalacrocorax carbo

Family Frigatidae

Magnificent frigatebird Fregata magnificens

Order Pelecaniformes

Family Threskiornithidae

Roseate spoonbill Platalea ajaja

Family Ardeidae
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Table 3.9-4: Birds of Conservation Concern that Occur within the Study Area (continued)

Order/Family Common Name Scientific Name

Reddish egret Egretta rufescens

Snowy egret Egretta thula

American bittern Botarus lentiginous

Least bittern Ixobrychus exilis

Order Falconiformes

Family Falconidae

Family Haematopodidae

American oystercatcher Haematopus palliatus

Family Scolopacidae

Subfamily Scolopacinae

Bar-tailed godwit Limosa lapponica

Dunlin Calidris alpina

Hudsonian godwit Limosa haemastica

Lesser yellowlegs Tringa flavipes

Marbled godwit Limosa fedoa

Purple sandpiper Calidris maritima

Red knot Calidris canutus

Semipalmated sandpiper Calidris pusilla

Short-billed dowitcher Limnodromus griseus

Solitary sandpiper Tringa solitaria

Whimbrel Numenius phaeopus

Family Laridae

Subfamily Rynchopinae Black skimmer Rynchops niger

Subfamily Sterninae

Arctic tern Sterna paradisaea

Gull-billed tern Gelochelidon nilotica

Least tern Sternula antillarum

Sandwich tern Thalasseus sandvicensis

Order Passeriformes

Family Emberizidae

Saltmarsh sparrow Ammodramus caudacutus

Seaside sparrow Ammodramus maritimus

Family Tyrannidae

Olive-sided flycatcher Contopus cooperi

Family Turdidae 

Bicknell’s thrush Catharus bicknelli

Wood thrush Hylocichla mustelina

Family Parulidae

Bay-breasted warbler Dendroica castanea

Blue-winged warbler Vermivora pinus

Canada warbler Wilsonia canadensis

Cerulean warbler Dendroica cerulea

Golden-winged warbler Vermivora chrysoptera

Kentucky warbler Oporornis formosus

Prairie warbler Dendroica discolor

Prothonotary warbler Protonotaria citrea

Swainson’s warbler Limnothlypis swainsonii

Worm-eating warbler Helmitheros vermivorum
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Table 3.9-4: Birds of Conservation Concern that Occur within the Study Area (continued)

Order/Family Common Name Scientific Name

Family Cardinalidae

Dickcissel Spiza americana

Painted bunting Passerina ciris

Order Cuculiformes

Family Cuculidae

Mangrove cuckoo Coccyzus minor

Yellow-billed cuckoo Coccyzus americanus

Order Strigiformes

Family Strigiformes

Short-eared owl Asio flammeus

Order Apodiformes

Family Apodidae

Black swift Cypseloides niger

3.9.3 ENVIRONMENTAL CONSEQUENCES

This section evaluates how and to what degree the activities described in Chapter 2 (Description of 

Proposed Action and Alternatives) potentially impact birds or bats known to occur within the Study 

Area. Tables 2.3-1 through 2.3-5 present the baseline and proposed typical training and testing activity 

locations for each alternative (including number of events). General characteristics of all Navy stressors 

were introduced in Section 3.0.3.3 (Identifying Stressors for Analysis), and living resources’ general 

susceptibilities to stressors were introduced in Section 3.0.3.6 (Biological Resource Methods). The 

stressors vary in intensity, frequency, duration, and location within the Study Area. The stressors 

analyzed for birds and bats are:

 Acoustics (sonar and other transducers; air guns; pile driving; aircraft noise; vessel noise; and 

weapons noise);

 Explosives (explosions in-air, explosions in-water);

 Energy (in-water electromagnetic devices, in-air electromagnetic devices; and high energy 

lasers);

 Physical disturbance and strikes (vessels & in-water devices, aircraft & aerial targets, military 

expended materials, seafloor devices);

 Entanglement (wires and cables; decelerators/parachutes; biodegradable polymers);

 Ingestion (military expended materials – munitions, military expended materials - other than 

munitions); and

 Secondary stressors (impacts to habitat, impacts to prey availability).

Each of these components is analyzed for potential impacts on birds and bats within the stressor 

categories contained in this section. The specific analysis of the training and testing activities considers 

these components within the context of geographic location and overlap of marine bird resources and 

bat occurrence. In addition to the analysis here, the details of all training and testing activities, stressors, 

components that cause the stressor, and geographic overlap within the Study Area are summarized in 

Section 3.0.3.3 (Identifying Stressors for Analysis) and detailed in Appendix B (Activity Stressor 

Matrices).
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3.9.3.1 Acoustic Stressors

This section evaluates the potential for acoustic stressors to impact birds and bats during training and 

testing activities in the Study Area. Assessing whether sounds may disturb or injure an animal involves 

understanding the characteristics of the acoustic sources, the animals that may be present in the vicinity 

of the sound, and the effects that sound may have on the physiology and behavior of those animals. 

Impacts could depend on other factors besides the received level of sound, such as the animal's physical 

condition, prior experience with the sound, and proximity to the source of the sound. 

The below analysis of effects to birds and bats follows the concepts outlined in Section 3.0.3.6.1 

(Conceptual Framework for Assessing Effects from Acoustic and Explosive Activities). This section begins 

with a summary of relevant data regarding acoustic impacts to birds and bats in Section 3.9.3.1.1

(Background). This is followed by an analysis of impacts to birds and bats due to specific Navy acoustic 

stressors (sonar and other transducers; air guns; pile driving; vessel noise; aircraft noise; and weapons 

noise). Additional explanation of the acoustic terms and sound energy concepts used in this section is 

found in Appendix D (Acoustic and Explosive Concepts).

3.9.3.1.1 Background

The sections below include a survey and synthesis of best-available-science published in peer-reviewed 

journals, technical reports, and other scientific sources pertinent to impacts to birds and bats potentially 

resulting from sound-producing Navy training and testing activities. Impacts to birds and bats depend on 

the sound source and context of exposure. Possible impacts include auditory or non-auditory trauma, 

hearing loss resulting in temporary or permanent hearing threshold shift, auditory masking, 

physiological stress, or changes in behavior, including changing habitat use and activity patterns, 

increasing stress response, decreasing immune response, reducing reproductive success, increasing 

predation risk, and degrading communication, (Larkin et al., 1996). Numerous studies have documented 

that birds and other wild animals respond to human-made noise (Bowles et al., 1994; Larkin et al., 1996; 

National Park Service, 1994). The manner in which birds or bats respond to noise could depend on 

species physiology, life stage, characteristics of the noise source, loudness, onset rate, distance from the 

noise source, presence/absence of associated visual stimuli, and previous exposure. Noise may cause 

physiological or behavioral responses that reduce the animals’ fitness or ability to grow, survive, and 

reproduce successfully. 

The types of birds and bats exposed to sound-producing activities depend on where training and testing 

activities occur. Birds in the Study Area can be divided into three groups based on breeding and foraging 

habitat: (1) those species such as albatrosses, petrels, frigatebirds, tropicbirds, boobies, alcids, and some 

terns that forage over the ocean and nest on oceanic islands; (2) species such as pelicans, cormorants, 

gulls, and some terns that nest along the coast and forage in nearshore areas; and (3) those few species 

such as skuas, jaegers, Franklin’s gull, Bonaparte’s gulls, ring-billed gulls, black terns, and ducks and 

loons that nest and forage in inland habitats and come to the coastal areas during nonbreeding seasons. 

In addition, birds that are typically found inland, such as songbirds, may be present flying in large 

numbers over open ocean areas (particularly over the Gulf of Mexico) during annual spring and fall 

migration periods. Bats in the Study Area that have the potential to be exposed to sound-producing 

activities from training and testing would be those that occur in coastal or offshore waters, or those that 

migrate over open ocean areas. 

Birds and bats could be exposed to sounds from a variety of sources. While above the water surface, 

birds and bats may be exposed to airborne sources such as pile driving, weapons noise, vessel noise, and 
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aircraft noise. While foraging and diving, birds may be exposed to underwater sources such as sonar, 

pile driving, air guns, and vessel noise. In addition, bats are typically nocturnal and would likely be 

exposed only to sources of noise from activities that occur between dusk and dawn. While foraging birds 

will be present near the water surface, migrating birds may fly at various altitudes. Some species such as 

sea ducks and loons may be commonly seen flying just above the water's surface, but the same species 

can also be spotted flying high enough (5800 ft.) that they are barely visible through binoculars (Lincoln 

et al., 1998). While there is considerable variation, the favored altitude for most small birds appears to 

be between 500 ft. (152 m) and 1,000 ft. (305 m). Radar studies have demonstrated that 95 percent of 

the migratory movements occur at less than 10,000 ft. (3,050 m), with the bulk of the movements 

occurring under 3,000 ft. (914 m) (Lincoln et al., 1998). While several studies have shown that bats 

typically fly lower than 10 m above sea level (Ahlén et al., 2009; Pelletier et al., 2013), others have 

shown that migrating bats have been observed over 200 m above sea level (Hatch et al., 2013; Sjollema 

et al., 2014).

Seabirds use a variety of foraging behaviors that could expose them to underwater sound. Most seabirds 

plunge-dive from the air into the water or perform aerial dipping (the act of taking food from the water 

surface in flight); others surface-dip (swimming and then dipping to pick up items below the surface) or 

jump-plunge (swimming, then jumping upward and diving underwater). Birds that feed at the surface by 

surface or aerial dipping with limited to no underwater exposure include petrels, jaegers, and 

phalaropes. Birds that plunge-dive are typically submerged for short durations, and any exposure to 

underwater sound would be very brief. Birds that plunge-dive include albatrosses, some tern species, 

masked boobies, gannets, shearwaters, and tropicbirds. Some birds, such as cormorants, seaducks, 

alcids, and loons pursue prey under the surface, swimming deeper and staying underwater longer than 

other plunge-divers. Some of these birds may stay underwater for up to several minutes and reach 

depths between 50 ft. (15 m) and 550 ft. (168 m) (Alderfer, 2003; Durant et al., 2003; Jones, 2001; Lin, 

2002; Ronconi, 2001). Birds that forage near the surface would be exposed to underwater sound for 

shorter periods of time than those that forage below the surface. Exposures of birds that forage below 

the surface may be reduced by destructive interference of reflected sound waves near the water surface 

(see Appendix D, Acoustic and Explosive Concepts). Sounds generated underwater during training and 

testing would be more likely to impact birds that pursue prey under the surface, although as previously 

stated, little is known about seabird hearing ability underwater.

3.9.3.1.1.1 Injury

Auditory structures can be susceptible to direct mechanical injury due to high levels of impulsive sound. 

This could include tympanic membrane rupture, disarticulation of the middle ear ossicles, and trauma to 

the inner ear structures such as the hair cells within the organ of Corti. Auditory trauma differs from 

auditory fatigue in that the latter involves the overstimulation of the auditory system, rather than direct 

mechanical damage, which may result in hearing loss (see Section 3.9.3.1.1.2, Hearing Loss). There are 

no data on damage to the middle ear structures of birds due to acoustic exposures. Because birds are 

known to regenerate auditory hair cells, studies have been conducted to purposely expose birds to very 

high sound exposure levels (SELs) in order to induce hair cell damage in the inner ear. Because damage 

can co-occur with fatiguing exposures at high SELs, effects to hair cells are discussed below in Section 

3.9.3.1.1.2 (Hearing Loss).

Because there is no data on non-auditory injury to birds from intense non-explosive sound sources, it 

may be useful to consider information for other similar-sized vertebrates. The rapid large pressure

change near non-explosive impulsive underwater sound sources, such as some large air guns and pile 
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driving, are thought to be potentially injurious to other small animals (fishes and sea turtles). While long 

duration exposures (i.e., minutes to hours) to high sound levels of sonars are thought to be injurious to 

fishes, this has not been experimentally observed [see Popper et al. (2014)]. Potential for injury is 

generally attributed to compression and expansion of body gas cavities, either due to rapid onset of 

pressure changes or resonance (enhanced oscillation of a cavity at its natural frequency). Because water 

is considered incompressible and animal tissue is generally of similar density as water, animals would be 

more susceptible to injury from a high-amplitude sound source in water than in air since waves would 

pass directly through the body rather than being reflected. Proximal exposures to high-amplitude nonimpulsive sounds underwater could be limited by a bird’s surfacing response.

In air, the risk of barotrauma would be associated with high-amplitude impulses, such as from explosives 

(discussed in Section 3.9.3.2, Explosive Stressors). Unlike in water, most acoustic energy will reflect off 

the surface of an animal’s body in air. Plus, air is compressible whereas water is not, allowing energy to 

dissipate more rapidly. For these reasons, in-air non-explosive sound sources in this analysis are 

considered to pose little risk of non-auditory injury. 

Limited data exists on instances of barotrauma to bats. The data that does exist has investigated the 

hypothesis of rapid pressure changes due to rotating wind turbine blades (Baerwald et al., 2008; Rollins 

et al., 2012). Bats in these situations have been shown to have ruptured tympana. Although it is 

undetermined if these ruptures were due to pressure changes or to direct strike, the potential exists for 

auditory injury as a result of high-amplitude sound exposure.

3.9.3.1.1.2 Hearing Loss

Exposure to intense sound may result in hearing loss which persists after cessation of the noise 

exposure. Hearing loss may be temporary or permanent, depending on factors such as the exposure 

frequency, received sound pressure level (SPL), temporal pattern, and duration. Hearing loss could 

impair a bird’s or a bat’s ability to hear biologically important sounds within the affected frequency 

range. Biologically important sounds come from social groups, potential mates, offspring, or parents; 

environmental sounds, prey, and predators. 

Because in-air measures of hearing loss and recovery in birds due to an acoustic exposure are limited 

[e.g., quail, budgerigars, canaries, and zebra finches (Ryals et al., 1999); budgerigar (Hashino et al., 

1988); parakeet (Saunders & Dooling, 1974); quail (Niemiec et al., 1994)] and no studies exist of bird 

hearing loss due to underwater sound exposures, auditory threshold shift in birds is considered to be 

consistent with general knowledge about noise-induced hearing loss described in the Conceptual 

Framework for Assessing Effects from Acoustic and Explosive Activities (see Section 3.0.3.6.1). The 

frequencies affected by hearing loss would vary depending on the exposure frequency. The limited data 

on hearing loss in birds shows that the frequency of exposure is the hearing frequency most likely to be 

affected (Saunders & Dooling, 1974). 

Hearing loss can be due to biochemical (fatiguing) processes or tissue damage. Tissue damage can 

include damage to the auditory hair cells and their underlying support cells. Hair cell damage has been 

observed in birds exposed to long-duration sounds that resulted in initial threshold shifts greater than 

40 dB (Niemiec et al., 1994; Ryals et al., 1999). Unlike many other animals, birds have the ability to 

regenerate hair cells in the ear, usually resulting in considerable anatomical, physiological, and 

behavioral recovery within several weeks (Rubel et al., 2013; Ryals et al., 1999). Still, intense exposures 

are not always fully recoverable, even over periods up to a year after exposure, and damage and 

subsequent recovery vary significantly by species (Ryals et al., 1999). Birds may be able to protect 
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themselves against damage from sustained sound exposures by reducing middle ear pressure, an ability 

that may protect ears while in flight (Ryals et al., 1999) and from injury due to pressure changes during 

diving (Dooling & Therrien, 2012).

Hearing loss is typically quantified in terms of threshold shift—the amount (in dB) that hearing 

thresholds at one or more specified frequencies are elevated, compared to their pre-exposure values, at 

some specific time after the noise exposure. The amount of threshold shift measured usually decreases 

with increasing recovery time—the amount of time that has elapsed since a noise exposure. If the 

threshold shift eventually returns to zero (i.e., the hearing threshold returns to the pre-exposure value), 

the threshold shift is called a temporary threshold shift (TTS). If the threshold shift does not completely 

recover (the threshold remains elevated compared to the pre-exposure value), the remaining threshold 

shift is called a permanent threshold shift (PTS). By definition, TTS is a function of the recovery time, 

therefore comparing the severity of noise exposures based on the amount of induced TTS can only be 

done if the recovery times are also considered. For example, a 20-dB TTS measured 24-h post-exposure 

indicates a more hazardous exposure than one producing 20 dB of TTS measured only 2 min after 

exposure; if the TTS is 20 dB after 24 h, the TTS measured after 2 min would have likely been much 

higher. Conversely, if 20 dB of TTS was measured after 2 min, the TTS measured after 24 h would likely 

have been much smaller. 

Studies in mammals have revealed that noise exposures resulting in high levels of TTS (greater than 40 

dB) may also result in neural injury without any permanent hearing loss (Kujawa & Liberman, 2009; Lin 

et al., 2011). It is unknown if a similar effect would be observed for birds.

Hearing Loss due to Non-Impulsive Sounds

Birds

Behavioral studies of threshold shift in birds within their frequencies of best hearing (between 2 and 4 

kHz) due to long-duration (30 minutes to 72 hours) continuous, non-impulsive, high-level sound 

exposures in air have shown that susceptibility to hearing loss varies substantially by species, even in 

species with similar auditory sensitivities, hearing ranges, and body size (Niemiec et al., 1994; Ryals et 

al., 1999; Saunders & Dooling, 1974). For example, Ryals et al. (1999) conducted the same exposure 

experiment on quail and budgerigars, which have very similar audiograms. A 12-hour exposure to a 2.86 

kHz tone at 112 dB re 20 μPa SPL [cumulative SEL of 158 dB re 20 μPa2s] resulted in a 70 dB threshold 

shift measured after 24 hours of recovery in quail, but a substantially lower 40 dB threshold shift 

measured after just 12 hours of recovery in budgerigars which recovered to within 10 dB of baseline 

after three days and fully recovered by one month (Ryals et al., 1999). Although not directly comparable, 

this SPL would be perceived as extremely loud but just under the threshold of pain for humans per the 

American Speech-Language-Hearing Association. Whereas the 158 dB re 20 μPa2-s SEL tonal exposure to 

quail discussed above caused 20 dB of PTS (Ryals et al., 1999), a shorter (4-hour) tonal exposure to quail 

with similar SEL (157 dB re 20 μPa

2

-s) caused 65 dB of threshold shift that fully recovered within two 

weeks (Niemiec et al., 1994). 

Data on threshold shift in birds due to relatively short-duration sound exposures that could be used to 

estimate the onset of threshold shift is limited. Saunders and Dooling (1974) provide the only threshold 

shift growth data measured for birds. Saunders and Dooling (1974) exposed young budgerigars to four 

levels of continuous 1/3-octave band noise (76, 86, 96, and 106 dB re 20 μPa) centered at 2.0 kHz and 

measured the threshold shift at various time intervals during the 72-hour exposure. The earliest 

measurement found 7 dB of threshold shift after approximately 20 minutes of exposure to the 96 dB re 
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20 μPa SPL noise (127 dB re 20 μPa2-s SEL). Generally, onset of TTS in other species has been considered 

6 dB above measured threshold (Finneran, 2015), which accounts for natural variability in auditory 

thresholds. The Saunders and Dooling (1974) budgerigar data is the only bird data showing low levels of 

threshold shift. Because of the observed variability of threshold shift susceptibility among bird species 

and the relatively long duration of sound exposure in Saunders and Dooling (1974), the observed onset 

level cannot be assumed to represent the SEL that would cause onset of TTS for other bird species or for 

shorter-duration exposures (i.e., a higher SEL may be required to induce TTS for shorter-duration 

exposures).

Since the goal of most bird hearing studies has been to induce hair cell damage to study regeneration 

and recovery, exposure durations were purposely long. Studies with other non-avian species have 

shown that long-duration exposures tend to produce more threshold shift than short-duration 

exposures with the same SEL [e.g., see Finneran (2015)]. The SELs that induced TTS and PTS in these 

studies likely over-estimate the potential for hearing loss due to any short-duration sound of 

comparable SEL that a bird could encounter outside of a controlled laboratory setting. In addition, these 

studies were not designed to determine the exposure levels associated with the onset of any threshold 

shift or to determine the lowest SEL that may result in PTS.

With insufficient data to determine PTS onset for birds due to a non-impulsive exposure, data from 

other taxa are considered. Studies of terrestrial mammals suggest that 40 dB of threshold shift is a 

reasonable estimate of where PTS onset may begin [see (Southall et al., 2009)]. Similar amounts of 

threshold shift has been observed in some bird studies with no subsequent PTS. Of the birds studied, the 

budgerigars showed intermediate susceptibility to threshold shift; the budgerigars exhibited threshold 

shifts in the range of 40 dB to 50 dB after 12-hour exposures to 112 dB and 118 dB re 20 μPa SPL tones 

at 2.86 kHz (158 – 164 dB re 20 μPa2-s SEL), which recovered to within 10 dB of baseline after three days 

and fully recovered by one month (Ryals et al., 1999). These experimental SELs are a conservative 

estimate of the SEL above which PTS may be considered possible for birds.

All of the above studies were conducted in air. There are no studies of hearing loss to diving birds due to 

underwater exposures.

Bats

Bats exposed to loud noise have not been shown to exhibit TTS (Hom et al., 2016; Simmons et al., 2015; 

Simmons et al., 2016). Recently, Hom et al. (2016) exposed four big brown bats (Eptesicus fuscus) to 

intense broadband noise (10—100 kHz with SEL 152 dB re 20 μPa2-s over 1 hour) and found no effect on 

the bats’ vocalizations (which could indicate a change in hearing) or psychophysical thresholds 20 

minutes, 24 hours, or 48 hours after exposure (Hom et al., 2016; Simmons et al., 2016). Another study 

on the Japanese house bat (Pipistrellus abramus) measured physiological (auditory brainstem response) 

thresholds immediately after a noise exposure (10—80 kHz, 90 dB re 20 μPa SPL, 30 minute duration) 

and also did not find evidence of TTS (Simmons et al., 2015). This may be because bats are adapted to 

hear in an acoustic environment where they are likely to experience loud sounds (110-140 dB re 20 μPa

SPL) continuously for several hours while hunting near other bats that are also echolocating (Jakobsen et 

al., 2013; Simmons et al., 2001). It is also possible that the stimuli used in these experiments were not 

loud enough to induce TTS or that measurements of hearing sensitivity took place outside the time 

window where TTS might be observed.
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Hearing Loss due to Impulsive Sounds

The only measure of hearing loss in a bird due to an impulsive noise exposure was conducted by Hashino 

et al. (1988), in which budgerigars were exposed to the firing of a pistol with a received level of 169 dB 

re 20 μPa peak SPL (two gunshots per each ear); SELs were not provided. While the gunshot frequency 

power spectrum had its peak at 2.8 kHz, threshold shift was most extensive below 1 kHz. Threshold shift 

recovered at frequencies above 1 kHz, while a 24 dB PTS was sustained at frequencies below 1 kHz. 

Studies of hearing loss in diving birds exposed to impulsive sounds underwater do not exist.

Because there is only one study of hearing loss in birds due to an impulsive exposure and no studies of 

hearing loss in bats due to an impulsive exposure, the few studies of hearing loss in birds and bats due 

to exposures to non-impulsive sound are the only other data upon which to assess bird and bat 

susceptibility to hearing loss from an impulsive sound source. Data from other taxa (U.S. Department of 

the Navy, 2017) indicate that, for the same SEL, impulsive exposures are more likely to result in hearing 

loss than non-impulsive exposures. This is due to the high peak pressures and rapid pressure rise times 

associated with impulsive exposures.

3.9.3.1.1.3 Masking

Masking occurs when one sound, distinguished as the ‘noise,’ interferes with the detection or 

recognition of another sound. The quantitative definition of masking is the amount in decibels an 

auditory detection or discrimination threshold is raised in the presence of a masker (Erbe et al., 2016). 

As discussed in Section 3.0.3.6.1 (Conceptual Framework for Assessing Effects from Acoustic and 

Explosive Stressors), masking can effectively limit the distance over which an animal can communicate 

and detect biologically relevant sounds. Masking only occurs in the presence of the masking noise and 

does not persist after the cessation of the noise.

Birds

Critical ratios are the lowest ratio of signal-to-noise at which a signal can be detected. When expressed 

in decibels, critical ratios can easily be calculated by subtracting the noise level (in dB re 1 Pa2/Hz) 

from the signal level (in dB re 1 Pa) at detection threshold. A signal must be received above the critical 

ratio at a given frequency to be detectable by an animal. Critical ratios have been determined for a 

variety of bird species [e.g., Dooling (1980), Noirot et al. (2011), Dooling and Popper (2000), and Crowell 

(2016)] and inter-species variability is evident. Some birds exhibit low critical ratios at certain vocal 

frequencies, perhaps indicating that hearing evolved to detect signals in noisy environments or over 

long distances (Dooling & Popper, 2000).

The effect of masking is to limit the distance over which a signal can be perceived. An animal may 

attempt to compensate in several ways, such as by increasing the source level of vocalizations (the 

Lombard effect), changing the frequency of vocalizations, or changing behavior (e.g., moving to another 

location, increase visual display). Birds have been shown to shift song frequencies in the presence of a 

tone at a similar frequency (Goodwin & Podos, 2013), and in continuously noisy urban habitats, 

populations have been shown to have altered song duration and shift to higher frequencies 

(Slabbekoorn & den Boer-Visser, 2006). Changes in vocalization may incur energetic costs and hinder 

communication with conspecifics, which, for example, could result in reduced mating opportunities. 

These effects are of long-term concern in constant noisy urban environments (Patricelli & Blickley, 2006)

where masking conditions are prevalent.
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Bats

Bats can experience masking during echolocation and communication from a variety of sources such as 

other bats and jamming of their echolocation signal by prey species (Bates et al., 2011; Chiu et al., 2008; 

Conner & Corcoran, 2012; Corcoran et al., 2009; Griffin et al., 1962; Simmons et al., 1988; Ulanovsky et 

al., 2004). They have many strategies to compensate for masking, such as dynamically changing the 

duration, spectrum, aim, and pattern of their echolocation (Bates et al., 2011; Moss et al., 2011; Petrites 

et al., 2009; Simmons et al., 2001; Wheeler et al., 2016).

Like other animals, bats increase the amplitude of their vocalizations in response to an increase in 

background noise level, which is known as the Lombard effect (Hage et al., 2013). It is estimated that a 

broadband signal of 65 dB re 20 μPa SPL would begin masking most bats’ echolocation from targets 

beyond 1.5 m away (Arnett et al., 2013). Bats have been shown to shift the frequency of their calls when 

a stimulus was within 2-3 kHz of their preferred frequency (Bates et al., 2008). 

Behavioral and psychophysical experiments show that the flexibility of bat vocalizations allows for 

perceptual rejection of masking due to clutter in the surroundings (Bates et al., 2011; Hiryu et al., 2010; 

Warnecke et al., 2015) or other sources of noise (Bates et al., 2008; Miller et al., 2004; Ulanovsky et al., 

2004).

Overall, bats seem to avoid areas with high levels of noise – especially when the noise frequency 

spectrum overlaps with frequencies important for hunting (20-90 kHz). In a controlled laboratory 

experiment, Schaub et al. (2008) found that, when given a choice, bats spent 10% less time foraging in 

the compartment with noise (traffic, wind, and broadband white noise) as compared to the silent 

control chamber. Additionally, hunting in the noisy compartment yielded 10% fewer successful prey 

interceptions. Bats spent significantly less time, and were significantly less successful as noise conditions 

increased in bandwidth and overall exposure levels. The greater the noise overlap with frequencies 

being attended to by the bat, the greater the disturbance to the bats’ foraging behavior. However, this 

experiment was conducted on a small spatial scale, and with the absence of other sensory cues (light). 

Although laboratory research has shown that noise can decrease hunting success (Siemers & Schaub, 

2011), and field and laboratory studies show that foraging bats avoid noise (Berthinussen & Altringham, 

2012; Schaub et al., 2008), no studies provide direct evidence from playback experiments in the field

that commuting or migrating bats are disturbed by sound.

3.9.3.1.1.4 Physiological Stress

Animals in the marine environment naturally experience stressors within their environment and as part 

of their life histories. Changing weather and ocean conditions, exposure to diseases and naturally 

occurring toxins, lack of prey availability, social interactions with members of the same species, nesting, 

and interactions with predators all contribute to stress. Anthropogenic sound-producing activities have 

the potential to provide additional stressors beyond those that naturally occur, as described in Section 

3.0.3.6.1 (Conceptual Framework for Assessing Effects from Acoustic and Explosive Stressors). 

Chronic stress due to disturbance may compromise the general health and reproductive success of birds 

(Kight et al., 2012), but a physiological stress response is not necessarily indicative of negative

consequences to individual birds or to populations (Larkin et al., 1996; National Park Service, 1994). The 

reported behavioral and physiological responses of birds to noise exposure can fall within the range of 

normal adaptive responses to external stimuli, such as predation, that birds face on a regular basis. 

These responses can include activation of the neural and endocrine systems, causing changes such as 

increased blood pressure, available glucose, and blood levels of corticosteroids (Manci et al., 1988). It is 
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possible that individuals would return to normal almost immediately after short-term or transient 

exposure, and the individual's metabolism and energy budget would not be affected in the long-term. 

Studies have also shown that birds can habituate to noise following frequent exposure and cease to 

respond behaviorally to the noise (Larkin et al., 1996; National Park Service, 1994; Plumpton, 2006). 

However, the likelihood of habituation is dependent upon a number of factors, including species of bird 

(Bowles et al., 1991), and frequency of and proximity to exposure. Although Andersen et al. (1990) did 

not evaluate noise specifically, they found evidence that anthropogenic disturbance is related to 

changes in home ranges; for example, raptors have been shown to shift their terrestrial home range 

when concentrated military training activity was introduced to the area. On the other hand, cardinals 

nesting in areas with high levels of military training activity (including gunfire, artillery, and explosives) 

were observed to have similar reproductive success and stress hormone levels as cardinals in areas of 

low activity (Barron et al., 2012).

While physiological responses such as increased heart rate or startle response can be difficult to 

measure in the field, they often accompany more easily measured reactions like behavioral responses. A 

startle is a reflex characterized by rapid increase in heart rate, shutdown of nonessential functions, and 

mobilization of glucose reserves. Habituation keeps animals from expending energy and attention on 

harmless stimuli, but the physiological component might not habituate completely (Bowles, 1995).

A strong and consistent behavioral or physiological response is not necessarily indicative of negative 

consequences to individuals or to populations (Bowles, 1995; Larkin et al., 1996; National Park Service, 

1994). For example, many of the reported behavioral and physiological responses to noise are within the 

range of normal adaptive responses to external stimuli, such as predation, that wild animals face on a 

regular basis. In many cases, individuals would return to homeostasis or a stable equilibrium almost 

immediately after exposure. The individual’s overall metabolism and energy budgets would not be 

affected if it had time to recover before being exposed again. If the individual does not recover before 

being exposed again, physiological responses could be cumulative and lead to reduced fitness. However, 

it is also possible that an individual would have an avoidance reaction (i.e., move away from the noise 

source) to repeated exposure or habituate to the noise when repeatedly exposed.

Due to the limited information about acoustically induced stress responses, the Navy conservatively 

assumes in its effects analysis that any physiological response (e.g., hearing loss or injury) or significant 

behavioral response is also associated with a stress response.

3.9.3.1.1.5 Behavioral Reactions

Numerous studies have documented that birds and other wild animals respond to human-made noise, 

including aircraft overflights, weapons firing, and explosions (Larkin et al., 1996; National Park Service, 

1994; Plumpton, 2006). The manner in which an animal responds to noise could depend on several 

factors, including life history characteristics of the species, characteristics of the noise source, sound 

source intensity, onset rate, distance from the noise source, presence or absence of associated visual 

stimuli, food and habitat availability, and previous exposure (see Section 3.0.3.6.1, Conceptual 

Framework for Assessing Effects from Acoustic and Explosive Activities). Researchers have documented 

a range of bird behavioral responses to noise, including no response, head turn, alert behavior, startle 

response, flying or swimming away, diving into the water, and increased vocalizations (Brown et al., 

1999; Larkin et al., 1996; National Park Service, 1994; Plumpton, 2006; Pytte et al., 2003; Stalmaster & 

Kaiser, 1997). Bat behavioral studies have shown reactions in response to acoustic interference such as 

reduced activity, area avoidance, and modifying the duration or frequency of calls (Arnett et al., 2013; 
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Bates et al., 2008; Baxter et al., 2006). Some behavioral responses may be accompanied by physiological 

responses, such as increased heart rate or short-term changes in stress hormone levels (Partecke et al., 

2006). 

Behavioral responses may depend on the characteristics of the noise, and whether the noise is similar to 

biologically relevant sounds, such as alarm calls by other birds and predator sounds. For example, 

European starlings (Sturnus vulgaris) took significantly longer to habituate to repeated bird distress calls 

than white noise or pure tones (Johnson et al., 1985). Starlings may have been more likely to continue to 

respond to the distress because it is a more biologically meaningful sound. Starlings were also more 

likely to habituate in winter than summer, possibly meaning that food scarcity or seasonal physiological 

conditions may affect intensity of behavioral response (Johnson et al., 1985).

Behavioral Reactions to Impulsive Sound Sources

Studies regarding behavioral responses by non-nesting birds to impulsive sound sources are limited. 

Seismic surveys had no noticeable impacts on the movements or diving behavior of long-tailed ducks 

undergoing wing molt, a period in which flight is limited and food requirements are high (Lacroix et al., 

2003). The birds may have tolerated the seismic survey noise to stay in preferred feeding areas. 

Responses to aircraft sonic booms are informative of responses to single impulsive sounds. Responses to 

sonic booms are discussed below in Behavioral Reactions to Aircraft.

Behavioral Reactions to Sonar and other Active Acoustic Sources

There are no studies of bird responses underwater to sonars, but the effect of pingers on fishing nets 

has been examined. Fewer common murres (Uria aalge) were entangled in gillnets when the gillnets 

were outfitted with 1.5 kHz pingers with a source level of 120 dB re 1 μPa; however, there was no 

significant reduction in rhinoceros auklet (Cerorhinca monocerata) bycatch in the same nets (Melvin et 

al., 1999; Melvin et al., 2011). It was unknown whether the pingers elicited a behavioral response by the 

birds, or decreased prey availability.

Behavioral Responses to Aircraft

There are multiple possible of the factors involved in behavioral responses to aircraft overflights, 

including the noise stimulus as well as the visual stimulus. 

Observations of tern colonies responses to balloon overflights suggest that visual stimulus is likely to be 

an important component of disturbance from overflights (Brown, 1990). Although it was assumed 

nesting colonial waterbirds may be more likely to flush or exhibit a mob response when disturbed, 

observations of nesting black skimmers and nesting least, gull-billed, and common terns showed they 

did not modify nesting behavior in response to military fixed-wing aircraft engaged in low-altitude 

tactical flights and rotary-wing overflights (Hillman et al., 2015). Maximum behavioral responses by 

crested tern (Sterna bergii) to aircraft noise were observed at sound level exposures greater than 85 

dBA re 20 μPa. However, herring gulls (Larus argentatus) significantly increased their aggressive 

interactions within the colony and their flights over the colony during overflights with received SPLs of 

101–116 dBA re 20 μPa (Burger, 1981).

Raptors and wading birds have responded minimally to jet (110 dBA re 20 μPa) and propeller plane (92 

dBA re 20 μPa) overflights, respectively (Ellis, 1981). Jet flights greater than 1,640 ft. (500 m) distance 

from raptors were observed to elicit no response (Ellis, 1981). The impacts of low-altitude military 

training flights on wading bird colonies in Florida were estimated using colony distributions and turnover 

rates. There were no demonstrated impacts of military activity on wading bird colony establishment or 
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size (Black et al., 1984). Fixed-winged jet aircraft disturbance did not seem to adversely affect waterfowl 

observed during a study in coastal North Carolina (Conomy et al., 1998); however, harlequin ducks were 

observed to show increased agonistic behavior and reduced courtship behavior up to one to two hours 

after low-altitude military jet overflights (Goudie & Jones, 2004).

It is possible that birds could habituate and no longer exhibit behavioral responses to aircraft noise, as 

has been documented for some impulsive noise sources (Ellis, 1981; Russel et al., 1996) and aircraft 

noise (Conomy et al., 1998). Ellis (1981) found that raptors would typically exhibit a minor short-term 

startle response to simulated sonic booms, and no long-term effect to productivity was noted.

Near-total failure of sooty tern nesting in the Dry Tortugas in the Key West Range Complex was reported 

in 1969 during a period when the birds were regularly exposed to sonic booms (Austin et al., 1970). In 

previous seasons, the birds were reported to react to the occasional sonic booms by rising immediately 

in a "panic flight," circling over the island, and then usually settling down on their eggs again. 

Researchers had no evidence that sonic booms caused physical damage to the sooty tern eggs, but 

hypothesized that the strong booms occurred often enough to disturb the sooty terns’ incubating 

rhythm and cause nest desertion. The 1969 sooty tern nesting failure also prompted additional research 

to test the hypothesis that sonic booms could cause bird eggs to crack or otherwise affect bird eggs or 

embryos. However, the findings of the additional research determined that aircraft overflight and sonic 

booms were not a cause of the failure, and neither were panic flights, predators, weather, inadequate 

food supplies, or tick infestation (Bowles et al., 1991; Bowles et al., 1994; Teer & Truett, 1973; Ting et 

al., 2002). That same year, the colony also contained approximately 2,500 brown noddies, whose young 

hatched successfully. While it was impossible to conclusively determine the cause of the 1969 sooty tern 

nesting failure, actions were taken to curb planes breaking the sound barrier within range of the 

Tortugas, and much of the excess vegetation was cleared (another hypothesized contributing factor to 

the nesting failure). Similar nesting failures have not been reported since the 1969 failure.

As described in Section 5.3.2.5 (Aircraft Overflight Noise), the Navy implements mitigation within the 

Tortugas Military Operations Area, which is a unique block of special use airspace above the Dry 

Tortugas National Park that has special flight rules designed to minimize military aircraft noise. 

Mitigation includes not conducting combat maneuver flights below 5,000-ft. or tactical maneuvers 

resulting in supersonic flights below 20,000 ft. Audible sonic booms within the Dry Tortugas National 

Park are predicted to be infrequent and at low received levels based on mitigation measures 

implemented by the Navy to reduce the occurrence of focused sonic booms in the Tortugas Military 

Operations Area. In addition, initial efforts by Florida Fish and Wildlife Conservation Commission and 

National Park Service biologists to reestablish a nesting colony of the federally listed roseate tern in the 

Dry Tortugas have been successful. During this time, Navy use of the Tortugas Military Operations Area 

and surrounding Special Use Airspace remained constant. Given the increase in nests coincident with air 

combat maneuver training, the aircraft training following guidelines of the Military Operations Area has 

likely had minimal impact on nesting roseate terns.

3.9.3.1.1.6 Long Term Consequences

Long-term consequences to birds and bats due to acoustic exposures are considered following the 

Conceptual Framework for Assessing Effects from Acoustic and Explosive Stressors (Section 3.0.3.6.1).

Long-term consequences due to individual behavioral reactions and short-term instances of 

physiological stress are especially difficult to predict because individual experience over time can create 

complex contingencies. It is more likely that any long-term consequences to an individual would be a 

result of costs accumulated over a season, year, or life stage due to multiple behavioral or stress 
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responses resulting from exposures to multiple stressors over significant periods of time. Conversely, 

some birds and bats may habituate to or become tolerant of repeated acoustic exposures over time, 

learning to ignore a stimulus that in the past did not accompany any overt threat. Most research on 

long-term consequences to birds due to acoustic exposures has focused on breeding colonies or shore 

habitats, and does not address the brief exposures that may be encountered during migration or 

foraging at sea. More research is needed to better understand the long-term consequences of humanmade noise on birds and bats, although intermittent exposures are assumed to be less likely than 

prolonged exposures to have lasting consequences.

3.9.3.1.2 Impacts from Sonar and Other Transducers

Sonar and other transducers emit sound waves into the water to detect objects, safely navigate, and

communicate. Use of sonar and other transducers would typically be transient and temporary. General 

categories of sonar systems are described in Section 3.0.3.3.1 (Acoustic Stressors).

Impacts from sonar and other transducers are not applicable to bats because bats are an airborne 

species and will not be analyzed further in this section. In addition, there is no overlap of sonar and 

other transducer noise and piping plover critical habitat.

Information regarding the impacts of sonar on birds is unavailable, and little is known about the ability 

of birds to hear underwater. The limited information (Johansen et al., 2016) and data from other species 

suggest the range of best hearing may shift to lower frequencies in water (Dooling & Therrien, 2012; 

Therrien, 2014) (see Section 3.9.2.1.4, Hearing and Vocalization). Because few birds can hear above 10 

kHz in air, it is likely that the only sonar sources they may be able to detect are low and mid-frequency 

sources.

Other than pursuit diving species, the exposure to birds by these sounds is likely to be negligible because 

they spend only a very short time underwater (plunge-diving or surface-dipping) or forage only at the 

water surface. Pursuit divers may remain underwater for minutes, increasing the chance of underwater 

sound exposure.

In addition to diving behavior, the likelihood of a bird being exposed to underwater sound depends on 

factors such as duty cycle (defined as the percentage of the time during which a sound is generated over 

a total operational period), whether the source is moving or stationary, and other activities that might 

be occurring in the area. When used, continuously active sonars transmit more frequently (greater than 

80% duty cycle) than traditional sonars, but at a substantially lower source level. However, it should be 

noted that active sonar is rarely used continuously throughout the listed activities, and many sources 

are mobile. For moving sources such as hull-mounted sonar, the likelihood of an individual bird being 

repeatedly exposed to an intense sound source over a short period of time is low because the training 

activities are transient and sonar use and bird diving are intermittent. The potential for birds to be 

exposed to intense sound associated with stationary sonar sources would likely be limited for some 

training and testing activities because other activities occurring in conjunction may cause them to leave 

the immediate area. For example, birds would likely react to helicopter noise during dipping sonar 

exercises by flushing from the immediate area, and would, therefore, not be exposed to underwater 

sonar.

Injury due to acoustic resonance of air space in the lungs from sonar and other transducers is unlikely in 

birds. Unlike mammals, birds have compact, rigid lungs with strong pulmonary capillaries that do not 

change much in diameter when exposed to extreme pressure changes (Baerwald et al., 2008), leading to 

resonant frequencies lower than the frequencies used for Navy sources. 
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A physiological impact, such as hearing loss, would likely only occur if a seabird were close to an intense 

sound source. An underwater sound exposure would have to be intense and of a sufficient duration to 

cause hearing loss. Avoiding the sound by returning to the surface would limit extended or multiple 

sound exposures underwater. Additionally, some diving birds may avoid interactions with large moving 

vessels upon which the most powerful sonars are operated (Schwemmer et al., 2011). In general, birds 

are less susceptible to both temporary and PTS than mammals (Saunders & Dooling, 1974). Diving birds 

have adaptations to protect the middle ear and tympanum from pressure changes during diving that 

may affect hearing (Dooling & Therrien, 2012). While some adaptions may exist to aid in underwater 

hearing, other adaptations to protect in-air hearing may limit aspects of underwater hearing 

(Hetherington, 2008). Because of these reasons, the likelihood of a diving bird experiencing an 

underwater exposure to sonar or other transducers that could result in an impact to hearing is 

considered low.

Because diving birds may rely more on vision for foraging, and there is no evidence that diving birds rely 

on underwater acoustic communication for foraging (see Section 3.9.2.1.4, Hearing and Vocalization), 

the masking of important acoustic signals underwater by sonar or other transducers is unlikely.

There have been no studies documenting diving seabirds’ reactions to sonar. However, given the 

information and adaptations discussed above, diving seabirds are not expected to detect high-frequency 

sources underwater and are only expected to detect mid- and low-frequency sources when in close 

proximity. A diving bird may not respond to an underwater source, or it may respond by altering its dive 

behavior, perhaps by reducing or ceasing a foraging bout. It is expected that any behavioral interruption 

would be temporary, as the source or the bird changes location.

Some birds commonly follow vessels, including certain species of gulls, storm petrels, and albatrosses, as 

there is increased potential of foraging success as the prop wake brings prey to the surface (Hamilton, 

1958; Hyrenbach, 2001, 2006; Melvin et al., 2001). Birds that approach vessels while foraging are the 

most likely to be exposed to underwater active acoustic sources, but only if the ship is engaged in antisubmarine warfare or mine warfare with active acoustic sources. However, hull-mounted sonar does not 

project sound aft of ships (behind the ship, opposite the direction of travel), so most birds diving in ship 

wakes would not be exposed to sonar. In addition, based on what is known about bird hearing 

capabilities in air, it is expected that diving birds may have limited or no ability to perceive highfrequency sounds, so they would likely not be impacted by high-frequency sources such as those used in 

mine warfare.

3.9.3.1.2.1 Impacts from Sonar and Other Transducers Under Alternative 1

Impacts from Sonar and Other Transducers Under Alternative 1 for Training Activities

General categories and characteristics of sonar systems and the number of hours these sonars would be 

operated during training under Alternative 1 are described in Section 3.0.3.3.1 (Acoustic Stressors). 

Activities using sonars and other transducers would be conducted as described in Chapter 2 (Description 

of Proposed Action and Alternatives) and Appendix A (Navy Activity Descriptions).

Under Alternative 1, the number of Major Training Exercises and Civilian Port Defense Activities would 

fluctuate annually. In addition, a portion of Anti-Submarine Warfare Tracking Exercise-Ship unit-level 

training activities would be conducted using synthetic means (e.g., simulators) or in conjunction with 

other training exercises. Training activities using sonar and other transducers could occur throughout 

the Study Area, although use would generally occur within Navy range complexes, on Navy testing 

ranges, or around inshore locations identified in Chapter 2 (Description of Proposed Action and 
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Alternatives). Use of sonars associated with anti-submarine warfare would be greatest in the 

Jacksonville and Virginia Capes Range Complexes. 

Sonar and other transducers would not be regularly used in nearshore areas that could be used by 

foraging shorebirds, except during maintenance and for navigation in areas around ports. Therefore, 

birds that forage in open ocean areas would have a greater chance of underwater sound exposure than 

birds that forage in coastal areas. 

The possibility of an ESA-listed bird species being exposed to sonar and other active acoustic sources 

depends on whether it submerges during foraging and whether it forages in areas where these sound 

sources may be used. Although Bermuda petrels forage in open ocean areas where sonar training 

occurs, it is unlikely they would be exposed to underwater sound because they typically forage at the 

surface and, if pursuit diving, only stay underwater for a short period (typically less than 10 seconds). 

The roseate tern’s plunge-dive is shallow and brief in duration. Typical dives submerge less than the full 

body length of the tern with the duration of submergence seldom exceeding 1 to 2 seconds. Any 

exterior sound would be masked by the sound of the tern entering and exiting the water so no exposure 

is expected. Piping plovers and red knots do not submerge while foraging in intertidal areas; therefore, 

they would not be exposed to underwater sound from sonar and other active acoustic sources. Because 

impacts to individual birds, if any, are expected to be minor and limited, no long-term consequences to 

individuals are expected. Accordingly, there would be no consequences to any bird populations, and 

sonar and other transducers will not have a significant adverse effect on populations of migratory bird 

species.

Pursuant to the ESA, the use of sonar and other transducers during training events as described under 

Alternative 1 will have no effect on Indiana bats, northern long-eared bats, roseate terns, piping plovers, 

red knots, or piping plover critical habitat. The use of sonar and other transducers during training 

activities as described under Alternative 1 may affect Bermuda petrels. The Navy has consulted with the 

USFWS as required by section 7(a)(2) of the ESA in that regard.

Impacts from Sonar and Other Transducers Under Alternative 1 for Testing

General categories and characteristics of sonar systems and the number of hours these sonars would be 

operated during testing under Alternative 1 are described in Section 3.0.3.3.1 (Acoustic Stressors). 

Activities using sonars and other transducers would be conducted as described in Chapter 2 (Description 

of Proposed Action and Alternatives) and Appendix A (Navy Activity Descriptions). Under Alternative 1, 

the number of testing activities would fluctuate annually. 

Testing activities using sonar and other transducers could occur throughout the Study Area, although 

use would generally occur within Navy range complexes, on Navy testing ranges, or around inshore 

locations identified in Chapter 2 (Description of Proposed Action and Alternatives).

The possibility of an ESA-listed bird species being exposed to sonar and other active acoustic sources 

depends on whether it submerges during foraging and whether it forages in areas where these sound 

sources may be used. Although Bermuda petrels forage in open ocean areas where sonar testing occurs, 

it is unlikely they would be exposed to underwater sound because they typically forage at the surface 

and, if pursuit diving, only stay underwater for a short period (typically less than 10 seconds). The 

roseate tern’s plunge-dive is shallow and brief in duration. Typical dives submerge less than the full body 

length of the tern with the duration of submergence seldom exceeding 1 to 2 seconds. Any exterior 

sound would be masked by the sound of the tern entering and exiting the water so no exposure is 

expected. Piping plovers and red knots do not submerge while foraging in intertidal areas; therefore, 
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they would not be exposed to underwater sound from sonar and other active acoustic sources. Because 

impacts to individual birds, if any, are expected to be minor and limited, no long-term consequences to 

individuals are expected. Accordingly, there would be no consequences to any bird populations, and 

sonar and other transducers will not have a significant adverse effect on populations of migratory bird 

species.

Pursuant to the ESA, the use of sonar and other transducers during testing activities as described under 

Alternative 1 will have no effect on Indiana bats, northern long-eared bats, roseate terns, piping plovers, 

red knots, or piping plover critical habitat. The use of sonar and other transducers during testing 

activities as described under Alternative 1 may affect Bermuda petrels. The Navy has consulted with the 

USFWS as required by section 7(a)(2) of the ESA in that regard.

3.9.3.1.2.2 Impacts from Sonar and Other Transducers Under Alternative 2

Impacts from Sonar and Other Transducers Under Alternative 2 for Training Activities

General categories and characteristics of sonar systems and the number of hours these sonars would be 

operated during training under Alternative 2 are described in Section 3.0.3.3.1 (Acoustic Stressors). 

Activities using sonars and other transducers would be conducted as described in Chapter 2 (Description 

of Proposed Action and Alternatives) and Appendix A (Navy Activity Descriptions).

Under Alternative 2, the maximum number of Major Training Exercises could occur every year, an 

additional Major Training Exercise would be conducted in the Gulf of Mexico Range Complex annually, 

and only the number of Civilian Port Defense Activities would fluctuate annually. In addition, all unit 

level Anti-Submarine Warfare Tracking Exercise-Ship activities would be completed through individual 

events conducted at sea, rather than through leveraging other anti-submarine warfare training exercises 

or the use of synthetic means (e.g., simulators). This would result in an increase of sonar use compared 

to Alternative 1. Training activities using sonar and other transducers could occur throughout the Study 

Area, although use would generally occur within Navy range complexes, on Navy testing ranges, or 

around inshore locations identified in Chapter 2 (Description of Proposed Action and Alternatives). Use 

of sonars associated with anti-submarine warfare would be greatest in the Jacksonville and Virginia 

Capes Range Complexes.

Sonar and other transducers would not be regularly used in nearshore areas that could be used by 

foraging shorebirds, except during maintenance and for navigation in areas around ports. Therefore, 

birds that forage in open ocean areas would have a greater chance of underwater sound exposure than 

birds that forage in coastal areas. 

The possibility of an ESA-listed bird species being exposed to sonar and other active acoustic sources 

depends on whether it submerges during foraging and whether it forages in areas where these sound 

sources may be used. Although Bermuda petrels forage in open ocean areas where sonar training 

occurs, it is unlikely they would be exposed to underwater sound because they typically forage at the

surface and, if pursuit diving, only stay underwater for a short period (typically less than 10 seconds). 

The roseate tern’s plunge-dive is shallow and brief in duration. Typical dives submerge less than the full 

body length of the tern with the duration of submergence seldom exceeding 1 to 2 seconds. Any 

exterior sound would be masked by the sound of the tern entering and exiting the water so no exposure 

is expected. Piping plovers and red knots do not submerge while foraging in intertidal areas; therefore, 

they would not be exposed to underwater sound from sonar and other active acoustic sources. Because 

impacts to individual birds, if any, are expected to be minor and limited, no long-term consequences to 

individuals are expected. Accordingly, there would be no consequences to any bird populations, and 
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sonar and other transducers will not have a significant adverse effect on populations of migratory bird 

species.

Pursuant to the ESA, the use of sonar and other transducers during training activities as described under 

Alternative 2 will have no effect on Indiana bats, northern long-eared bats, piping plover critical habitat, 

roseate terns, piping plovers, red knots, or piping plover critical habitat. The use of sonar and other 

transducers during training activities as described under Alternative 2 may affect Bermuda petrels.

Impacts from Sonar and Other Transducers Under Alternative 2 for Testing Activities 

General categories and characteristics of sonar systems and the number of hours these sonars would be 

operated during testing under Alternative 2 are described in Section 3.0.3.3.1 (Acoustic Stressors). 

Activities using sonars and other transducers would be conducted as described in Chapter 2 (Description 

of Proposed Action and Alternatives) and Appendix A (Navy Activity Descriptions).

Under Alternative 2, the maximum number of nearly all testing activities would occur every year. This 

would result in an increase of sonar use compared to Alternative 1. 

Testing activities using sonar and other transducers could occur throughout the Study Area, although 

use would generally occur within Navy range complexes, on Navy testing ranges, or around inshore 

locations identified in Chapter 2 (Description of Proposed Action and Alternatives).

The possibility of an ESA-listed bird species being exposed to sonar and other active acoustic sources 

depends on whether it submerges during foraging and whether it forages in areas where these sound 

sources may be used. Although Bermuda petrels forage in open ocean areas where sonar testing occurs, 

it is unlikely they would be exposed to underwater sound because they typically forage at the surface 

and, if pursuit diving, only stay underwater for a short period (typically less than 10 seconds). The 

roseate tern’s plunge-dive is shallow and brief in duration. Typical dives submerge less than the full body 

length of the tern with the duration of submergence seldom exceeding 1 to 2 seconds. Any exterior 

sound would be masked by the sound of the tern entering and exiting the water so no exposure is 

expected. Piping plovers and red knots do not submerge while foraging in intertidal areas; therefore, 

they would not be exposed to underwater sound from sonar and other active acoustic sources. Because 

impacts to individual birds, if any, are expected to be minor and limited, no long-term consequences to 

individuals are expected. Accordingly, there would be no consequences to any bird populations, and 

sonar and other transducers will not have a significant adverse effect on populations of migratory bird 

species.

Pursuant to the ESA, the use of sonar and other transducers during testing activities as described under 

Alternative 2 will have no effect on Indiana bats, northern long-eared bats, roseate terns, piping plovers, 

red knots, or piping plover critical habitat. The use of sonar and other transducers during testing 

activities as described under Alternative 2 may affect Bermuda petrels. 

3.9.3.1.2.3 Impacts from Sonar and Other Transducers Under No Action Alternative 

Impacts from Sonar and Other Transducers Under No Action Alternative for Training and Testing 

Activities 

Under the No Action Alternative, the Navy would not conduct the training and testing activities in the 

AFTT Study Area. Various acoustic stressors (e.g., sonar and other transducers) would not be introduced 

into the marine environment. Therefore, baseline conditions of the existing environment would either 

remain unchanged or would improve slightly after cessation of ongoing training and testing activities.
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3.9.3.1.3 Impacts from Air Guns

Air guns can introduce brief impulsive, broadband sounds into the marine environment. Section 

3.0.3.3.1.2 (Air Guns) provides additional details on the use and acoustic characteristics of the small 

underwater air guns used during Navy activities. 

Impulses from air guns used by the Navy lack the strong shock wave and rapid pressure increases of 

explosions that can cause primary blast injury or barotraumas. Underwater impulses would be 

generated using small (approximately 60 cubic in.) air guns, which are essentially stainless steel tubes 

charged with high-pressure air via a compressor. An impulsive sound is generated when the air is almost 

instantaneously released into the surrounding water, an effect similar to popping a balloon in air. 

Generated impulses would have short durations, typically a few hundred milliseconds. 

Impacts from air guns are not applicable to bats because bats are an airborne species and will not be 

analyzed further in this section. In addition, there is no overlap of air gun noise and piping plover critical 

habitat.

The exposure to these sounds by birds, other than pursuit diving species, would be negligible because 

they spend only a very short time underwater (plunge-diving or surface-dipping) or forage only at the 

water surface. Pursuit divers may remain underwater for minutes, increasing the chance of underwater 

sound exposure. However, the short duration of an air gun pulse and its relatively low source level 

means that a bird would have to be very close to a small air gun used in Navy activities at the moment of 

discharge to be exposed. In addition, air guns may be fired at greater depths than birds conduct their 

foraging dives. Because of these reasons, the likelihood of a diving bird experiencing an underwater 

exposure to an air gun that could result in an impact to hearing is negligible.

Because diving birds may rely more on vision for foraging, there is no evidence that diving birds rely on 

underwater acoustic communication for foraging (see Section 3.9.2.1.4, Hearing and Vocalization), and 

the signal from an air gun is very brief, the masking of important acoustic signals underwater by an air 

gun is unlikely.

The limited data on behavioral reactions to underwater impulsive noise suggest that birds are unlikely to 

exhibit any notable behavioral reaction toward a small air gun (see Section 3.9.3.1.1.5, Behavioral 

Reactions).

3.9.3.1.3.1 Impacts from Air Guns Under Alternative 1

Impacts form Air Guns Under Alternative 1 for Training Activities

Training activities under Alternative 1 do not use air guns.

Impacts from Air Guns Under Alternative 1 for Testing

Characteristics of air guns and the number of times they would be operated during testing under 

Alternative 1 are described in Section 3.0.3.3.1 (Acoustic Stressors). Activities using air guns would be 

conducted as described in Chapter 2 (Description of Proposed Action and Alternatives) and Appendix A

(Navy Activity Descriptions).

Under Alternative 1, small air guns (12 - 60 in.3) would be fired pierside at Newport, Rhode Island and at 

offshore locations typically in the Northeast, Virginia Capes, and Gulf of Mexico Range Complexes. 

The possibility of an ESA-listed seabird species being exposed to sounds from air guns depends on 

whether it submerges during foraging and whether it forages in areas where this sound source may be 

used. Although Bermuda petrels forage in open ocean areas where some air gun use occurs, it is unlikely 
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they would be exposed to underwater sound because they typically forage at the surface and, if pursuit 

diving, only stay underwater for a short period (typically less than 10 seconds). Red knots and piping 

plovers do not submerge while foraging; therefore, they would not be exposed to underwater sound 

from air guns. Because roseate terns only briefly submerge while plunge-diving during foraging in 

coastal shallow waters, their risk of air gun exposure is negligible. As discussed above, impacts to 

individual birds, if any, are expected to be minor and limited. No long-term consequences to individuals 

are expected. Accordingly, there would be no consequences to any bird populations, and air guns will 

not have a significant adverse effect on populations of migratory bird species.

Pursuant to the ESA, the use of air guns during testing activities as described under Alternative 1 will 

have no effect on Indiana bats, northern long-eared bats, piping plovers, roseate terns, red knots, or

piping plover critical habitat. The use of air guns during testing activities as described under Alternative 

1 may affect Bermuda petrels. The Navy has consulted with the USFWS as required by section 7(a)(2) of 

the ESA in that regard.

3.9.3.1.3.2 Impacts from Air Guns Under Alternative 2

Impacts from Air Guns Under Alternative 2 for Training Activities

Training activities under Alternative 2 do not use air guns.

Impacts from Air Guns Under Alternative 2 for Testing Activities 

Air gun testing activities planned under Alternative 2 are identical to those planned under Alternative 1; 

therefore, the estimated impacts would be identical. Because impacts to individual birds, if any, are 

expected to be minor and limited, no long-term consequences to individuals are expected. Accordingly, 

there would be no consequences to any bird populations, and air guns will not have a significant adverse 

effect on populations of migratory bird species. 

Pursuant to the ESA, the use of air guns during testing activities as described under Alternative 2 will 

have no effect on Indiana bats, northern long-eared bats, piping plovers, roseate terns, red knots, or

piping plover critical habitat. The use of air guns during testing activities as described under Alternative 

2 may affect Bermuda petrels. 

3.9.3.1.3.3 Impacts from Air Guns Under No Action Alternative 

Impacts from Air Guns Under No Action Alternative for Training and Testing Activities 

Under the No Action Alternative, the Navy would not conduct the training and testing activities in the 

AFTT Study Area. Various acoustic stressors (e.g., air guns) would not be introduced into the marine 

environment. Therefore, baseline conditions of the existing environment would either remain 

unchanged or would improve slightly after cessation of ongoing training and testing activities.

3.9.3.1.4 Impacts from Pile Driving

Impact pile driving and vibratory pile extraction would occur during construction of an Elevated 

Causeway System, a temporary pier that allows the offloading of ships in areas without a permanent 

port. Installation of piles would involve the use of an impact hammer mechanism and pile extraction 

would involve using the vibratory mechanism. These activities would occur over multiple days, although 

noise generated by the actual pile driving and extraction would only occur over a portion of any given 

day (generally an hour or less in total). Section 3.0.3.3.1.3 (Pile Driving) provides additional details on 

pile driving activities and the noise levels measured from a prior elevated causeway installation and 

removal.
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Noise from the installation and removal of piles has a potential to affect animals in the vicinity of the 

training event. Impact pile driving creates repetitive impulsive sound. An impact pile driver generally 

operates in the range of 36–50 blows per minute. Vibratory pile extraction creates a nearly continuous 

sound made up of a series of short duration rapid impulses at a much lower source level than impact 

pile driving. The sounds are emitted both in the air and in the water in nearshore areas where some 

birds forage. It is expected that most birds would exhibit avoidance behavior and leavethe pile driving 

location. However, if prey species such as fish are killed or injured as a result of pile driving, some birds 

may continue to forage close to the construction area, or may be attracted to the area, and be exposed 

to associated noise. Behavioral responses and displacement from the area are expected to be temporary 

for the duration of the pile driving and extraction activities. Bats may be exposed to the in-air noise from 

pile driving installation and extraction. 

Impulses from the impact hammer are broadband and carry most of their energy in the lower 

frequencies. The underwater SPLs produced by impact pile driving during Navy activities are below the 

conservatively estimated injury thresholds recommended for other small animals with similar sized air 

cavities [sea turtles and fish; see Popper et al. (2014)]. Therefore, the risk of barotrauma to any diving 

birds is negligible. Impulses from the impact hammer attenuate more quickly in air than in water and 

birds are likely to avoid the area during impact driving. Therefore, the risk of barotrauma to birds in air 

or at the water surface is negligible. 

Pursuit divers may remain underwater for minutes, increasing the chance of underwater sound 

exposure. However, the short duration of driving or extracting a single pile would limit the likelihood of 

exposure, especially since a bird that is disturbed by pile driving while underwater may respond by 

swimming to the surface. Although it is not known what duration or intensity of underwater sound 

exposure would put a bird at risk of hearing loss, birds are less susceptible to both temporary and PTS

than mammals (Saunders & Dooling, 1974). Diving birds have adaptations to protect the middle ear and 

tympanum from pressure changes during diving that may affect hearing (Dooling & Therrien, 2012). 

While some adaptions may exist to aid in underwater hearing, other adaptations to protect in-air 

hearing may limit aspects of underwater hearing (Hetherington, 2008). Because of these reasons, the 

likelihood of a diving bird experiencing an underwater exposure to impact pile driving that could affect 

hearing is considered low. Vibratory pile extraction sound levels are low and are not considered to pose 

a risk to bird hearing in air or in water.

Because diving birds may rely more on vision for foraging, there is no evidence that diving birds rely on 

underwater acoustic communication for foraging (see Section 3.9.2.1.4, Hearing and Vocalization), and 

individual pile driving and extraction occurs only over a few minutes, the masking of important acoustic 

signals underwater by pile driving is unlikely. The potential for masking of calls in air would also likely be 

limited because of the short duration of individual pile driving and extraction and the likelihood that 

birds would avoid the area around pile driving activities.

Responses by birds to noise from pile driving would be short-term behavioral or physiological responses 

(e.g., alert response, startle response, and temporary increase in heart rate). Startle or alert reactions 

are not likely to disrupt major behavior patterns such as migrating, breeding, feeding, and sheltering, or 

to result in serious injury to any birds. Some birds may be attracted to the area to forage forn prey 

species killed or injured as a result of pile driving and be exposed to noise from pile driving temporarily. 

Birds may be temporarily displaced and there may be temporary increases in stress levels; however, 

behavior and use of habitat would return shortly after the training is complete.
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3.9.3.1.4.1 Impacts from Pile Driving Under Alternative 1

Impacts form Pile Driving Under Alternative 1 for Training Activities

Characteristics of pile driving and the number of times pile driving for the Elevated Causeway System 

would occur during training under Alternative 1 are described in Section 3.0.3.3.1 (Acoustic Stressors). 

Activities with pile driving would be conducted as described in Chapter 2 (Description of Proposed 

Action and Alternatives) and Appendix A (Navy Activity Descriptions). This activity would take place 

nearshore and within the surf zone up to two times per year, once at Joint Expeditionary Base Little 

Creek-Fort Story, Virginia and once at Marine Corps Base Camp Lejeune, North Carolina. 

The impact of noise produced by pile driving and extraction would be short-term and localized. Birds in 

the close vicinity are expected to most likely respond by increasing distance from pile driving and 

extraction activities, or not respond at all to extraction activities. As discussed above, impacts to 

individual birds or bats, if any, are expected to be minor and limited. No long-term consequences to 

individuals are expected. Accordingly, there would be no consequences to any bird or bat populations 

and pile driving will not have a significant adverse effect on populations of migratory bird species.

Bermuda petrels are unlikely to be present in coastal areas where pile driving could occur. Piping 

plovers, roseate terns, and red knots may be present in coastal areas where pile driving could occur, 

depending on time of year. None of these species are pursuit divers; therefore, there would be no risk 

from underwater pile driving noise exposure. If present, birds of these species may be exposed to in-air 

noise from pile driving, but would be expected to avoid the area around active impact pile driving and 

extraction construction activities. Pile driving activities would not occur at beaches that are designated 

as piping plover critical habitat. Bats may be exposed to the in-air noise from pile driving installation and 

extraction; however, most of the energy from pile driving would be carried in the lower frequencies out 

of the hearing range of bats.

Pursuant to the ESA, the use of pile driving during training activities described under Alternative 1 will 

have no effect on piping plover critical habitat. The use of pile driving during training activities described 

under Alternative 1 may affect piping plovers, Bermuda petrels, roseate terns, red knots, Indiana bats,

and northern long-eared bats. The Navy has consulted with the USFWS as required by section 7(a)(2) of 

the ESA in that regard.

Impacts from Pile Driving Under Alternative 1 for Testing

Testing activities under Alternative 1 do not include pile driving.

3.9.3.1.4.2 Impacts from Pile Driving Under Alternative 2

Impacts from Pile Driving Under Alternative 2 for Training Activities

Pile driving training activities planned under Alternative 2 are identical to those planned under 

Alternative 1; therefore, the estimated impacts would be identical. Because impacts on individual birds 

and bats, if any, are expected to be minor and limited, no long-term consequences to individuals are 

expected. Accordingly, there would be no consequences to any bird or bat populations, and pile driving 

will not have a significant adverse effect on populations of migratory bird species.

Pursuant to the ESA, the use of pile driving during training activities described under Alternative 2 will 

have no effect on piping plover critical habitat. The use of pile driving during training activities described 

under Alternative 2 may affect piping plovers, Bermuda petrels, roseate terns, red knots, Indiana bats, 

and northern long-eared bats.
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Impacts from Pile Driving Under Alternative 2 for Testing Activities 

Testing activities under Alternative 2 do not include pile driving.

3.9.3.1.4.3 Impacts from Pile Driving Under No Action Alternative 

Impacts from Pile Driving Under No Action Alternative for Training and Testing Activities 

Under the No Action Alternative, the Navy would not conduct the training and testing activities in the 

AFTT Study Area. Various acoustic stressors (e.g., pile driving) would not be introduced into the marine 

environment. Therefore, baseline conditions of the existing environment would either remain 

unchanged or would improve slightly after cessation of ongoing training and testing activities.

3.9.3.1.5 Impacts from Vessel Noise

The training and testing proposed in the Study Area involve maneuvers by various types of surface ships, 

boats, submarines, and unmanned vehicles (collectively referred to as vessels) (see Section 3.0.3.3.1.4, 

Vessel Noise). Birds could be exposed to both in-air and underwater noise from vessels throughout the 

Study Area and bats may be exposed to in-air noise from vessels throughout the Study Area, but few 

exposures would occur based on the infrequency of operations and the low density of vessels within the 

Study Area at any given time. Potential for exposure to vessel noise due to Navy activities would be 

greatest near Navy ports.

Birds respond to vessels in various ways. Some birds are commonly attracted to and follow vessels 

including certain species of gulls, storm-petrels, and albatrosses (Hamilton, 1958; Hyrenbach, 2001, 

2006), while other species such as frigatebirds, sooty terns, and a variety of diving birds seem to avoid 

vessels (Borberg et al., 2005; Hyrenbach, 2006; Schwemmer et al., 2011). Vessel noise could elicit shortterm behavioral or physiological responses but are not likely to disrupt major behavior patterns, such as 

migrating, breeding, feeding, and sheltering, or to result in serious injury to any birds. Harmful 

bird/vessel interactions are commonly associated with commercial fishing vessels because birds are 

attracted to concentrated food sources around these vessels (Dietrich & Melvin, 2004; Melvin & Parrish, 

2001). The concentrated food sources (catch and bycatch) that attract birds to commercial fishing 

vessels are not present around Navy vessels.

Although loud sudden noises can startle and flush birds, Navy vessels are not expected to result in major 

acoustic disturbance of birds in the Study Area. The continuous noise from Navy vessels has the 

potential to cause masking for birds, both in air and underwater. Due to the transient nature of Navy 

vessels, this masking is expected to be temporary. Birds near ports may experience increased masking 

and become habituated to this noise or attempt to compensate for the masking. Noises from Navy 

vessels are similar to or less than those of the general maritime environment. Birds may respond to the 

physical presence of a vessel, regardless of the associated noise (See section 3.9.3.4.1, Impacts from 

Vessels and In-water Devices). 

Very little is known about the impact of vessel noise on bats, although studies of vehicle noise suggest 

that the distance from and number of passing vehicles affect the intensity of the acoustic habitat 

degradation, which will affect bats’ behavior (Schaub et al., 2008). Bats have been known to temporarily 

roost on vessels along their migration routes as noted in Section 3.9.2.1 (General Background). 

Anecdotal evidence exists for the ability of bats to cope with considerable background noise in nonforaging situations (Schaub et al., 2008). Navy vessels are not expected to result in major acoustic 

disturbance of bats in the Study Area.
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3.9.3.1.5.1 Impacts from Vessel Noise Under Alternative 1

Impacts form Vessel Noise Under Alternative 1 for Training Activities

Characteristics of Navy vessel noise are described in Section 3.0.3.3.1 (Acoustic Stressors). Activities with 

vessel noise would be conducted as described in Chapter 2 (Description of Proposed Action and 

Alternatives) and Appendix A (Navy Activity Descriptions). Navy vessel traffic could occur anywhere 

within the Study Area, but would be concentrated near the Norfolk and Mayport Navy ports and within 

the Virginia Capes, Navy Cherry Point, and Jacksonville Range Complexes. Navy vessel noise would 

continue to be a minor contributor to overall radiated vessel noise in the exclusive economic zone. A 

study of Navy vessel traffic found that traffic was heaviest just offshore between the mouth of the 

Chesapeake Bay and Jacksonville, FL, with very little Navy vessel traffic in the Northeast or Gulf of 

Mexico Range Complexes (Mintz, 2012). There is no overlap of vessel noise and piping plover critical 

habitat.

A bird in the open ocean could be exposed to vessel noise as the vessel passes. Birds foraging or 

migrating through a training area in the open ocean may respond by avoiding areas of temporarily 

concentrated vessel noise. Exposures to most seabirds would be infrequent, based on the brief duration 

and dispersed nature of the vessels. 

If a bird or bat responds to vessel noise, only short-term behavioral responses such as startle responses, 

head turning, or avoidance responses would be expected. Repeated exposures would be limited due to 

the transient nature of vessel use and regular movement of birds and bats. Because impacts to 

individual birds and bats, if any, are expected to be minor and limited, no long-term consequences to 

individuals are expected. Accordingly, there would be no consequences to any bird or bat populations, 

and vessel noise will not have a significant adverse effect on populations of migratory bird species.

Coastal roseate terns, red knots, and piping plovers could be exposed to intermittent vessel noise along 

the coast. If present in the open water areas where training activities involving vessel noise occur, 

roseate terns, red knots, Bermuda petrels, Indiana bats, and northern long-eared bats could be 

temporarily disturbed while foraging or migrating. 

Pursuant to the ESA, vessel noise during training activities as described under Alternative 1 will have no 

effect on piping plover critical habitat. Vessel noise during training activities as described under 

Alternative 1 may affect roseate terns, red knots, Bermuda petrels, piping plovers, Indiana bats, and 

northern long-eared bats. The Navy has consulted with the USFWS as required by section 7(a)(2) of the 

ESA in that regard.

Impacts from Vessel Noise Under Alternative 1 for Testing

Characteristics of Navy vessel noise are described in Section 3.0.3.3.1 (Acoustic Stressors). Activities with 

vessel noise would be conducted as described in Chapter 2 (Description of Proposed Action and 

Alternatives) and Appendix A (Navy Activity Descriptions). Testing activities within the Study Area 

typically consist of a single vessel involved in unit-level activity for a few hours, one or two small boats 

conducting testing, or during a larger training event. Navy vessel traffic could occur anywhere within the 

Study Area, primarily concentrated within the Jacksonville and Virginia Capes Range Complexes; the 

Northeast Range Complexes and adjacent inshore waters, especially near the Naval Underwater 

Warfare Center Newport Testing Range; and in the Gulf of Mexico, especially in areas near Naval Surface 

Warfare Center, Panama City Division Testing Range. There is no overlap of vessel noise and piping 

plover critical habitat.
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A bird or bat in the open ocean could be exposed to vessel noise as the vessel passes. Birds and bats 

foraging or migrating through a testing area in the open ocean may respond by avoiding areas of 

temporarily concentrated vessel noise. Exposures to most birds and bats would be infrequent, based on 

the brief duration and dispersed nature of the vessels. 

If a bird or bat responds to vessel noise, only short-term behavioral responses such as startle responses, 

head turning, or avoidance responses would be expected. Repeated exposures would be limited due to 

the transient nature of vessel use and regular movement of birds and bats. Because impacts to 

individual birds or bats, if any, are expected to be minor and limited, no long-term consequences to 

individuals are expected. Accordingly, there would be no consequences to any bird or bat populations, 

and vessel noise will not have a significant adverse effect on populations of migratory bird species.

Coastal roseate terns, red knots, and piping plovers could be exposed to intermittent vessel noise along 

the coast. If present in the open water areas where testing activities involving vessel noise occur, 

roseate terns, red knots, Bermuda petrels, Indiana bats, and northern long-eared bats could be 

temporarily disturbed while foraging or migrating. 

Pursuant to the ESA, vessel noise during testing activities as described under Alternative 1 will have no 

effect on piping plover critical habitat. Vessel noise during testing activities as described under 

Alternative 1 may affect roseate terns, red knots, Bermuda petrels, piping plovers, Indiana bats, and 

northern long-eared bats. The Navy has consulted with the USFWS as required by section 7(a)(2) of the 

ESA in that regard.

3.9.3.1.5.2 Impacts from Vessel Noise Under Alternative 2

Impacts from Vessel Noise Under Alternative 2 for Training Activities

While there would be an increase in the amount of at-sea vessel time during training under Alternative 

2, the general locations and types of effects due to vessel noise would be the same as described in 

Alternative 1. Therefore, the general locations and types of effects due to vessel noise described above 

for training under Alternative 1 would be similar under Alternative 2. Navy vessel noise would continue 

to be a minor contributor to overall radiated vessel noise in the exclusive economic zone.

Pursuant to the ESA, vessel noise during training activities as described under Alternative 2 will have no 

effect on piping plover critical habitat. Vessel noise during training activities as described under 

Alternative 2 may affect roseate terns, red knots, Bermuda petrels, piping plovers, Indiana bats, and 

northern long-eared bats.

Impacts from Vessel Noise Under Alternative 2 for Testing Activities 

The difference in vessel noise contributed by testing activities under Alternative 2 compared to 

Alternative 1 is so small as to not be discernable. Therefore, the general locations and types of effects 

due to vessel noise described above for testing under Alternative 1 would be the same under Alternative 

2. Navy vessel noise would continue to be a minor contributor to overall radiated vessel noise in the 

exclusive economic zone.

Pursuant to the ESA, vessel noise during testing activities as described under Alternative 2 will have no 

effect on piping plover critical habitat. Vessel noise during testing activities as described under 

Alternative 2 may affect roseate terns, red knots, Bermuda petrels, piping plovers, Indiana bats, and 

northern long-eared bats. 
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3.9.3.1.5.3 Impacts from Vessel Noise Under No Action Alternative 

Impacts from Vessel Noise Under No Action Alternative for Training and Testing Activities 

Under the No Action Alternative, the Navy would not conduct the training and testing activities in the 

AFTT Study Area. Various acoustic stressors (e.g., vessel noise) would not be introduced into the marine 

environment. Therefore, baseline conditions of the existing environment would either remain 

unchanged or would improve slightly after cessation of ongoing training and testing activities.

3.9.3.1.6 Impacts from Aircraft Noise

Birds and bats could be exposed to airborne noise associated with subsonic and supersonic fixed-wing 

aircraft and helicopter overflights while foraging or migrating in open water, nearshore, or coastal 

environments within the Study Area. Tilt-rotor impacts would be similar to fixed-wing or helicopter 

impacts depending which mode the aircraft is in. A description of aircraft noise produced during Navy 

activities is provided in Section 3.0.3.3.1.5 (Aircraft Overflight Noise).

Exposure to fixed-wing aircraft noise would be brief as an aircraft quickly passes overhead. Exposures 

would be infrequent based on the transitory and dispersed nature of the overflights; repeated exposure 

of individual birds and bats over a short period of time (hours or days) is unlikely. Birds repeatedly 

exposed to aircraft noise often become habituated to the noise and do not respond behaviorally (Larkin 

et al., 1996; National Park Service, 1994; Plumpton, 2006). However, habituation seems unlikely in the 

Study Area given the widely dispersed and infrequent nature of the operations.

Common behavioral responses of wildlife to aircraft noise include no response or stationary alert 

behavior (Johnson & Reynolds, 2002), startle response, flying away, and increased vocalizations (Bowles, 

1995; Larkin et al., 1996; National Park Service, 1994). In some instances, behavioral responses could 

interfere with breeding, raising young, foraging, habitat use, and physiological energy budgets, 

particularly when an animal continues to respond to repeated exposures. The potential for masking of 

calls in air is possible if a bird or bat remains in the area; however, due to the transitory nature of 

aircraft overflights, the duration of masking would be limited.

Some air combat maneuver training would involve high altitude, supersonic flight, which would produce 

sonic booms, but such airspeeds would be infrequent and are typically conducted at high altitudes and 

far from shore, limiting the areas where birds and bats could be exposed. Boom duration is generally 

less than 300 milliseconds. Sonic booms would cause seabirds to startle, but the exposure would be 

brief, and any reactions are expected to be short-term. Startle impacts range from altering behavior 

(e.g., stop feeding or preening), minor behavioral changes (e.g., head turning), or at worst, a flight 

response. Because most fixed-wing flights are not supersonic and birds, bats, and aircraft are transient 

in any area, exposure of birds and bats in the open ocean to sonic booms would be infrequent. It is 

unlikely that individual birds or bats would be repeatedly exposed to sonic booms in the open ocean.

Helicopters typically operate below 1,000 ft. (304.8 m) altitude and often occur as low as 75–100 ft. 

(22.9–30.5 m) altitude. This low-altitude increases the likelihood that birds and bats would respond to 

noise from helicopter overflights with reactions such as flushing (Stalmaster & Kaiser, 1997), although a 

large portion of birds may exhibit no reaction to nearby helicopters (Grubb et al., 2010). Helicopters 

travel at slower speeds (less than 100 knots) which increases the duration of noise exposure compared 

to fixed-wing aircraft. Helicopter flights are generally limited to locations closer to the coast, unless 

deployed onboard ships. Helicopter flights, therefore, are more likely to impact the greater numbers of 

birds and bats that forage in coastal areas than those that forage in open ocean areas. Nearshore areas 
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of the coast are the primary foraging habitat for many bird species. The presence of dense aggregations 

of sea ducks, other seabirds, and migrating land birds is a potential concern during low-altitude 

helicopter activities. Although birds may be more likely to react to helicopters than to fixed-wing 

aircraft, Navy helicopter pilots avoid large flocks of birds to protect aircrews and equipment, thereby 

reducing disturbance to birds as well. Within the Virginia Capes Range Complex, during mine 

countermeasure and neutralization activities, helicopters will remain at least 1 nautical miles (NM) from 

the beach except when transiting offshore. When transiting from Norfolk Naval Station to waters 

offshore, helicopters will avoid overflying Fisherman Island National Wildlife Refuge off the coast of 

Cape Charles, Virginia by at least 3,000 ft. vertically and horizontally to avoid disturbing ESA-listed piping 

plovers and other birds. Noise from low-altitude helicopter overflights would only be expected to elicit 

short-term behavioral or physiological responses in exposed birds and bats. 

Birds in areas that may experience repeated exposure often habituate and do not respond behaviorally 

(Larkin et al., 1996; National Park Service, 1994; Plumpton, 2006). Throughout the Study Area, repeated 

exposure of individual birds or groups of birds is unlikely based on the dispersed nature of the 

overflights and the capability of birds to avoid or rapidly vacate an area of disturbance. Therefore, the 

general health of individual birds would not be compromised. Although no studies have been conducted 

specifically investigating the impact of aircraft noise on bats, bats are expected to adjust their call 

frequency when in the presence of high-frequency sounds within their own range of emissions as well as 

avoid areas of high levels of broadband background noise (Bates et al., 2008). Therefore, if the aircraft 

noise were within the bats’ hearing range the area would be expected to be avoided or the bat would 

adjust their call frequency. Occasional startle or alert reactions to aircraft noise are not likely to disrupt 

major behavior patterns (such as migrating, breeding, feeding, and sheltering) or to result in serious 

injury to any birds or bats.

3.9.3.1.6.1 Impacts from Aircraft Noise Under Alternative 1

Impacts form Aircraft Noise Under Alternative 1 for Training Activities

Characteristics of aircraft noise are described in Section 3.0.3.3.1 (Acoustic Stressors) and the number of 

training activities that include aircraft under Alternative 1 are shown in Section 3.0.3.3.4.4 (Aircraft). 

Training activities with aircraft would be conducted as described in Chapter 2 (Description of Proposed 

Action and Alternatives) and Appendix A (Navy Activity Descriptions). Aircraft overflights would usually 

occur near Navy airfields, installations, and in special use airspace within Navy range complexes. Aircraft 

flights during training would be most concentrated within the Virginia Capes, Navy Cherry Point, 

Jacksonville, and Key West Range Complexes.

Most helicopter training would occur adjacent to fleet concentration areas at Naval Station Norfolk 

(including lower Chesapeake Bay and inshore estuarine areas) and at Naval Station Mayport, 

Jacksonville, Florida; in Onslow Bay, North Carolina; and in the waters off the coast of Naval Surface 

Warfare Center, Panama City Testing Range. Helicopters use the shortest route available and do not fly 

adjacent to the coastline when flying to the training and testing areas. Takeoffs and landings on vessels 

at sea would occur at unspecified locations throughout the Study Area.

Navy aircraft training activities over the Atlantic Ocean are concentrated near the outer continental 

shelf and the Gulf Stream. Pelagic birds that forage offshore may have greater presence in these 

productive areas. A bird in the open ocean could be exposed for a few seconds to fixed-wing aircraft 

noise as the aircraft quickly passes overhead. If present in the open water areas where training activities 

involving aircraft overflights occur, roseate terns, red knots, Bermuda petrels, Indiana bats, and 
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northern long-eared bats could be temporarily disturbed while foraging or migrating. Birds foraging or 

migrating through a training area in the open ocean may respond by avoiding areas of temporarily 

concentrated aircraft noise. Exposures to most seabirds would be infrequent, based on the brief 

duration and dispersed nature of the overflights. 

Most helicopter activities are transient in nature, although helicopters could also hover for extended 

periods. Activities involving helicopters would occur closer to the coast and in inshore estuarine 

locations. Activities involving helicopters may occur for extended periods of time, up to a couple of 

hours in some areas, increasing the potential for exposure. In addition to daytime activities, activities 

involving helicopters could also occur at night, increasing the potential for exposure to bats. During 

these activities, helicopters would typically transit throughout an area and may hover over the water. 

Longer activity durations and periods of time where helicopters hover may increase the potential for 

behavioral reactions, startle reactions, and physiological stress. However, the likelihood that birds or 

bats would remain in the immediate vicinity while an aircraft or helicopter transits directly nearby would 

be low. Helicopters that hover in a fixed location for an extended period of time could increase the 

potential for exposure. However, impacts from training activities would be highly localized and

concentrated in space and duration.

If a bird or bat responds to aircraft noise, only short-term behavioral responses such as startle 

responses, head turning, or avoidance responses would be expected. Repeated exposures would be 

limited due to the transient nature of aircraft use and regular movement of birds and bats. Because 

impacts to individual birds and bats, if any, are expected to be minor and limited, no long-term 

consequences to individuals are expected. Accordingly, there would be no consequences to any bird or 

bat populations, and aircraft overflight noise will not have a significant adverse effect on populations of 

migratory bird species. Within the Virginia Capes Range Complex, during mine countermeasure and 

neutralization activities, helicopters will remain at least 1 NM from the beach except when transiting 

offshore. When transiting from Norfolk Naval Station to waters offshore, helicopters will avoid 

overflying Fisherman Island National Wildlife Refuge off the coast of Cape Charles, Virginia by at least 

3,000 ft. vertically and horizontally to avoid disturbing ESA-listed piping plovers and other birds.

Critical habitat for wintering piping plovers is designated in the Marquesas Keys. Although there could 

be intermittent increases in ambient noise levels, aircraft overflights would not impact the ability of 

critical habitat designated in the Marquesas Keys to support roosting, refuge, or feeding of wintering 

piping plovers.

Pursuant to the ESA, aircraft noise during training activities as described under Alternative 1 will have no 

effect on piping plover critical habitat. Aircraft noise during training activities as described under 

Alternative 1 may affect roseate terns, red knots, piping plovers, Bermuda petrels, Indiana bats, and

northern long-eared bats. The Navy has consulted with the USFWS as required by section 7(a)(2) of the 

ESA in that regard.

Impacts from Aircraft Noise Under Alternative 1 for Testing

Characteristics of aircraft noise are described in Section 3.0.3.3.1 (Acoustic Stressors) and the number of 

testing activities with aircraft under Alternative 1 are shown in Section 3.0.3.3.4.4. (Aircraft). Testing 

activities using aircraft would be conducted as described in Chapter 2 (Description of Proposed Action 

and Alternatives) and Appendix A (Navy Activity Descriptions). Aircraft overflights would usually occur 

near Navy airfields, installations, and in special use airspace within Navy range complexes. Testing 

activities with aircraft would be most concentrated in the Virginia Capes Range Complex. 
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Flights involving sonic booms would occur in the area of the Delmarva Peninsula in Virginia Capes, which 

has the potential to result in startle responses from foraging piping plovers, red knots, and roseate 

terns, as well as nesting piping plovers. These flights occur offshore and parallel to the peninsula, and up 

to 60 percent involve a turn towards shore. Of the scheduled flights, only 85 percent may actually go 

supersonic. Only 30 percent of the flights will be conducted below 20,000 ft., and none of these flights 

will be conducted below 5,000 ft. 

Navy aircraft testing activities over the Atlantic Ocean are concentrated near the outer continental shelf 

and the Gulf Stream. Pelagic birds that forage offshore may have greater presence in these productive 

areas. A bird or bat in the open ocean could be exposed for a few seconds to fixed-wing aircraft noise as 

the aircraft quickly passes overhead. If present in the open water areas where testing activities involving 

aircraft overflights occur, roseate terns, red knots, Bermuda petrels, Indiana bats, and northern longeared bats could be temporarily disturbed while foraging or migrating. Birds and bats foraging or 

migrating through a training area in the open ocean may respond by avoiding areas of temporarily 

concentrated aircraft noise. Exposures to most birds and bats would be infrequent, based on the brief 

duration and dispersed nature of the overflights. 

Most helicopter activities are transient in nature, although helicopters could also hover for extended 

periods. Activities involving helicopters would occur closer to the coast and in inshore estuarine 

locations. Activities involving helicopters may occur for extended periods of time, up to a couple of 

hours in some areas, increasing the potential for exposure. In addition to daytime activities, activities 

involving helicopters could also occur at night, increasing the potential for exposure to bats. During 

these activities, helicopters would typically transit throughout an area and may hover over the water. 

Longer activity durations and periods of time where helicopters hover may increase the potential for 

behavioral reactions, startle reactions, and physiological stress. However, the likelihood that birds or 

bats would remain in the immediate vicinity while an aircraft or helicopter transits directly nearby would 

be low. Helicopters that hover in a fixed location for an extended period of time could increase the 

potential for exposure. However, impacts from training activities would be highly localized and 

concentrated in space and duration.

If a bird or bat responds to aircraft noise, only short-term behavioral responses such as startle 

responses, head turning, or avoidance responses would be expected. Repeated exposures would be 

limited due to the transient nature of aircraft use and regular movement of birds and bats. Because 

impacts to individual birds or bats, if any, are expected to be minor and limited, no long-term 

consequences to individuals are expected. Accordingly, there would be no consequences to any bird or 

bat populations, and aircraft overflight noise will not have a significant adverse effect on populations of 

migratory bird species.

Critical habitat for wintering piping plovers is designated in the Marquesas Keys. Although there could 

be intermittent increases in ambient noise levels, aircraft overflights would not impact the ability of 

critical habitat designated in the Marquesas Keys to support roosting, refuge, or feeding of wintering 

piping plovers. 

Pursuant to the ESA, aircraft overflight noise during testing activities as described under Alternative 1 

will have no effect on piping plover critical habitat. Aircraft noise during testing activities as described 

under Alternative 1 may affect roseate terns, red knots, piping plovers, Bermuda petrels, Indiana bats, 

and northern long-eared bats. The Navy has consulted with the USFWS as required by section 7(a)(2) of 

the ESA in that regard.
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3.9.3.1.6.2 Impacts from Aircraft Noise Under Alternative 2

Impacts from Aircraft Noise Under Alternative 2 for Training Activities

There would be minor increase in aircraft overflights under Alternative 2 compared to Alternative 1; 

however, the types of impacts would not be discernible from those described for training under 

Alternative 1.

Pursuant to the ESA, aircraft overflight noise during training activities as described under Alternative 2 

will have no effect on piping plover critical habitat. Aircraft noise during training activities as described 

under Alternative 2 may affect roseate terns, red knots, piping plovers, Bermuda petrels, Indiana bats, 

and northern long-eared bats. 

Impacts from Aircraft Noise Under Alternative 2 for Testing Activities 

There would be a minor increase in aircraft overflights under Alternative 2 compared to Alternative 1; 

however, the types of impacts would not be discernible from those described for testing under 

Alternative 1. 

Pursuant to the ESA, aircraft overflight noise during testing activities as described under Alternative 2 

will have no effect on piping plover critical habitat. Aircraft noise during testing activities as described 

under Alternative 2 may affect roseate terns, red knots, piping plovers, Bermuda petrels, Indiana bats, 

and northern long-eared bats. 

3.9.3.1.6.3 Impacts from Aircraft Noise Under No Action Alternative 

Impacts from Aircraft Noise Under No Action Alternative for Training and Testing Activities 

Under the No Action Alternative, the Navy would not conduct the training and testing activities in the 

AFTT Study Area. Various acoustic stressors (e.g., aircraft noise) would not be introduced into the 

marine environment. Therefore, baseline conditions of the existing environment would either remain 

unchanged or would improve slightly after cessation of ongoing training and testing activities.

3.9.3.1.7 Impacts from Weapons Noise 

Birds and bats may be exposed to sounds caused by the firing of weapons, objects in flight, and the 

impact of non-explosive projectiles on the water's surface. Other devices intentionally produce noise to 

serve as a non-lethal deterrent. These sounds are described in Section 3.0.3.3.1.6 (Weapons Noise). 

Navy training activities in the Study Area include firing or launching a variety of weapons, including 

missiles; rockets; and small-, medium-, and large-caliber projectiles. Most weapons firing activities occur 

far from shore, limiting most possible exposures to birds that forage or migrate greater than 3 NM 

offshore. In addition to noise from weapons firing and launching, birds and bats could be briefly 

disturbed by the impact of non-explosive practice munitions at the water surface. Because of the 

potential for blast injury due to explosives, the impacts due to explosive munitions and other explosives 

used during Navy activities are discussed in Section 3.9.3.2.2 (Impacts from Explosives).

Sounds produced by weapons firing (muzzle blast), launch boosters, and projectile travel are potential 

stressors to birds and bats. Sound generated by a muzzle blast is intense, but very brief. A bird or bat 

very close to a large weapons blast could be injured or experience hearing loss due to acoustic trauma 

or threshold shift. Sound generated by a projectile travelling at speeds greater than the speed of sound 

can produce a low amplitude bow shock wave in a narrow area around its flight path. Inert objects 

hitting the water surface would generate a splash and the noise may disturb nearby birds and bats. Bird 

and bat responses to weapons-firing and projectile travel noise may include short-term behavioral or 
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physiological responses such as alert responses, startle responses, or temporary increases in heart rate. 

Studies of impacts of weapons noise on raptors show that these birds show little reaction (e.g., head 

turn) and do not alter behavior in the presence of noise from weapons testing (Brown et al., 1999; 

Schueck et al., 2001; Stalmaster & Kaiser, 1997). Once surface weapons firing activities begin, birds and 

bats would likely disperse away from the area around the ship and the path of projectiles if disturbed. 

Other activities in the general area that precede these activities, such as vessel movement or target 

setting, could potentially disperse birds away from the area in which weapons-firing noise would occur.

Species such as frigatebirds and sooty terns seem to avoid vessels (Borberg et al., 2005; Hyrenbach, 

2006). Increased ship activity could drive these and other species from their natural habitat at a critical 

time or in an important foraging area (Borberg et al., 2005). On the other hand, some birds commonly 

follow vessels, including certain species of gulls, storm petrels, and albatrosses (Hamilton, 1958; 

Hyrenbach, 2001, 2006). A number of bird species are attracted to ships because of the increased 

potential for foraging success (Dietrich & Melvin, 2004; Melvin et al., 2001). The propeller wake 

generated by all ships, but particularly larger ships, disrupts the water column, causing prey to be 

brought to the surface where it is more easily captured by a greater variety of bird species. Birds that 

are attracted to ships could be more likely to be exposed to weapons firing noise.

Airborne weapons firing at airborne targets typically occur at high altitudes of 15,000–25,000 ft. during 

air-to-air gunnery exercises. Noise generated by firing at such high altitudes is unlikely to generate a 

strong reaction in birds or bats migrating at lower altitudes or foraging at the surface. While several 

studies have shown that bats typically fly lower than 10 m above sea level (Ahlén et al., 2009; Pelletier et 

al., 2013), others have shown that migrating bats have been observed over 200 m above sea level (Hatch 

et al., 2013; Sjollema et al., 2014). The altitudes at which migrating birds fly can vary greatly based on 

the type of bird, where they are flying (over water or over land), and other factors such as weather. 

Approximately 95 percent of bird flight during migrations occurs below 10,000 ft. (3,048 m) with the 

majority below 3,000 ft. (914 m) (Lincoln et al., 1998). While there is considerable variation, the favored 

altitude for most small birds appears to be between 500 ft. (152 m) and 1,000 ft. (305 m).

Literature on non-migratory flight altitudes for the four ESA protected species varies in availability. 

Perkins et al. (2004) found that during the breeding period, most common and roseate terns flew at 

altitudes below 21 m. The average height from which roseate terns plunge-dive for fish is 4.4 m above 

the water’s surface (Duffy, 1986), and foraging flights rarely, if ever, exceed 12 m in height (Hatch & 

Kerlinger, 2004; Mostello, 2007). Perkins et al. (2004) recorded most terns (common and roseate) seen 

in Nantucket Sound (less than 10 mi. offshore) flying at altitudes of less than 30 m. Non-migratory piping 

plover flight altitude is normally below 120 m, except for courtship flights, which are land-based (U.S. 

Fish and Wildlife Service, 2008a). Red knot and Bermuda petrel information was not available for nonmigratory flight heights.

If a bird or bat does not avoid the area of Navy activity and is in the vicinity of a muzzle blast from a 

large-caliber gun or the bow shock wave of a large supersonic projectile, the potential for auditory 

impacts exists. If in the immediate vicinity of a large gun muzzle blast, a bird could experience peak SPLs 

that have been shown to cause a permanent reduction in hearing sensitivity over the low-frequency 

portion of hearing range (see Section 3.9.3.1.1.2, Hearing Loss). Similarly, the bow shock waves of larger 

projectiles would create a zone around the path of the projectile where a bird or bat could experience 

auditory effects due to the near-instantaneous passing of a high peak pressure wave (subjectively a 

“crack” sound). The estimated range to peak sound levels shown to cause permanent reduction in 

hearing sensitivity over a portion of a bird’s hearing range from the projectile path of a large-caliber gun 
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projectile travelling at supersonic speed is about 10 m. Data for onset of PTS is unavailable, but the 

range to onset of PTS can be assumed to extend beyond 10 m from a large-caliber projectile path. The 

amplitude of the bow shock wave would increase with supersonic projectile size and speed. Because 

most projectiles spend all or part of their travel path at altitudes above 20 m, impacts to many low-flying 

seabirds would be minimal.

The impulsive sound caused by weapon firings would have limited potential to mask any important 

biological sound simply because the duration of the impulse is brief, even when multiple shots are fired 

in series.

3.9.3.1.7.1 Impacts from Weapons Noise Under Alternative 1

Impacts form Weapons Noise Under Alternative 1 for Training Activities

Activities using weapons and deterrents would be conducted as described in Chapter 2 (Description of 

Proposed Action and Alternatives) and Appendix A (Navy Activity Descriptions). General characteristics 

of types of weapons noise are described in Section 3.0.3.3.1.6 (Weapons Noise), and quantities and 

locations of expended non-explosive practice munitions and explosives (fragment-producing) for 

training under Alternative 1 are shown in 3.0.3.3.4.2. (Military Expended Materials). (For explosive 

munitions, only associated firing noise is considered in the analysis of weapons noise. The noise 

produced by the detonation of explosive weapons is analyzed in Section 3.0.3.3.2, Explosive Stressors).

Use of weapons during training would typically occur in the range complexes, with greatest use of most 

types of munitions in the Virginia Capes, Navy Cherry Point, and Jacksonville Range Complexes. Most 

activities involving large-caliber naval gunfire or the launching of targets, missiles, bombs, or other 

munitions are conducted more than 3 NM from shore. 

Most sounds would be brief, lasting from less than a second for a blast or inert impact to a few seconds 

for other launch and object travel sounds. Most incidents of impulsive sounds produced by weapons 

firing, launch, or inert object impacts would be single events, with the exception of gunfire activities. 

Variants of the Long Range Acoustic Device are used both on vessels and on piers. These devices 

communicate voice, tones, or prerecorded tracks within the range of human hearing and may reach 

birds within 3,000 m of the device. Birds have the potential to be briefly startled or temporarily 

displaced during training with this device, though it is unlikely this device will produce sounds within the 

hearing range of bats.

Birds and bats that migrate or forage in open ocean areas could be exposed to large-caliber weapons 

noise, including foraging and migrating Bermuda petrels, migrating roseate terns, and migrating red 

knots. All species could be exposed to small- and medium-caliber weapons noise that may occur closer 

to shore. Temporary disturbance due to weapons noise is not expected to result in major impacts on 

these ESA-listed species. Because large weapons firing would typically occur offshore, roseate tern 

nesting colonies in the Key West Range Complex are unlikely to be disturbed. Piping plovers would not 

be present in the offshore areas where weapons are fired; additionally, weapons firing noise would not 

overlap with piping plover critical habitat. 

Because weapon firing occurs at varying locations over a short time period and seabird and bat presence 

changes seasonally and on a short-term basis, individual birds and bats would not be expected to be 

repeatedly exposed to weapons firing, launch, or projectile noise. Any impacts on migratory or breeding 

seabirds and bats related to startle reactions, displacement from a preferred area, or reduced foraging 

success in offshore waters would likely be short-term and infrequent. Because impacts to individual 
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birds and bats, if any, are expected to be minor and limited, no long-term consequences to individuals 

are expected. Accordingly, there would be no consequences to any bird or bat populations, and

weapons noise will not have a significant adverse effect on populations of migratory bird species.

Pursuant to the ESA, weapons noise during training activities described under Alternative 1 will have no 

effect on piping plover critical habitat. Weapons noise during training activities described under 

Alternative 1 may affect Indiana bats, northern long-eared bats, piping plovers, Bermuda petrels, 

roseate terns, and red knots. The Navy has consulted with the USFWS as required by section 7(a)(2) of 

the ESA in that regard.

Impacts from Weapons Noise Under Alternative 1 for Testing

Activities using weapons and deterrents would be conducted as described in Chapter 2 (Description of 

Proposed Action and Alternatives) and Appendix A (Navy Activity Descriptions). General characteristics 

of types of weapons noise are described in Section 3.0.3.3.1.6 (Weapons Noise), and quantities and 

locations of expended non-explosive practice munitions and explosives (fragment-producing) for testing 

under Alternative 1 are shown in 3.0.3.3.4.2. (Military Expended Materials). [For explosive munitions, 

only associated firing noise is considered in the analysis of weapons noise. The noise produced by the 

detonation of explosive weapons is analyzed in Section 3.9.3.2 (Explosive Stressors)].

Use of weapons during testing would typically occur on the range complexes, with some activity also 

occurring on testing ranges. Most activities involving large-caliber naval gunfire or the launching of 

targets, missiles, bombs, or other munitions are conducted more than 3 NM from shore. 

All of these sounds would be brief, lasting from less than a second for a blast or inert impact to few 

seconds for other launch and object travel sounds. Most incidents of impulsive sounds produced by 

weapons firing, launch, or inert object impacts would be single events, with the exception of gunfire 

activities.

Birds and bats that migrate or forage in open ocean areas could be exposed to large-caliber weapons 

noise, including foraging and migrating Bermuda petrels, migrating roseate terns, and migrating red 

knots. All species could be exposed to small- and medium-caliber weapons noise that may occur closer 

to shore. Temporary disturbance due to weapons noise is not expected to result in major impacts on 

these ESA-listed species. Because large weapons firing would typically occur offshore, roseate tern 

nesting colonies in the Key West Range Complex are unlikely to be disturbed. Piping plovers would not 

be present in the offshore areas where weapons are fired; additionally, weapons firing noise would not 

overlap with piping plover critical habitat. 

Because weapon firing occurs at varying locations over a short time period and seabird and bat presence 

changes seasonally and on a short-term basis, individual birds and bats would not be expected to be 

repeatedly exposed to weapons firing, launch, or projectile noise. Any impacts on migratory or breeding 

seabirds and bats related to startle reactions, displacement from a preferred area, or reduced foraging 

success in offshore waters would likely be short-term and infrequent. Because impacts to individual 

birds and bats, if any, are expected to be minor and limited, no long-term consequences to individuals 

are expected. Accordingly, there would be no consequences to any bird or bat populations, and 

weapons noise will not have a significant adverse effect on populations of migratory bird species.

Pursuant to the ESA, weapons noise during testing activities described under Alternative 1 will have no 

effect on piping plover critical habitat. Weapons noise during testing activities described under 

Alternative 1 may affect Indiana bats, northern long-eared bats, piping plovers, Bermuda petrels, 
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roseate terns, and red knots. The Navy has consulted with the USFWS as required by section 7(a)(2) of 

the ESA in that regard.

3.9.3.1.7.2 Impacts from Weapons Noise Under Alternative 2

Impacts from Weapons Noise Under Alternative 2 for Training Activities

There would be minor increase in weapons use under Alternative 2 compared to Alternative 1; however, 

the types of impacts and locations of impacts would be the same as those described for training under 

Alternative 1. Because impacts to individual birds or bats, if any, are expected to be minor and limited, 

no long-term consequences to individuals are expected. Accordingly, there would be no consequences 

to any bird or bat populations, and weapons noise will not have a significant adverse effect on 

populations of migratory bird species.

Pursuant to the ESA, weapons noise during training activities described under Alternative 2 will have no 

effect on piping plover critical habitat. Weapons noise during training activities described under 

Alternative 2 may affect Indiana bats, northern long-eared bats, piping plovers, Bermuda petrels, 

roseate terns, and red knots. 

Impacts from Weapons Noise Under Alternative 2 for Testing Activities 

There would be a minor increase in weapons use under Alternative 2 compared to Alternative 1; 

however, the types and locations of impacts would be the same as those described for testing under 

Alternative 1. Because impacts to individual birds or bats, if any, are expected to be minor and limited, 

no long-term consequences to individuals are expected. Accordingly, there would be no consequences 

to any bird or bat populations, and weapons noise will not have a significant adverse effect on 

populations of migratory bird species.

Pursuant to the ESA, weapons noise during testing activities described under Alternative 2 will have no 

effect on piping plover critical habitat. Weapons noise during testing activities described under 

Alternative 2 may affect Indiana bats, northern long-eared bats, piping plovers, Bermuda petrels, 

roseate terns, and red knots. 

3.9.3.1.7.3 Impacts from Weapons Noise Under No Action Alternative 

Impacts from Weapons Noise Under No Action Alternative for Training and Testing Activities 

Under the No Action Alternative, the Navy would not conduct the training and testing activities in the 

AFTT Study Area. Various acoustic stressors (e.g., weapons noise) would not be introduced into the 

marine environment. Therefore, baseline conditions of the existing environment would either remain 

unchanged or would improve slightly after cessation of ongoing training and testing activities.

3.9.3.2 Explosive Stressors

Explosions in the water, near the water surface, and in the air can introduce loud, impulsive, broadband 

sounds into the marine environment. But, unlike other acoustic stressors, explosives release energy at a 

high rate producing a shock wave that can be injurious and even deadly. Therefore, explosive impacts to 

birds and bats are discussed separately from other acoustic stressors, even though the analysis of 

explosive impacts will rely on data for bird and bat impacts due to impulsive sound exposure where 

appropriate.

Explosives are usually described by their net explosive weight, which accounts for the weight and type of 

explosive material. Additional explanation of the acoustic and explosive terms and sound energy 

concepts used in this section is found in Appendix D (Acoustic and Explosive Concepts).
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This section begins with a summary of relevant data regarding explosive impacts to birds and bats in 

Section 3.9.2.1 (General Background). The ways in which an explosive exposure could result in 

immediate effects or lead to long-term consequences for an animal are explained in Section 3.0.3.6.1

(Conceptual Framework for Assessing Effects from Acoustic and Explosive Stressors), and this section 

follows that framework. Studies of the effects of sound and energy from explosives on birds and bats are 

limited, therefore, where necessary, knowledge of impacts to other species from explosives is used to 

assess impacts to birds and bats.

3.9.3.2.1 Background

The sections below include a survey and synthesis of best-available-science published in peer-reviewed 

journals, technical reports, and other scientific sources pertinent to impacts to birds and bats potentially 

resulting from Navy training and testing activities. A range of impacts could occur to a bird or bat 

depending on the explosive source and context of the exposure. In addition to acoustic impacts 

including temporary or permanent hearing loss, auditory masking, physiological stress, or changes in 

behavior; potential impacts from an explosive exposure can include non-lethal injury and mortality.

3.9.3.2.2 Impacts from Explosives

3.9.3.2.2.1 Injury

If a bird or bat is close to an explosive detonation, the exposure to high pressure levels and sound 

impulse can cause barotrauma. Barotrauma is physical injury due to a difference in pressure between an 

air space inside the body and the surrounding air or water. Sudden very high pressures can also cause 

damage at tissue interfaces due to the way pressure waves travel differently through tissues with 

different material properties. Damage could also occur to the structure of the ear, considered to be the 

body part most susceptible to pressure damage. The differences between bird and bat respiratory 

systems indicate that bats may be more susceptible to pulmonary barotrauma than birds. Birds have 

compact, rigid lungs with strong pulmonary capillaries that do not change much in diameter when 

exposed to extreme pressure changes, while bats have large, pliable lungs that expand when exposed to 

a sudden drop in pressure causing tissue damage. Although the pressure reduction required to cause 

the type of internal injuries observed in bats is unknown, pressure differences as small as 4.4 kPa are 

lethal to Norway rats (Rattus norvegicus), which has been used as a surrogate species for bat 

barotrauma studies (Baerwald et al., 2008).

Detonations that occur underwater could injure, kill, or disturb diving birds, particularly pursuit divers 

that spend more time underwater than other foraging birds (Danil & St Leger, 2011). Studies show that 

birds are more susceptible to underwater explosions when they are submerged versus partially 

submerged on the surface. Two species of duck were exposed to explosive blasts while submerged 0.61 

m and while sitting on the water surface. Onset of mortality (LD1) was predicted to occur at an impulse 

exposure of 248 Pa-s (36 psi-ms) for birds underwater and 690 Pa-s (100 psi-ms) for birds at the water 

surface (Yelverton & Richmond, 1981). No injuries would be expected for birds underwater at blast 

pressures below 41 Pa-s (6 psi-msec) and for birds on the surface at blast pressures below 207 Pa-s (30 

psi-msec) (Yelverton & Richmond, 1981). Tests of underwater explosive exposures to other taxa (fish, 

mammals) have shown that susceptibility to injury is related to animal mass, with smaller animals being 

more susceptible to injury (Yelverton & Richmond, 1981). It is reasonable to assume that this 

relationship would apply to birds as well. The range to these thresholds would be based on several 

factors including charge size, depth of the detonation, and how far the bird is beneath the water 

surface.
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Detonations in air or at the water surface could also injure birds or bats while either in flight or at the 

water surface. Experiments that exposed small, medium, and large birds to blast waves in air were 

conducted to determine the exposure levels that would be injurious (Damon et al., 1974). Birds were 

assessed for internal injuries to air sacs, organs, and vasculature, as well as injury to the auditory 

tympanum, but internal auditory damage was not assessed. Results indicated that peak pressure 

exposure of 5 psi would be expected to produce no blast injuries, 10 psi would produce slight to 

extensive injuries, and 20 psi would produce 50 percent mortality. These results also suggested that 

birds with higher mass may be less susceptible to injury. In addition to the risk of direct blast injury, 

exposure to an explosion in air may cause physical displacement of a bird that could be injurious if the 

animal impacts a surface. The same study examined displacement injuries to birds (Damon et al., 1974). 

Results indicated that impulse exposures below 5 psi-msec would not be expected to result in injuries. 

One experiment was conducted with birds in flight, showing how birds can withstand relatively close 

exposures to in-air explosions (Damon et al., 1974). Flying pigeons were exposed to a 64-lb net explosive 

weight explosion. Birds at 44 to 126 ft. from the blast exhibited no signs of injury, while serious injuries 

were sustained at ranges less than 40 ft. The no injury zone in this experiment was also for exposures 

less than 5 psi-msec impulse, similar to the results of the displacement injury study.

Ranges to the no injury threshold for a range of in-air explosives are shown in Table 3.9-5. Data for birds 

in this study is assumed to also be applicable to bats due to similar body size.

Table 3.9-5: Range to No Blast Injury for Birds and Bats Exposed to Aerial Explosives 

Net explosive weight Range to 5 psi

5 lb. 21 ft.

10 lb. 26 ft.

100 lb. 57 ft.

Notes: Ranges calculated using the methods in U.S. 

Department of the Navy (1975).

Another risk of explosions in air is exposure to explosive fragmentation, in which pieces of the casing of 

a cased explosive are ejected at supersonic speeds from the explosion. The risk of direct strike by 

fragmentation would decrease exponentially with distance from the explosion, as the worst case for 

strike at any distance is the surface area of the casing fragments, which ultimately would decrease their 

outward velocity under the influence of drag. It is reasonable to assume that a direct strike in air or at 

the water surface would be mortal. Once in water, the drag on any fragments would quickly reduce their 

velocity to non-hazardous levels (Swisdak & Montanaro, 1992).

The initial detonation in a series of detonations may deter birds and bats from subsequent exposures via 

an avoidance response, however, birds have been observed taking interest in surface objects related to 

detonation events and subsequently being killed by a following detonation [Stemp, R. in Greene et al. 

(1985)].

3.9.3.2.2.2 Hearing Loss

Exposure to intense sound may result in hearing loss which persists after cessation of the noise 

exposure. There are no data on hearing loss in birds or bats specifically due to explosives; therefore, the 

limited data on hearing loss due to impulsive sounds, described for acoustic stressors in Section 

3.9.3.1.1.2 (Hearing Loss), apply to explosive exposures.
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3.9.3.2.2.3 Physiological Stress

Birds and bats naturally experience stressors within their environment and as part of their life histories. 

Changing weather and ocean conditions, exposure to diseases and naturally occurring toxins, lack of 

prey availability, social interactions with members of the same species, nesting, and interactions with 

predators all contribute to stress. Exposures to explosives have the potential to provide additional 

stressors beyond those that naturally occur, as described in Section 3.0.3.6.1 (Conceptual Framework for 

Assessing Effects from Acoustic and Explosive Stressors). 

There are no data on physiological stress in birds or bats specifically due to explosives; therefore, the 

limited data on physiological stress due to impulsive sounds, described for acoustic stressors in Section 

3.9.3.2.2.3 (Physiological Stress), apply to explosive exposures.

3.9.3.2.2.4 Masking

Masking occurs when one sound, distinguished as the ‘noise,’ interferes with the detection or 

recognition of another sound. Exposure to explosives may result in masking. There are no data on 

masking in birds or bats specifically due to explosives; therefore, the limited data on masking due to 

impulsive sounds, described for acoustic stressors in Section 3.9.3.2.2.4 (Masking), apply to explosive 

exposures. Due to the very brief duration of an explosive sound, any masking would be brief during an 

explosive activity.

3.9.3.2.2.5 Behavioral Reactions

Numerous studies have documented that birds and other wild animals respond to human-made noise, 

including aircraft overflights, weapons firing, and explosions (Larkin et al., 1996; National Park Service, 

1994; Plumpton, 2006). The limited data on behavioral reactions to impulsive sounds, described for 

acoustic stressors in Section 3.9.3.2.2.5 (Behavioral Reactions), apply to explosive exposures.

Because data on behavioral responses by birds and bats to explosions is limited, information on bird and 

bat responses to other impulsive sounds may be informative. Seismic surveys had no noticeable impacts 

on the movements or diving behavior of long-tailed ducks undergoing wing molt, a period in which flight 

is limited and food requirements are high (Lacroix et al., 2003). The birds may have tolerated the seismic 

survey noise to stay in preferred feeding areas. The sensitivity of birds to disturbance may also vary 

during different stages of the nesting cycle. Similar noise levels may be more likely to cause nest 

abandonment during incubation of eggs than during brooding of chicks because birds have invested less 

time and energy and have a greater chance of re-nesting (Knight & Temple, 1986).

3.9.3.2.2.6 Long-term Consequences 

Long-term consequences to birds and bats due to explosive exposures are considered following the 

Conceptual Framework for Assessing Effects from Acoustic and Explosive Activities (see Section 

3.0.3.6.1).

Long-term consequences to a population are determined by examining changes in the population 

growth rate. Physical effects that could lead to a reduction in the population growth rate include 

mortality or injury, which could remove animals from the reproductive pool, and permanent hearing 

impairment, which could impact foraging and communication. The long-term consequences due to 

individual behavioral reactions and short-term instances of physiological stress are especially difficult to 

predict because individual experience over time can create complex contingencies. It is more likely that 

any long-term consequences to an individual would be a result of costs accumulated over a season, 

year, or life stage due to multiple behavioral or stress responses resulting from exposures to multiple 
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stressors over significant periods of time. Conversely, some birds and bats may habituate to or become 

tolerant of repeated acoustic exposures over time, learning to ignore a stimulus that in the past did not 

accompany any overt threat. More research is needed to better understand the long-term 

consequences of anthropogenic stressors, although intermittent exposures to explosive noise are 

assumed to be less likely to have lasting consequences.

3.9.3.2.2.7 Impacts from Explosives Under Alternative 1

Impacts from Explosives Under Alternative 1 for Training Activities

Activities using explosives would be conducted as described in Chapter 2 (Description of Proposed 

Action and Alternatives) and Appendix A (Navy Activity Descriptions). General characteristics, quantities, 

and net explosive weights of underwater explosives used during training under Alternative 1 are 

provided in Section 3.0.3.3.2 (Explosive Stressors). Quantities and locations of fragment-producing 

explosives during training under Alternative 1 are shown in 3.0.3.3.4.2 (Military Expended Materials). 

Under Alternative 1, there could be fluctuation in the amount of explosives use that could occur 

annually, although potential impacts would be similar from year to year. 

Training activities involving explosions would typically be conducted in the range complexes, with 

greater occurrence in the Virginia Capes, Jacksonville, Navy Cherry Point, Gulf of Mexico, and Key West 

Range Complexes, and the lower Chesapeake Bay, although training activities could occur anywhere 

within the Study Area. Activities that involve underwater detonations and explosive munitions typically 

occur more than 3 NM from shore however, some mine warfare and demolition activities could also 

occur in shallow water close to shore. Some surface detonations could occur near areas with the 

potential for relatively high concentrations of seabirds or bats near the western frontal boundary of the 

Gulf Stream, including gunnery, bombing, and missile exercises in either Virginia Capes or Navy Cherry 

Point Range Complexes. Any impacts on seabirds and bats may be greater in these areas. There is no 

overlap of explosives and piping plover critical habitat.

Sound and energy generated by most small underwater explosions are unlikely to disturb birds and bats 

above the water surface. If a detonation is sufficiently large or is near the water surface, however, 

pressure will be released at the air-water interface. Birds and bats above this pressure release could be 

injured or killed. Explosives detonated at or just above the water surface, such as those used in antisurface warfare, would create blast waves that would propagate through both the water and air. 

Detonations in air could also injure birds and bats while either in flight or at the water surface. 

Detonations in air during anti-air warfare training would typically occur at much higher altitudes (greater 

than 3,000 ft. [914 m] above sea level) where seabirds, migrating birds, and bats are less likely to be 

present, although some events target incoming threats at lower altitudes. Detonations of bombs with 

larger net explosive weight, any event employing static targets, or multiple detonations could be more 

likely to cause seabird mortalities or injuries. If prey species, such as fish, are killed or injured as a result 

of detonations, some birds may continue to forage close to the area, or may be attracted to the area 

and be exposed to subsequent detonations in the same area within a single event, such as gunnery

exercises, which involves firing multiple high-explosive 5-in. rounds at a target area; bombing exercises, 

which could involve multiple bomb drops separated by several minutes; or underwater detonations, 

such as multiple explosive ordnance disposal charges. However, a fleeing response to an initial explosion 

may reduce seabird and bat exposure to any additional explosions that occur within a short timeframe. 
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Detonations either in air or underwater have the potential to cause a permanent or TTS, which could 

affect the ability of a bird or bat to communicate with conspecifics or detect biologically relevant 

sounds.

An explosive detonation would likely cause a startle reaction, as the exposure would be brief and any 

reactions are expected to be short-term. Startle impacts range from altering behavior (e.g., stop feeding 

or preening), minor behavioral changes (e.g., head turning), or a flight response. The range of impacts 

could depend on the charge size, distance from the charge, and the animal’s behavior at the time of the 

exposure. Any impacts related to startle reactions, displacement from a preferred area, or reduced 

foraging success in offshore waters would likely be short-term and infrequent. 

Bermuda petrels and roseate terns may be present near the Gulf Stream, where detonations could 

occur, although little is known about Bermuda petrel distribution. Although Bermuda petrels and 

roseate terns could be present in range complexes where explosives are used, the likelihood of an 

injurious exposure is expected to be low based on the limited in-air range of injury from explosions and 

the expected low density of these birds. Piping plovers may be briefly disturbed in the vicinity of 

nearshore activities; however, they would not forage or migrate in the open ocean areas where other 

detonations occur. Red knots could be present during migration over open ocean areas where 

detonations could occur. If a detonation occurred in the vicinity of migrating red knots, impacts would 

likely be limited to short-term startle reactions. 

Because most events would consist of a limited number of detonations, exposures would not occur over 

long durations; and since events occur at varying locations, it is expected there would be an opportunity 

to recover from an incurred energetic cost and individual birds and bats would not be repeatedly 

exposed to explosive detonations. Indiana bats and northern long-eared bats may be briefly disturbed in 

the vicinity of nearshore activities, but do not forage or migrate in the open ocean areas where other 

detonations occur. Although a few individuals may experience long-term impacts and potential 

mortality, population-level impacts are not expected, and explosives will not have a significant adverse 

effect on populations of migratory bird species.

Pursuant to the ESA, the use of explosives during training activities described under Alternative 1 will 

have no effect on piping plover critical habitat. The use of explosives during training activities described 

under Alternative 1 may affect Bermuda petrels, roseate terns, piping plovers, red knots, Indiana bats, 

and northern long-eared bats. The Navy has consulted with the USFWS as required by section 7(a)(2) of 

the ESA in that regard.

Impacts from Explosives Under Alternative 1 for Testing Activities

Activities using explosives would be conducted as described in Chapter 2 (Description of Proposed 

Action and Alternatives) and Appendix A (Navy Activity Descriptions). General characteristics, quantities, 

and net explosive weights of underwater explosives used during training under Alternative 2 are 

provided in Section 3.0.3.3.2 (Explosive Stressors). Quantities and locations of fragment-producing 

explosives during training under Alternative 2 are shown in 3.0.3.3.4.2 (Military Expended Materials).

Testing activities involving explosions would typically be conducted in the range complexes, with greater 

occurrence in the Virginia Capes, Jacksonville, Northeast, Gulf of Mexico, Key West, and Navy Cherry 

Point Range Complexes, as well as the Naval Surface Warfare Center, Panama City Testing Range. Very 

few activities would be conducted in the Naval Undersea Warfare Center Division, Newport Testing 

Range, and the Naval Surface Warfare Center Carderock Division, South Florida Ocean Measurement 

Facility Testing Range. Small Ship Shock Trials could take place any season within the deep offshore 
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water of the Virginia Capes Range Complex or in the spring, summer or fall within the Jacksonville Range 

Complex and would occur up to three times over a 5-year period. The Large Ship Shock Trial could take 

place in the Jacksonville Range Complex during the Spring, Summer, or Fall and during any season within 

the deep offshore water of the Virginia Capes Range Complex or within the Gulf of Mexico. The Large 

Ship Shock Trial would occur once over 5 years. Activities that involve underwater detonations and 

explosive munitions typically occur more than 3 NM from shore; the exception is the designated 

underwater detonation area near Naval Surface Warfare Center, Panama City Division Testing Range, 

which is nearshore, partially within the surf zone. Some surface detonations could occur near areas with 

the potential for relatively high concentrations of seabirds and bats near the western frontal boundary 

of the Gulf Stream, including firing, bombing, and missile exercises in either Virginia Capes or Navy 

Cherry Point Range Complexes. Any impacts on seabirds or bats may be greater in these areas. There is 

no overlap of explosives and piping plover critical habitat. Although testing activities under Alternative 1 

differ in number and location from training activities under Alternative 1 and include Ship Shock trials, 

the types and severity of impacts would not be discernible from those described above in Impacts from 

Explosives under Alternative 1 for Training Activities.

Sound and energy generated by most small underwater explosions are unlikely to disturb birds and bats 

above the water surface. If a detonation is sufficiently large or is near the water surface, however, 

pressure will be released at the air-water interface. Birds and bats above this pressure release could be 

injured or killed. Explosives detonated at or just above the water surface, such as those used in antisurface warfare, would create blast waves that would propagate through both the water and air. 

Detonations in air could also injure birds and bats while either in flight or at the water surface. 

Detonations in air during anti-air warfare testing would typically occur at much higher altitudes (greater 

than 3,000 ft. [914 m] above sea level) where seabirds, migrating birds, and bats are less likely to be 

present, although some events target incoming threats at lower altitudes. Detonations of bombs with 

larger net explosive weights, any event employing static targets, or multiple detonations could be more 

likely to cause seabird mortalities or injuries. If prey species, such as fish, are killed or injured as a result 

of detonations, some birds may continue to forage close to the area, or may be attracted to the area,

and be exposed to subsequent detonations in the same area within a single event, such as firing 

exercises, which involves firing multiple high-explosive 5-in. rounds at a target area; bombing exercises, 

which could involve multiple bomb drops separated by several minutes; or underwater detonations, 

such as multiple explosive ordnance disposal charges. However, a fleeing response to an initial explosion 

may reduce seabird or bat exposure to any additional explosions that occur within a short timeframe. 

Detonations either in air or underwater have the potential to cause a permanent or TTS, which could 

affect the ability of a bird to communicate with conspecifics or detect biologically relevant sounds.

An explosive detonation would likely cause a startle reaction, as the exposure would be brief and any 

reactions are expected to be short-term. Startle impacts range from altering behavior (e.g., stop feeding 

or preening), minor behavioral changes (e.g., head turning), or a flight response. The range of impacts 

could depend on the charge size, distance from the charge, and the animal’s behavior at the time of the 

exposure. Any impacts related to startle reactions, displacement from a preferred area, or reduced 

foraging success in offshore waters would likely be short-term and infrequent. 

Bermuda petrels and roseate terns may be present near the Gulf Stream, where detonations could 

occur, although little is known about Bermuda petrel distribution. Although Bermuda petrel and roseate 

tern could be present in range complexes where explosives are used, the likelihood of an injurious 

exposure is expected to be low based on the limited in-air range of injury from explosions and the 
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expected low density of these birds. Piping plovers may be briefly disturbed in the vicinity of nearshore 

activities; however, they would not forage or migrate in the open ocean areas where other detonations 

occur. Red knots could be present during migration over open ocean areas where detonations could 

occur. If a detonation occurred in the vicinity of migrating red knots, impacts would likely be limited to 

short-term startle reactions. 

Because most events would consist of a limited number of detonations, exposures would not occur over 

long durations, and events occur at varying locations, it is expected there would be an opportunity to 

recover from an incurred energetic cost and individual birds and bats would not be repeatedly exposed 

to explosive detonations. Indiana bats and northern long-eared bats may be briefly disturbed in the 

vicinity of nearshore activities, but do not forage or migrate in the open ocean areas where other 

detonations occur. Although a few individuals may experience long-term impacts and potential 

mortality, population-level impacts are not expected, and explosives will not have a significant adverse 

effect on populations of migratory bird species. The Navy will implement mitigation to avoid potential 

impacts on birds during ship shock trials, including ceasing the detonation if flocks of seabirds are 

observed during the activity, as discussed in Chapter 5 (Mitigation).

Pursuant to the ESA, the use of explosives during testing activities described under Alternative 1 will 

have no effect on piping plover critical habitat. The use of explosives during testing activities described 

under Alternative 1 may affect Bermuda petrels, roseate terns, piping plovers, red knots, Indiana bats, 

and northern long-eared bats . The Navy has consulted with the USFWS as required by section 7(a)(2) of 

the ESA in that regard.

3.9.3.2.2.8 Impacts from Explosives Under Alternative 2

Impacts from Explosives Under Alternative 2 for Training Activities

There would be a minor increase in explosives use under Alternative 2 compared to Alternative 1; 

however, the types and locations of impacts would be the same as those described for training under 

Alternative 1. Most impacts to individual birds and bats, if any, are expected to be minor and limited. 

Although a few individuals may experience long-term impacts and potential mortality, population-level 

impacts are not expected, and explosives will not have a significant adverse effect on populations of 

migratory bird species.

Pursuant to the ESA, the use of explosives during training activities described under Alternative 2 will 

have no effect on piping plover critical habitat. The use of explosives during training activities described 

under Alternative 2 may affect Bermuda petrels, roseate terns, piping plovers, red knots, Indiana bats, 

and northern long-eared bats. 

Impacts from Explosives Under Alternative 2 for Testing Activities

There would be minor increase in explosives use under Alternative 2 compared to Alternative 1; 

however, the types of impacts and locations of impacts would be the same as those described for 

testing under Alternative 1. Most impacts to individual birds and bats, if any, are expected to be minor 

and limited. Although a few individuals may experience long-term impacts and potential mortality, 

population-level impacts are not expected, and explosives will not have a significant adverse effect on 

populations of migratory bird species.

Pursuant to the ESA, the use of explosives during testing activities described under Alternative 1 will 

have no effect on piping plover critical habitat. The use of explosives during testing activities described 
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under Alternative 2 may affect Bermuda petrels, roseate terns, piping plovers, red knots, Indiana bats, 

and northern long-eared bats. 

3.9.3.2.2.9 Impacts from Explosives Under the No Action Alternative

Impacts from Explosives Under the No Action Alternative for Training and Testing Activities

Under the No Action Alternative, the Navy would not conduct the training and testing activities in the 

AFTT Study Area. Various explosive stressors would not be introduced into the marine environment. 

Therefore, baseline conditions of the existing environment would either remain unchanged or would 

improve slightly after cessation of ongoing training and testing activities.

3.9.3.3 Energy Stressors

This section analyzes the potential impacts of the various types of energy stressors that can occur during 

training and testing activities within the Study Area. This section includes analysis of the potential 

impacts from (1) in-water electromagnetic devices, (2) in-air electromagnetic devices, and (3) highenergy lasers. As discussed in Section 3.0.3.3.3.3 (Lasers, subsection on Low-Energy Lasers), analysis has 

shown that low-energy lasers would not affect animals and therefore do not require further analysis.

3.9.3.3.1 Impacts from In-Water Electromagnetic Devices

Several different types of in-water electromagnetic devices are used during training and testing 

activities. In-water electromagnetic training and testing activities include an array of magnetic 

measuring components used in mine countermeasure operations in the Study Area. For information on 

the types of activities that use in-water electromagnetic devices, see Appendix B (Activity Stressor 

Matrices), Table B-1. For information on where they are used, and how many activities would occur 

under each alternative, see Section 3.0.3.3.3.1 (In-Water Electromagnetic Devices), Tables 3.0-14 and 

3.0-15. Aspects of in-water electromagnetic stressors that are applicable to marine organisms in general 

are presented in Section 3.0.3.6.2 (Conceptual Framework for Assessing Effects from Energy-Producing 

Activities). Potential impacts of those activities on birds and bats are applicable to everywhere in the 

Study Area that in-water electromagnetic devices are used. 

The kinetic energy weapon referred to as a rail gun is an in-water electromagnetic device that will be 

tested and eventually used in training events aboard surface vessels, firing non-explosive projectiles at 

land- or sea-based targets. This system charges for approximately two minutes and discharges in less 

than a second. The duration of the firing event is extremely short (about 8 milliseconds), which makes it 

quite unlikely that a bird or bat would fly over at the precise moment of firing. The short duration of 

each firing event also means that the likelihood of affecting any animal using magnetic fields for 

orientation is extremely small. Further, the high magnetic field levels experienced within 80 ft. of the 

launcher quickly dissipate and return to background levels beyond 80 ft. The magnetic field levels 

outside of the 80 ft. buffer zone would be below the most stringent guidelines for humans (i.e., people 

with pacemakers or active implantable medical devices). Therefore, the electromagnetic impacts would 

be temporary in nature and not expected to result in impacts on organisms (U.S. Department of the 

Navy, 2009), and are not analyzed further in this section.

Birds are known to use the Earth’s magnetic field as a navigational cue during seasonal migrations 

(Akesson & Hedenstrom, 2007; Fisher, 1971; Haftorn et al., 1988; Wiltschko & Wiltschko, 2005). Birds 

use numerous other orientation cues to navigate in addition to magnetic fields. These include position 

of the sun, celestial cues, visual cues, wind direction, and scent (Akesson & Hedenstrom, 2007; Fisher, 

1971; Haftorn et al., 1988; Wiltschko & Wiltschko, 2005). It is believed that birds are able to successfully 
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navigate long distances by using a combination of these cues. A magnetite-based (magnetic mineral) 

receptor mechanism in the upper beak of birds provides information on position and compass direction

(Wiltschko & Wiltschko, 2005).Towed in-water electromagnetic device impacts to birds would only occur 

underwater and would only impact diving species or species on the surface in the immediate area where 

the device is deployed. There is no information available on how birds react to electromagnetic fields 

underwater.

Since bats do not dive into water, in-water electromagnetic devices would not affect bats. As such, 

impacts to bats from in-water electromagnetic devices will not be discussed further.

3.9.3.3.1.1 Impacts from In-Water Electromagnetic Devices Under Alternative 1

Impacts from In-Water Electromagnetic Devices Under Alternative 1 for Training Activities

As indicated in Section 3.0.3.3.3.1 (In-Water Electromagnetic Devices) and Table 3.0-14, and described 

further in Appendix A (Navy Activity Descriptions), under Alternative 1, training activities involving inwater electromagnetic devices would occur in the Northeast and Southeast U.S. Continental Shelf Large 

Marine Ecosystems as well as Gulf Stream Open Ocean Area—specifically within the Virginia Capes, Navy 

Cherry Point, Jacksonville, and Gulf of Mexico Range Complexes. Use of in-water electromagnetic 

devices would be concentrated within the Virginia Capes Range Complex. Activities would also occur in 

one or more of the following bays or inshore waters (Table 3.0-15): Boston, Massachusetts;, Earle, New 

Jersey; Hampton Roads, Virginia; Delaware Bay, Delaware; Beaufort Inlet Channel, Morehead City, North 

Carolina; Wilmington, North Carolina; Savannah, Georgia; Kings Bay, Georgia; Mayport, Florida; Port 

Canaveral, Florida; Tampa, Florida; Sabine Lake, Beaumont, Texas; and Corpus Christi Bay, Corpus 

Christi, Texas.

The distribution of birds in these portions of the Study Area is patchy (Fauchald et al., 2002; Nevitt & 

Veit, 1999; Savoca, 2016; Schneider & Duffy, 1985). Exposure of birds would be limited to those foraging 

at or below the surface (e.g., terns, cormorants, loons, petrels, or grebes) because that is where the 

devices are used. Birds that forage onshore (e.g., piping plover or red knot) would not be exposed to 

these in-water electromagnetic stressors because in-water electromagnetic devices are not used in 

areas close to shore and are used only underwater. Also, the in-water electromagnetic fields generated 

would be distributed over time and location near mine warfare ranges and harbors, and any influence 

on the surrounding environment would be temporary and localized. More importantly, the in-water 

electromagnetic devices used are typically towed by a helicopter, surface ship, or unmanned vehicle. It 

is likely that any birds in the vicinity of an approaching vehicle towing an in-water electromagnetic 

device would be dispersed by the sound and disturbance generated by the vehicle (Section 3.9.3.4.1,

Impacts from Vessels and In-Water Devices, and Section 3.9.3.4.2, Impacts from Aircraft and Aerial 

Targets) and therefore move away from the vehicle and device before any exposure could occur. 

Designated piping plover critical habitat occurs throughout the coastal habitats of the Southeast U.S. 

Continental Shelf and Gulf of Mexico Large Marine Ecosystems; however, none of these areas overlap 

with the use of in-water electromagnetic devices in the Study Area. While piping plovers do forage in the 

intertidal portions of the Study Area, these areas do not overlap with any locations where in-water 

electromagnetic devices are used. Therefore, none of the in-water electromagnetic stressors would

affect piping plover critical habitat.

Impacts on birds from potential exposure to in-water electromagnetic devices would be temporary and 

inconsequential based on the: (1) relatively low intensity of the magnetic fields generated 

(0.2 microtesla at 656 ft. [200 m] from the source), (2) very localized potential impact area, 
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(3) temporary duration of the activities (hours), (4) occurrence only underwater, and (5) the likelihood 

that any birds in the vicinity of the approaching vehicles towing an in-water electromagnetic devices 

would move away from the vehicle and device before any exposure could occur. No long-term or 

population-level impacts are expected.

Pursuant to the ESA, the use of in-water electromagnetic devices during training activities as described 

under Alternative 1 would have no effect on Indiana bats, northern long-eared bats, piping plovers, red 

knots, or piping plover critical habitat; but may affect Bermuda petrels and roseate terns. The Navy has 

consulted with the USFWS as required by section 7(a)(2) of the ESA in this regard.

Impacts from In-Water Electromagnetic Devices Under Alternative 1 for Testing Activities

As indicated in Section 3.0.3.3.3.1 (In-Water Electromagnetic Devices) and Table 3.0-14, under 

Alternative 1, testing activities involving in-water electromagnetic devices would occur in the Northeast 

and Southeast U.S. Continental Shelf Large Marine Ecosystems as well as Gulf Stream Open Ocean 

Area—specifically within the Virginia Capes, Navy Cherry Point, Jacksonville, and Gulf of Mexico Range 

Complexes as well as the Naval Undersea Warfare Center Newport Testing Range, Naval Surface 

Warfare Center Carderock Division’s South Florida Ocean Measurement Facility, and Naval Surface 

Warfare Center Panama City Testing Range. Activities using in-water electromagnetic devices would be 

concentrated within the Naval Undersea Warfare Center Newport Testing Range. Activities would also 

occur in the inshore waters at Little Creek, Virginia (Table 3.0-15).

Birds that forage on shore (e.g., piping plover or red knot) would not be exposed to these in-water 

electromagnetic stressors because in-water electromagnetic devices are not used in areas close to shore 

and are only used underwater. As mentioned in the training activities discussion above, it is likely that 

any birds in the vicinity of an approaching vehicle towing an in-water electromagnetic device would be 

dispersed by the sound and disturbance generated by the vehicle (Section 3.9.3.4.1, Impacts from 

Vessels and In-Water Devices, and Section 3.9.3.4.2, Impacts from Aircraft and Aerial Targets) and would 

therefore move away from the vehicle and device before any exposure could occur. Although 

designated piping plover critical habitat occurs throughout the coastal habitats of the Southeast U.S. 

Continental Shelf and Gulf of Mexico Large Marine Ecosystems, none of these areas overlap with the use 

of in-water electromagnetic devices in the Study Area. Therefore, for reasons stated in the training 

activities, no long-term or population-level impacts to birds are expected and none of the in-water 

electromagnetic stressors will affect piping plover critical habitat.

Pursuant to the ESA, the use of in-water electromagnetic devices during testing activities as described 

under Alternative 1 would have no effect on Indiana bats, northern long-eared bats, or piping plover 

critical habitat; but may affect Bermuda petrels, piping plovers, roseate terns, and red knots. The Navy 

has consulted with the USFWS as required by section 7(a)(2) of the ESA in this regard.

3.9.3.3.1.2 Impacts from In-Water Electromagnetic Devices Under Alternative 2

Impacts from In-Water Electromagnetic Devices Under Alternative 2 for Training Activities

The number and distribution of training activities using in-water electromagnetic devices under 

Alternative 2 would be the same as under Alternative 1 (Tables 3.0-14 and 3.0-15); therefore, the 

impacts would be the same as for Alternative 1.

Pursuant to the ESA, the use of in-water electromagnetic devices during training activities as described 

under Alternative 2 would have no effect on Indiana bats, northern long-eared bats, or piping plover 

critical habitat; but may affect Bermuda petrels, piping plovers, roseate terns, and red knots. 
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Impacts from In-Water Electromagnetic Devices Under Alternative 2 for Testing Activities

The number and distribution of testing activities using in-water electromagnetic devices under 

Alternative 2 would be the same as for Alternative 1 (Tables 3.0-14 and 3.0-15); therefore, impacts 

would be the same as for Alternative 1.

Pursuant to the ESA, the use of in-water electromagnetic devices during testing activities as described 

under Alternative 2 would have no effect on Indiana bats, northern long-eared bats, or piping plover 

critical habitat; but may affect Bermuda petrels, piping plovers, roseate terns, and red knots. 

3.9.3.3.1.3 Impacts from In-Water Electromagnetic Devices Under the No Action 

Alternative

Impacts from In-Water Electromagnetic Devices Under the No Action Alternative for Training and 

Testing Activities

Under the No Action Alternative, the Navy would not conduct the proposed training and testing 

activities in the AFTT Study Area. Various energy stressors (e.g., in-water electromagnetic devices) would 

not be introduced into the marine environment. Therefore, baseline conditions of the existing 

environment would either remain unchanged or would improve slightly after cessation of ongoing 

training and testing activities. 

3.9.3.3.2 Impacts from In-Air Electromagnetic Devices

Several different types of in-air electromagnetic devices are used during training and testing activities, 

including an array of communications transmitters, radars, and electronic countermeasures 

transmitters. For information on the types of activities that use in-water electromagnetic devices, see 

Appendix B (Activity Stressor Matrices), Table B-1. For a information on where they are used, and how 

many activities would occur under each alternative, see Section 3.0.3.3.3.2 (In-Air Electromagnetic 

Devices). Aspects of in-air electromagnetic stressors that are applicable to marine organisms in general 

are presented in Section 3.0.3.6.2 (Conceptual Framework for Assessing Effects from Energy-Producing 

Activities). 

As discussed in Section 3.0.3.3.3.2 (In-Air Electromagnetic Devices), most of the transmissions from inair electromagnetic devices (e.g., for routine surveillance, communications, and navigation) will be at 

low power. Based on human standards, high-power in-air electromagnetic devices are those that 

produce peak pulses of 200 kilovolts per meter in a single pulse (U.S. Department of Defense, 2009); 

there are no federal standards for electromagnetic radiation exposure on wildlife (Manville, 2016; U.S. 

Department of Defense, 2009). In-air electromagnetic devices can also be characterized as “near-field” 

or “far-field” (i.e., near to, or far from, the source of electromagnetic radiation).

Studies conducted on in-air electromagnetic sensitivity in birds have typically been associated with land, 

and little information exists specifically on seabird response to in-air electromagnetic changes at sea. 

Based on these studies, in-air electromagnetic effects can be categorized as thermal (i.e., capable of 

causing damage by heating tissue) or non-thermal. Thermal effects are most likely to occur when near 

high-power systems. Should such effects occur, they would likely cause birds and bats to temporarily 

avoid the area receiving the electromagnetic radiation until the stressor ceases (Ahlén et al., 2009; 

Manville, 2016; Nicholls & Racey, 2007, 2009). For example, studies have found that bat activity and 

foraging effort is substantially reduced in the vicinity of radar (Ahlén et al., 2009; Nicholls & Racey, 2007, 

2009). Heat energy produced during flight makes bats susceptible to overheating, and (Nicholls & Racey, 

2007); Nicholls and Racey (2009) theorize that the large surface area of bats’ wing membranes may 
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absorb electromagnetic radiation, thereby increasing the risk of hyperthermia and causing bats to avoid 

sources of electromagnetic radiation. 

Currently, questions exist about far-field, non-thermal effects from low power, in-air electromagnetic 

devices. Manville (2016) performed a literature review of this topic. Although findings are not always 

consistent, Manville (2016) reported that several peer-reviewed studies have shown non-thermal effects 

can include (1) affecting behavior by preventing birds from using their magnetic compass, which may in 

turn affect migration; (2) fragmenting the DNA of reproductive cells, decreasing the reproductive 

capacity of living organisms; (3) increasing the permeability of the blood-brain barrier; (4) other 

behavioral effects; (5) other molecular, cellular, and metabolic changes; and (6) increasing cancer risk. 

Cucurachi et al. (2013) also performed a literature review of 113 studies and reported that (1) few field 

studies were performed (the majority were conducted in a laboratory setting); (2) 65% of the studies 

reported ecological effects both at high as well as low dosages (i.e., those that are compatible with real 

field situations, at least on land); (3) no clear dose-effect relationship could be discerned but that studies 

finding an effect applied higher durations of exposure and focused more on mobile phone frequency 

ranges; and (4) a lack of standardization and a limited number of observations limited the possibility of 

generalizing results from an organism to an ecosystem level.

Many bird species return to the same stopover, wintering, and breeding areas every year and often 

follow the exact same or very similar migration routes (Akesson, 2003; Alerstam et al., 2006), and ample 

evidence exists that displaced birds can successfully reorient and find their way when one or more cues 

are removed (Akesson, 2003; Haftorn et al., 1988). For example, Haftorn et al. (1988) found that after 

removal from their nests and release into a different area, snow petrels (Pagodrama nivea) were able to 

successfully navigate back to their nests even when their ability to smell was removed. Furthermore, 

Wiltschko and Wiltschko (2005) report that in-air electromagnetic pulses administered to birds during 

an experimental study on orientation do not deactivate the magnetite-based receptor mechanism in the 

upper beak altogether but instead cause the receptors to provide altered information, which in turn 

causes birds to orient in different directions. However, these impacts were temporary, and the ability of 

the birds to correctly orient themselves eventually returned. Similar results were found by a subsequent 

study by Wiltschko et al. (2011) on European robins (Erithacus rubecula) that tested the effects of 

exposure to specific wavelengths of visible light. Therefore, in the unlikely event that a bird is 

temporarily disoriented by an electromagnetic device, it is expected that it would still be able to reorient

using its internal magnetic compass to aid in navigation once the stressor ceases or the bird and stressor 

are separated by sufficient distance. Therefore, any temporary disorientation experienced by birds from 

electromagnetic changes caused by training activities in the Study Area may be considered a short-term 

impact and would not hinder bird navigation abilities. Furthermore, other orientation cues may include 

position of the sun and moon, visual cues, wind direction, infrasound, and scent; these cues would not 

be affected by in-air electromagnetic devices.

The Environmental Assessment for the Upgraded AEGIS Combat System concluded that the rapid 

increase of the bird population around a newly constructed radar installation “indicates that any 

negative effects of the radiation zone overhead have been negligible.” Another study on the impacts of 

extremely low-frequency in-air electromagnetic fields on breeding and migrating birds around the 

Navy’s extra-low-frequency communication system antenna in Wisconsin found no evidence that bird 

distribution or abundance was impacted by in-air electromagnetic fields produced by the antenna. In 

addition, radars, including X-band systems, are frequently used to track bird movements as it has been 

demonstrated that they do not affect bird behavior. Moreover, previous studies have consistently 
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determined that the chances that a bird or bat will move in the same direction and at the same speed as 

a constant beam of electromagnetic radiation (e.g., while an in-air electromagnetic device tracks a 

target), and therefore be exposed to radiation that could cause thermal damage, are extremely small.

Studies have found that bat activity and foraging effort is substantially reduced in the vicinity of radar 

(Ahlén et al., 2009; Nicholls & Racey, 2007, 2009). Heat energy produced during flight makes bats 

susceptible to overheating, and Nichols & Racey theorize that the large surface area of bats’ wing 

membranes may absorb electromagnetic radiation, thereby increasing the risk of hyperthermia and 

causing bats to avoid sources of electromagnetic radiation (Nicholls & Racey, 2007, 2009). As such, bats 

may temporarily avoid the general vicinity where training or testing activities that generate in-air 

electromagnetic radiation and the potential to for in-air electromagnetic radiation to injure a bat is 

negligible. Given the infrequent and seasonal use of the Study Area by bats (Section 3.9.2.1.2, Habitat 

Use), the localized nature of the area affected by in-air electromagnetic radiation, and that impacts 

would be limited to temporary behavioral responses and displacement from the affected area, few, if 

any, individual bats would be affected, and exposure would not have persistent or accumulating effects.

Given (1) the information provided above; (2) the dispersed nature of Navy testing and training activities 

at sea; and (3) the relatively low-level and dispersed use of these systems at sea, the following 

conclusions are reached:

1. The chance that in-air electromagnetic devices would cause thermal damage to an individual 

bird or bat is extremely low; 

2. It is possible, although unlikely, that some bird or bat individuals would be exposed to levels of 

electromagnetic radiation that would cause discomfort, in which case they would likely avoid 

the immediate vicinity of testing and training activities; 

3. The strength of any avoidance response would decrease with increasing distance from the in-air 

electromagnetic device; and 

4. No long-term or population-level impacts would occur.

3.9.3.3.2.1 Impacts from In-Air Electromagnetic Devices Under Alternative 1 

Impacts from In-Air Electromagnetic Devices Under Alternative 1 for Training Activities

As indicated in Section 3.0.3.3.3.2 (In-Air Electromagnetic Devices) and Tables 3.0-18 and 3.0-37, under 

Alternative 1, training activities involving in-air electromagnetic devices would occur throughout the 

Study Area but would be concentrated in the Virginia Capes Range Complex, Navy Cherry Point Range 

Complex, Jacksonville Range Complex, and inshore waters. For the reasons described above, however, 

no long-term or population-level impacts to birds or bats would occur.

Pursuant to the ESA, the use of in-air electromagnetic devices during training activities as described 

under Alternative 1 would have no effect on piping plover critical habitat, but may affect Bermuda 

petrels, piping plovers, roseate terns, red knots, Indiana bats, and northern long-eared bats. The Navy 

has consulted with the USFWS as required by section 7(a)(2) of the ESA in this regard.

Impacts from In-Air Electromagnetic Devices Under Alternative 1 for Testing Activities

As indicated in Section 3.0.3.3.3.2 (In-Air Electromagnetic Devices) and Tables 3.0-18 and 3.0-37, under 

Alternative 1, testing activities involving in-air electromagnetic devices would occur throughout the 

Study Area but would be concentrated in the Northeast Range Complexes, Virginia Capes Range 

Complex, Navy Cherry Point Range Complex, Jacksonville Range Complex, and Naval Undersea Warfare 
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Center Newport Testing Range. For the reasons described above, however, no long-term or populationlevel impacts to birds or bats would occur. 

Pursuant to the ESA, the use of in-air electromagnetic devices during testing activities as described 

under Alternative 1 would have no effect on piping plover critical habitat, but may affect Bermuda 

petrels, piping plovers, roseate terns, red knots, Indiana bats, and northern long-eared bats. The Navy 

has consulted with the USFWS as required by section 7(a)(2) of the ESA in this regard.

3.9.3.3.2.2 Impacts from In-Air Electromagnetic Devices Under Alternative 2

Impacts from In-Air Electromagnetic Devices Under Alternative 2 for Training Activities

The number and distribution of training activities using in-air electromagnetic devices under 

Alternative 2 would differ slightly from Alternative 1 insofar as the average number of total vessel and 

aircraft activities within the Study Area would increase slightly (by approximately 1.0 percent for vessel 

activities, and a fraction of a percent for aircraft activity) over a 5-year period (Tables 3.0-18 and 3.0-37, 

respectively). Given the foregoing analysis, this difference is inconsequential and the impacts would be 

essentially the same as for Alternative 1.

Pursuant to the ESA, the use of in-air electromagnetic devices during training activities as described 

under Alternative 2 would have no effect on piping plover critical habitat, but may affect Bermuda 

petrels, piping plovers, roseate terns, red knots, Indiana bats, and northern long-eared bats.

Impacts from In-Air Electromagnetic Devices Under Alternative 2 for Testing Activities

The number and distribution of testing activities using in-air electromagnetic devices under Alternative 2 

would differ slightly from Alternative 1 insofar as the average number of total vessel and aircraft 

activities within the Study Area would increase slightly (by approximately 1.1 percent for both vessel and 

aircraft activity) over a 5-year period (Tables 3.0-18 and 3.0-37, respectively). The majority of the 

increase in activity would occur at the Virginia Capes Range Complex. Given the foregoing analysis, this 

difference is inconsequential and the impacts would be essentially the same as for Alternative 1.

Pursuant to the ESA, the use of in-air electromagnetic devices during testing activities as described 

under Alternative 2 would have no effect on piping plover critical habitat, but may affect Bermuda 

petrels, piping plovers, roseate terns, red knots, Indiana bats, and northern long-eared bats.

3.9.3.3.2.3 Impacts from In- Air Electromagnetic Devices Under the No Action 

Alternative

Impacts from In- Air Electromagnetic Devices Under the No Action Alternative for Training and 

Testing Activities

Under the No Action Alternative, the Navy would not conduct the proposed training and testing 

activities in the AFTT Study Area. Various energy stressors (e.g., in-air electromagnetic devices) would 

not be introduced into the marine environment. Therefore, baseline conditions of the existing 

environment would either remain unchanged or would improve slightly after cessation of ongoing 

training and testing activities.

3.9.3.3.3 Impacts from High-Energy Lasers

This section analyzes the potential impacts of high-energy lasers on birds and bats. As discussed in 

Section 3.0.3.3.3.3 (Lasers), high energy laser weapons are designed to disable targets, rendering them 

immobile. The primary concern is the potential for a bird or bat to be directly struck with the laser 

beam, which could result in injury or death, depending on the wavelength of the laser and where and 
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for how long the beam contacts the animal. Tissue damage results primarily from thermal effects of the 

radiation. The eyes and areas of thin, exposed skin are the tissues most susceptible to damage from 

lasers.

Birds or bats could be exposed to a laser only if they fly through the beam at the instant the laser is 

fired. This has a very low probability of occurrence because of the limited use of high-energy lasers in 

the Study Area and the fact that the energy of the laser is concentrated within a very small area for only 

a few seconds. For a bird or bat in flight – the circumstance under which contact with a laser beam is 

most likely, the possibility that parts of the animal most susceptible to damage, especially the eyes, 

would cross the beam is remote. 

3.9.3.3.3.1 Impacts from High-Energy Lasers Under Alternative 1

Impacts from High-Energy Lasers Under Alternative 1 for Training Activities

Under Alternative 1, training activities using high-energy lasers would occur 4 times per year at the 

Virginia Capes and Jacksonville Range Complexes (Table 3.0-16). ESA-listed bird and bat species that 

could occur in these areas include the Bermuda petrel, piping plover, roseate tern, red knot, Indiana bat, 

and northern long-eared bat. The likelihood of a bird or bat crossing the laser beam at the instant the 

laser is fired is extremely remote but possible. 

No long-term or population-level impacts are expected. Neither birds nor bats are likely to be exposed 

to high energy lasers based on the: (1) relatively low number of activities, (2) very localized potential 

impact area of the laser beam, and (3) temporary duration of potential impact (seconds). The likelihood 

that an ESA-listed bird or bat species would be struck by a high-energy laser beam is so small as to be 

discountable; no impacts to ESA-listed species are anticipated.

Pursuant to the ESA, the use of high-energy lasers during training activities as described under 

Alternative 1 would have no effect on piping plover critical habitat, piping plovers, or red knots; but may 

affect Bermuda petrels, roseate terns, Indiana bats, and northern long-eared bats. The Navy has 

consulted with the USFWS as required by section 7(a)(2) of the ESA in this regard.

Impacts from High-Energy Lasers Under Alternative 1 for Testing Activities

High-energy laser testing activities would occur predominantly in the Virginia Capes Range Complex, and 

to a lesser degree at other Navy range complexes and facilities (Northeast Range Complexes, Navy 

Cherry Point Range Complex, Jacksonville Range Complex, Key West Range Complex, Gulf of Mexico

Range Complex, Naval Undersea Warfare Center Newport Testing Range, Naval Surface Warfare Center 

Carderock Division’s South Florida Ocean Measurement Facility, and Naval Surface Warfare Center

Panama City Testing Range), although not in the inshore waters, within the Study Area (Table 3.0-16).

The likelihood of a bird or bat crossing the laser beam at the instant the laser is fired is extremely 

remote but possible. 

No long-term or population-level impacts are expected. Neither birds nor bats are likely to be exposed 

to high energy lasers based on the: (1) relatively low number of activities, (2) very localized potential 

impact area of the laser beam, and (3) temporary duration of potential impact (seconds). The likelihood 

that an ESA-listed bird or bat species would be struck by a high-energy laser beam is so small as to be 

discountable; no impacts to ESA-listed species are anticipated.

Pursuant to the ESA, the use of high-energy lasers during testing activities as described under 

Alternative 1 would have no effect on piping plover critical habitat, piping plovers, or red knots; but may 
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affect Bermuda petrels, roseate terns, Indiana bats, and northern long-eared bats. The Navy has 

consulted with the USFWS as required by section 7(a)(2) of the ESA in this regard.

3.9.3.3.3.2 Impacts from High-Energy Lasers Under Alternative 2

Impacts from High-Energy Lasers Under Alternative 2 for Training Activities

The use of high energy lasers under Alternative 2 for training activities would be the same as under 

Alternative 1 (Table 3.0-16); therefore, impacts would be the same.

Pursuant to the ESA, the use of high-energy lasers during training activities as described under 

Alternative 2 would have no effect on piping plover critical habitat, piping plovers, or red knots; but may 

affect Bermuda petrels, roseate terns, Indiana bats, and northern long-eared bats. 

Impacts from High-Energy Lasers Under Alternative 2 for Testing Activities

The use of high-energy lasers under Alternative 2 for testing activities would be the same as under 

Alternative 1 (Table 3.0-16); therefore, impacts would be the same.

Pursuant to the ESA, the use of high-energy lasers during testing activities as described under 

Alternative 2 would have no effect on piping plover critical habitat, piping plovers, or red knots; but may 

affect Bermuda petrels, roseate terns, Indiana bats, and northern long-eared bats. 

3.9.3.3.3.3 Impacts from High-Energy Lasers Under the No Action Alternative

Impacts from High-Energy Lasers Under the No Action Alternative for Training and Testing 

Activities

Under the No Action Alternative, the Navy would not conduct the proposed training and testing 

activities in the AFTT Study Area. Various energy stressors (e.g., high-energy lasers) would not be 

introduced into the marine environment. Therefore, baseline conditions of the existing environment 

would either remain unchanged or would improve slightly after cessation of ongoing training and testing 

activities. 

3.9.3.4 Physical Disturbance and Strike Stressors

This section describes the potential impacts to birds and bats by aircraft and aerial target strikes, vessels 

(disturbance and strike), and military expended material strike. For a list of Navy activities that involve 

this stressor refer to Appendix B (Activity Stressor Matrices). Aircraft include fixed-wing and rotary-wing 

aircraft; vessels include various sizes and classes of ships, and other boats; in-water devices include 

devices that are towed, unmanned surface, and underwater vehicles; military expended materials 

include non-explosive practice munitions, target fragments, decelerators/parachutes, and other objects. 

Physical disturbance and strike risks, primarily from aircraft, have the potential to impact all taxonomic 

groups found within the Study Area (Table 3.9-1). In addition to the potential for injury and mortality, 

impacts of physical disturbance include behavioral responses such as temporary disorientation, change 

in flight direction, and avoidance response behavior. Physical disturbances (discussed in Section

3.9.3.4.2, Impacts from Aircraft and Aerial Targets) may elicit short-term behavioral or physiological 

responses in birds or bats such as alert response, startle response, cessation of feeding, fleeing the 

immediate area, and a temporary increase in heart rate. These disturbances can also result in abnormal 

behavioral, growth, or reproductive impacts in nesting birds and can cause foraging and nesting birds to 

flush from or abandon their habitats or nests (Andersen et al., 1989; Komenda-Zehnder et al., 2003). 

Aircraft strikes often result in bird or bat mortalities or injuries (Dolbeer, 2006). 
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Although birds and bats likely hear and see approaching vessels and aircraft, they cannot avoid all 

collisions. Nighttime lighting on vessels, specifically high-powered searchlights used for navigation in icy 

waters off of Greenland, has caused birds to become confused and collide with naval vessels, cargo 

vessels, and trawlers (Gehring et al., 2009; Merkel & Johansen, 2011; Poot et al., 2008). Bats are also

known to collide with buildings and communication towers (Cryan & Brown, 2007; Hatch et al., 2013)

and therefore may also collide with vessels. Collisions with vessels can result in bird or bat mortalities or 

injuries. 

3.9.3.4.1 Impacts from Vessels and In-Water Devices

Vessels

The majority of the training and testing activities in the Study Area involve vessels. For a discussion of 

the types of vessels used as well as the number and location of activities that include vessels under each 

alternative, see Section 3.0.3.3.4.1 (Vessels and In-Water Devices). Table 3.0-17 provides representative 

vessel types and their sizes and typical operating speeds; Table 3.0-18 provides the number and 

locations of activities that include vessels; Table 3.0-19 provides the number and location of activities in 

inshore waters that include vessels; and Table 3.0-20 provides the location and annual number of high 

speed vessel hours for small crafts in inshore waters. Appendix B (Activity Stressor Matrices) provides

the types of activities that use vessels.

Potential impacts of those activities on birds and bats are applicable to everywhere in the Study Area 

that vessels are used. Training and testing activities within the Study Area involve maneuvers by various 

types of surface ships, boats, and submarines. The number of Navy ships and smaller vessels in the 

Study Area varies based on training and testing schedules. Activities involving vessel movements occur 

intermittently, ranging from a few hours to a few weeks. Events involving large vessels are widely spread 

over the open ocean, while smaller vessels are more active and more concentrated in nearshore areas.

Direct collisions with most Navy vessels (or a vessel’s rigging, cables, poles, or masts) are unlikely but 

may occur, especially at night. Lighting on boats and vessels has also contributed to bird fatalities in 

open ocean environments when birds are attracted to these lights, usually in inclement weather 

conditions (Merkel & Johansen, 2011). Birds can become disoriented at night in the presence of artificial 

light (Favero et al., 2011; Hamilton, 1958; Hyrenbach, 2001, 2006), and lighting on vessels may attract 

some birds, increasing the potential for harmful encounters. Other impacts to birds would be the visual 

and behavioral disturbance from a vessel. Birds respond to moving vessels in various ways. Some birds, 

including certain species of gulls, storm petrels, and albatrosses, commonly follow vessels; while other 

species such as plovers, curlews, frigatebirds, and sooty terns seem to avoid vessels (Borberg et al., 

2005; Hyrenbach, 2006). There could be a slightly increased risk of impacts during the winter, or 

fall/spring migrations when migratory birds use celestial clues during night time flight and are 

concentrated in coastal areas. However, despite this concentration, most birds would still be able to 

avoid collision with a vessel. Vessel movements could elicit short-term behavioral or physiological 

responses (e.g., alert response, startle response, fleeing the immediate area, temporary increase in 

heart rate).

Navy aircraft carriers, surface combatant vessels, and amphibious warfare ships are minimally lighted for 

tactical purposes. For vessels of this type there are two white lights that shine forward and one that 

shines aft; these lights must be visible for at least 6 NM. A single red and a single green light are located 

on the port and starboard sides of vessels, respectively. These lights are visible for a minimum of 3 NM. 

Solid white lighting appears more problematic for birds, especially nocturnal migrants (Gehring et al., 
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2009; Poot et al., 2008). Navy vessel lights are mostly solid, but sometimes may not appear solid 

because of the constant movement of the vessel (wave action), making vessel lighting potentially less 

problematic for birds in some situations.

Cryan and Brown (2007) suggested that bats may be attracted to tall and highly visible landmarks (e.g., 

crowns of trees, islands, and wind turbines), and Thompson et al. (2015) provided anecdotal evidence 

that a flock of Myotis sp. may temporarily roost overnight on a fishing vessel at sea. To date, however, 

no studies have suggested that bats are attracted to ships at sea. Regardless, since bats (especially 

migratory bats) are known to collide with buildings and communication towers (Cryan & Brown, 2007; 

Hatch et al., 2013), and insects (which bats in the Study Area prey upon) can be attracted to ships at sea 

during certain weather conditions (Ahlén et al., 2009), it is possible that bats may collide with naval 

vessels at sea. However, the likelihood that this could occur is considered low given the infrequent, 

seasonal use of the Study Area by bats and that bats may be deterred from getting too close to naval 

vessels by behavioral responses to in-air electromagnetic devices (refer to Section 3.9.3.3.2, Impacts 

from In-Air Electromagnetic Stressors).

While some potential exists for birds or bats to be struck by vessels as they are foraging, resting, or 

flying near the water surface, most birds and bats would be expected to see or hear an oncoming vessel 

and to fly or swim away to avoid a potentially harmful encounter. Injury or mortality could occur if a bird

or bat were struck, but most bird or bat encounters with vessels would be expected to result in a brief 

behavioral and physiological response as described above. It should be noted that such responses 

involve at the least a temporary displacement of birds or bats (to a lesser degree, since bats are most 

active from dusk to dawn) from foraging areas, resulting in energetic costs to the animals. Birds and bats 

would be expected to return and resume foraging soon after the vessel passed through the area, or to 

forage elsewhere, and the fitness of individual animals would probably not be compromised.

Other harmful bird-vessel interactions are commonly associated with commercial fishing vessels 

because birds are attracted to concentrated food sources around these vessels. However, these 

concentrated food sources are not associated with Navy vessels, so birds following Navy vessels would 

be very unlikely.

Amphibious vessel movements could elicit short-term behavioral or physiological responses such as 

alert response, startle response, cessation of feeding, fleeing the immediate area, nest abandonment, 

and a temporary increase in heart rate. There could be a slightly increased risk of impacts during the 

winter, or fall/spring migrations and during the nesting season when migratory birds or bats are 

concentrated in coastal areas where amphibious vessels have the potential to disturb nesting or 

foraging shorebirds or foraging or migrating bats. The general health of individual birds or bats would 

not be compromised, unless a direct strike occurred. However, it is highly unlikely that a bird or bat 

would be struck in this scenario because most foraging shorebirds and bats in the vicinity of the 

approaching amphibious vessel would likely be dispersed by the sound of its approach before it could 

come close enough to strike a bird or bat (Section 3.9.3.1.5, Impacts from Vessel Noise).

Large vessel movement primarily occurs within the U.S. Exclusive Economic Zone, with the majority of 

the traffic flowing in a direct line between Naval Stations Norfolk and Mayport. There would be a higher 

likelihood of vessel strikes over the continental shelf portions than in the open ocean portions of the 

Study Area because of the concentration of vessel movements in those areas. Even in areas of 

concentrated vessel use, the probability of bird/vessel or bat/vessel interaction is low because of the 
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high mobility of birds and bats, and because bats are most active from dusk to dawn and are unlikely to 

be found in open ocean areas.

Under a worst-case scenario, vessel movements could cause the localized, temporary movement of 

birds or bats to areas that are less desirable, resulting in some energetic cost which may or may not be 

important to an individual’s survival and reproduction. However, it is unlikely that impacts would occur 

to the point that birds or bats would be permanently displaced from important habitats that were not 

already subject to heavy ongoing use. As such, no long-term or population-level impacts are expected. 

In-Water Devices

Section 3.0.3.3.4.1 (Vessels and In-water Devices) provides information on the types, sizes and speeds of 

in-water devices, and Table 3.0-22 provides the locations where they would be used. For a list of 

activities by name that include the use of in-water devices, see Appendix B (Activity Stressor Matrices). 

In-water devices include surface and underwater unmanned vehicles, torpedoes and towed devices, and 

their use occurs virtually throughout the Study Area.

As discussed in Section 3.0.3.3.4.1 (Vessels and In-water Devices), these devices are self-propelled and 

unmanned or towed through the water from a variety of platforms, including helicopters, unmanned 

underwater vehicles, and surface ships. In-water devices are generally smaller than most Navy vessels, 

ranging from several in. to about 50 ft. These devices can operate anywhere from the water surface to 

the benthic zone. Most of these devices do not have a realistic potential to strike living marine resources 

because they either move slowly through the water column (e.g., most unmanned undersea vehicles) or 

are closely monitored by observers manning the towing platform (e.g., most towed devices) who ensure 

the towed in-water device does not run into objects in the water. Unmanned surface vehicles, because 

of their size and potential operating speed, have the potential to strike living marine resources. 

Unmanned surface vehicles are remotely operated, fast-moving, agile vehicles that may operate at 

speeds up to 50+ knots (Table 3.0-21), thus the potential for disturbance exists. The likelihood of a 

strike, however is very low because they are operated only in conditions of good visibility.

Mine warfare devices that are towed through the water (or the aircraft and cables that connect the 

aircraft to the device) and remotely operated underwater vehicles used during mine neutralization 

training and testing could also strike seabirds or bats. No documented instances of seabirds or bats 

being struck by towed devices have occurred in the Study Area. Additionally, based on the low altitudes 

and relatively slow air speeds, seabirds and bats would be able to detect and avoid the aircraft and 

cables that connect the aircraft to the towed device.

3.9.3.4.1.1 Impacts from Vessels and In-Water Devices Under Alternative 1

Impacts from Vessels and In-Water Devices Under Alternative 1 for Training Activities

Vessels

The potential for interaction is greater in coastal areas than pelagic areas where Navy vessel use is less 

concentrated. However, even in areas of concentrated vessel use, the probability of seabird/vessel or 

bat/vessel interaction is low because the high mobility of seabirds and bats allows them to move away 

from an oncoming vessel. Flushing of birds is expected to be greatest when vessels, towed devices, and 

unmanned surface vehicles are operated at relatively high speeds (as described in Tables 3.0-17 through 

3.0-23). While such flushing or other impacts of vessels on individual birds may occur, and bats may be 

temporarily displaced from a foraging area, none of these temporary impacts are expected to have an 

impact on the long-term fitness of individual birds or bats or have population-level impacts.
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Amphibious vessels and especially amphibious landings could potentially impact bird species, specifically 

shorebirds that nest and forage along the shoreline. These activities also have a greater probability of 

temporarily displacing bats from foraging in these areas, since bats are forage more frequently near land 

than in open ocean areas in the Study Area. Amphibious landings would occur at traditionally used 

beaches in the Virginia Capes, Navy Cherry Point, and Jacksonville Range Complexes (Table 2.3-3). The 

ESA-listed species that would be potentially impacted at these locations would be piping plover, roseate 

tern, red knot, and northern long-eared bat.

The locations where amphibious landing activities occur at Onslow Beach and Seminole Beach are not 

considered optimal habitat for piping plovers (U.S. Fish and Wildlife Service, 2009b). Piping plovers have 

been documented foraging within the intertidal shoreline at Onslow Beach and Seminole Beach during 

the winter, spring, and fall migration periods and during the nesting season, although no nests have 

been found to date (U.S. Fish and Wildlife Service, 2009b). Roseate terns and red knots could use these 

beaches as a resting area and could be found foraging in the waters near the beach. Northern longeared bats could use these beaches as foraging areas during spring and fall migration. While they could 

be present, it is highly unlikely that a piping plover, roseate tern, red knot, or northern long-eared bat

would be struck in this scenario because most foraging or resting shorebirds, or foraging bats, in the 

vicinity of the approaching amphibious vessel would likely be dispersed by the sound of its approach 

before it could come close enough for a collision to take place (Section 3.9.3.1.6, Impacts from Aircraft 

Noise). Furthermore, Marine Corps Base Camp Lejeune, and Naval Station Mayport have specific 

Integrated Natural Resource Management Plans for addressing ESA-listed bird species, and those plans 

already include project avoidance and minimization actions that reduce threats from military activities 

to wintering and migrating piping plovers to a minimal level (U.S. Fish and Wildlife Service, 2009b).

There is no overlap of vessels with designated critical habitat for piping plover. Additionally no critical 

habitat is designated at Onslow Beach or Seminole Beach. However, critical habitat does exist on the 

opposite (north) side of the St. Johns River from Seminole Beach. This area of critical habitat is outside 

the boundary of the Study Area. No long-term or population-level impacts are expected.

In-Water Devices

In-water devices used are typically towed by a boat or helicopter, unmanned vehicles or fired from a 

ship. As discussed for electromagnetic devices (Section 3.9.3.3.2, Impacts from In-Air Electromagnetic 

Devices), it is likely that any birds or bats in the vicinity of the approaching boat, helicopter, unmanned 

vehicle or ship firing torpedoes would be dispersed by their sound (Section 3.9.3.1.6, Impacts from 

Aircraft Noise) and move away from the in-water device before any exposure could occur. Therefore, 

the use of in-water devices is expected to have only short-term impacts on individual birds and bats, 

with very low potential for injury or mortality, and no population-level impacts.

Pursuant to the ESA, the use of vessels and in-water devices during training activities as described under 

Alternative 1 would have no effect on piping plover critical habitat, but may affect Bermuda petrels, 

piping plovers, roseate terns, red knots, Indiana bats, and northern long-eared bats. The Navy has 

consulted with the USFWS as required by section 7(a)(2) of the ESA in this regard.

Impacts from Vessels and In-Water Devices Under Alternative 1 for Testing Activities

As indicated in Section 3.0.3.3.4.1 (Vessels and In-Water Devices), Navy vessel and in-water activities

associated with testing activities would be fewer than those associated with training. While there is 

considerable overlap between training and testing activities, test activities would occur more frequently 
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in established test areas that are relatively closer to shore, including the Newport and Panama City 

Testing Ranges and South Florida Ocean Measurement Facility (Tables 3.10-17 through 3.0-23).

The potential for interaction is greater in coastal areas than pelagic areas where Navy vessel use is less 

concentrated. However, even in areas of concentrated vessel use, the probability of seabird/vessel or 

bat/vessel interaction is low because of the high mobility of seabirds and bats that would allow them to

move away from an oncoming vessel. Flushing of birds is expected to be greatest when vessels, towed 

devices, and unmanned surface vehicles are operated at relatively high speeds (as described in Tables 

3.0-17 through 3.0-23). While such flushing or other impacts of vessels on individual birds may occur, 

and bats may be temporarily displaced from foraging areas, none of these temporary impacts are 

expected to have an impact on the long-term fitness of individual birds or bats or have population-level

impacts.

Disturbance or strike from vessels or in-water devices are not expected to have lasting effects on the 

survival, growth, recruitment, or reproduction of bird or bat populations. Similarly, vessels and in-water 

devices would not result in impacts to critical habitat for piping plover because there is no overlap of the 

stressor with designated critical habitat. No long-term or population-level impacts are expected.

Pursuant to the ESA, the use of vessels and in-water devices during testing activities as described under 

Alternative 1 would have no effect on piping plover critical habitat, but may affect Bermuda petrels, 

piping plovers, roseate terns, red knots, Indiana bats, and northern long-eared bats. The Navy has 

consulted with the USFWS as required by section 7(a)(2) of the ESA in this regard.

3.9.3.4.1.2 Impacts from Vessels and In-Water Devices Under Alternative 2

Impacts from Vessels and In-Water Devices Under Alternative 2 for Training Activities

Under Alternative 2, potential impacts to birds or bats resulting from vessels and in-water devices 

associated with training activities would be similar to those of Alternative 1, but would be expected to 

occur with slightly greater frequency. Training over a 5-year period under Alternative 2 would have 

approximately 2.1 percent more vessel activities (Tables 3.0-18 and 3.0-19) and 5.3 percent more inwater device activities (Tables 3.0-22 and 3.0-23). Refer to Section 3.9.3.4.1.1 (Impacts from Vessels and 

In-Water Devices under Alternative 1) for a discussion of potential impacts. The potential for 

disturbance to individual birds or bats, and the number of individuals affected, would increase 

proportionately, but these impacts would still be temporary and unlikely to affect the long-term fitness 

of individuals or have population-level impacts. 

Pursuant to the ESA, the use of vessels and in-water devices during training activities as described under 

Alternative 2 would have no effect on piping plover critical habitat, but may affect Bermuda petrels, 

piping plovers, roseate terns, red knots, Indiana bats, and northern long-eared bats. 

Impacts from Vessels and In-Water Devices Under Alternative 2 for Testing Activities

Under Alternative 2, potential impacts to birds or bats resulting from vessels and in-water devices 

associated with testing activities would be similar to those of Alternative 1, but would be expected to 

occur with greater frequency. Testing over a 5-year period under Alternative 2 would have 

approximately 7.0 percent more vessel activities (Table 3.0-18 and Table 3.0-19) and 8.5 percent more 

in-water device activities (Tables 3.0-22 and 3.0-23). Refer to Section 3.9.3.4.1.1 (Impacts from Vessels 

and In-Water Devices under Alternative 1) for a discussion of potential impacts. The potential for 

disturbance to individual birds or bats and the number of individuals affected would increase 
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proportionately, but these impacts would still be temporary and unlikely to affect the long-term fitness 

of individuals or have population-level impacts.

Pursuant to the ESA, the use of vessels and in-water devices during testing activities as described under 

Alternative 2 would have no effect on piping plover critical habitat, but may affect Bermuda petrels, 

piping plovers, roseate terns, red knots, Indiana bats, and northern long-eared bats.

3.9.3.4.1.3 Impacts from Vessels and In-Water Devices Under the No Action 

Alternative

Impacts from Vessels and In-Water Devices Under the No Action Alternative for Training and 

Testing Activities

Under the No Action Alternative, the Navy would not conduct the proposed training and testing 

activities in the AFTT Study Area. Various physical disturbance and strike stressors (e.g. vessels and inwater devices) would not be introduced into the marine environment. Therefore, baseline conditions of 

the existing environment would either remain unchanged or would improve slightly after cessation of 

ongoing training and testing activities.

3.9.3.4.2 Impacts from Aircraft and Aerial Targets

Information on aircraft and aerial target use is provided in Section 3.0.3.3.4.4 (Aircraft) and Appendix A 

(Navy Activity Descriptions). Bird or bat strikes could occur during training and testing activities that use 

aircraft, particularly in nearshore areas, where birds and bats are more concentrated in the Study Area. 

Training and testing activities where aircraft are used typically occur further offshore, within the range 

complexes.

Bird-aircraft strikes are a serious concern for the Navy because these incidents can result in injury to 

aircrews as well as damage equipment and injure or kill birds (Bies et al., 2006). The Naval Aviation 

Safety Program Instruction, Chief of Naval Operations Instruction 3750.6R, identifies measures to 

evaluate and reduce or eliminate bird/animal aircraft strike hazards to aircraft, aircrews, and birds and 

requires the reporting of all strikes when damage or injuries occur as a result of a bird/aircraft strike. 

From 2006 to 2015, the Navy Bird/Animal Aircraft Strike Hazard program recorded 10,496 bird strikes 

Navy-wide with the majority occurring during the fall period from September to November. During the 

10-year period, bird strikes were greatest in the year 2015 with 1,283 strikes, and lowest in the year 

2008 with 755 (Naval Safety Center, 2017). However, the numbers of bird deaths that occur annually 

from all Navy activities are insignificant from a bird population standpoint. Since 2006, naval aviators 

reported 10,496 bird strikes at a cost of approximately $105 million (Naval Safety Center, 2017). About 

90 percent of wildlife/aircraft damaging collisions involving commercial and military aircraft involve 

large birds or large flocks of smaller birds (Federal Aviation Administration, 2003). ESA-listed seabird

strikes reported in the aircraft strike database include a roseate tern in the East China Sea in 2007; 

western snowy plovers at Naval Air Station Point Mugu in 2009 and 2014; a least tern in Kingsville, Texas 

in 2014; and a California least Tern at Naval Air Station North Island in 2008. 

Bird or bat strike potential is greatest in foraging or resting areas, in migration corridors at night, and at 

low altitudes during the periods around dawn and dusk. For example, birds can be attracted to airports 

because they often provide foraging and nesting resources. Approximately 97 percent of the reported 

civilian aircraft-wildlife damaging strikes from 1990 to 1999 involved common, large-bodied birds or 

large flocks of small birds. Almost 70 percent of these events involved gulls, waterfowl, and raptors

(Federal Aviation Administration, 2003). Nicholls and Racey (2009) and Ahlén et al. (2009) found that bat
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foraging activity is substantially reduced in the vicinity of radar; as such, bats may avoid airports because 

of the radar used to track aircraft.

As described in Section 2.1.1.3 (Standard Operating Procedures), the Navy implements standard 

operating procedures for aircraft safety. Pilots of Navy aircraft make every attempt to avoid large flocks 

of birds to reduce the safety risk involved with a potential bird strike. Since 2011, the Navy has required 

that all Navy flying units report all bird strikes through the Web-Enabled Safety System Aviation Mishap 

and Hazard Reporting System. The standard operating procedures for aircraft safety will benefit birds 

and bats through a reduction in the potential for aircraft strike.

While wildlife strikes can occur anywhere aircraft are operated, Navy data indicate that they occur most 

often within the airfield environment – i.e. over land or close to shore (Naval Air Station Jacksonville, 

2012). Dolbeer (2006) reports that about 90 percent of aircraft-wildlife strikes occur on or near airports, 

when aircraft are below altitudes of 3,500 ft. For military rotary-wing aircraft, wildlife strikes happened 

most frequently when the aircraft were traveling en route (flying [moving forward] at an altitude greater 

than 1,000 ft. above ground level) or were engaged in terrain flight (flying at an altitude less than 1,000 

ft. above ground level), as opposed to (1) hovering (off the ground at less than 1,000 ft. above ground 

level, and stationary), (2) on approach (in the early stages of the landing process at greater than 100 ft. 

above ground level and moving forward), (3) landing (the final stages of landing at less than 100 ft. 

above ground level), (4) taxiing (moving along the ground, or at less than 10 ft. above ground level, in 

transition from one part of the airport to another), (5) taking off (leaving the ground and ascending 

upward at less than 100 ft. above ground level), or (6) climbing out (for rotary-wing aircraft in the later 

stages of taking off at greater than 100 ft. above ground level) (Washburn et al., 2014). The potential for 

bird strikes to occur in offshore areas is relatively low because Navy activities are widely dispersed and 

above 3,000 ft. (for fixed-wing aircraft) where bird densities are low. The potential for bat strikes to 

occur in offshore areas is substantially lower than that for birds because bat densities are substantially 

lower than bird densities in these areas.

For the majority of fixed-wing activities, flight altitudes would be above 3,000 ft., with the exception of 

sorties associated with air-to-surface bombing exercises and sonobuoy drops. Typical flight altitudes 

during air-to-surface bombing exercises are from 500 to 5,000 ft. above ground level. Most fixed-wing 

aircraft flight hours (greater than 90 percent) occur at distances greater than 12 NM offshore. 

Helicopter flights would occur closer to the shoreline where sheltering, roosting, and foraging birds and 

bats occur. Helicopters can hover and fly low, and would be used to tow electromagnetic devices as well 

as for other military activities at sea. This combination would make helicopter bird or bat strikes more 

likely than for fixed-wing aircraft. Additional details on typical altitudes and characteristics of aircraft 

used in the Study Area are provided in Chapter 2 (Description of Proposed Action and Alternatives) and 

Section 3.0.3.3.4.4 (Aircraft).

Approximately 95 percent of bird flight during migration occurs below 10,000 ft., with the majority 

below 3,000 ft. (U.S. Geological Survey, 2006). Aircraft encounters with birds or bats are more likely to 

occur during aircraft takeoffs and landings than when the aircraft is engaged in low-level flight. In a 

study that examined 38,961 bird and aircraft collisions, Dolbeer (2006) found that the majority (74 

percent) of collisions occurred below 500 ft. However, collisions have been recorded at elevations as 

high as 12,139 ft. (Dove & Goodroe, 2008).

Bird and bat populations may consist of hundreds or thousands of individuals, ranging across a large 

geographical area. In this context, the loss of a small number of birds or bats due to physical strikes does 
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not constitute a population-level effect. Bird or bat exposure to a strike potential would be relatively 

brief as an aircraft transits the area. Strike potential is further decreased by Navy aircrafts’ active 

avoidance of large flocks of birds.

In addition to manned aircraft, aerial targets such as unmanned drones could also incur a bird or bat 

strike, however, evidence from returned drones indicate the probability is low.In a bird strike study for 

the U.S. Air Force, vultures were the most hazardous group to aircraft, followed by geese, pelicans, and 

buteo hawks, based on the number of bird strikes reported (Zakrajsek & Bissonette, 2005). These 

species groups occur within the Study Area but are generally found in nearshore areas (Mowbray et al., 

2002; Shields et al., 2002). The potential for bird or bat strikes to occur in offshore areas is relatively low 

because activities are widely dispersed and occur at relatively high altitudes (above 3,000 ft. for fixedwing aircraft) where seabird or bat occurrences are generally low.

3.9.3.4.2.1 Impacts from Aircraft and Aerial Targets Under Alternative 1

Impacts from Aircraft and Aerial Targets Under Alternative 1 for Training Activities

Aircraft use in the Study Area is described in Section 3.0.3.3.4.4 (Aircraft). Approximately 131,000

training activities involving aircraft would occur annually in the Study Area under Alternative 1, with 

activities concentrated in the Virginia Capes, Navy Cherry Point, Jacksonville, and Key West Range 

Complexes (Tables 3.0-37 and 3.0-38). Aerial targets used in the Study Area are described in Appendix A

(Navy Activity Descriptions) (A.1.3, Targets) and include expendable rocket-powered missiles and 

recoverable radio-controlled drones, as well as air-launched decoys (A.2.3.6, Missile Exercise Air-to-Air). 

Under Alternative 1 for Training Activities, approximately 207 air targets (decoy) and 55 air targets 

(drone) would be expended annually (Table 3.0-29).

Some individual bird or bat strikes and associated bird or bat mortalities or injuries could occur as a 

result of aircraft and aerial target use in the Study Area under the Alternative 1; however, populationlevel impacts to birds would not likely result. ESA-listed species could be impacted by aircraft 

disturbance or strikes while in flight in areas where low-altitude operations are taking place. However, 

no ESA-listed bird or bat strikes have been reported during training activities. 

Although piping plover critical habitat occurs throughout the coastal habitats of the Southeast U.S. 

Continental Shelf and Gulf of Mexico Large Marine Ecosystems, it does not overlap with fixed-wing 

aircraft training which would take place further than 1 NM from shore. While aircraft overflights could 

occur near piping plover critical habitat, the altitudes of their flight paths would be high enough to not 

pose a direct strike risk to piping plovers while sheltering, roosting, or feeding. Potential impacts from 

aircraft and aerial targets would have no effect on critical habitat for the piping plover.

Helicopters can hover and fly low as well as out over the open ocean. The combination of helicopters 

hovering and flying low over the open ocean could result in possible strikes to ESA-listed piping plover, 

roseate tern, red knot, Bermuda petrel, or northern long-eared bat. As described in Section 5.3 

(Procedural Mitigation to be Implemented), the Navy will implement mitigation to avoid potential 

impacts from rotary-wing aircraft overflight noise on piping plovers and other nesting birds during 

explosive ordnance disposal activities, including maneuvering to maintain a specified distance from the 

beach within the Virginia Capes Range Complex (except when transiting from Norfolk Naval Station to 

waters offshore) and from Fisherman Island National Wildlife Refuge off the coast of Cape Charles, 

Virginia (when transiting from Norfolk Naval Station to waters offshore). The mitigation for aircraft 

overflight noise will consequently help avoid potential physical disturbance and strike impacts on birds 

that occur in these locations.
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Bird or bat exposure to strike potential would be relatively brief as an aircraft quickly passes. 

Disturbance by aircraft and aerial targets would be temporary and inconsequential to the long-term 

fitness of individuals. Bird or bat strikes may occur to a relatively small number of individuals, but no 

population-level impacts would occur, especially when considering the Navy’s standard operating 

procedures for aircraft safety (see Section 2.1.1.3, Standard Operating Procedures) and mitigation (see 

Chapter 5, Mitigation).

Pursuant to the ESA, the use of aircraft and aerial targets during training activities as described under 

Alternative 1 would have no effect on piping plover critical habitat, but may affect Bermuda petrels, 

piping plovers, roseate terns, red knots, Indiana bats, and northern long-eared bats. The Navy has 

consulted with the USFWS as required by section 7(a)(2) of the ESA in this regard.

Impacts from Aircraft and Aerial Targets Under Alternative 1 for Testing Activities

Aircraft use in the Study Area is described in Section 3.0.3.3.4.4 (Aircraft). Approximately 7,700 testing 

activities involving aircraft would occur annually in the Study Area under Alternative 1, with activities 

especially concentrated in the Virginia Capes Range Complex (Tables 3.0-37 and 3.0-38). Under 

Alternative 1 for testing activities, 7 air targets (decoy) and 316 air targets (drone) would be expended 

annually (Table 3.0-31). Impacts from testing activities would be similar to those of training activities, 

but would occur in proportion to the number of activities, i.e., less frequent interactions with aircraft, 

more frequent interactions with targets as compared to training. Disturbance by aircraft and aerial 

targets would be temporary and inconsequential to long-term fitness of individuals. Bird or bat strikes 

may occur to a relatively small number of individuals, but no population-level impacts would occur, 

especially when considering the Navy’s standard operating procedures for aircraft safety (see Section 

2.1.1.3, Standard Operating Procedures).

Pursuant to the ESA, the use of aircraft and aerial targets during testing activities as described under 

Alternative 1 would have no effect on piping plover critical habitat, but may affect Bermuda petrels,

piping plovers, roseate terns, red knots, Indiana bats, and northern long-eared bats. The Navy has 

consulted with the USFWS as required by section 7(a)(2) of the ESA in this regard.

3.9.3.4.2.2 Impacts from Aircraft and Aerial Targets Under Alternative 2

Impacts from Aircraft and Aerial Targets Under Alternative 2 for Training Activities

The use of aircraft and aerial targets under Alternative 2 for training would be virtually identical to what 

would occur under Alternative 1 (Tables 3.0-37, 3.0-38, and 3.0-29); therefore, the same impact 

conclusions apply.

Pursuant to the ESA, the use of aircraft and aerial targets during training activities as described under 

Alternative 2 would have no effect on piping plover critical habitat, but may affect Bermuda petrels, 

piping plovers, roseate terns, red knots, Indiana bats, and northern long-eared bats. 

Impacts from Aircraft and Aerial Targets Under Alternative 2 for Testing Activities

Compared to Alternative 1, the use of aircraft under Alternative 2 for testing would be slightly greater 

(5.3 percent difference over a 5-year period) (Tables 3.0-37 and 3.0-38) but would be the same for 

targets (Table 3.0-31). Therefore, impacts would be slightly greater under Alternative 2, but would still 

be inconsequential due to the relatively small number of individuals affected and the lack of populationlevel effects.
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Pursuant to the ESA, the use of aircraft and aerial targets during testing activities as described under 

Alternative 2 would have no effect on piping plover critical habitat, but may affect Bermuda petrels, 

piping plovers, roseate terns, red knots, Indiana bats, and northern long-eared bats. 

3.9.3.4.2.3 Impacts from Aircraft and Aerial Targets Under the No Action Alternative

Impacts from Aircraft and Aerial Targets Under the No Action Alternative for Training and Testing 

Activities

Under the No Action Alternative, the Navy would not conduct the proposed training and testing 

activities in the AFTT Study Area. Various physical disturbance and strike stressors (e.g., aircraft and 

aerial targets) would not be introduced into the marine environment. Therefore, baseline conditions of 

the existing environment would either remain unchanged or would improve slightly after cessation of 

ongoing training and testing activities.

3.9.3.4.3 Impacts from Military Expended Materials

This section analyzes the strike potential to birds and bats from the following categories of military 

expended materials: (1) all sizes of non-explosive practice munitions, (2) fragments from high-explosive 

munitions, and (3) expended materials other than munitions, such as sonobuoys, and expendable 

targets. See Appendix F (Military Expended Materials and Direct Strike Impact Analyses) for more 

information on the locations, types and quantities of military expended materials proposed to be used. 

Exposure of birds or bats to military expended materials during Navy training and testing activities could 

result in physical injury or behavioral disturbances to birds or bats in air, at the surface, or underwater 

during foraging dives. Although a quantitative analysis is not possible due to the absence of bird or bat

density information in the Study Area, an assessment of the likelihood of exposure to military expended 

materials was conducted based on general bird and bat distributions in the Study Area.

The widely dispersed area in which bombs and missiles would be expended in the Study Area annually 

(see Chapter 2, Description of Proposed Action and Alternatives), coupled with the often patchy 

distribution of seabirds (Fauchald et al., 2002; Haney, 1986a; Schneider & Duffy, 1985) and the

infrequent use of the Study Area by foraging bats (Ahlén et al., 2009; Bureau of Ocean Energy 

Management, 2013; Johnson et al., 2011; U.S. Department of Energy, 2016), suggest that the probability 

of these types of ordnance striking a seabird or bat would be low. The number of small-caliber 

projectiles that would be expended annually during various activities (e.g., gunnery exercises) is much 

higher than the number of large-caliber projectiles and other large munitions. However, the total 

number of rounds expended is not a good indicator of strike probability during gunnery exercises 

because multiple rounds of large-caliber projectiles and other large munitions are generally fired at 

individual targets during a single event.

Human activity such as vessel or boat movement, aircraft overflights, and target placement, could cause 

birds or bats to flee a target area before the onset of firing, thus avoiding harm. If birds or bats were in 

the target area, they would likely flee the area prior to the release of military expended materials or just 

after the initial rounds strike the target area. Additionally, the force of military expended material 

fragments dissipates quickly once the pieces hit the water, so direct strikes on birds foraging below the 

surface would not be likely. Also, munitions would not be used in shallow/nearshore areas. The 

potential likelihood of individual birds or bats being struck by munitions is very low; thus, impacts on 

bird or bat populations would not be expected.
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3.9.3.4.3.1 Impacts from Military Expended Materials Under Alternative 1

Impacts from Military Expended Materials Under Alternative 1 for Training Activities

Table B-1 in Appendix B (Actvivity Stressor Matrices) provides a breakdown of the different activities 

that generate these military expended materials for training. Tables 3.0-24, 3.0-25, 3.0-27, 3.0-29, 3.0-

30, and 3.0-32 in Section 3.0.3.3.4.2 (Military Expended Materials) provide a breakdown of the types of 

materials expended and the loctations of where they are expended under both action alternatives for 

training. Training activities would occur throughout the Study Area. Appendix F (Military Expended 

Materials and Direct Strike Impact Analyses) provides details on the types, numbers and footprints of 

expended materials by location.

The potential impact of military expended materials on birds or bats in the Study Area is dependent on 

the ability of birds or bats to detect and avoid foreign objects through their sensory systems and the 

relatively fast flying speeds and maneuverability of most bird and bat species. The potential for impact is 

related to the probability of a bird or bat and a projectile meeting in the same space at the same time. 

The amount of materials expended over the vast area over which training and testing activities occur,

combined with the ability of birds and bats to flee disturbance and the infrequent use of the Study Area

by foraging bats (Ahlén et al., 2009; Bureau of Ocean Energy Management, 2013; Johnson et al., 2011; 

U.S. Department of Energy, 2016), would make direct strikes unlikely. Individual birds or bats may be 

impacted, but strikes would have no impact on species or populations.

Direct strikes from firing weapons (projectiles) or air-launched devices (e.g., sonobuoys, torpedoes) are 

a potential stressor to seabirds and bats. Seabirds in flight, resting on the water’s surface, or foraging 

just below the water surface, as well as bats in flight, would be vulnerable to a direct strike. Strikes have 

the potential to injure or kill seabirds or bats in the Study Area. However, there would not be long-term 

population-level impacts. The footprint calculations in Appendix F (Military Expended Materials and 

Direct Strike Impact Analyses, Tables F-2 through F-7) indicate relatively small areas of impact and, 

consequently, a low probability of strikes to birds by the types of materials that pose the greatest risk to 

birds (e.g., projectiles, torpedoes, surface targets) on an annual or cumulative 5-year basis. Since bats 

occur in the Study Area much less frequently than birds, it is expected that the likelihood of a bat strike 

is proportionally less than that for a bird strike. Furthermore, the vast area over which training activities 

occur combined with the ability of seabirds and bats to flee disturbance, would make direct strikes 

unlikely. Individual seabirds or bats may be affected, but strikes would have no impact on species or 

populations.

If ESA-listed species were in the immediate area where military expended materials are present, they

could be impacted by military expended material strikes. It is highly unlikely that a bird or bat would be 

struck by military expended materials because most birds and bats in the vicinity of the approaching 

aircraft or vessel, from which the military expended materials are released, would likely be dispersed by 

the sound of its approach before it could come close enough for an impact from a strike or a disturbance 

to take place. Therefore, activities that release military expended materials would not likely cause any 

potential strike risk to birds or bats in the Study Area. 

Although designated piping plover critical habitat occurs throughout the coastal habitats of the 

Southeast U.S. Continental Shelf and Gulf of Mexico Large Marine Ecosystems, none of these areas 

overlap with the use of military expended materials in the Study Area. Behavioral changes are not 

expected to have lasting effects on the survival, growth, recruitment, or reproduction of bird 
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populations. Therefore, none of the military expended materials will affect piping plover critical habitat. 

No long-term or population-level impacts are expected.

Pursuant to the ESA, the use of military expended materials during training activities as described under 

Alternative 1 would have no effect on piping plover critical habitat, Indiana bats, or northern long-eared 

bats; but may affect Bermuda petrels, piping plovers, roseate terns, and red knots. The Navy has 

consulted with the USFWS as required by section 7(a)(2) of the ESA in this regard.

Impacts from Military Expended Materials Under Alternative 1 for Testing Activities

Table B-2 in Appendix B (Actvivity Stressor Matrices) provides a breakdown of the different activities 

that generate these military expended materials for testing. Tables 3.0-26, 3.0-28, 3.0-31, and 3.0-33 in 

Section 3.0.3.3.4.2 (Military Expended Materials) provide a breakdown of the types of materials 

expended and the loctations of where they are expended under both action alternatives for testing.

Testing activities would occur throughout the Study Area. Appendix F (Military Expended Materials and 

Direct Strike Impact Analyses) provides details on the types, numbers and footprints of expended 

materials by location.

The potential impact of military expended materials on birds or bats in the Study Area is dependent on 

the ability of birds or bats to detect and avoid foreign objects through their sensory systems and the 

relatively fast flying speeds and maneuverability of most bird and bat species. The potential for impact is 

related to the probability of a bird or bat and a projectile meeting in the same space at the same time. 

The amount of materials expended over the vast area over which training and testing activities occur,

combined with the ability of birds and bats to flee disturbance and the infrequent use of the Study Area

by foraging bats (Ahlén et al., 2009; Bureau of Ocean Energy Management, 2013; Johnson et al., 2011; 

U.S. Department of Energy, 2016), would make direct strikes unlikely. Individual birds or bats may be 

impacted, but strikes would have no impact on species or populations.

Direct strikes from firing weapons (projectiles) or air-launched devices (e.g., sonobuoys, torpedoes) are 

a potential stressor to seabirds and bats. Seabirds in flight, resting on the water’s surface, or foraging 

just below the water surface, as well as bats in flight, would be vulnerable to a direct strike. Strikes have 

the potential to injure or kill seabirds or bats in the Study Area. However, there would not be long-term 

population-level impacts. The footprint calculations in Appendix F (Military Expended Materials and 

Direct Strike Impact Analyses, Tables F-14 through F-17) indicate relatively small areas of impact and,

consequently, a low probability of strikes to birds by the types of materials that pose the greatest risk to 

birds (e.g., projectiles, torpedoes, surface targets) on an annual or cumulative 5-year basis. Since bats 

occur in the Study Area much less frequently than birds, it is expected that the likelihood of a bat strike 

is proportionally less than that for a bird strike. Furthermore, the vast area over which testing activities 

occur combined with the ability of seabirds and bats to flee disturbance, would make direct strikes 

unlikely. Individual seabirds or bats may be affected, but strikes would have no impact on species or 

populations.

If ESA-listed species were in the immediate area where military expended materials are present, they

could be impacted by military expended material strikes. It is highly unlikely that a bird or bat would be 

struck by military expended materials because most birds and bats in the vicinity of the approaching 

aircraft or vessel, from which the military expended materials are released, would likely be dispersed by 

the sound of its approach before it could come close enough for an impact from a strike or a disturbance 

to take place. Therefore, activities that release military expended materials would not likely cause any 

potential strike risk to birds or bats in the Study Area.
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Pursuant to the ESA, the use military expended materials during testing activities as described under 

Alternative 1 would have no effect on piping plover critical habitat, piping plovers, red knots, Indiana 

bats, or northern long-eared bats; but may affect Bermuda petrels and roseate terns. The Navy has 

consulted with the USFWS as required by section 7(a)(2) of the ESA in this regard.

3.9.3.4.3.2 Impacts from Military Expended Materials Under Alternative 2

Impacts from Military Expended Materials Under Alternative 2 for Training Activities

The differences in expended materials between Alternatives 1 and 2 for training activities are relatively 

small and inconsequential with respect to the types of materials that pose the greatest risk to birds 

(Appendix F, Military Expended Materials and Direct Strike Impact Analyses, Tables F-2 through F-7). 

Since bats occur in the Study Area much less frequently than birds, it is expected that the likelihood of a 

bat strike is proportionally less than that for a bird strike. As a result, impacts of military expended 

materials from training activities under Alternative 2 would be essentially the same as those of 

Alternative 1.

Pursuant to the ESA, the use of military expended materials during training activities as described under 

Alternative 2 would have no effect on piping plover critical habitat, Indiana bats, or northern long-eared 

bats; but may affect Bermuda petrels, piping plovers, roseate terns, and red knots. 

Impacts from Military Expended Materials Under Alternative 2 for Testing Activities

The differences in expended materials between Alternatives 1 and 2 for testing activities are relatively 

small and inconsequential with respect to the types of materials that pose the greatest risk to birds 

(Appendix F, Military Expended Materials and Direct Strike Impact Analyses, Tables F-14 through F-17). 

Since bats occur in the Study Area much less frequently than birds, it is expected that the likelihood of a 

bat strike is proportionally less than that for a bird strike. As a result, impacts of military expended 

materials from testing activities under Alternative 2 would be essentially the same as those of 

Alternative 1.

Pursuant to the ESA, the use of military expended materials during testing activities as described under 

Alternative 2 would have no effect on piping plover critical habitat, piping plovers, red knots, Indiana 

bats, or northern long-eared bats; but may affect Bermuda petrels and roseate terns. 

3.9.3.4.3.3 Impacts from Military Expended Materials Under the No Action Alternative

Impacts from Military Expended Materials Under the No Action Alternative for Training and 

Testing Activities

Under the No Action Alternative, the Navy would not conduct the proposed training and testing 

activities in the AFTT Study Area. Various physical disturbance and strike stressors (e.g., military 

expended materials) would not be introduced into the marine environment. Therefore, baseline 

conditions of the existing environment would either remain unchanged or would improve slightly after 

cessation of ongoing training and testing activities. 

3.9.3.4.4 Impacts from Seafloor Devices

As discussed in Section 3.0.3.3.4.3 (Seafloor Devices), seafloor devices that are used during training and 

testing activities are deployed onto the seafloor in shallow water and later recovered. Because these 

devices are stationary or very slow moving, they do not pose a risk of physical disturbance or strike to 

birds, including ESA-listed species. Since bats do not occur in the water column, there is no potential for 

seafloor devices and bats to interact. Because of this, seafloor devices would have no impacts to birds or 
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bats and will not be discussed further. Pursuant to the ESA, the use of seafloor devices during training 

and testing activities as described under Alternatives 1 and 2 would have no effect on piping plover 

critical habitat, Bermuda petrels, piping plovers, red knots, roseate terns, Indiana bats, or northern longeared bats. The Navy has consulted on Alterntive 1 with the USFWS as required by section 7(a)(2) of the 

ESA in this regard.

3.9.3.4.5 Impacts from Pile Driving

There would be no pile driving or vibratory pile extraction associated with testing activities. Therefore, 

pile driving related to testing is not analyzed in this subsection. Section 3.9.3.1.4 (Impacts from Pile 

Driving) describes the impacts from noise to birds and bats that would occur from the installation and 

removal of piles in the vicinity of training events involving the construction of an Elevated Causeway 

System, a temporary pier that allows the offloading of ships in areas without a permanent port. Human 

activity such as vessel or boat movement, and equipment setting and movement, is expected to cause 

birds and bats to flee the activity area before the onset of pile driving. If birds or bats were in the activity 

area, they would likely flee the area prior to, or just after, the initial strike of the pile at the beginning of 

the ramp-up procedure. Pile driving during training is, therefore, not considered physical disturbance or 

strike stressor for birds or bats. Pursuant to the ESA, pile driving during training activities as described 

under Alternatives 1 and 2 would have no effect on piping plover critical habitat, Bermuda petrels, 

piping plovers, red knots, roseate terns, Indiana bats, or northern long-eared bats. The Navy has 

consulted on Alterntive 1 with the USFWS as required by section 7(a)(2) of the ESA in this regard.

3.9.3.5 Entanglement Stressors

This section analyzes the potential entanglement impacts of the various types of expended materials 

used by the Navy during training and testing activities within the Study Area. This analysis includes the 

potential impacts of three types of military expended materials, including: (1) wires and cables, (2) 

decelerators/parachutes, and (3) biodegradable polymers. Aspects of entanglement stressors that are 

applicable to marine organisms in general are presented in Section 3.0.3.3.5 (Entanglement Stressors). 

The annual numbers and locations of expended wires, cables, parachutes, and activities using 

biodegradable polymers are provided in Tables 3.0-32 through 3.0-34.

Along the continental U.S. and near Hawaii, at least 44 species of seabirds are known to become 

entangled in plastic or marine debris. From 2001–2005, entanglement rates ranged from 0.2% to 1.2% 

for all seabirds observed by beach monitoring programs in California, Oregon, and Washington. 

Common murres and western gulls were the most common species found entangled. While the vast 

majority of entanglements involved fishing gear (e.g., monofilament line and hooks), approximately 

8.3% of the entanglements were from non-fishery-related items (e.g., plastics and other synthetic 

materials that they may gather for making nests). Cormorants in Maine have been observed making 

nests from such plastic marine debris, including net fragments and fishing line. It is thought that the 

biggest threat of entanglement from using debris as nesting material is to the chicks, but no such 

entanglements have been observed (National Oceanic and Atmospheric Administration, 2016). 

Given the limited amount of time that wires and cables would remain suspended in air and the ability of 

birds and bats to detect and avoid parachutes in-air, the likelihood that a bird or bat would become 

entangled in-air is considered remote and discountable. As such, this analysis is focused on the potential 

for entanglement at the water surface, in the water column, or on the seafloor.

The cables, wires, decelerators/parachutes, and biodegradable polymer are relatively conspicuous in 

contrast to fishing lines, do not form long loops of line that are hard to break, do not tend to snag 
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animals that swim through them, and do not persist for a long time in the water column. The Navyexpended materials sink gradually (0.24 m/second in the case of guidance wires) to the bottom. These 

materials would be readily avoided by visually oriented seabirds that could be foraging or resting in the 

water. Unlike fishing gear, the Navy’s equipment does not capture fish and therefore decreases the 

attractiveness to foraging seabirds. Additional information is provided in the sections below.

Since bats considered in this analysis do not occur in the water column, rarely occur at the water surface 

in the Study Area, and would not be attracted to cables, wires, or decelerators/parachutes, few, if any, 

impacts to bats are anticipated from these entanglement stressors. As discussed in Section 3.9.2.1.3

(Dive Behavior), the Mexican bulldog bat (or fishing bat) primarily eats fish caught with its relatively 

large feet and long, sharp claws near the water’s surface and would not be expected to become 

entangled with any entanglement stressor. Furthermore, this species occurs outside of the Study Area in 

Mexico, Puerto Rico, and the U.S. Virgin Islands (Jones et al., 1973; Placer, 1998) and is expected to 

venture into the Study Area while foraging only infrequently. Therefore, bats are not evaluated further 

for entanglement stressors.

3.9.3.5.1 Impacts from Wires and Cables

Table B-1 in Appendix B (Actvivity Stressor Matrices) provides a breakdown of the different activities 

that have wires and cables for training. Table 3.0-39 in Section 3.0.3.3.5.1 (Wires and Cables) provides a 

breakdown of the types of wires and cables used and the quantities and loctations of where they are 

used under both action alternatives for training. These items include fiber optic cables, guidance wires, 

and sonobuoy components. 

Fiber optic cables are flexible cables that can range in size up to 300 m in length. The length of guidance 

wires would generally be equal to the distance the torpedo or missile travels to impact the target, which 

may increase entanglement risk to birds with long wires (over 1,000 m) expended into the environment.

Sonobuoys consist of a surface antenna and float unit and a subsurface hydrophone assembly unit. The 

two units are attached through a thin-gauge, dual-conductor, hard draw copper strand cable, which is 

then wrapped by a hollow rubber tubing or bungee in a spiral configuration. The length of cable that 

extends out is no more than 1500 ft. and is dependent on the water depth and type of sonobuoy. The 

hydrophone components maybe covered by thin plastic netting depending on type of sonobuoy. Each 

sonobuoy has a saltwater activated polyurethane float that inflates when the sonobuoy is submerged 

and keeps the sonobuoy components floating vertically in the water column below it. Sonobuoys remain 

suspended in the water column for no more than 30 hours, after which they sink to the seafloor. While 

longer cables present a higher likelihood of bird interactions, and therefore present an increased risk of 

entanglement of a bird, these cables should be readily avoidable by birds that could be foraging or 

resting in the water. 

The entanglement risk from these components would only occur when a bird and these components 

were in close proximity at the water surface, in the water column, or on the seafloor. As stated above, 

however, these materials would be readily avoided by visually oriented seabirds that could be foraging 

or resting in the water and do not pose the same entanglement risks as fishing gear. Some sonobuoy 

components, once they sink to the bottom, may be transported by bottom currents or active tidal 

influence, and present an enduring entanglement risk. In the benthic environment, however, 

subsequent colonization by encrusting organisms, burying by sediment, and chemical breakdown of the 

various materials would further reduce the potential for reintroduction as an entanglement risk.
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3.9.3.5.1.1 Impacts from Wires and Cables under Alternative 1

Impacts from Wires and Cables under Alternative 1 for Training Activities

As discussed in Section 3.0.3.3.5.1 (Wires and Cables), under Alternative 1 training activities, fiber optic 

cables, guidance wires, and sonobuoy components that would pose an entanglement risk to birds would 

be expended primarily in the Northeast, Virginia Capes, Navy Cherry Point, Jacksonville, and Gulf of 

Mexico Range Complexes. However, given that these stressors are widely dispersed over vast areas and 

do not persist or accumulate at the surface or in the water column where seabirds forage, encounters 

with seabirds would be infrequent. This is coupled with a remote likelihood that a bird encountering the 

expended material would become entangled, as described above. As a result, the potential for 

entanglement from wires and cables to lead to injury or mortality is negligible. Therefore, no long-term 

or population-level impacts to birds would occur.

Pursuant to the ESA, the use of wires and cables during training activities as described under 

Alternative 1 would have no effect on Bermuda petrels, piping plovers, roseate terns, red knots, Indiana 

bats, or northern long-eared bats, and would have no effect on piping plover critical habitat. The Navy 

has consulted with the USFWS as required by section 7(a)(2) of the ESA in this regard.

Impacts from Wires and Cables under Alternative 1 for Testing Activities

As discussed in Section 3.0.3.3.5.1 (Wires and Cables), under Alternative 1 testing activities, fiber optic 

cables, guidance wires, and sonobuoy components that would pose an entanglement risk to birds would

be expended primarily in the Northeast, Virginia Capes, Navy Cherry Point, Jacksonville, Key West, and 

Gulf of Mexico Range Complexes, along with testing ranges (Naval Undersea Warfare Center Newport, 

South Florida Ocean Measurement Facility, and Naval Surface Warfare Center Panama). However, given 

that these stressors are widely dispersed over vast areas and do not persist or accumulate at the surface 

or in the water column where seabirds forage, encounters with seabirds would be infrequent. This is 

coupled with a remote likelihood that a bird encountering the expended material would become 

entangled, as described above. As a result, the potential for entanglement from wires and cables to lead 

to injury or mortality is negligible. Therefore, no long-term or population-level impacts to birds would 

occur.

Pursuant to the ESA, the use of wires and cables during testing activities as described under 

Alternative 1 would have no effect on Bermuda petrels, piping plovers, roseate terns, red knots, Indiana 

bats, or northern long-eared bats, and would have no effect on piping plover critical habitat. The Navy 

has consulted with the USFWS as required by section 7(a)(2) of the ESA in this regard.

3.9.3.5.1.2 Impacts from Wires and Cables under Alternative 2

Impacts from Wires and Cables under Alternative 2 for Training Activities

As discussed in Section 3.0.3.3.5.1 (Wires and Cables), under Alternative 2 training activities, fiber optic 

cables, guidance wires, and sonobuoy components would be expended in the same areas as Alternative 

1, with increases in the number of expended items that would pose an entanglement risk. Under 

Alternative 2, increases in sonobuoy component releases would occur in Virginia Capes, Navy Cherry 

Point, Jacksonville, and Gulf of Mexico Range Complexes. Fiber optic cable releases would increase 

under Alternative 2 in Virginia Capes, Jacksonville, and Gulf of Mexico Range Complexes, while there 

would be no change in the number or locations of guidance wire releases compared to Alternative 1. 

Given the foregoing analysis, however, the impacts would be essentially the same as for Alternative 1. 

Therefore, no long-term or population-level impacts to birds would occur.
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Pursuant to the ESA, the use of wires and cables during training activities as described under 

Alternative 2 would have no effect on Bermuda petrels, piping plovers, roseate terns, red knots, Indiana 

bats, or northern long-eared bats, and would have no effect on piping plover critical habitat. 

Impacts from Wires and Cables under Alternative 2 for Testing Activities

As discussed in Section 3.0.3.3.5.1 (Wires and Cables), under Alternative 2 testing activities, fiber optic 

cables, guidance wires, and sonobuoy components would be expended in the same areas as Alternative 

1, with increases to the number of expended items that would pose an entanglement risk. Under 

Alternative 2, increases in sonobuoy component releases would occur in Northeast, Virginia Capes, Navy 

Cherry Point, Jacksonville, Key West, and Gulf of Mexico Range Complexes. Fiber optic cable releases 

would increase under Alternative 2 in Virginia Capes Range Complex and Naval Surface Warfare Center 

Panama, while there would be no change in the number or locations of guidance wire releases 

compared to Alternative 1. Given the foregoing analysis, however, the impacts would be essentially the 

same as for Alternative 1. Therefore, no long-term or population-level impacts to birds would occur.

Pursuant to the ESA, the use of wires and cables during testing activities as described under 

Alternative 1 would have no effect on Bermuda petrels, piping plovers, roseate terns, red knots, Indiana 

bats, or northern long-eared bats, and would have no effect on piping plover critical habitat. 

3.9.3.5.1.3 Impacts from Wires and Cables under the No Action Alternative

Impacts from Wires and Cables under the No Action Alternative for Training and Testing Activities

Under the No Action Alternative, the Navy would not conduct the proposed training and testing 

activities in the AFTT Study Area. Various entanglement stressors (e.g., wires and cables) would not be 

introduced into the marine environment. Therefore, baseline conditions of the existing environment 

would either remain unchanged or would improve slightly after cessation of ongoing training and testing 

activities.

3.9.3.5.2 Impacts from Decelerators/Parachutes

Section 3.0.3.3.5.2 (Decelerators/Parachutes) describes the use and platforms where 

decelerators/parachutes would be released into the marine environment and therefore present an 

entanglement risk to birds. Aircraft-launched sonobuoys, lightweight torpedoes (such as the MK 46 and 

MK 54), illumination flares, and targets use nylon decelerators/parachutes ranging in size from 1.5 to 82

feet in diameter. The majority are relatively small cruciform shape decelerators/parachutes associated 

with sonobuoys (18 to 48 inches in diameter). Once a sonobuoy hits the water surface, its 

decelerator/parachute is designed to produce drag at the surface for 5–15 seconds, allowing for 

deployment of the sonobuoy, then the decelerator/parachute separates and sinks. The 

decelerator/parachute assembly contains metallic components and could be at the surface for a short 

period before sinking to the seafloor. Sonobuoy decelerators/parachutes are designed to sink within 15 

minutes, but the rate of sinking depends upon sea conditions and the shape of the 

decelerator/parachute, and the duration of the descent would depend on the water depth. 

Decelerators/parachutes or decelerator/parachute lines may be a risk for birds to become entangled, 

particularly while at the surface. As stated above, however, these materials would be readily avoided by 

visually oriented seabirds that could be foraging or resting in the water and do not pose the same 

entanglement risks as fishing gear.

If the decelerator/parachute and its lines sink to the seafloor in an area where the bottom is calm, it 

would remain there undisturbed. Over time, it may become covered by sediment in most areas or 
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colonized by attaching and encrusting organisms, which would further stabilize the material and reduce 

the potential for reintroduction as an entanglement risk. If bottom currents are present, the canopy may 

billow and pose an entanglement threat to birds that feed in benthic habitats. Bottom-feeding birds 

tend to forage in nearshore areas rather than offshore, where these decelerators/parachutes are used; 

therefore, birds are not likely to encounter decelerators/parachutes once they reach the seafloor. The 

potential for a bird to encounter an expended decelerator/parachute at the surface or in the water 

column is extremely low, it is even less probable at the seafloor given the general improbability of a bird 

being near the deployed decelerator/parachute as well as the general behavior of birds. Depending on 

how quickly the decelerator/parachute may degrade, the risk may increase with time if the 

decelerator/parachute remains intact. Factors that may influence degradation times include exposure to 

ultraviolet radiation and the extent of physical damage of the decelerator/parachute on the water’s 

surface, as well as water temperature and sinking depth.

3.9.3.5.2.1 Impacts from Decelerators/Parachutes under Alternative 1

Impacts from Decelerators/Parachutes under Alternative 1 for Training Activities

As detailed in Table 3.0-32, under Alternative 1 training activities, decelerators/parachutes that would 

pose an entanglement risk to birds would be expended primarily in the Northeast, Virginia Capes, Navy 

Cherry Point, and Jacksonville Range Complexes. However, given that these stressors are widely 

dispersed over vast areas and do not persist or accumulate at the surface or in the water column where 

seabirds forage, encounters with seabirds would be infrequent. This is coupled with a remote likelihood 

that a bird encountering the expended material would become entangled, as described above. As a 

result, the potential for entanglement from decelerators/parachutes to lead to injury or mortality is 

negligible. Therefore, no long-term or population-level impacts to birds would occur.

Pursuant to the ESA, the use of decelerators/parachutes during training activities as described under 

Alternative 1 would have no effect on Bermuda petrels, piping plovers, roseate terns, red knots, Indiana 

bats, or northern long-eared bats, and would have no effect on piping plover critical habitat. The Navy 

has consulted with the USFWS as required by section 7(a)(2) of the ESA in this regard.

Impacts from Decelerators/Parachutes under Alternative 1 for Testing Activities

As detailed in Table 3.0-34, under Alternative 1 testing activities, decelerators/parachutes that would 

pose an entanglement risk would be used throughout the range complexes and testing ranges of the 

Study Area. However, given that these stressors are widely dispersed over vast areas and do not persist 

or accumulate at the surface or in the water column where seabirds forage, encounters with seabirds 

would be infrequent. This is coupled with a remote likelihood that a bird encountering the expended 

material would become entangled, as described above. As a result, the potential for entanglement from 

decelerators/parachutes to lead to injury or mortality is negligible. Therefore, no long-term or 

population-level impacts to birds would occur.

Pursuant to the ESA, the use of decelerators/parachutes during testing activities as described under 

Alternative 1 would have no effect on Bermuda petrels, piping plovers, roseate terns, red knots, Indiana 

bats, or northern long-eared bats, and would have no effect on piping plover critical habitat. The Navy 

has consulted with the USFWS as required by section 7(a)(2) of the ESA in this regard.
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3.9.3.5.2.2 Impacts from Decelerators/Parachutes under Alternative 2

Impacts from Decelerators/Parachutes under Alternative 2 for Training Activities

Under Alternative 2, the number of decelerators/parachutes that would be expended during training 

activities would be about 2.8 percent larger than under Alternative 1. This difference reflects the 

addition of training activities using decelerators/parachutes in the Gulf of Mexico Range Complex (Table 

3.0-32). This would proportionally increase the possibility of entanglement relative to Alternative 1, but, 

the likelihood of injury or mortality is still considered negligible, and the impact conclusion for 

decelerators/parachutes under Alternative 2 training activities is the same as for Alternative 1.

Pursuant to the ESA, the use of decelerators/parachutes during training activities as described under 

Alternative 2 would have no effect on Bermuda petrels, piping plovers, roseate terns, red knots, Indiana 

bats, or northern long-eared bats, and would have no effect on piping plover critical habitat.

Impacts from Decelerators/Parachutes under Alternative 2 for Testing Activities

Under Alternative 2, the number of decelerators/parachutes that would be expended during testing 

activities would be about 8.6 percent larger than under Alternative 1, with the same general distribution 

of activities throughout the Study Area (Table 3.0-34). This would proportionally increase the possibility 

of entanglement relative to Alternative 1, but, the likelihood of injury or mortality is still considered 

negligible, and the impact conclusion for decelerators/parachutes under Alternative 2 testing activities is 

the same as for Alternative 1.

Pursuant to the ESA, the use of decelerators/parachutes during testing activities as described under 

Alternative 2 would have no effect on Bermuda petrels, piping plovers, roseate terns, red knots, Indiana 

bats, or northern long-eared bats, and would have no effect on piping plover critical habitat.

3.9.3.5.2.3 Impacts from Decelerators/Parachutes under the No Action Alternative

Impacts from Decelerators/Parachutes under the No Action Alternative for Training and Testing 

Activities

Under the No Action Alternative, the Navy would not conduct the proposed training and testing 

activities in the AFTT Study Area. Various entanglement stressors (e.g., decelerators/parachutes) would 

not be introduced into the marine environment. Therefore, baseline conditions of the existing 

environment would either remain unchanged or would improve slightly after cessation of ongoing 

training and testing activities.

3.9.3.5.3 Impacts from Biodegradable Polymers

The possibility of entanglement in the biodegradable polymer is considered remote and discountable 

given the fact that the material is only deployed on a small-scale in test locations (Table 3.0-42), is shortlived in the water, and that diving birds routinely navigate through floating vegetation without becoming 

entangled (unlike boat propellers which the polymer is designed to entangle). The biodegradable

polymer is, therefore, not considered an entanglement stressor for birds.

3.9.3.6 Ingestion Stressors

As described in Section 3.0.3.3.6 (Ingestion Stressors), the types of expended materials that are 

potentially a source of ingestion stressors include non-explosive practice munitions (small and medium 

caliber), fragments from high-explosive munitions, fragments from targets, chaff, plastic end caps from 

chaff cartridges, the plastic compression pads, end caps from pistons and flares, small 

decelerators/parachutes, and biodegradable polymers (discussed in Section 3.0.3.3.5.3, Biodegradable 
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Polymer). Other types of expended materials are too large to be mistaken for food items and consumed 

by birds. Since bats considered in this analysis do not occur in the water column and rarely feed at the 

water surface in the Study Area, few, if any, impacts to bats are anticipated from ingestion stressors. As 

such, impacts to bats from ingestion stressors will not be discussed further.

3.9.3.6.1 Impacts from Military Expended Materials - Munitions

Two types of munitions are potentially a source of ingestion stressors: non-explosive practice munitions 

(small and medium caliber) and fragments from high-explosive munitions. Both types of munitions sink 

rapidly through the water column and settle to the bottom. Munitions are not used in nearshoreshallow areas and, because of their density, are likely to bury in the bottom and are unlikely to be 

transported from offshore to nearshore. It is thus highly unlikely that munitions would accumulate 

where benthic nearshore or intertidal foraging would occur. Rapidly sinking munitions and fragments 

are unlikely to be accessible or attractive as potential food items to diving birds that feed on fish and 

invertebrates in the water column. Accordingly, there are no potential impacts to birds feeding in the 

water column or on the bottom from this category of ingestion stressors and it will not be discussed 

further.

3.9.3.6.2 Impacts from Military Expended Materials - Other Than Munitions

The analysis in this section includes the potential ingestion of military expended materials other than 

munitions, all of which are expended away from nearshore habitats and close to the water surface. 

Tables 3.0-24 through 3.0-28; 3.0-32 through 3.0-34; and 3.0-43 and 3.0-44 describe the annual 

quantities and locations where these materials would be generated by training and testing activities 

under Alternatives 1 and 2. Appendix A (Navy Activity Descriptions) provides more specific information 

on the activities that may result in ingestion stressors, and the typical locations where these activities 

occur. 

While it has been widely documented that a wide range of marine organisms (including zooplankton, 

baleen whales, and seabirds) will ingest plastic, the mechanism that causes these organisms to do so 

was discovered only recently (Savoca, 2016; Savoca et al., 2016). Procellariiformes, or tube-nosed 

seabirds (e.g., albatrosses, shearwaters and petrels) utilize a highly developed sense of smell to find 

food that is patchily distributed in offshore and open ocean environments. Specifically, these birds are 

attracted to dimethyl sulfide, which is produced when the cell walls of algae are damaged (e.g., when 

marine herbivores such as krill eat it), thereby alerting the seabirds that food (e.g., krill) are nearby. 

Through a literature review, Savoca et al. (2016) demonstrated that seabirds that utilize dimethyl sulfide 

as a foraging cue consumed plastic nearly six times more frequently than species that were not attracted 

to dimethyl sulfide. Savoca et al. (2016) also performed field studies that confirmed that algae growing 

on three of the most common types of plastic debris (polypropylene and low- and high-density 

polyethylene) can produce dimethyl sulfide within three weeks at concentrations at least four orders of 

magnitude above the behavioral detection threshold for Antarctic prions (Pachyptila desolata), thereby 

creating an “olfactory trap.” 

Birds could potentially ingest expended materials other than munitions used by the Navy during training 

and testing activities within the Study Area. The Navy expends the following types of materials that 

could become ingestion stressors for birds during training and testing in the Study Area: missile 

components, target fragments, chaff and flare endcaps/pistons, and decelerators/parachutes. 

Biodegradable polymers generated during countermeasures testing are also considered. Ingestion of 

expended materials by birds could occur in all large marine ecosystems and open ocean areas and would 
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occur either at the surface or just below the surface portion of the water column, depending on the size 

and buoyancy of the expended object and the feeding behavior of the birds. Floating material of 

ingestible size could be eaten by birds that feed at or near the water surface, while materials that sink 

pose a potential risk to diving birds that feed just below the water’s surface (Titmus & Hyrenbach, 2011). 

Some items, such as decelerators/parachutes or sonobuoys are too large to be ingested and will not be 

discussed further. Also, decelerators/parachutes sink rapidly to the seafloor. 

Physiological impacts to birds from ingestion include blocked digestive tracts and subsequent food 

passage, blockage of digestive enzymes, lowered steroid hormone levels, delayed ovulation (egg 

maturation), reproductive failure, nutrient dilution (nonnutritive debris displaces nutritious food in the 

gut), exposure to indirect effects from harmful chemicals found in and on the plastic material, and 

altered appetite satiation (the sensation of feeling full), which can lead to starvation (Azzarello & Van 

Vleet, 1987; Provencher et al., 2014). While ingestion of marine debris has been linked to bird 

mortalities, sublethal impacts are more common (Moser & Lee, 1992).

Many species of seabirds are known to ingest floating plastic debris and other foreign matter while 

feeding on the surface of the ocean (Auman et al., 1997; Provencher et al., 2014; Yamashita et al., 2011). 

A recent review of the literature documented the ingestion of marine debris by 122 species of seabirds 

(Gall & Thompson, 2015). Evidence indicates that physical and toxicological impacts from plastic 

ingestion by seabirds are widespread among species and pervasive in terms of the number of individuals 

affected, and that impacts are increasing (Wilcox et al., 2016). For example, 21 of 38 seabird species (55 

percent) collected off the coast of North Carolina from 1975 to 1989 contained plastic particles (Moser 

& Lee, 1992). The mean particle sizes of ingested plastic were positively correlated with the birds’ size 

though the mean mass of plastic found in the stomachs and gizzards of 21 species was below 3 grams. 

Some seabirds have used plastic and other marine debris for nest building which may lead to ingestion 

of that debris (Votier et al., 2011). Indirect ingestion of plastic also occurs from consuming prey such as 

fish that ingest plastic.

Plastic is often mistaken for prey, and the incidence of plastic ingestion appears to be related to a bird’s 

feeding mode and diet (Henry et al., 2011; Provencher et al., 2014). Seabirds that feed by pursuit diving, 

surface-seizing, and dipping tend to ingest plastic, while those that feed by plunging or piracy typically 

do not ingest plastic (Azzarello & Van Vleet, 1987; Provencher et al., 2014). Birds of the order 

Procellariiformes, which include petrels, shearwaters, and albatrosses, tend to accumulate more plastic 

than other species (Azzarello & Van Vleet, 1987; Moser & Lee, 1992; Pierce et al., 2004; Provencher et 

al., 2014). Some birds, including gulls and terns, commonly regurgitate indigestible parts of their food 

items such as shell and fish bones. However, the structure of the digestive systems of most 

Procellariiformes makes it difficult to regurgitate solid material such as plastic (Azzarello & Van Vleet, 

1987; Moser & Lee, 1992; Pierce et al., 2004). 

As summarized by Pierce et al. (2004), Auman et al. (1997), and Azzarello and Van Vleet (1987), 

documented consequences of plastic ingestion by seabirds include blockage of the intestines and 

ulceration of the stomach, reduction in the functional volume of the gizzard leading to a reduction of 

digestive capability, and distention of the gizzard leading to a reduction in hunger. Dehydration has also 

been documented in seabirds that have ingested plastic (Sievert & Sileo, 1993). Studies have also found 

negative correlations between body weight and plastic load, as well as between body fat (a measure of 

energy reserves), and the number of pieces of plastic in a seabird’s stomach (Auman et al., 1997; Sievert 

& Sileo, 1993). Other possible concerns that have been identified include toxic plastic additives and toxic 

contaminants that could be adsorbed to the plastic from ambient seawater. Pierce et al. (2004)
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described two cases where plastic ingestion caused seabird mortality from starvation. The examination 

of a deceased adult northern gannet revealed that a 1.5 in. diameter plastic bottle cap lodged in its 

gizzard blocked the passage of food into the small intestine, which resulted in its death from starvation. 

Northern gannets are substantially larger, and dive deeper than the ESA-listed birds in the Study Area. 

Also, since gannets typically utilize flotsam in nest building (Votier et al., 2011), they may be more 

susceptible to ingesting marine debris than other species as it gathers that material. Dissection of an 

adult greater shearwater’s gizzard revealed that a 1.5 in. by 0.5 in. fragment of plastic blocked the 

passage of food in the digestive system, which also resulted in death from starvation. 

Species such as storm-petrels, albatrosses, shearwaters, fulmars, and noddies that forage by picking 

prey from the surface may have a greater potential to ingest any floating plastic debris. Ingestion of 

plastic military expended materials by any species from the 10 taxonomic groups found within the Study 

Area (Table 3.9-1) has the potential to impact individual birds. Ocean currents concentrate plastic 

debris, making birds that feed along frontal zones more susceptible (Azzarello & Van Vleet, 1987). While 

some seabird mortality could occur, these factors indicate that a small number of birds would be 

affected and that population-level effects would not be expected.

Items of concern are those of ingestible size that remain floating at the surface, including lighter items 

such as plastic end caps from chaff and flares, pistons, and chaff, that may be caught in currents and 

gyres or snared in floating Sargassum before sinking. 

Target-Related Materials. As described in Section 3.0.3.3.6.3 (Military Expended Materials Other Than 

Munitions), at-sea targets are usually remotely-operated airborne, surface, or subsurface traveling units, 

most of which are designed to be recovered for reuse. However, if they are used during activities that 

utilize high-explosives then they may result in fragments. Expendable targets that may result in 

fragments would include air-launched decoys, surface targets (e.g., marine markers, paraflares, 

cardboard boxes, and 10 ft. diameter red balloons), and mine shapes. Most target fragments would sink 

quickly to the seafloor. Floating material, such as Styrofoam, may be lost from target boats and remain 

at the surface for some time. Only targets that may result in smaller fragments that do not immediately 

sink are included in the analyses of ingestion potential.

There are additional types of targets discussed previously, but only surface targets, subsurface targets, 

air targets, sinking exercise ship hulks, and mine shapes would be expected to result in fragments when 

high-explosive munitions are used.

Chaff. As described in Section 3.0.3.3.6.3 (Military Expended Materials Other Than Munitions), large 

areas of air space and open water within the Study Area would be exposed to chaff at very low

concentrations. This same section also provides a general discussion of chaff as an ingestion stressor and 

concludes that chaff poses little risk to organisms, except at concentrations substantially higher than 

those that could reasonably occur from military training. Additional information is provided below.

It is unlikely that chaff would be selectively ingested (U.S. Air Force, 1997). Ingestion of chaff fibers is not 

expected to cause substantial damage to a bird’s digestive tract based on the fibers’ small size (ranging 

in lengths of 0.25–3 in. with a diameter of about 40 micrometers) and flexible nature, as well as the 

small quantity that could reasonably be ingested. In addition, concentrations of chaff fibers that could 

reasonably be ingested are not expected to be toxic to birds. Scheuhammer (1987) reviewed the 

metabolism and toxicology of aluminum in birds and mammals. Intestinal adsorption of orally ingested 

aluminum salts was very poor, and the small amount adsorbed was almost completely removed from 

the body by excretion. Dietary aluminum normally has minor impacts on healthy birds and mammals, 
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and often high concentrations (greater than 1,000 milligrams per kilogram) are needed to induce effects 

such as impaired bone development, reduced growth, and anemia (U.S. Department of the Navy, 1999). 

A bird weighing 2.2 pounds (lb.) would need to ingest more than 83,000 chaff fibers per day to receive a 

daily aluminum dose equal to 1,000 milligram per kilogram; this analysis was based on chaff consisting 

of 40 percent aluminum by weight and a 5-ounce chaff canister containing 5 million fibers. As an 

example, an adult herring gull weighs about 1.8–2.7 lb. (Cornell Lab of Ornithology, 2009). It is highly 

unlikely that a bird would ingest a toxic dose of chaff based on the anticipated environmental 

concentration of chaff (i.e., 1.8 fibers per square foot for an unrealistic, worst-case scenario of 360 chaff 

cartridges simultaneously released at a single drop point).

Flares. A general discussion of flares as an ingestion stressor is presented in Section 3.0.3.3.6.3 (Military 

Expended Materials Other Than Munitions). Ingestion of flare compression pads or pistons 1.3 in. in 

diameter and 0.13 in. thick (U.S. Air Force, 1997) by birds may result in gastrointestinal obstruction or 

reproductive complications. Based on the information presented above, if a seabird were to ingest a 

compression pads or pistons, the response would vary based on the species and individual bird. The 

responses could range from none, to sublethal (reduced energy reserves), to lethal (digestive tract 

blockage leading to starvation). Ingestion of compression pads or pistons by species that regularly 

regurgitate indigestible items would likely have no adverse impacts. However, compression pads or

pistons are similar in size to those plastic pieces described above that caused digestive tract blockages 

and eventual starvation. Therefore, ingestion of compression pads or pistons could be lethal to some 

individual seabirds. Species with small gizzards and anatomical constrictions that make it difficult to 

regurgitate solid material would likely be most susceptible to blockage (such as Procellariiformes). Based 

on available information, it is not possible to accurately estimate actual ingestion rates or responses of 

individual birds.

Biodegradable Polymer. The biodegradable polymer used in countermeasure testing could theoretically 

be ingested by birds; however, the likelihood is low because the material would persist only until the 

polymer degrades. Some of the polymer constituents would dissolve within two hours of immersion 

and it is anticipated that the material will breakdown into small pieces within a few days to weeksof 

deployment (discussed in Section 3.0.3.3.5.3, Biodegradable Polymer). Therefore, the biodegradable 

polymer is not considered an ingestion stressor for birds and will not be discussed further.

3.9.3.6.2.1 Impacts from Military Expended Materials - Other Than Munitions Under

Alternative 1

Impacts from Military Expended Materials- Other Than Munitions Under Alternative 1 for Training 

Activities

As indicated in Section 3.0.3.3.6.3 (Military Expended Materials Other Than Munitions), the use of chaff,

flares, and targets would occur and could generate expended materials constituting ingestion stressors 

throughout the Study Area. Although chaff fibers and pieces of biodegradable polymer are too small for 

birds to confuse with prey, there is some potential for chaff and biodegradable polymer to be 

incidentally ingested along with other prey items. If ingested, neither chaff nor biodegradable polymer 

are expected to impact birds, due to the low concentration that would be ingested and the small size of 

the fibers. 

The plastic materials associated with flare compression pads or pistons sink in saltwater (U.S. 

Department of the Navy, 1999), which reduces the likelihood of ingestion by seabirds. However, some of 

the material could remain at or near the surface if it were to fall directly on a dense Sargassum mat. 

Actual environmental concentrations would vary based on actual release points and dispersion by wind 
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and water currents. The number of compression pads and pistons that would remain at the surface in 

Sargassum mats, and would potentially be available to seabirds, is expected to be an extremely small 

percentage of the total.

Although the overall concentration of military expended materials would be low, and Navy standard 

practice is to collect and remove as much Styrofoam as possible when retrieving a degraded target, 

military expended materials would not be evenly distributed. Similarly, seabirds are not evenly 

distributed in the Study Area (Fauchald et al., 2002; Haney, 1986a, 1986b; Schneider & Duffy, 1985). As 

noted previously, there is some potential for expended materials that float (e.g., some types of target 

fragments or chaff end caps or flare compression pads and pistons) to become concentrated along 

frontal zones, along with food resources that tend to attract foraging seabirds, resulting in the incidental 

ingestion of such materials, most likely as very small fragments. Military expended materials would 

constitute a minute portion of the floating debris that seabirds would be exposed to and may 

accidentally consume in such situations, but could nevertheless contribute to harmful effects of 

manmade debris on some seabirds. The overall likelihood that individual birds would be negatively 

impacted by ingestion of military expended materials in the Study Area under Alternative 1 for training 

is considered low, but not discountable. Population-level effects would be very unlikely given the 

relatively small quantities and limited persistence of military expended materials in habitats where birds 

are most likely to forage. This conclusion applies to ESA-listed bird species as well.

If foraging in an area where military expended materials are present on the sea surface, roseate terns 

and Bermuda petrels could ingest military expended materials. The odds of this are low because of the 

very low density of birds and large areas over which they forage, combined with the low density of Navy 

activities and expended materials across the vast Study Area. Piping plovers and red knots may 

encounter expended materials on beaches (e.g., along the James River and tributaries where up to 

20,400 flares would be expended per year [Table 3.0-33]). A bird’s consumption of a piece of Navyexpended material may or may not be harmful, but if added to the burden of marine debris from other 

sources (Wilcox et al., 2016), harmful effects would be more likely. Effects to individuals are thus 

possible, but it is unlikely that populations of these ESA-listed species would be affected. The same 

considerations apply to the rare but unlisted black-capped petrel. No long-term or population-level 

impacts are expected.

Pursuant to the ESA, the potential for ingestion of military expended materials other than munitions 

during training activities as described under Alternative 1 would have no effect on Indiana bats, 

northern long-eared bats, or piping plover critical habitat; but may affect Bermuda petrels, piping 

plovers, red knots, and roseate terns. The Navy has consulted with the USFWS as required by section 

7(a)(2) of the ESA in this regard.

Impacts from Military Expended Materials - Other Than Munitions Under Alternative 1 for Testing 

Activities

Testing activities under Alternative 1 would generate the same types of ingestible materials generated 

by training activities. As shown in Tables 3.0-26, 3.0-28, 3.0-31, 3.0-34, and 3.0-42, the quantity of 

materials used during testing activities would generally be substantially less than those used during 

training activities (except for mine shapes, which would be used substantially more frequently during 

testing activities). Testing activities would also occur in other areas not used for training activities (e.g., 

Naval Undersea Warfare Center Newport Testing Range, Naval Surface Warfare Center Carderock 

Division’s South Florida Ocean Measurement Facility, and Naval Surface Warfare Center Panama City 
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Testing Range). Therefore, testing activities would have similar, but generally reduced, impacts to those 

of training activities under Alternative 1.

Pursuant to the ESA, the potential for ingestion of military expended materials other than munitions 

during testing activities as described under Alternative 1 would have no effect on Indiana bats, northern 

long-eared bats, piping plovers, red knots, or piping plover critical habitat; but may affect Bermuda 

petrels and roseate terns. The Navy has consulted with the USFWS as required by section 7(a)(2) of the 

ESA in this regard.

3.9.3.6.2.2 Impacts from Military Expended Materials - Other Than Munitions Under

Alternative 2

Impacts from Military Expended Materials - Other Than Munitions Under Alternative 2 for Training 

Activities

Training activities under Alternative 2 would generate the same types of ingestible materials generated 

by training activities under Alternative 1. While the quantities and locations of some expended materials 

would change slightly, the vast majority would be the same under Alternative 2 as under Alternative 1 

(Tables 3.0-24, 3.0-25, 3.0-29, 3.0-30, and 3.0-32). Therefore, the implementation of Alternative 2 would 

have similar impacts to those of training activities under Alternative 1.

Pursuant to the ESA, the potential for ingestion of military expended materials other than munitions 

during training activities as described under Alternative 2 would have no effect on Indiana bats, 

northern long-eared bats, or piping plover critical habitat; but may affect Bermuda petrels, piping 

plovers, red knots, and roseate terns. 

Impacts from Military Expended Materials - Other Than Munitions Under Alternative 2 for Testing 

Activities

Testing activities under Alternative 2 would generate the same types of ingestible materials generated 

by testing activities under Alternative 1. While the quantities and locations of some expended materials 

would change slightly, the vast majority would be the same under Alternative 2 as under Alternative 1 

(Tables 3.0-26, 3.0-28, 3.0-31, 3.0-34, and 3.0-42). Therefore, the implementation of Alternative 2 would 

have similar impacts to those of testing activities under Alternative 1.

Pursuant to the ESA, the potential for ingestion of military expended materials other than munitions 

during testing activities as described under Alternative 2 would have no effect on Indiana bats, northern 

long-eared bats, piping plovers, red knots, or piping plover critical habitat; but may affect Bermuda 

petrels and roseate terns. 

3.9.3.6.2.3 Impacts from Military Expended Materials - Other Than Munitions Under the 

No Action Alternative

Impacts from Military Expended Materials - Other Than Munitions Under the No Action Alternative 

for Training and Testing Activities

Under the No Action Alternative, the Navy would not conduct the proposed training and testing 

activities in the AFTT Study Area. Various physical disturbance and strike stressors (e.g., military 

expended materials other than munitions) would not be introduced into the marine environment. 

Therefore, baseline conditions of the existing environment would either remain unchanged or would 

improve slightly after cessation of ongoing training and testing activities. 
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3.9.3.7 Secondary Stressors

This section analyzes potential impacts on birds exposed to stressors indirectly through impacts to 

habitat and prey availability (e.g., sediment, water and air quality). Since these stressors also affect 

primary elements of bird habitat, firm distinctions between indirect impacts and habitat impacts are 

difficult to maintain. It is important to note that the terms “indirect” and “secondary” do not imply 

reduced severity of environmental consequences, but instead describe how the impact may occur in an 

organism or its ecosystem.

Stressors from Navy training and testing activities could pose secondary or indirect impacts on birds via 

impacts to habitat, sediment, or water quality. Disturbing sediment or impacting water quality could 

also impact the food-chain, which in turn could largely impact vital seabird habitat and prey availability. 

Components of these stressors that could pose indirect impacts are detailed in Tables 2.6-1 to 2.6-5, and 

analyses of their potential impacts are discussed in Section 3.2 (Sediments and Water Quality), Section 

3.4 (Invertebrates), Section 3.5 (Habitats), and Section 3.6 (Fishes).

Since bats considered in this analysis do not occur in the water column and rarely feed at the water 

surface in the Study Area, few, if any, impacts to bats are anticipated from secondary stressors. As such, 

impacts to bats from secondary stressors will not be discussed further.

3.9.3.7.1 Impacts on Habitat

The potential of water, air quality, and abiotic habitat stressors associated with training and testing 

activities to indirectly affect birds, as a secondary stressor, was analyzed. The assessment of potential 

water, air quality, and abiotic habitat stressors is discussed in previous sections in this DEIS/OEIS 

(Section 3.1, Air Quality; Section 3.2, Sediments and Water Quality; and Section 3.5, Habitats). These 

analyses addresses specific activities in local environments that may affect bird habitats. At-sea activities 

that may impact water and air include general emissions, and at-sea activities that may affect habitats 

include explosives and physical disturbance and strike. 

As noted in Sections 3.1 (Air Quality), Section 3.2 (Sediments and Water Quality), and Section 3.5 

(Habitats), implementation of the No Action Alternative, Alternative 1, or Alternative 2 would minimally 

impact sediments, water, air quality, or habitats, and therefore would not indirectly impact seabirds as 

secondary stressors. Furthermore, any physical impacts on seabird habitats would be temporary and 

localized because training and testing activities would occur infrequently. These activities would not be 

expected to indirectly impact birds or bird habitats.

Although designated piping plover critical habitat occurs throughout the coastal habitats of the 

Southeast U.S. Continental Shelf and Gulf of Mexico Large Marine Ecosystems, none of these areas 

overlap activities that could potentially impact sediments, water, or air quality. While piping plovers do 

forage in the intertidal portions of the Study Area, these areas do not overlap with any locations where 

military activities occur that have any potential to impact sediments, water, or air quality. Therefore, 

secondary stressors will not affect piping plover critical habitat. 

Indirect impacts on sediments, water, or air quality under Alternative 1 or Alternative 2 would have no 

effect on ESA-listed bird species due to: (1) the temporary nature of impacts on sediments, water, or air 

quality, (2) the distribution of temporary sediments, water, or air quality impacts, (3) the wide 

distribution of birds in the Study Area, and (4) the dispersed spatial and temporal nature of the training 

and testing activities that may have temporary sediments, water, or air quality impacts. No long-term or 

population-level impacts are expected.
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Pursuant to the ESA, secondary impacts on habitat during training or testing activities as described 

under Alternative 1 would have no effect on piping plover critical habitat, Bermuda pretrels, piping 

plovers, red knots, and roseate terns. The Navy has consulted with the USFWS as required by section 

7(a)(2) of the ESA in this regard.

3.9.3.7.2 Impacts on Prey Availability

As noted in Section 3.4 (Invertebrates) and Section 3.6 (Fishes), implementation of the No Action 

Alternative, Alternative 1, or Alternative 2 would not adversely impact populations of invertebrate or 

fish prey resources (e.g., crustaceans, bivalves, worms, sand lance, herring, etc.) of birds and therefore 

would not indirectly impact birds as secondary stressors. Any impacts on seabird prey resources would 

be temporary and localized. Furthermore, as discussed above, these activities are expected to have 

minimal impacts to bird habitats. Additional detail is provided below.

As discussed in Section 3.4.3.7 (Secondary Stressors), impacts on invertebrate prey availability resulting 

from explosives, explosives byproducts, unexploded munitions, metals, and chemicals would likely be 

negligible overall and population-level impacts on marine invertebrates are not expected. Because 

individuals of many invertebrate taxa prey on other invertebrates, mortality resulting from explosions or 

exposure to metals or chemical materials would reduce the number of invertebrate prey items available. 

A few species prey upon fish, and explosions and exposure to metals and chemical materials could result 

in a minor reduction in the number of fish available. However, the effect is expected to be small and 

discountable. Any vertebrate or invertebrate animal killed or significantly impaired by Navy activities 

could potentially represent an increase in food availability for scavenging invertebrates. None of the 

effects described above would likely be detectable at the population or subpopulation level.

As noted in Section 3.6.3.7.2, (Fishes, Impacts on Prey Availability), prey species might exhibit a strong 

startle reaction to detonations that might include swimming to the surface or scattering away from the 

source. This startle and flight response is the most common secondary defense among animals (Hanlon 

& Messenger, 1996). The sound from underwater explosions might induce startle reactions and 

temporary dispersal of schooling fishes if they are within close proximity to an explosion (Popper et al., 

2014; Wright, 1982), which in turn could make them more visible to predators (Kastelein et al., 2008). 

The abundances of fish and invertebrate prey species near the detonation point could be diminished for 

a short period of time before being repopulated by animals from adjacent waters. Alternatively, any 

prey species that would be directly injured or killed by the blast could draw in scavengers from the 

surrounding waters that would feed on those organisms, who in turn could be susceptible to becoming 

directly injured or killed by subsequent explosions. Any of these scenarios would be temporary, only 

occurring during activities involving explosives, and no lasting impact on prey availability or the food 

web would be expected. Indirect impacts of underwater detonations and high-explosive munitions use 

under the Proposed Action would not result in a decrease in fish populations in the Study Area.

Based on Sections 3.4 (Invertebrates) and 3.6 (Fishes), project-related stressors would not impact 

populations of invertebrates and fishes that support birds in the Study Area. Therefore, no secondary 

impacts to birds associated with prey availability are expected. Furthermore, the Navy will implement 

mitigation (e.g., not conducting gunnery activities within a specified distance of shallow-water coral 

reefs) to avoid potential impacts from explosives and physical disturbance and strike stressors on 

seafloor resources in mitigation areas throughout the Study Area (see Section 5.4.1, Mitigation Areas for 

Seafloor Resources). This mitigation will consequently help avoid potential impacts on bird prey that 

inhabits shallow-water coral reefs, live hard bottom, artificial reefs, and shipwrecks.
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Pursuant to the ESA, secondary impacts on prey availability during training or testing activities as 

described under Alternative 1 would have no effect on piping plover critical habitat, Bermuda pretrels, 

piping plovers, red knots and roseate terns. The Navy has consulted with the USFWS as required by 

section 7(a)(2) of the ESA in this regard.

3.9.4 SUMMARY OF POTENTIAL IMPACTS ON BIRDS AND BATS

3.9.4.1 Combined Impacts of All Stressors Under Alternative 1

As described in Section 3.0.3.5 (Resource-Specific Impacts Analysis for Multiple Stressors), this section 

evaluates the potential for combined impacts of all stressors from the Proposed Action. The analysis and 

conclusions for the potential impacts from each of the individual stressors are discussed in the sections 

above and, for ESA-listed species, summarized in Section 3.9.5 (Endangered Species Act 

Determinations). Stressors associated with Navy training and testing activities do not typically occur in 

isolation but rather occur in some combination. For example, mine neutralization activities include 

elements of acoustic, physical disturbance and strike, entanglement, ingestion, and secondary stressors 

that are all coincident in space and time. An analysis of the combined impacts of all stressors considers 

the potential consequences of aggregate exposure to all stressors and the repetitive or additive 

consequences of exposure over multiple years. The individual stressor analyses provided previously 

indicate that the vast majority of exposures to stressors are non-lethal. Hence the analysis of combined 

effects focuses on consequences potentially impacting the organism’s fitness (e.g., physiology, behavior, 

reproductive potential).

Most of the birds in the Study Area are relatively long-lived and wide-ranging seabirds, making it likely 

that individuals would be exposed to multiple activities and stressors over the course of their lifespans. 

Multiple stressors can affect individual birds in two ways: 1) from exposure to multiple sources of stress 

during a single event or activity; and 2) from exposure to a combination of stressors over the course of 

the bird’s life. Both general scenarios are more likely to occur where training and testing activities are 

concentrated. The key difference between the two scenarios is the amount of time between exposures 

to stressors. Time is an important factor because subsequent disturbances or injuries often increase the 

time needed for the organism to recover to baseline behavior or physiology, extending the time that the 

organism’s fitness is impacted. On the other hand, bats are not relatively long-lived and occur in the 

Study Area only infrequently while foraging. As such, individual bats are unlikely to be exposed to a 

combination of stressors over the course of its lifetime.

Birds and bats are susceptible to multiple stressors (see Section 3.9.2.1.5, General Threats), and the 

susceptibility of many species could be enhanced by additive or synergistic effects of multiple stressors. 

As discussed in the analyses above, birds and bats are not particularly susceptible to energy, 

entanglement, or ingestion stressors resulting from Navy activities; therefore, the opportunity for Navy 

stressors to result in additive or synergistic consequences is most likely limited to acoustic/explosive, 

and physical strike and disturbance stressors. The potential for impacts associated with combined 

acoustic/explosive and physical strike and disturbance stressors is lessened by the fact that most 

activities are conducted offshore in areas where birds, and especially bats, occur at relatively low 

concentrations.

Despite uncertainty in the nature of consequences resulting from combined impacts, the location of 

potential combined impacts can be predicted with more certainty because combinations are much more 

likely in locations where training and testing activities are concentrated. However, analyses of the 

nature of potential consequences of combined impacts of all stressors on birds and bats remain largely 
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qualitative and speculative. For example, an individual bird or bat that becomes injured or disoriented 

from an acoustic or explosive exposure may be less able to avoid subsequent exposure to physical 

disturbance and strike. Where multiple stressors coincide with high abundances of birds (bats do not 

occur in the Study Area in high abundance), the possibilities of negative consequences are increased, 

but not enough is known about the potential additive or synergistic effects to predict them with any 

confidence. Stressors vary in intensity, with injuries or mortality occurring rarely, and most exposures 

not having persistent or accumulating effects to individuals or populations. In general, combined 

impacts will depend upon the coincidence of multiple stressors affecting the same individuals at the 

same place and time. Such occurrences are relatively infrequent because the activities and stressors are 

widely dispersed, affecting very small portions of the Study Area and relatively small numbers of 

individuals at any given time.

It is also likely that Navy stressors will combine with non-Navy stressors, as qualitatively discussed in 

Chapter 4 (Cumulative Impacts).

3.9.4.2 Combined Impacts of All Stressors Under Alternative 2

Combined impacts of all stressors under Alternative 2 would be largely the same as, but incrementally 

greater than, those of Alternative 1. Given the slightly larger number of activities overall and 

proportionately greater exposure of birds and bats to most types of stressors, the potential for additive 

or synergistic effects is slightly greater under Alternative 2 than Alternative 1. However, as for 

Alternative 1, the nature of combined impacts is difficult to predict or quantify. Activities and the 

resultant stressors are widely dispersed, affecting very small portions of the Study Area and relatively 

small numbers of individuals at any given time.

3.9.4.3 Combined Impacts of All Stressors Under the No Action Alternative

Under the No Action Alternative, the Navy would not conduct the proposed training and testing 

activities in the AFTT Study Area. Various stressors would not be introduced into the marine 

environment. Therefore, baseline conditions of the existing environment would either remain 

unchanged or would improve slightly after cessation of ongoing training and testing activities. 

3.9.5 ENDANGERED SPECIES ACT DETERMINATIONS

Pursuant to the ESA, the Navy identified Alternative 1 as the preferred alternative under the proposed 

action. As identified in section 3.9.3 (Environmental Consequences), under Alternative 1, Navy training 

and testing activities may affect ESA-listed bird or bat species and will have no effect on designated 

critical habitat because the proposed action does not have any elements with the potential to modify 

such habitat. In all cases for which a “may affect” determination was reached, the Navy determined that 

the corresponding activities are not likely to adversely affect the species. The Navy has consulted with 

the USFWS as required by section 7(a)(2) of the ESA in that regard. The Navy’s ESA determinations for 

the effects of specific stressors on birds and bats under Alternative 1 are summarized in Table 3.9 6 and 

Table 3.9 7, respectively. USFWS concurred with all Navy determinations. 

3.9.6 MIGRATORY BIRD TREATY ACT DETERMINATIONS

The Navy has determined that the Proposed Action may result in the “take” of migratory birds. The term 

“take” as defined by the USFWS for Migratory Bird Treaty Act purposes means to “pursue, hunt, shoot, 

wound, kill, trap, capture, or collect” (50 CFR part 10.12). The Proposed Action, however is a military 

readiness activity; therefore, “take” is in compliance with the Migratory Bird Treaty Act. Under the 

Migratory Bird Treaty Act regulations applicable to military readiness activities (50 CFR Part 21), the 
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USFWS has promulgated a rule that authorizes the incidental take of migratory birds provided they do 

not result in a significant adverse effect on a population of a migratory seabird species. These proposed 

training and testing activities would not result in a significant adverse impact on any population of a 

migratory bird species.
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Table 3.9-6: Bird Effect Determinations for Training and Testing Activities Under the Proposed Action

Species

Designation 

Unit

Effect Determinations by Stressor

Acoustic

Explo

-sives Energy Physical Disturbance and Strike Entanglement Ingestion

Sonar and Other TransducersAir GunsPile DrivingVessel NoiseAircraft NoiseWeapons NoiseExplosivesIn-water Electromagnetic DevicesIn-air Electromagnetic DevicesHigh-energy LasersVessels In-water DevicesAircraft and Aerial TargetsMilitary Expended MaterialsSeafloor DevicesWires and CablesDecelerators/ParachutesBiodegradable PolymerMilitary Expended Materials - MunitionsMilitary Expended Materials - Other Than Munitions

Training Activities

Bermuda 

petrel

Throughout 

range NLAA N/A NLAA NLAA NLAA NLAA NLAA NLAA NLAA NLAA NLAA NLAA NLAA NLAA NE NE NE N/A NE NLAA

Piping plover

Throughout 

range NE N/A NLAA NLAA NLAA NLAA NLAA NE NLAA NE NLAA NLAA NLAA NLAA NE NE NE N/A NE NLAA

Critical habitat NE N/A NE NE NE NE NE NE NE NE NE NE NE NE NE NE NE N/A NE NE

Red knot Throughout 

range NE N/A NLAA NLAA NLAA NLAA NLAA NE NLAA NE NLAA NLAA NLAA NLAA NE NE NE N/A NE NLAA

Roseate tern

Northeast 

Region NE N/A NLAA NLAA NLAA NLAA NLAA NLAA NLAA NLAA NLAA NLAA NLAA NLAA NE NE NE N/A NE NLAA

Southeast 

Region NE N/A NLAA NLAA NLAA NLAA NLAA NLAA NLAA NLAA NLAA NLAA NLAA NLAA NE NE NE N/A NE NLAA

Testing Activities

Bermuda 

petrel

Throughout 

range NLAA NLAA N/A NLAA NLAA NLAA NLAA NLAA NLAA NLAA NLAA NLAA NLAA NLAA NE NE NE NE NE NLAA

Piping plover

Throughout 

range NE NE N/A NLAA NLAA NLAA NLAA NLAA NLAA NE NLAA NLAA NLAA NE NE NE NE NE NE NE

Critical habitat NE NE N/A NE NE NE NE NE NE NE NE NE NE NE NE NE NE NE NE NE

Red knot Throughout 

range NE NE N/A NLAA NLAA NLAA NLAA NLAA NLAA NE NLAA NLAA NLAA NE NE NE NE NE NE NE

Roseate tern

Northeast 

Region NE NE N/A NLAA NLAA NLAA NLAA NLAA NLAA NLAA NLAA NLAA NLAA NLAA NE NE NE NE NE NLAA

Southeast 

Region NE NE N/A NLAA NLAA NLAA NLAA NLAA NLAA NLAA NLAA NLAA NLAA NLAA NE NE NE NE NE NLAA

Note: NE = no effect; NLAA = may effect, not likely to adversely affect; LAA = may effect, likely to adversely affect; N/A = not applicable, activity related to the stressor does not occur during specified training or testing

events (e.g., there are no testing activities that involve the use of pile driving).
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Table 3.9-7: Bat Effect Determinations for Training and Testing Activities under the Proposed Action

Species Designati

on Unit

Effect Determinations by Stressor

Acoustic

Explo

-sives Energy Physical Disturbance & Strike Entanglement Ingestion

Sonar and Other TransducersAir GunsPile DrivingVessel NoiseAircraft NoiseWeapons NoiseExplosivesIn-water Electromagnetic DevicesIn-air Electromagnetic DevicesHigh-energy LasersVessels In-water DevicesAircraft and Aerial TargetsMilitary Expended MaterialsSeafloor DevicesPile DrivingWires and CablesDecelerators/ParachutesBiodegradable PolymerMilitary Expended Materials - MunitionsMilitary Expended Materials - Other Than Munitions

Training Activities

Indiana bat Throughout 

range NE N/A NLAA NLAA NLAA NLAA NLAA NE NLAA NLAA NLAA NLAA NLAA NE NE NE NE NE N/A NE NE

Northern longeared batThroughout 

range NE N/A NLAA NLAA NLAA NLAA NLAA NE NLAA NLAA NLAA NLAA NLAA NE NE NE NE NE N/A NE NE

Testing Activities

Indiana bat Throughout 

range NE NE N/A NLAA NLAA NLAA NLAA NE NLAA NLAA NLAA NLAA NLAA NE NE N/A NE NE NE NE NE

Northern longeared batThroughout 

range NE NE N/A NLAA NLAA NLAA NLAA NE NLAA NLAA NLAA NLAA NLAA NE NE N/A NE NE NE NE NE

Note: NE = no effect; NLAA = may effect, not likely to adversely affect; LAA = may effect, likely to adversely affect; N/A = not applicable, activity related to the stressor does not occur during specified training or testing events (e.g., 

there are no testing activities that involve the use of pile driving).
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3.9 References

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Table of Contents

Final

Environmental Impact Statement/Overseas Environmental Impact Statement

Atlantic Fleet Training and Testing

TABLE OF CONTENTS

3.10 Cultural Resources..................................................................................... 3.10-1

3.10.1 Introduction and Methods................................................................................3.10-1

3.10.1.1 Introduction......................................................................................3.10-1

3.10.1.2 Identification, Evaluation, and Treatment of Cultural 

Resources .........................................................................................3.10-2

3.10.1.3 Methods............................................................................................3.10-3

3.10.1.4 Methods for Impact Analysis............................................................3.10-7

3.10.2 Affected Environment.......................................................................................3.10-7

3.10.2.1 Submerged Prehistoric Resources....................................................3.10-8

3.10.2.2 Known Wrecks, Obstructions, Occurrences, or “Unknowns”...........3.10-8

3.10.2.3 Tortugas Military Operations Area ...................................................3.10-9

3.10.3 Environmental Consequences ........................................................................3.10-16

3.10.3.1 Explosive Stressors..........................................................................3.10-16

3.10.3.2 Physical Disturbance and Strike Stressors......................................3.10-21

3.10.4 Summary of Potential Impacts on Cultural Resources ...................................3.10-27

3.10.4.1 Combined Impacts of All Stressors under Alternative 1.................3.10-27

3.10.4.2 Combined Impacts of All Stressors under Alternative 2.................3.10-27

3.10.4.3 Combined Impacts of All Stressors under the No Action 

Alternative......................................................................................3.10-28

3.10.4.4 National Historic Preservation Act..................................................3.10-28

List of Figures

Figure 3.10-1: Artifacts from a Submerged Prehistoric Resource ........................................................3.10-6

Figure 3.10-2: Submerged Historic Resource (Spanish Galleon) ..........................................................3.10-7

Figure 3.10-3: High-Resolution Side-Scan Sonar Image of Submerged Historic Resource...................3.10-7

Figure 3.10-4: Known Shipwrecks, Obstructions, Occurrences, or Sites Marked as 

“Unknown” in the Northeast United States Continental Shelf Large Marine 

Ecosystem......................................................................................................................3.10-10

Figure 3.10-5: Known Shipwrecks, Obstructions, Occurrences, or Sites Marked as 

“Unknown” in the Southeast United States Continental Shelf Large Marine 

Ecosystem......................................................................................................................3.10-11
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Table of Contents

Figure 3.10-6: Known Shipwrecks, Obstructions, Occurrences, or Sites Marked as 

“Unknown” in the Southeast United States Continental Shelf, Caribbean Sea, 

and Gulf of Mexico Large Marine Ecosystems...............................................................3.10-12

List of Tables

Table 3.10-1: National Historic Landmarks, Monuments, and Cultural Resource Listed in the 

National Register of Historic Places...............................................................................3.10-13

Table 3.10-2: Summary of Section 106 Effects of Training and Testing Activities on Cultural 

Resources.......................................................................................................................3.10-28
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Training and Testing Final EIS/OEIS September 2018

3.10-1

3.10 Cultural Resources

3.10CULTURAL RESOURCES

3.10.1 INTRODUCTION AND METHODS

3.10.1.1 Introduction

Submerged cultural resources are found throughout the Atlantic Fleet Training and Testing (AFTT) Study 

Area. The approach for the assessment of submerged cultural resources includes defining the resource; 

presenting the regulatory requirements for the identification, evaluation, and treatment within 

established jurisdictional parameters; establishing the specific resources subtypes in the Study Area; 

identifying the data used to define the current conditions; and providing the method for impact analysis.

Cultural resources are defined as districts, landscapes, sites, structures, objects, and ethnographic 

resources, as well as other physical evidence of human activities that are considered important to a 

culture, subculture, or community for scientific, traditional, religious, or other reasons. Cultural 

resources include archaeological resources, architectural resources, and traditional cultural properties 

related to pre-contact (prior to European contact) and post-contact periods.

Archaeological resources include prehistoric and historic sites and artifacts. Archaeological resources 

can have a surface component, a subsurface component, or both. Prehistoric resources are physical 

properties resulting from human activities that predate written records and can include village sites, 

temporary camps, lithic scatters, roasting pits, hearths, milling features, petroglyphs, rock features, shell 

mounds, and burials. Historic resources postdate the advent of written records in a region and include 

building foundations, refuse scatters, wells, cisterns, and privies. Submerged cultural resources include 

historical shipwrecks and other submerged historical materials, such as sunken airplanes and prehistoric 

cultural remains. Architectural resources are elements of the built environment consisting of standing 

buildings or structures from the historic period. These resources include existing buildings, dams, 

bridges, lighthouses, and forts. Traditional cultural properties are resources associated with beliefs and 

cultural practices of a living culture, subculture, or community. These beliefs and practices must be 

rooted in the group’s history and must be important in maintaining the cultural identity of the group. 

Prehistoric archaeological sites and artifacts, historic and contemporary locations of traditional events, 

sacred places, landscapes, and resource collection areas, including fishing, hunting, or gathering areas, 

may be traditional cultural resources.

CULTURAL RESOURCES SYNOPSIS

The United States Department of the Navy considered all potential stressors that cultural resources 

could potentially be exposed to from the Proposed Action. The following conclusions have been 

reached for the Preferred Alternative (Alternative 1):

 Explosive: Explosive stressors resulting from underwater explosions creating shock waves 

and cratering of the seafloor would not result in adverse effects to known submerged 

cultural resources. Therefore, no submerged cultural resources are expected to be affected.

 Physical Disturbance and Strike: Physical disturbance and strike stressors resulting from 

in-water devices, military expended materials, seafloor devices, pile driving, and vibration 

from sonic booms during training and testing activities would not result in adverse effects to 

known or unknown submerged cultural resources. Therefore, no submerged cultural 

resources are expected to be affected.
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3.10.1.2 Identification, Evaluation, and Treatment of Cultural Resources

Procedures for identifying, evaluating, and treating cultural resources within state territorial waters 

(within 3 nautical miles [NM] of the coast) and United States (U.S.) territorial waters (within 12 NM of 

the coast) are contained in a series of federal and state laws and regulations, and agency guidelines. 

Archaeological, architectural, and cultural (including Native American and Native Hawaiian) resources 

are protected by a variety of laws and their implementing regulations: the National Historic Preservation 

Act of 1966 as amended in 2006, the Archeological and Historic Preservation Act of 1974, the 

Archaeological Resources Protection Act of 1979, the American Indian Religious Freedom Act of 1978, 

the Native American Graves Protection and Repatriation Act of 1990, the Submerged Lands Act of 1953, 

the Abandoned Shipwreck Act of 1987, and the Sunken Military Craft Act of 2004. The Advisory Council 

on Historic Preservation further guides treatment of archaeological and architectural resources through 

the regulations, Protection of Historic Properties (36 Code of Federal Regulations [CFR] part 800). The 

category of “historic properties” is a subset of cultural resources that is defined in the National Historic 

Preservation Act (54 United States Code [U.S.C.] section 300308) as any prehistoric or historic district, 

site, building, structure, or object included in, or eligible for inclusion in, the National Register of Historic 

Places (National Register), including artifacts, records, and material remains related to such a property 

or resource.

Section 106 of the National Historic Preservation Act currently codified in 54 U.S.C. 306108 requires 

federal agencies to consider the effects of their actions on cultural resources listed in or eligible for 

inclusion in the National Register of Historic Places. The regulations implementing Section 106 (36 CFR

part 800) specify a consultation process to assist in satisfying this requirement including efforts in 

identification of historic places. Consultation with the appropriate State Historic Preservation Offices, 

the Advisory Council on Historic Preservation, Native American tribes and Native Hawaiian 

organizations, the public, and state and federal agencies is required by Section 106 of the National 

Historic Preservation Act. Scoping letters for this Environmental Impact Statement (EIS)/Overseas 

Environmental Impact Statement (OEIS) were sent to appropriate State Historic Preservation Offices and 

appropriate federally recognized Native American tribes (refer to Chapter 8, Public Involvement) on 

November 12, 2015.

Additional regulations and guidelines for submerged historical resources include 10 U.S.C. section 113, 

Title XIV for the Sunken Military Craft Act; the Abandoned Shipwreck Guidelines prepared by the 

National Park Service (National Park Service, 2007); and, for the purposes of conducting research or 

recovering U.S. Department of the Navy (Navy) ship and aircraft wrecks, the Guidelines for 

Archaeological Research Permit Applications on Ship and Aircraft Wrecks under the Jurisdiction of the 

Department of the Navy (32 CFR part 767) overseen by the Naval History and Heritage Command. The 

Sunken Military Craft Act does not apply to actions taken by, or at the direction of, the United States. In 

accordance with the Abandoned Shipwreck Act, abandoned shipwrecks in state waters are considered 

the property of the U.S. government; however, the federal government may transfer titles to 

abandoned shipwrecks to a state where shipwrecks fall within the jurisdiction of the state (Barnette, 

2010). Warships or other vessels used for military purposes at the time of their sinking retain sovereign 

immunity (e.g., German U-boats). According to the principle of sovereign immunity, foreign warships 

sunk in U.S. territorial waters are protected by the U.S. government, which acts as custodian of the sites 

in the best interest of the sovereign nation (Neyland, 2001). In addition, the National Park Service

Archeology Program, developed as a result of a presidential order, includes a collection of historical and 

archaeological resource protection laws to which federal managers adhere.
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The addendum to the National Historic Preservation Act (54 U.S.C. section 307101(e)) requires an 

assessment by federal agencies of project effects to resources located outside U.S. territorial waters that 

are identified on the World Heritage List or on the applicable country’s equivalent of the National 

Register of Historic Places. Eight resources listed on the World Heritage List and four resources listed on 

Canada’s Historic Places Register are located adjacent to but not within the AFTT Study Area. No 

resources listed on the World Heritage List or on Canada’s Historic Places Register occur in the AFTT 

Study Area.

No specific procedures for the identification and protection of cultural resources within the open ocean 

have been defined by the international community (Zander & Varmer, 1996). No treaty offering 

comprehensive protection of submerged cultural resources has been developed and implemented. 

However, a few international conventions prepared by the United Nations Educational, Scientific, and 

Cultural Organizations are applicable to submerged cultural resources, including the 1970 Convention on 

the Means of Prohibiting and Preventing the Illicit Import, Export and Transfer of Ownership of Cultural 

Property; the 1972 Convention Concerning the Protection of the World Cultural and Natural Heritage;

the 1982 Convention on the Law of the Sea; and the 2001 Convention on the Protection of the 

Underwater Cultural Heritage. Only the 1970 and 1972 conventions have been fully ratified by the 

United States. Individual submerged resources may be protected by international agreements, such as 

the RMS Titanic Maritime Memorial Act of 1986. The RMS Titanic Maritime Memorial Act of 1986 

established the RMS Titanic as an international maritime memorial and gravesite.

3.10.1.3 Methods

3.10.1.3.1Approach

The approach for establishing current conditions is based on different regulatory parameters defined by 

geographical location. Within U.S. territorial waters (within 12 NM of the coast), the National 

Environmental Policy Act (NEPA) is the guiding mandate. Areas beyond 12 NM in the open ocean will not 

be analyzed because obtaining data beyond 12 NM and at relatively great depths are not practicable, 

they are not associated with any state, and there are no State Historic Preservation Office consultation 

requirements beyond 3 NM in some cases and beyond 9 NM for some Gulf coast states and the territory 

of Puerto Rico. As such, impacts on potential cultural resources in the open ocean are discussed as a

programmatic analysis in terms of the potential impact a stressor could have on a historic property 

within the Study Area beyond 12 NM.

The implementing regulations of Section 106 of the National Historic Preservation Act require federal 

agencies to take into account the effects that a proposed action would have on cultural resources 

included in or eligible for inclusion in the National Register of Historic Places. “Historic properties” is

synonymous with National Register-eligible or -listed archaeological, architectural, or traditional 

resources. Cultural resources that have not been formally evaluated (i.e., have not had a Consensus 

Determination in consultation with the State Historic Preservation Office) may be considered potentially 

eligible, and thus are afforded the same regulatory consideration as resources listed in the National 

Register. Evaluations and determinations of historic properties within the Study Area are the 

responsibility of the federal agency, in consultation with the appropriate State Historic Preservation 

Office.

Properties are evaluated for nomination to the National Register and for National Register eligibility 

using the following criteria (36 CFR section 60.4(a)–(d)):
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 Criterion A: Be associated with events that have made a significant contribution to the broad 

patterns of American history

 Criterion B: Be associated with the lives of persons significant in the American past

 Criterion C: Embody the distinctive characteristics of a type, period, or method of construction, 

or represent the work of a master, or possess high artistic values, or represent a significant and 

distinguishable entity whose components may lack individual distinction

 Criterion D: Yield, or may be likely to yield, information important in prehistory or history

A historic property also must possess the following aspects of integrity: location, design, setting, 

materials, workmanship, feeling, and association to convey its significance and to qualify for the 

National Register. These seven aspects, in various combinations, define integrity. To retain integrity, a 

property will always possess several, and usually most, of these aspects.

Cultural resources in U.S. territorial waters (within 12 NM of the coast) are as follows:

 Resources listed in or eligible for listing in the National Register of Historic Places (Section 106 of 

the National Historic Preservation Act)

 Resources entitled to sovereign immunity (e.g., German U-boats)

3.10.1.3.2Data Sources

Cultural resources information relevant to this EIS/OEIS was derived from a variety of sources, including 

previous environmental documents, previous technical memoranda on submerged cultural resource 

predictive models (Krivor, 2009; Southeastern Archaeological Research, 2009a, 2009b, 2009c), national 

and international shipwreck databases, the National Register Information System (managed by the 

National Park Service), information repositories associated with State Historic Preservation Offices, 

online maps and data, and published sources, as cited.

National and international shipwreck databases researched included the National Oceanic and 

Atmospheric Administration Advanced Wreck and Obstruction Information System, National Oceanic 

and Atmospheric Administration Aids to Navigation, the United States Coast Guard Hazards to 

Navigation, the General Dynamics Global Maritime Wrecks Database, the Northern Shipwrecks 

Database, accessible state archaeological master site files (Alabama, Florida, Georgia, Mississippi, North 

Carolina, and Virginia), and secondary sources of historic (older than 50 years) shipwreck information 

such as the Lytle-Holdcamper List, Shipwrecks in the Americas, and the Encyclopedia of American 

Shipwrecks (Burns, 2011). Many of the shipwreck databases and secondary sources overlap, generating 

data repetition. Many federal agencies “share” data as well as secondary sources. The intent of this 

analysis is not to provide a definitive number of shipwrecks, obstructions, or hazards within a defined 

area, but rather to provide an overview of potential resources within an area.

The online National Register Information System was reviewed to identify National Register of Historic 

Places-listed resources, historic districts, and National Historic Landmarks. Appropriate information 

repositories associated with the State Historic Preservation Offices were contacted and online databases 

reviewed for information on the location of submerged resources, type, and eligibility for listing on the 

state registers and National Register of Historic Places. 
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3.10.1.3.3Cultural Context

Several types of cultural resources are associated with the Study Area: submerged prehistoric sites along 

the continental shelf, submerged historic resources and manmade obstructions, and historic 

architectural resources (e.g., Fort Jefferson in the Dry Tortugas). No Native American traditional use 

areas (e.g., fishing grounds) have been identified in the Study Area. The context within which these 

types of resources were formed provides an understanding of the overall development of the resource 

base and information on relative locations.

About 20,000 years ago, at the height of the last major glaciation (the Late Wisconsinan), sea level was 

as much as 328–393 feet (ft.) lower than present. Throughout the Holocene (since about 10,000 years 

ago), sea level has undergone a net rise, the rate of which has varied from as much as 0.39 inch per year 

to as little as 0.04 inch per year. The Holocene transgression has resulted in the landward migration of 

coastal habitats across the shelf and, in some cases, submergence and preservation of geomorphic 

features and landforms. Relative sea level varied considerably along the Atlantic and Gulf coasts. In the 

Northeast, paleo-landscapes were depressed by glacial isostatic pressure; in the Gulf of Mexico, 

paleo-landscapes were depressed by tectonic processes and sediment loading associated with the 

abandoned lobes of the Mississippi River delta.

The lower sea level during and following the Wisconsinan glaciation is an important factor for 

determining the potential for prehistoric sites on drowned continental shelf surfaces. Development of 

vegetation and adaptation of natural resources would have made the exposed continental shelf 

attractive to human populations. Those paleo-environmental conditions provide the basis for theories 

concerning prehistoric subsistence and settlement patterns that are extrapolated for the continental

shelf.

The potential for prehistoric and historic archaeological sites has been the subject of hypothesis and a 

number of detailed studies (Bourque, 1979; Coastal Environments Inc., 1977; Garrison et al., 1989; 

Pearson et al., 2003; Science Applications International Corporation, 1981). These studies were 

commissioned to establish baselines for submerged cultural resource management policy by agencies 

responsible for those resources (Research Planning Inc. et al., 2004). The North Atlantic cultural 

resources baseline study covered the continental shelf between Cape Hatteras, North Carolina and the 

Bay of Fundy just over the U.S. border in Canada. The report identified high-probability areas for both 

prehistoric and submerged historic resources (Bourque, 1979). The South Atlantic cultural resources 

baseline study covered the continental shelf between Cape Hatteras, North Carolina and Key West, 

Florida. The research and predictive models for South Atlantic submerged cultural resources were 

published in 1979 (Science Applications International Corporation, 1981). The Gulf of Mexico cultural 

resources baseline study was carried out for the National Park Service and published in 1977. One of the 

most important management tools produced by this study was identification of high-probability areas 

for both submerged prehistoric and historic resources (Coastal Environments Inc., 1977).

Submerged prehistoric archaeological sites most likely represent Paleoindian (late Pleistocene) and Early 

Archaic to Middle Archaic (early Holocene) occupations on the continental shelves, when the 

post-glacial sea level rise inundated low-lying areas (Faught, 2004) (Figure 3.10-1). Submerged 

prehistoric sites are most likely associated with relic landforms such as relic rivers and stream channels; 

relic estuary complexes; and relic berms, dunes, and hummocks. Paleoindian and Early Archaic site types 

include base camps, outlying hunting stations, quarries, and reduction stations. Site resources of this 

time period typically consist of low-density lithic scatters and hearths.
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Source: Florida Division of Historical Resources (2011)

Figure 3.10-1: Artifacts from a Submerged Prehistoric Resource

The Atlantic and the Gulf of Mexico continental shelves have become repositories for the remains of the 

entire spectrum of vessels that supported development of the Western Hemisphere from the early 16th 

century to modern day. While the distribution of shipwreck sites on the continental shelf cannot be 

associated specifically with the submerged ridge and swale features that currently represent major 

sources of sand, those deposits lie amid the historic routes of navigation. Although shipwrecks are 

somewhat random in their areal distribution, it is generally accepted that higher densities exist in 

association with established navigation routes, with environmental obstructions to navigation, and by 

inshore areas (Research Planning Inc. et al., 2004).

Historic shipwrecks (example provided in Figure 3.10-2 and Figure 3.10-3), classified as archaeological 

resources, are numerous in the Study Area (53,436 known wrecks, obstructions, occurrences, or 

“unknowns”) (Burns, 2011). As the result of mechanical, chemical, and biological erosion and decay, 

shipwrecks exhibit differential preservation. Shipwrecks in high-energy zones, such as in shallow waters 

along the coastlines, are generally less well preserved because they have been scoured by the abundant 

fluvial sediments driven by coastal currents and heavy wave action (Pearson et al., 2003). However, if 

portions of the shipwreck are buried in sediment and protected from scouring, preservation may be 

high. Ferrous metal oxidation is accelerated by elevated seawater temperature, and shipworms 

consume wooden ship members. Deep-water wrecks may be better preserved because the lower 

seawater temperatures at depth slow the oxidation of ferrous metals and reduce the number of 

wood eating shipworms; however, preservation of deep-water shipwrecks does vary (Pearson et al., 

2003).

In accordance with the Abandoned Shipwreck Act, abandoned shipwrecks in state waters on the Atlantic 

coast and in the Gulf of Mexico are considered the property of the U.S. government (Barnette, 2010).

According to the principle of sovereign immunity, foreign warships sunk in U.S. territorial waters are 

protected by the U.S. government, which acts as custodian of the sites in the best interest of the 

sovereign nation (Neyland, 2001). 

Estimated numbers of identified historic submerged resources used in this EIS/OEIS are compiled from 

information obtained from various databases. Because no comprehensive survey or evaluation of 

submerged historic resources has occurred in the entire Study Area and because some areas 

(e.g., coastal zones and continental shelf) are considered high probability for historic shipwrecks, 

discoveries of additional historic shipwrecks may occur. Additionally, some existing and unrecorded 

historic shipwrecks could be considered eligible for the National Register of Historic Places.
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Source: Florida Division of Historical Resources (2011)

Figure 3.10-2: Submerged Historic Resource (Spanish Galleon)

Source: Warren (2004)

Figure 3.10-3: High-Resolution Side-Scan Sonar Image of Submerged Historic Resource

(World War II Vessel)

3.10.1.4 Methods for Impact Analysis

Impact analysis for cultural resources is based on different parameters defined by geographical location. 

Within U.S. territorial waters, Section 106 of the National Historic Preservation Act and NEPA evaluation 

are the guiding mandates. In general, impacts are assessed by the importance of the resource, the 

sensitivity of the resource to the proposed activities, and the duration of the effects on the

environment.

3.10.2 AFFECTED ENVIRONMENT

Seven large marine ecosystems are located entirely or partially within the Study Area: the West 

Greenland Shelf, Newfoundland-Labrador Shelf, Scotian Shelf, Northeast U.S. Continental Shelf, 
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3.10 Cultural Resources

Southeast U.S. Continental Shelf, Caribbean Sea, and Gulf of Mexico. These ecosystems exhibit similar 

types of cultural resources in similar submerged settings.

3.10.2.1 Submerged Prehistoric Resources

Submerged prehistoric sites have been documented in shallow offshore areas in the Northeast U.S. 

Continental Shelf and the Gulf of Mexico Large Marine Ecosystems.

Submerged prehistoric sites have been identified offshore in southern New England (Merwin et al., 

2003). Submerged prehistoric sites are most likely associated with relic landforms such as relic rivers and 

stream channels; relic estuary complexes; and relic berms, dunes, and hummocks (Research Planning 

Inc. et al., 2004), and may occur in the Northeast U.S. Continental Shelf Large Marine Ecosystem.

Geologic features in the eastern Gulf of Mexico (karst topography, relic barrier islands with back barrier 

bays and lagoons, and coastal dune lakes) are used as indicators of potential cultural resources and have 

a high probability of containing prehistoric sites. Sites in high-probability zones may date from the 

Paleoindian to the Archaic periods. Submerged prehistoric sites have been identified offshore in 

northwestern Florida (Faught, 2004). Submerged prehistoric archaeological sites have been identified 

out to a distance of 9 NM in Florida (Faught, 2010), but sites are predicted as far as 85 linear miles 

offshore at a depth of 130 ft., along the inundated Paleoindian or Clovis Shoreline (Faught, 2010).

3.10.2.2 Known Wrecks, Obstructions, Occurrences, or “Unknowns”

Freighters, tankers, ships-of-war, passenger ships, submarines, and fishing vessels have been sunk, lost, 

or run aground. Natural activities and features have played important roles in creating submerged 

cultural resources; those include powerful currents (e.g., the Labrador Current), winds (including cold 

fronts), rough seas (gales, hurricanes, blizzards), coastal topography (e.g., Cape Cod, Vineyard Sound, 

Cape Hatteras, Cape Fear), and shallow water and sandbars (Isles of Shoals, Nantucket Shoals, Diamond 

Shoals, Lookout Shoals, and Frying Pan Shoals). The Revolutionary War, the War of 1812, and the Civil 

War contributed to numerous ship losses from the northeast to the Gulf of Mexico. World Wars I and II 

used submarine warfare, which destroyed numerous cargo ships. Wrecks are concentrated in the Cape 

Hatteras area, where the intersection of cold northern currents and the northbound Gulf Stream forms 

shoals and submerged shifting sandbars that, in combination with powerful currents, treacherous seas, 

and wind, create hazards for mariners.

Review of all databases indicates the presence of 13,606 known wrecks, obstructions, occurrences, or 

sites marked as “unknown” in U.S. territorial waters in the seven large marine ecosystems, and 

3,774 resources beyond U.S. territorial waters (outside 12 NM) (Figures 3.10-4, 3.10-5, and 3.10-6). 

Most “unknown” obstructions tend to be modern debris but cannot be ruled out as potential cultural 

resources. Because no comprehensive survey or evaluation of submerged historic resources has 

occurred in the Study Area, additional shipwrecks may exist, and some existing and newly discovered 

shipwrecks could be considered eligible for the National Register of Historic Places. A predictive model 

was used to determine the probability of encountering additional shipwrecks in portions of the Study 

Area (Burns, 2011; Roberts, 2012). The predictive model is based on a point system, where the higher 

point assumes a higher probability for submerged cultural resources. This model assigns points to 

various factors, including ports/anchorages, obstructions/hazards, shipping routes, and known 

shipwreck locations; the model assumes there is a higher probability of vessel loss near a 

port/anchorage, near an obstruction/navigational hazard, or near a designated shipping route. This 

model also acknowledges that if other known shipwreck sites are nearby, the probability increases for 

additional sites within that area. Results of the predictive model indicate that the portions of the Study 
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3.10 Cultural Resources

Area (Exclusive Economic Zones of Bermuda, Canada, and Mexico) within the large marine ecosystems 

exhibit moderate to high potential to contain submerged cultural resources (Burns, 2011; Roberts, 

2012).

3.10.2.2.1Cultural Resources Eligible for or Listed in the National Register of Historic 

Places

There are three National Historic Landmarks or monuments and two National Register of Historic Places 

historic districts or Multiple Property Sites within the Study Area. In addition, there are 21 resources 

listed in the National Register of Historic Places, and 10 resources that are considered eligible for the 

National Register of Historic Places within the Study Area (Table 3.10-1).

3.10.2.2.2Resources with Sovereign Immunity

Sovereign immunity is an international law which preserves each nation’s title in their governmental 

ships and property. German U-boats retain sovereign immunity and include the U-869 (Uboat.net, 

2010c) and the U-853 (Uboat.net, 2010a) in the Northeast U.S. Continental Shelf Large Marine 

Ecosystem, U-352 (North Carolina Wreck Diving, 2008) in the Southeast U.S. Continental Shelf Large 

Marine Ecosystem, and U-166 (Warren, 2004) and U-157 (Uboat.net, 2010b) in the Gulf of Mexico Large 

Marine Ecosystem.

3.10.2.3 Tortugas Military Operations Area

The Tortugas Military Operations Area is not a traditional military operating area but rather an air 

exclusion zone established to protect Fort Jefferson and Dry Tortugas National Park. Tactical maneuvers 

resulting in supersonic flight are not conducted in the Tortugas Military Operations Area above Fort 

Jefferson and Dry Tortugas National Park between 5,000 ft. and 18,000 ft. The Tortugas Military 

Operations Area is the airspace within an area bounded by a line 12 NM from and parallel to the 

shoreline of the Dry Tortugas Islands, creating a circular area (Federal Aviation Administration, 2009).

Previous research indicates that fragile mortar in the brick masonry at Fort Jefferson may be susceptible 

to damage from sonic booms (Hanson et al., 1991; James et al., 2009). No supersonic flight activity is 

authorized in the Tortugas Military Operations Area; therefore, no sonic booms are intentionally 

generated below 18,000 ft. and within 12 NM from the shoreline of all the islands encompassing Fort 

Jefferson. Sonic booms are occasionally generated by military aircraft and are logged by National Park 

Service staff at Fort Jefferson. Due to the increase in sonic booms logged at Fort Jefferson in 2008 and 

early 2009, the Navy took precautionary measures to minimize the number of sonic booms reaching Fort 

Jefferson. In April 2009, the Naval Air Station Key West Air Operations Department incorporated 

Tortugas Military Operations Area flight avoidance awareness briefings into pre-flight planning guidance 

provided to all aircrew. Increased awareness of the airspace restrictions helps minimize inadvertent 

supersonic flight in the vicinity of Dry Tortugas. Additionally, air combat maneuver engagement zones 

and basic fighter maneuvering areas have been modified in W-174 so that the resulting flight activities 

generate fewer sonic booms in the airspace adjacent to Fort Jefferson. Furthermore, training flights 

predisposed to supersonic conditions are segregated and only conducted in redesignated airspace at 

least 30 NM from Fort Jefferson. Avoidance and mitigation measures were enacted in May 2009. The 

Navy will continue to implement mitigation measures under the Proposed Action to help preserve the 

structural integrity of Fort Jefferson, as described in Section 5.3.2.5 (Aircraft Overflight Noise).
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Notes: AFTT: Atlantic Fleet Training and Testing; NRHP: National Register of Historic Places; OPAREA: Operating Area; VACAPES: Virginia Capes

Figure 3.10-4: Known Shipwrecks, Obstructions, Occurrences, or Sites Marked as “Unknown”

in the Northeast United States Continental Shelf Large Marine Ecosystem
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Notes: AFTT: Atlantic Fleet Training and Testing; NRHP: National Register of Historic Places; OPAREA: Operating Area

Figure 3.10-5: Known Shipwrecks, Obstructions, Occurrences, or Sites Marked as “Unknown” in the

Southeast United States Continental Shelf Large Marine Ecosystem
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Notes: AFTT: Atlantic Fleet Training and Testing; NRHP: National Register of Historic Places; OPAREA: Operating Area

Figure 3.10-6: Known Shipwrecks, Obstructions, Occurrences, or Sites Marked as “Unknown” in the Southeast United States

Continental Shelf, Caribbean Sea, and Gulf of Mexico Large Marine Ecosystems
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Table 3.10-1: National Historic Landmarks, Monuments, and Cultural Resource Listed in the National Register of Historic Places

Resource

Large Marine 

Ecosystem

Description

National 

Register of 

Historic Places

National 

Historic 

Landmark/

Monument

Reference

HMS Orpheus Northeast U.S. 

Continental Shelf British vessel, 1773–1778 Listed No National Park Service (2010)

USS 

Cumberland

Northeast U.S. 

Continental Shelf 

(pierside)

Wooden frigate, 1842–1862 Listed No

Judge (2007); National Park Service (2010); 

Virginia Department of Historic Resources 

(2010)

CSS Florida

Northeast U.S. 

Continental Shelf 

(pierside)

Three-masted, wooden-hulled 

vessel, 1864 Listed No

Judge (2007); Virginia Department of 

Historic Resources (2010)

USS Monitor

Southeast U.S. 

Continental Shelf Ironclad Civil War gunship, 1862 Listed Yes

National Park Service (2008); National 

Register Information System (2008); Naval 

Historical Center (2008); Neyland (2001); 

USS Monitor Center (2008)

USS Huron Southeast U.S. 

Continental Shelf Iron vessel, 1875–1877 Listed No

National Register Information System 

(2010); North Carolina Office of State 

Archaeology (2010)

Cape Fear Civil 

War Shipwrecks 

Discontiguous 

District

Southeast U.S. 

Continental Shelf

Civil War shipwrecks, 1861–1864 

(16 blockade-running steamers, 4 

Union vessels, and 1 Confederate 

vessel)

Historic District No Wilde-Ramsing and Angley (1985)

Barge Wreck Southeast U.S. 

Continental Shelf 19th-century barge Listed No

Paul Palmer Northeast U.S. 

Continental Shelf Five-masted schooner, 1913 Listed No Northern Atlantic Dive Expeditions (2018)

Joffre Northeast U.S. 

Continental Shelf

Auxiliary fishing schooner and 

then converted into an eastern 

rig dragger, 1947

Listed No

Gerry E. Studds Stellwagen Bank National 

Marine Sanctuary (2018)
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Table 3.10-1: National Historic Landmarks, Monuments, and Cultural Resource Listed in the National Register of Historic Places 

(continued)

Resource

Large Marine 

Ecosystem

Description

National 

Register of 

Historic Places

National 

Historic 

Landmark/

Monument

Reference

Robert J. Walker Northeast U.S. 

Continental Shelf

Side-wheel steamer served as a 

survey ship, 1860 Listed No Delgado (2013)

Empire Gem

Northeast U.S. 

Continental Shelf Steel Tanker, 1942 Listed No

National Oceanic and Atmospheric 

Administration and National Marine 

Sanctuaries (2017b)

Lancing Northeast U.S. 

Continental Shelf

Steel Tanker, 1942 Listed No National Oceanic and Atmospheric 

Administration and National Marine 

Sanctuaries (2017a)

Roosevelt Inlet 

Shipwreck

Northeast U.S. 

Continental Shelf

Rigged commercial ship, 18th

Century Listed No

Southeastern Archaeological Research 

(2010)

Cape Gull Southeast U.S. 

Continental Shelf United States Coast Guard cutter Listed No Burns (2011)

1733 Spanish 

Plate Fleet 

Shipwrecks 

Southeast U.S. 

Continental Shelf

Spanish Fleet, 1733 (Angustias, 

Chavas, El Gallo Indiano, El 

Infante, El Rubi, Herrara, Populo, 

San Felipe, San Francisco, San 

Jose, San Pedro, Sueco de Arizon, 

and Tres Puentes)

Multiple 

Property Site No McKinnon et al. (2006)

General C.B. 

Comstock

Southeast U.S. 

Continental Shelf

A U.S. hydraulic hopper dredge, 

1913 Listed No

National Register Information System

(2016)

H.L. Hunley Southeast U.S. 

Continental Shelf Submarine, 1864 Listed No

The Editors of Encyclopedia Britannica 

(2018)

SS Antonio 

Lopez

Caribbean Spanish blockade runner, 1989 Listed Yes

National Register Information System 

(2016)
Atlantic Fleet

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3.10 Cultural Resources

Table 3.10-1: National Historic Landmarks, Monuments, and Cultural Resource Listed in the National Register of Historic Places 

(continued)

Resource

Large Marine 

Ecosystem

Description

National 

Register of 

Historic Places

National 

Historic 

Landmark/

Monument

Reference

Fort Jefferson Gulf of Mexico Third System seacoast 

fortification, 1846 Listed Yes Clark (2008); Morrison et al. (1974)

Henrietta Marie Gulf of Mexico English merchant/slave ship, 

1700 Eligible No

Mel Fisher Maritime Heritage Society 

(2001)

Vamar Gulf of Mexico Reinforced metal hulled vessel, 

1919–1942 Listed No Burns (2011)

SS Tarpon Gulf of Mexico Cargo ship, 1896–1937 Listed No Florida Department of State (1997, 2007)

USS 

Massachusetts Gulf of Mexico Battleship, 1896–1921 Listed No Florida Department of State (2008)

USS Hatteras Gulf of Mexico Iron-hulled, side-wheel steamer, 

1861–1863 Listed No

Bureau of Ocean Energy Management and 

Regulation and Enforcement (2011)

R.M. Parker, Jr. Gulf of Mexico Tanker, 1919–1942 Eligible No Enright et al. (2006)

Castine Gulf of Mexico Steel-hulled gunboat, 1892–1924 Eligible No Enright et al. (2006)

Sheherazade Gulf of Mexico French tanker, 1935–1942 Eligible No Enright et al. (2006)

Boca Chica No.1 Gulf of Mexico Wooden-hull sailing ship, 1800s Eligible No Enright et al. (2006)

Boca Chica No.2 Gulf of Mexico Unknown Eligible No None

SS Nicaragua Gulf of Mexico Cargo steamer, 1912 Eligible No National Park Service (2015)

SS Mary Gulf of Mexico Sidewheeler, 1876 Eligible No Ford (2014)

Santa Maria De 

Yicar Gulf of Mexico Spanish cargo and passenger ship, 1554 Eligible No National Park Service (2017)

Espiritu Santo Gulf of Mexico Spanish cargo and passenger 

ship, 1554 Eligible No National Park Service (2017)

Note: U.S. = United States
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3.10.3 ENVIRONMENTAL CONSEQUENCES

This section evaluates how and to what degree the activities described in Chapter 2 (Description of 

Proposed Action and Alternatives) could impact cultural resources within U.S. territorial waters and 

World Heritage sites located in the Study Area. Tables 2.6-1 through 2.6-4 present the proposed training 

and testing activities and locations for each alternative. Additional details of the proposed training and 

testing activities are provided in Appendix A (Navy Activity Descriptions). Appendix B (Activity Stressor 

Matrices) describes the warfare areas and associated stressors that were considered for analysis of 

cultural resources. The stressors vary in intensity, frequency, duration, and location within the Study 

Area. The stressors applicable to cultural resources in the Study Area that are analyzed include:

 Explosives (explosives – shock [pressure] waves from underwater explosions, explosives –

cratering)

 Physical Disturbance and Strikes (in-water devices, military expended materials, seafloor 

devices, pile driving, and vibration from sonic booms)

The use of sonar does not affect the structural elements of historic shipwrecks. Archaeologists regularly 

use multi-beam sonar and side-scan sonar to explore shipwrecks without disturbing them. Based on the 

physics of underwater sound, the shipwreck would need to be very close (less than 22 ft.) to the sonar 

sound source for the shipwreck to experience any slight oscillations from the induced pressure waves. 

Any oscillations experienced at a depth of less than 22 ft. would be negligible up to within a few yards 

from the sonar source. This distance is smaller than the typical safe navigation and operating depth for 

most sonar sources, and is not expected to impact historic shipwrecks. Therefore, sonar is not 

considered a stressor that would result in an impact on cultural resources and will not be analyzed 

further in this document.

The analysis includes consideration of the mitigation that the Navy will implement to avoid potential 

impacts on cultural resources from explosives and physical disturbance and strike stressors. In the event 

that the Navy impacts a submerged historic or prehistoric resource, consultation would be conducted 

with the appropriate State Historic Preservation Officers in accordance with 36 CFR section 800.13(a)(3).

3.10.3.1 Explosive Stressors

Explosive stressors that could impact cultural resources are vibration, shock waves, and explosive 

cratering from underwater explosions. A shock wave and oscillating bubble pulses resulting from any 

kind of underwater explosion, such as explosive torpedoes, missiles, bombs, projectiles, mines, and 

explosive sonobuoys, could impact the exposed portions of submerged historic resources if such 

resources were located nearby. Shock waves (pressure) generated by underwater explosions would be 

periodic rather than continuous, and could create overall structural instability and eventual collapse of 

architectural features of submerged historic resources. The amount of damage would depend on factors 

such as the size of the charge, the distance from the historic shipwreck, the water depth, and the 

topography of the ocean floor.

In addition, impacts from aircraft noise (i.e., vibration from sonic booms) could create increased 

structural instability and damage to Fort Jefferson, a fragile historic architectural resource in the Gulf of 

Mexico Large Marine Ecosystem (Hanson et al., 1991; James et al., 2009).
Atlantic Fleet

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3.10.3.1.1Impacts of Explosives — Shock Waves from Underwater Explosions

Anti-surface missiles and projectiles explode at or immediately below the ocean surface (within the first 

meter of depth). Shock waves (pressure) from these types of explosions within the water column would 

not reach historic resources on the ocean floor. Underwater detonations of explosive sonobuoys would 

occur below the surface and detonate in the mid-water column. Shock waves from nearby underwater 

detonations may affect the exposed portions of historic shipwrecks if such resources were located in the 

area and near the depth of the explosive. Impacts on previously identified cultural resources from 

underwater explosions generating vibration and shock waves within the Study Area are not anticipated

because (1) detonations at or near the surface from missiles and projectiles all occur in deep water, and 

the shock waves would not reach historic resources on the seafloor, and (2) detonations that occur in 

the mid-water column from explosive sonobuoys, which are much smaller explosive charges than 

missiles and projectiles, would also occur in deep water, well above the seafloor; so the shock waves 

would not reach historic resources on the seafloor, and (3) underwater detonations placed by Navy 

divers occur only in specially designated areas (see Section 2.3.3.9, Underwater Detonation Safety), far 

from any identified historic resources.

3.10.3.1.1.1 Impacts of Explosive Shock Waves from Underwater Explosions under 

Alternative 1

Impacts of Explosive Shock Waves from Underwater Explosions under Alternative 1 for Training

Activities

Under Alternative 1, training activities (including the use of explosives) would continue within the 

Northeast U.S. Continental Shelf (Virginia Capes Range Complex), the Southeast U.S. Continental Shelf 

(Navy Cherry Point and Jacksonville Range Complexes), the Gulf of Mexico (Key West and Gulf of Mexico 

Range Complexes), and the Caribbean (Key West Range Complex) Large Marine Ecosystems. Because no 

comprehensive survey or evaluation of submerged historic resources has occurred in the Study Area, 

unrecorded historic resources could be disturbed by underwater detonations. However, because the 

Navy routinely avoids locations of known obstructions which include submerged historic resources, and 

because overall types and locations of training activities are not expected to change from those 

currently conducted by the Navy (refer to Table 3.0-27), no impacts on identified submerged historic 

resources located in the Study Area are expected from shock waves created by underwater explosives.

As discussed in Section 5.4.1 (Mitigation Areas for Seafloor Resources), the Navy will implement 

mitigation to avoid impacts from explosives on seafloor resources in mitigation areas throughout the 

Study Area. For example, the Navy will not conduct explosive mine countermeasure and neutralization 

activities within a specified distance of shipwrecks and identified submerged historic properties.

Impacts of Explosive Shock Waves from Underwater Explosions under Alternative 1 for Testing

Activities

Under Alternative 1, testing activities (including the use of explosives) would continue within the 

Northeast U.S. Continental Shelf Large Marine Ecosystem (Naval Undersea Warfare Center Division, 

Newport Testing Range; Virginia Capes Range Complex) and the Gulf of Mexico Large Marine Ecosystem 

(Naval Surface Warfare Center, Panama City Division Testing Range). Because no comprehensive survey 

or evaluation of submerged historic resources has occurred in the Study Area, unrecorded historic 

resources could be disturbed by underwater detonations. However, because the Navy routinely avoids 

locations of known obstructions which include submerged historic resources and overall types and 

locations of testing activities are not expected to change from those currently conducted by the Navy

(refer to Table 3.0-28), no impacts on submerged historic resources located in the Study Area are 
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Training and Testing Final EIS/OEIS September 2018

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3.10 Cultural Resources

expected from shock waves created by underwater explosives. As discussed in Section 5.4.1 (Mitigation 

Areas for Seafloor Resources), the Navy will implement mitigation to avoid impacts from explosives on 

seafloor resources in mitigation areas throughout the Study Area. For example, the Navy will not 

conduct explosive mine countermeasure and neutralization activities within a specified distance of

shipwrecks.

3.10.3.1.1.2 Impacts of Explosive Shock Waves from Underwater Explosions under 

Alternative 2 

Impacts of Explosive Shock Waves from Underwater Explosions under Alternative 2 for Training

Activities

Under Alternative 2, training activities (including the use of explosives) would remain the same as those 

described under Alternative 1 and would continue to occur within the Northeast U.S. Continental Shelf 

(Virginia Capes Range Complex), the Southeast U.S. Continental Shelf (Navy Cherry Point and 

Jacksonville Range Complexes), the Gulf of Mexico (Key West and Gulf of Mexico Range Complexes), and 

the Caribbean (Key West Range Complex) Large Marine Ecosystems. Because no comprehensive survey 

or evaluation of submerged historic resources has occurred in the Study Area, unrecorded historic 

resources could be disturbed by underwater detonations. However, because the Navy routinely avoids 

locations of known obstructions which include submerged historic resources and overall types and 

locations of training activities are not expected to change from those currently conducted by the Navy

(refer to Table 3.0-27), no impacts on submerged historic resources located in the Study Area are 

expected from shock waves created by underwater explosives. As discussed in Section 5.4.1 (Mitigation 

Areas for Seafloor Resources), the Navy will implement mitigation to avoid impacts from explosives on 

seafloor resources in mitigation areas throughout the Study Area. For example, the Navy will not 

conduct explosive mine countermeasure and neutralization activities within a specified distance of

shipwrecks.

Impacts of Explosive Shock Waves from Underwater Explosions under Alternative 2 for Testing

Activities

Under Alternative 2, testing activities (including the use of explosives) would remain the same as those 

described under Alternative 1 and would continue to occur within Northeast U.S. Continental Shelf Large 

Marine Ecosystem (Naval Undersea Warfare Center Division, Newport Testing Range; Virginia Capes

Range Complex) and the Gulf of Mexico Large Marine Ecosystem (Naval Surface Warfare Center, 

Panama City Division Testing Range). Because no comprehensive survey or evaluation of submerged 

historic resources has occurred in the Study Area, unrecorded historic resources could be disturbed by 

underwater detonations. However, because the Navy routinely avoids locations of known obstructions 

which include submerged historic resources and overall types and locations of testing activities are not 

expected to change from those currently conducted by the Navy (refer to Table 3.0-28), no impacts on 

submerged historic resources located in the Study Area are expected from shock waves created by 

underwater explosives. As discussed in Section 5.4.1 (Mitigation Areas for Seafloor Resources), the Navy 

will implement mitigation to avoid impacts from explosives on seafloor resources in mitigation areas 

throughout the Study Area. For example, the Navy will not conduct explosive mine countermeasure and 

neutralization activities within a specified distance of shipwrecks.

3.10.3.1.1.3 Impacts of Explosive Shock Waves from Underwater Explosions under the 

No Action Alternative

Under the No Action Alternative, the Navy would not conduct the proposed training and testing 

activities in the AFTT Study Area. Various explosive stressors (e.g., explosive shockwaves) would not be 
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Training and Testing Final EIS/OEIS September 2018

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3.10 Cultural Resources

introduced into the marine environment. Therefore, baseline conditions of the existing environment 

would either remain unchanged or would improve slightly after cessation of ongoing training and testing

activities.

3.10.3.1.2Impacts from Explosives – Cratering

Underwater explosions near or on the seafloor could create sediment displacement in the form of 

cratering and could affect submerged prehistoric sites and unrecorded historic resources at or near the 

explosive impact. Cratering of unconsolidated soft bottom habitats would result from charges set on or 

near the bottom. For a specific explosive charge size, crater depths and widths would vary depending on 

depth of the charge and sediment type. However, crater dimensions generally decrease as bottom 

depth increases.

As discussed in Section 2.3.3.9 (Underwater Detonation Safety), underwater detonation training takes 

place in specially designated areas, and bottom-placed explosives are laid by divers who are able to 

observe bottom conditions and avoid sensitive areas. In addition, all other explosives would detonate 

near the surface and would occur in deep water. 

3.10.3.1.2.1 Impacts from Explosives – Cratering under Alternative 1

Impacts from Explosives – Cratering under Alternative 1 for Training Activities

Under Alternative 1, mine warfare activities would occur within the Northeast U.S. Continental Shelf 

(Virginia Capes Range Complex), the Southeast U.S. Continental Shelf (Navy Cherry Point and 

Jacksonville Range Complexes), the Caribbean Sea (Key West Range Complex), the Gulf of Mexico (Key 

West and Gulf of Mexico Range Complexes), and the Caribbean (Key West Range Complex) Large Marine 

Ecosystems. Cratering created by deep underwater explosions is not expected to disturb or damage 

artifacts on the seafloor and archaeological deposits buried in the ocean sediments in the Study Area

because bottom-placed explosives are laid by divers who are able to observe bottom conditions and 

avoid sensitive areas and all other explosives would detonate near the surface in deep water. Because 

standard operating procedures (refer to Section 2.3.3.9, Underwater Detonation Safety) are 

implemented to protect submerged cultural resources, and overall types and locations of training 

activities are not expected to change from those currently conducted by the Navy (refer to 

Table 3.0-27), no impacts on submerged historic resources located in the Study Area are expected from 

cratering by underwater explosions. As discussed in Section 5.4.1 (Mitigation Areas for Seafloor 

Resources), the Navy will implement mitigation to avoid impacts from explosives on seafloor resources 

in mitigation areas throughout the Study Area. For example, the Navy will not conduct explosive mine 

countermeasure and neutralization activities within a specified distance of shipwrecks.

Impacts from Explosives – Cratering under Alternative 1 for Testing Activities

Under Alternative 1, testing activities would occur within the Northeast U.S. Continental Shelf (Virginia 

Capes Range Complex) and the Gulf of Mexico (Naval Surface Warfare Center, Panama City Division 

Testing Range and Gulf of Mexico Range Complex) Large Marine Ecosystems. Cratering created by deep 

underwater explosions is not expected to disturb or damage artifacts on the seafloor and archaeological 

deposits buried in the ocean sediments in the Study Area because bottom-placed explosives are laid by 

divers who are able to observe bottom conditions and avoid sensitive areas and all other explosives 

would detonate near the surface in deep water. Because standard operating procedures are 

implemented to protect submerged cultural resources, and overall types and locations of testing 

activities are not expected to change from those currently conducted by the Navy (refer to Table 

3.0-28), no impacts on submerged historic resources located in the Study Area are expected from 
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Training and Testing Final EIS/OEIS September 2018

3.10-20

3.10 Cultural Resources

cratering by underwater explosions. As discussed in Section 5.4.1 (Mitigation Areas for Seafloor 

Resources), the Navy will implement mitigation to avoid impacts from explosives on seafloor resources 

in mitigation areas throughout the Study Area. For example, the Navy will not conduct explosive mine 

countermeasure and neutralization activities within a specified distance of shipwrecks.

3.10.3.1.2.2 Impacts from Explosives – Cratering under Alternative 2

Impacts from Explosives – Cratering under Alternative 2 for Training Activities

Under Alternative 2, the number of explosive rounds and locations associated with training activities are

the same as under Alternative 1 and would occur within the Northeast U.S. Continental Shelf (Virginia 

Capes Range Complex), the Southeast U.S. Continental Shelf (Navy Cherry Point and Jacksonville Range 

Complexes), the Gulf of Mexico (Key West and Gulf of Mexico Range Complexes), and the Caribbean Sea 

(Key West Range Complex) Large Marine Ecosystems. Cratering created by deep underwater explosions 

is not expected to disturb or damage artifacts on the seafloor and archaeological deposits buried in the 

ocean sediments in the Study Area because bottom-placed explosives are laid by divers who are able to 

observe bottom conditions and avoid sensitive areas and all other explosives would detonate near the 

surface in deep water. Because standard operating procedures are implemented to protect submerged 

cultural resources and overall types, and locations of training activities are not expected to change from 

those currently conducted by the Navy (refer to Table 3.0-27), no impacts on submerged historic 

resources located in the Study Area are expected from cratering by underwater explosions. As discussed 

in Section 5.4.1 (Mitigation Areas for Seafloor Resources), the Navy will implement mitigation to avoid 

impacts from explosives on seafloor resources in mitigation areas throughout the Study Area. For 

example, the Navy will not conduct explosive mine countermeasure and neutralization activities within a 

specified distance of shipwrecks.

Impacts from Explosives – Cratering under Alternative 2 for Testing Activities

Under Alternative 2, the number of explosive rounds and locations associated with testing activities are

the same as under Alternative 1 with the exception of neutralizers and would occur within the Northeast 

U.S. Continental Shelf (Virginia Capes Range Complex) and the Gulf of Mexico (Naval Surface Warfare 

Center, Panama City Division Testing Range and Gulf of Mexico Range Complex) Large Marine 

Ecosystems (refer to Table 3.0-28). Cratering created by deep underwater explosions is not expected to 

disturb or damage artifacts on the seafloor and archaeological deposits buried in the ocean sediments in 

the Study Area because bottom-placed explosives are laid by divers who are able to observe bottom 

conditions and avoid sensitive areas and all other explosives would detonate near the surface in deep 

water. Because standard operating procedures are implemented to protect submerged cultural 

resources, and overall types and locations of testing activities are not expected to change from those 

currently conducted by the Navy (refer to Table 3.0-28), no impacts on submerged historic resources 

located in the Study Area are expected from cratering by underwater detonations. As discussed in 

Section 5.4.1 (Mitigation Areas for Seafloor Resources), the Navy will implement mitigation to avoid 

impacts from explosives on seafloor resources in mitigation areas throughout the Study Area. For 

example, the Navy will not conduct explosive mine countermeasure and neutralization activities within a 

specified distance of shipwrecks.

3.10.3.1.2.3 Impacts from Explosives – Cratering under the No Action Alternative

Under the No Action Alternative, the Navy would not conduct the proposed training and testing 

activities in the AFTT Study Area. Various explosive stressors (e.g., cratering) would not be introduced 
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Training and Testing Final EIS/OEIS September 2018

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3.10 Cultural Resources

into the marine environment. Therefore, baseline conditions of the existing environment would either 

remain unchanged or would improve slightly after cessation of ongoing training and testing activities.

3.10.3.2 Physical Disturbance and Strike Stressors

Any physical disturbance on the continental shelf and seafloor, such as ship anchoring, targets or mines 

resting on the seafloor, moored mines, bottom-mounted tripods, and bottom crawling unmanned 

underwater vehicles could inadvertently damage or destroy submerged prehistoric sites and historic 

resources. However, in-water devices are operated to avoid obstructions, such as submerged objects, to 

minimize damage to the device. In the event that the Navy impacts a submerged historic or prehistoric 

resource, consultation would be conducted with the appropriate State Historic Preservation Officers.

Therefore, a towed system or vessel is very unlikely to encounter a submerged historic resource 

inadvertently. Expended materials such as chaff, flares, projectiles, casings, target or missile fragments, 

non-explosive practice munitions, rocket fragments, ballast weights, sonobuoys, torpedo launcher 

accessories, or mine shapes could be deposited on the ocean bottom on or near submerged prehistoric 

sites or historic resources. Heavier expended materials could damage intact fragile submerged historic 

or prehistoric resources if they landed with velocity on a resource.

3.10.3.2.1Impacts from In-Water Devices under Alternative 1

Impacts from In-Water Devices under Alternative 1 for Training Activities

Under Alternative 1, training activities using towed in-water devices would occur within the Northeast 

U.S. Continental Shelf (Virginia Capes Range Complex), the Southeast U.S. Continental Shelf (Navy 

Cherry Point and Jacksonville Range Complexes), and the Gulf of Mexico (Key West and Gulf of Mexico

Range Complexes) Large Marine Ecosystems. Because no comprehensive survey or evaluation of 

submerged historic resources has occurred in the Study Area, unrecorded historic resources could be 

disturbed by in-water devices. However, because in-water devices are operated in a manner to avoid 

obstructions and overall types and locations of training activities are not expected to change from those 

currently conducted by the Navy (refer to Tables 3.0-21, 3.0-22, and 3.0-23), no impacts on submerged 

historic resources located in the Study Area are expected from in-water devices.

Impacts from In-Water Devices under Alternative 1 for Testing Activities

Under Alternative 1, testing activities using in-water devices would occur within the Northeast U.S. 

Continental Shelf (Northeast and Virginia Capes Range Complexes) and the Gulf of Mexico (Naval 

Surface Warfare Center, Panama City Division Testing Range) Large Marine Ecosystems. Because no 

comprehensive survey or evaluation of submerged historic resources has occurred in the Study Area, 

unrecorded historic resources could be disturbed by in-water devices. However, because in-water 

devices are operated in a manner to avoid obstructions, and overall types and locations of testing 

activities are not expected to change from those currently conducted by the Navy (refer to Tables 3.0-21

and 3.0-22, no impacts on submerged historic resources located in the Study Area are expected from inwater devices.

3.10.3.2.2Impacts from In-Water Devices under Alternative 2

Impacts from In-Water Devices under Alternative 2 for Training Activities

Under Alternative 2, the number of training activities using in-water devices is the same as under 

Alternative 1 and would occur within the Northeast U.S. Continental Shelf (Virginia Capes Range 

Complex), the Southeast U.S. Continental Shelf (Navy Cherry Point and Jacksonville Range Complexes), 

and the Gulf of Mexico (Key West and Gulf of Mexico Range Complex) Large Marine Ecosystems. 
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3.10 Cultural Resources

Because no comprehensive survey or evaluation of submerged historic resources has occurred in the 

Study Area, unrecorded historic resources could be disturbed by underwater detonations. However, 

because in-water devices are operated in a manner to avoid obstructions, and overall types and 

locations of testing activities are not expected to change from those currently conducted by the Navy 

(refer to Tables 3.0-21, 3.0-22, and 3.0-23), no impacts on submerged historic resources located in the 

Study Area are expected from in-water devices.

Impacts from In-Water Devices under Alternative 2 for Testing Activities

Under Alternative 2, the number of testing activities using in-water devices is the same as under 

Alternative 1 and would occur within the Northeast U.S. Continental Shelf (Northeast and Virginia Capes

Range Complexes) and the Gulf of Mexico (Naval Surface Warfare Center, Panama City Division Testing 

Range) Large Marine Ecosystems. Because in-water devices are operated in a manner to avoid 

obstructions, and overall types and locations of testing activities are not expected to change from those 

currently conducted by the Navy (refer to Table 3.0-21 and 3.0-22), no impacts on submerged historic 

resources located in the Study Area are expected from in-water devices.

3.10.3.2.3Impacts from In-Water Devices under the No Action Alternative

Under the No Action Alternative, the Navy would not conduct the proposed training and testing 

activities in the AFTT Study Area. Various physical disturbance and strike stressors (e.g., in-water 

devices) would not be introduced into the marine environment. Consequently, no impacts on cultural 

resources are expected from underwater explosions. Therefore, baseline conditions of the existing 

environment would either remain unchanged or would improve slightly after cessation of ongoing 

training and testing activities.

3.10.3.2.4Impacts from Military Expended Materials 

Deposition of non-explosive practice munitions, sonobuoys, and military expended materials may affect 

submerged cultural resources through possible impact of resources on the seafloor or the simple 

settling of military expended materials on top of submerged cultural resources. These potential impacts 

are combined in this discussion.

The large marine ecosystems that overlap the Study Area cover 1,255,365 square nautical miles (NM2), 

and contain records of 53,436 known wrecks, obstructions, occurrences, or sites that are marked as 

“unknown” are potential cultural resources. The large marine ecosystems have the potential to contain 

submerged prehistoric sites (on the continental shelf associated with the Northeast U.S. Continental 

Shelf and the Gulf of Mexico Large Marine Ecosystems). The highest density of historic resources ranges 

from one possible historic resource in 7 NM2(combined Newfoundland-Labrador Shelf and Scotian Shelf 

Large Marine Ecosystems) to one possible historic resource in 79 NM2(Southeast U.S. Continental Shelf 

Large Marine Ecosystem). The likelihood of expended materials either impacting or landing on 

submerged cultural resources is very low given the size of the regions.

Most of the anticipated expended materials would be small objects and fragments that slowly drift to 

the seafloor after striking the ocean surface. Larger and heavier objects, such as non-explosive practice 

munitions, could strike the ocean surface with greater velocity, but their acceleration would slow as 

they move through the water. It is possible these larger and heavier objects could impact a submerged 

prehistoric site by creating sediment and artifact displacement. A prehistoric or historic resource could 

be impacted by damaging structural elements and the probability increases in areas where there is a 
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3.10 Cultural Resources

higher density of resources. However, it is not anticipated because the Navy avoids areas with identified

submerged obstructions.

3.10.3.2.4.1 Impacts from Military Expended Materials under Alternative 1

Impacts from Military Expended Materials under Alternative 1 for Training Activities

Under Alternative 1, training activities would occur within existing designated areas in the Northeast 

U.S. Continental Shelf, the Southeast U.S. Continental Shelf, the Caribbean Sea, and the Gulf of Mexico 

Large Marine Ecosystems. Expended materials could be deposited on or in the vicinity of submerged 

prehistoric sites and known and unrecorded historic resources. However, the Study Area is so large and 

because the Navy avoids areas with known submerged obstructions, it is unlikely these materials would 

come into contact with a submerged prehistoric site or a historic resource. If they should sink on or in 

the vicinity of either type of cultural resource, the expended materials would not likely diminish the 

qualifying characteristics of the submerged prehistoric site or the historic resource.

Impacts from Military Expended Materials under Alternative 1 for Testing Activities

Under Alternative 1, testing activities would occur within existing designated areas in the Northeast U.S. 

Continental Shelf, the Southeast U.S. Continental Shelf, the Caribbean Sea, and the Gulf of Mexico Large 

Marine Ecosystems. Under Alternative 1, expended materials could be deposited on or in the vicinity of 

submerged prehistoric sites and known and unrecorded historic resources. However, because the Study 

Area is so large, and because the Navy avoids areas with known submerged obstructions, it is unlikely 

these materials would come into contact with a submerged prehistoric site or a historic resource. If they 

should sink on or in the vicinity of either type of cultural resource, the expended materials would not 

likely diminish the qualifying characteristics of the submerged prehistoric site or the historic resource.

3.10.3.2.4.2 Impacts from Military Expended Materials under Alternative 2 

Impacts from Military Expended Materials under Alternative 2 for Training Activities

Under Alternative 2, the number of expended materials from training activities would be the same as 

those described under Alternative 1. Expended materials could be deposited on or in the vicinity of 

submerged prehistoric sites and known and unrecorded historic resources. However, because the Study 

Area is so large and because the Navy avoids areas with known submerged obstructions, it is unlikely 

these materials would come into contact with a submerged prehistoric site or a historic resource. If they 

should sink on or in the vicinity of either type of cultural resource, the expended materials would not 

likely diminish the qualifying characteristics of the submerged prehistoric site or the historic resource.

Impacts from Military Expended Materials under Alternative 2 for Testing Activities

Under Alternative 2, the number of expended materials from testing activities would the same as those 

described under Alternative 1. Expended materials could be deposited on or in the vicinity of submerged 

prehistoric sites and known and unrecorded historic resources; however, because the Study Area is so 

large and because the Navy avoids areas with known submerged obstructions, it is unlikely these 

materials would come into contact with a submerged prehistoric site or a historic resource. If they 

should sink on or in the vicinity of either type of cultural resource, the expended materials would not 

likely diminish the qualifying characteristics of the submerged prehistoric site or the historic resource.

3.10.3.2.4.3 Impacts from Military Expended Materials under the No Action Alternative

Under the No Action Alternative, the Navy would not conduct the proposed training and testing 

activities in the AFTT Study Area. Various physical disturbance and strike stressors (e.g., military 

expended material) would not be introduced into the marine environment. Therefore, baseline 
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Training and Testing Final EIS/OEIS September 2018

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3.10 Cultural Resources

conditions of the existing environment would either remain unchanged or would improve slightly after 

cessation of ongoing training and testing activities.

3.10.3.2.4.4 Impacts from Seafloor Devices

Physical disturbances on the continental shelf and seafloor, such as precision anchoring, targets or 

mines resting on the ocean floor, moored mines, bottom-mounted tripods, and bottom crawlers 

(unmanned underwater vehicles) could damage or destroy submerged prehistoric sites or historic 

resources if such resources are directly impacted. Regarding targets, mines, and similar seafloor devices, 

because the Study Area is so large, and because the Navy avoids areas with known submerged 

obstructions, it is unlikely these materials would come into contact with a submerged prehistoric site or 

a historic resource. Because of their size and weight, if they should settle on or in the vicinity of either 

type of cultural resource, the seafloor devices would not likely diminish the qualifying characteristics of 

the submerged prehistoric site or the historic resource. The Navy operates bottom crawlers (unmanned 

underwater vehicles) only where the safety of the equipment and the success of the mission would be 

assured. Therefore, the Navy does not deploy these devices where there is a risk of snagging the vehicle 

on obstacles, such as shipwrecks.

Impacts on previously identified cultural resources from seafloor devices within the Study Area are not 

anticipated because (1) precision anchoring does not occur near known historic shipwrecks, 

(2) obstructions, and archaeological sites are routinely avoided during training and testing, and (3) most 

shipwrecks are located at substantial depths and distributed over large areas of the seafloor. 

3.10.3.2.4.5 Impacts from Seafloor Devices under Alternative 1

Impacts from Seafloor Devices under Alternative 1 for Training Activities

Under Alternative 1, training activities using seafloor devices would occur within the Northeast U.S. 

Continental Shelf (Virginia Capes Range Complex), the Southeast U.S. Continental Shelf (Navy Cherry 

Point and Jacksonville Range Complexes), and the Gulf of Mexico (Key West and Gulf of Mexico Range 

Complexes) Large Marine Ecosystems. Because no comprehensive survey or evaluation of submerged 

historic resources has occurred in the Study Area, unrecorded historic resources could be disturbed by 

seafloor devices. The Navy would implement mitigation that includes not conducting precision 

anchoring (except in designated anchorages) within the anchor swing circle of shipwrecks to avoid 

potential impacts from seafloor devices on cultural resources in mitigation areas throughout the Study 

Area (see Section 5.4.1, Mitigation Areas for Seafloor Resources). However, because bottom and 

moored mine anchors are laid by divers who are able to observe bottom conditions and avoid sensitive 

areas, most seafloor devices would not be used in deep water, overall types and locations of training 

activities are not expected to change from those currently conducted by the Navy (refer to Tables 3.0-35

and 3.0-36), and considering the implementation of mitigation for precision anchoring, no impacts on 

submerged historic resources located in the Study Area are expected from seafloor devices.

Impacts from Seafloor Devices under Alternative 1 for Testing Activities

Under Alternative 1, testing activities using seafloor devices would occur within the Northeast U.S. 

Continental Shelf (Northeast and Virginia Capes Range Complexes), the Southeast U.S. Continental Shelf 

(Navy Cherry Point and Jacksonville Range Complexes), and the Gulf of Mexico (Naval Surface Warfare 

Center, Panama City Division Testing Range) Large Marine Ecosystems. Because no comprehensive 

survey or evaluation of submerged historic resources has occurred in the Study Area, unrecorded 

historic resources could be disturbed by seafloor devices. However, because seafloor devices associated 
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3.10 Cultural Resources

with testing activities would not be used in deep water and overall types and locations of testing 

activities are not expected to change from those currently conducted by the Navy (refer to Table 3.0-35)

no impacts on submerged historic resources located in the Study Area are expected from seafloor 

devices.

3.10.3.2.4.6 Impacts from Seafloor Devices under Alternative 2

Impacts from Seafloor Devices under Alternative 2 for Training Activities

Under Alternative 2, the number of training activities using seafloor devices is the same as under 

Alternative 1 and would occur within the Northeast U.S. Continental Shelf (Virginia Capes Range 

Complex), the Southeast U.S. Continental Shelf (Navy Cherry Point and Jacksonville Range Complexes), 

and the Gulf of Mexico (Key West and Gulf of Mexico Range Complexes) Large Marine Ecosystems. 

Because no comprehensive survey or evaluation of submerged historic resources has occurred in the 

large marine ecosystems, unrecorded historic resources could be disturbed by seafloor devices. The 

Navy will implement mitigation that includes not conducting precision anchoring (except in designated 

anchorages) within the anchor swing circle of shipwrecks to avoid potential impacts from seafloor 

devices on cultural resources in mitigation areas throughout the Study Area (see Section 5.4.1,

Mitigation Areas for Seafloor Resources). Because most sea floor devices would not be used in deep 

water, overall types and locations of training activities are not expected to change from those currently 

conducted by the Navy (refer to Tables 3.0-35 and 3.0-36), and considering the implementation of 

mitigation for precision anchoring, no impacts on submerged historic resources located in the Study 

Area are expected from seafloor devices.

Impacts from Seafloor Devices under Alternative 2 for Testing Activities

Under Alternative 2, the number of testing activities using seafloor devices is virtually the same as under 

Alternative 1 and would occur within the Northeast U.S. Continental Shelf (Northeast and Virginia Capes

Range Complexes), the Southeast U.S. Continental Shelf (Navy Cherry Point and Jacksonville Range 

Complexes), and the Gulf of Mexico (Naval Surface Warfare Center, Panama City Division Testing Range) 

Large Marine Ecosystems. However, because seafloor devices associated with testing activities would 

not be used in deep water and overall types and locations of testing activities are not expected to 

change from those currently conducted by the Navy (refer to Table 3.0-35), no impacts on submerged 

prehistoric sites or submerged historic resources located in the Study Area are expected from the use of 

seafloor devices.

3.10.3.2.4.7 Impacts from Seafloor Devices under the No Action Alternative

Under the No Action Alternative, the Navy would not conduct the proposed training and testing 

activities in the AFTT Study Area. Various physical disturbance and strike stressors (e.g., seafloor devices) 

would not be introduced into the marine environment. Therefore, baseline conditions of the existing 

environment would either remain unchanged or would improve slightly after cessation of ongoing 

training and testing activities.

3.10.3.2.5Impacts from Pile Driving

3.10.3.2.5.1 Impacts from Pile Driving under Alternative 1

Impacts from Pile Driving under Alternative 1 for Training Activities

Under Alternative 1, a total of two Elevated Causeway System training events would occur in the Lower 

Chesapeake Bay and Navy Cherry Point Range Complex. Pile driving for elevated causeway system

training would subject nearshore sediments to vibration, disruption, and compaction. Elevated 
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3.10 Cultural Resources

causeway system training would not occur near known submerged cultural resources and the potential 

for encountering submerged historic resources in those areas is low. Surveys of the planned location of 

the elevated causeway system training would be conducted to ensure there are no obstructions prior to 

construction; this would prevent impacts to submerged resources.

Impacts from Pile Driving under Alternative 1 for Testing Activities

Pile driving is not associated with any testing activities under Alternative 1.

3.10.3.2.5.2 Impacts from Pile Driving under Alternative 2 

Impacts from Pile Driving under Alternative 2 for Training Activities

Under Alternative 2, the number of elevated causeway system training events would not increase 

relative to Alternative 1. Therefore, the potential for affecting submerged historic resources would be 

the same as described under Alternative 1.

Impacts from Pile Driving under Alternative 2 for Testing Activities

Pile driving is not associated with any testing activities under Alternative 2.

3.10.3.2.5.3 Impacts from Pile Driving under the No Action Alternative

Under the No Action Alternative, the Navy would not conduct the proposed training and testing 

activities in the AFTT Study Area. Various physical disturbance and strike stressors (e.g., pile driving) 

would not be introduced into the marine environment. Therefore, baseline conditions of the existing 

environment would either remain unchanged or would improve slightly after cessation of ongoing 

training and testing activities. 

3.10.3.2.6Impacts from Vibration from Sonic Booms

Impulsive noise, such as that resulting from supersonic overflights (sonic booms) can create intense 

shock waves that cause airborne vibration. Repeated vibration, over time, has the potential to degrade 

or destroy sensitive structural or cultural elements. Supersonic aircraft flights can occur and are usually 

limited to altitudes above 30,000 ft. and locations more than 30 NM from shore. Several factors 

influence sonic booms: weight, size, and shape of the aircraft; altitude; flight paths; and atmospheric 

conditions. A larger and heavier aircraft displaces more air and creates more lift to sustain flight, 

compared with small, light aircraft. Therefore, larger aircraft create sonic booms that are stronger and 

louder than those of smaller, lighter aircraft.

Vibration and shock waves from sonic booms could create increased structural instability and damage to 

a fragile historic architectural resource in the Study Area (Fort Jefferson in the Key West Range Complex) 

(Hanson et al., 1991; James et al., 2009).

3.10.3.2.6.1 Impacts from Aircraft Noise—Vibration from Sonic Booms under 

Alternative 1

Impacts from Vibration from Sonic Booms under Alternative 1 for Training Activities

Only the Key West Range Complex in the Gulf of Mexico Large Marine Ecosystem contains a cultural 

resource that could be susceptible to sonic booms; no other regions are associated with supersonic 

flight activities where susceptible cultural resources occur.

The Key West Range Complex contains a National Register of Historic Places-listed resource, Fort 

Jefferson, which is susceptible to damage from vibration and shock waves generated from sonic booms. 

A sonic boom study was conducted as part of the Key West Range Complex Environmental 
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3.10 Cultural Resources

Assessment/Overseas Environmental Assessment (James et al., 2009). Fragile mortar in the brick 

masonry at Fort Jefferson may be susceptible to damage from sonic booms (Hanson et al., 1991; James 

et al., 2009); however, the study concluded that restored sections of Fort Jefferson are not susceptible 

to sonic boom damage (James et al., 2009). The exclusionary Tortuga Military Operations Area around 

the Dry Tortugas National Park, combined with the Navy’s existing avoidance and mitigation measures 

enacted, means that sonic boom vibration has little potential for structural damage to historic structures 

and features associated with National Register of Historic Places-listed Fort Jefferson.

Impacts from Vibration from Sonic Booms under Alternative 1 for Testing Activities

No testing activities that could create sonic booms would occur in or near the Dry Tortugas National 

Park in the Gulf of Mexico Large Marine Ecosystem.

3.10.3.2.6.2 Impacts from Vibration from Sonic Booms under Alternative 2 

Impacts Vibration from Sonic Booms under Alternative 2 for Training Activities

As indicated in Alternative 1, only the Key West Range Complex in the Gulf of Mexico Large Marine 

Ecosystem contains a cultural resource that could be susceptible to sonic booms; no other large marine 

ecosystems are either associated with activities generating sonic booms or contain susceptible cultural

resources.

There would be no increase in aircraft activity in the Key West Range Complex under Alternative 2 

compared with Alternative 1. The exclusionary Tortuga Military Operations Area around the Dry 

Tortugas National Park, combined with the Navy’s existing avoidance and mitigation measures, means 

that sonic boom vibration has little potential for structural damage to historic structures and features 

associated with National Register of Historic Places-listed Fort Jefferson.

Impacts from Vibration from Sonic Booms under Alternative 2 for Testing Activities

No testing activities that could create sonic booms would occur in or near the Dry Tortugas National 

Park in the Gulf of Mexico Large Marine Ecosystem.

3.10.3.2.6.3 Impacts from Vibration from Sonic Booms under the No Action Alternative

Under the No Action Alternative, the Navy would not conduct the proposed training and testing 

activities in the AFTT Study Area. Various physical disturbance and strike stressors (e.g., vibration from 

sonic booms) would not be introduced into the marine environment. Therefore, baseline conditions of 

the existing environment would either remain unchanged or would improve slightly after cessation of 

ongoing training and testing activities.

3.10.4 SUMMARY OF POTENTIAL IMPACTS ON CULTURAL RESOURCES

3.10.4.1 Combined Impacts of All Stressors under Alternative 1

Explosive and physical disturbance and strike stressors associated with training and testing activities 

would not impact cultural resources with implementation of mitigation measures.

3.10.4.2 Combined Impacts of All Stressors under Alternative 2

Explosive and physical disturbance and strike stressors associated with training and testing activities 

associated with explosive and physical stressors would not impact cultural resources with 

implementation of mitigation measures.
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3.10 Cultural Resources

3.10.4.3 Combined Impacts of All Stressors under the No Action Alternative

Under the No Action Alternative, the Navy would not conduct the proposed training and testing 

activities. Baseline conditions of the existing environment would either remain unchanged or would 

improve slightly after cessation of ongoing training and testing activities.

3.10.4.4 National Historic Preservation Act

Table 3.10-2 summarizes the potential effects of the Proposed Action on submerged resources in 

accordance with Section 106 of the National Historic Preservation Act for Alternative 1, Alternative 2, 

and the No Action Alternative. The Proposed Action is not anticipated to affect known cultural resources 

within the Study Area. Accordingly, in the event that the Navy impacts a submerged historic or 

prehistoric resource, consultation would be conducted with the appropriate State Historic Preservation 

Officers.

Table 3.10-2: Summary of Section 106 Effects of Training and Testing Activities on Cultural 

Resources

Alternative and Stressor Section 106 Effects

Alternative 1

Explosive Stressors

Explosive stressors resulting from underwater explosions creating shock waves and 

cratering of the seafloor would not affect known or unknown submerged cultural 

resources; mitigation measures would continue to be implemented to protect

shipwrecks.

Physical Disturbance and 

Strike Stressors

Physical stressors resulting from in-water devices, military expended materials, 

seafloor devices, pile driving, and vibration from sonic booms during training and 

testing activities would not affect known or unknown submerged cultural resources;

mitigation measures, would continue to be implemented to protect shipwrecks.

Regulatory Determination No adverse effects on submerged cultural resources would occur.

Alternative 2 

Explosive Stressors

Explosive stressors resulting from underwater explosions creating shock waves and 

cratering of the seafloor would not affect known or unknown submerged cultural;

mitigation measures would continue to be implemented to protect shipwrecks.

Physical Disturbance and 

Strike Stressors

Physical stressors resulting from in-water devices, military expended materials, 

seafloor devices, pile driving, and vibration from sonic booms during training and 

testing activities would not affect known or unknown submerged cultural resources;

mitigation measures, would continue to be implemented to protect shipwrecks.

Regulatory Determination No adverse effects on submerged cultural resources would occur.

No Action Alternative

Explosive Stressors

Explosive stressors would not be introduced into the marine environment. 

Therefore, baseline conditions of the existing environment would either remain 

unchanged or would improve slightly after cessation of ongoing training and testing

activities

Physical Disturbance and 

Strike Stressors

Physical disturbance and strike stressors would not be introduced into the marine 

environment. Therefore, baseline conditions of the existing environment would 

either remain unchanged or would improve slightly after cessation of ongoing 

training and testing activities.
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3.10 References

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Table of Contents

Final

Environmental Impact Statement/Overseas Environmental Impact Statement 

Atlantic Fleet Training and Testing

TABLE OF CONTENTS

3.11 Socioeconomics.................................................................................................... 3.11-1

3.11.1 Introduction and Methods................................................................................3.11-1

3.11.2 Affected Environment.......................................................................................3.11-2

3.11.2.1 Sources of Energy Production and Distribution ...............................3.11-2

3.11.2.2 Mineral Extraction............................................................................3.11-7

3.11.2.3 Commercial Transportation and Shipping......................................3.11-10

3.11.2.4 Commercial and Recreational Fishing ............................................3.11-23

3.11.2.5 Aquaculture ....................................................................................3.11-33

3.11.2.6 Tourism...........................................................................................3.11-35

3.11.3 Environmental Consequences ........................................................................3.11-36

3.11.3.1 Impacts on Accessibility..................................................................3.11-37

3.11.3.2 Impacts from Airborne Acoustics...................................................3.11-47

3.11.3.3 Physical Disturbance and Strike Stressors......................................3.11-51

3.11.4 Secondary Stressors........................................................................................3.11-57

3.11.5 Summary of Potential Impacts on Socioeconomics........................................3.11-58

3.11.5.1 Combined Impacts of All Stressors under Alternative 1.................3.11-58

3.11.5.2 Combined Impacts of All Stressors under Alternative 2.................3.11-59

3.11.5.3 Combined Impacts of All Stressors under the No Action 

Alternative......................................................................................3.11-59

List of Figures

Figure 3.11-1: Bureau of Ocean Energy Management Planning Areas.................................................3.11-6

Figure 3.11-2: Oil and Gas Structures in the Gulf of Mexico ................................................................3.11-8

Figure 3.11-3: Active and Proposed Oil and Gas Pipelines in the Gulf of Mexico ................................3.11-9

Figure 3.11-4: Commercially Used Waterways and Major Ports in the Study Area ...........................3.11-12

Figure 3.11-5: Commercial Landings Since 1950 in Atlantic Coast States..........................................3.11-24

Figure 3.11-6: Commercial Landings Since 1950 in Gulf Coast States................................................3.11-25

Figure 3.11-7: Annual Recreational Catch of All Species for the 18 Coastal States (2012–

2017)..............................................................................................................................3.11-27

Figure 3.11-8: Top Five Recreational Species Caught in the Atlantic States (2012–2017).................3.11-28

Figure 3.11-9: Top Five Recreational Species Caught in the Gulf States (2012–2017).......................3.11-29
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Figure 3.11-10: Percent of Harvest in Federal Waters for Top Five Atlantic Coast 

Recreational Species (Measured By Number of Fish Caught) in 2016 ..........................3.11-30

Figure 3.11-11: Percent of Harvest in Federal Waters for Top Five Gulf Coast Recreational 

Species (Measured By Number of Fish Caught) in 2016................................................3.11-31

Figure 3.11-12: Danger Zones and Restricted Areas in the Northeast Atlantic Ocean.......................3.11-39

Figure 3.11-13: Danger Zones and Restricted Areas in the Mid-Atlantic Ocean ................................3.11-40

Figure 3.11-14: Danger Zones and Restricted Areas in the Southeast Atlantic Ocean and 

Eastern Gulf of Mexico...................................................................................................3.11-41

Figure 3.11-15: Danger Zones and Restricted Areas in the Western Gulf of Mexico.........................3.11-42

List of Tables

Table 3.11-1: Value of Top Commercial Catch in Atlantic and Gulf States, 2016...............................3.11-25

Table 3.11-2: Economic Benefit of Recreational Fishing Expenditures in the Northeast in 

2014 ...............................................................................................................................3.11-31

Table 3.11-3: Economic Benefit of Recreational Fishing Expenditures in the Mid-Atlantic 

in 2014 ...........................................................................................................................3.11-32

Table 3.11-4: Economic Benefit of Recreational Fishing Expenditures in the Southeast 

Atlantic in 2014..............................................................................................................3.11-32

Table 3.11-5: Economic Benefit of Recreational Fishing Expenditures in the Gulf of Mexico 

in 2014 ...........................................................................................................................3.11-33

Table 3.11-6: Ocean Economy Data for the Tourism and Recreation Sector by State, 2014 .............3.11-36
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3.11SOCIOECONOMICS

3.11.1 INTRODUCTION AND METHODS

This section provides an overview of the characteristics of socioeconomic resources in the Atlantic Fleet 

Training and Testing (AFTT) Study Area (Study Area) and describes in general terms the methods used to 

analyze potential impacts on these resources from the Proposed Action. 

The Council on Environmental Quality regulations implementing the National Environmental Policy Act 

state that when economic or social effects and natural or physical environmental effects are 

interrelated, the Environmental Impact Statement/Overseas Environmental Impact Statement (EIS/OEIS) 

SOCIOECONOMICS SYNOPSIS

The United States (U.S.) Department of the Navy (Navy) considered all potential stressors that 

socioeconomics could potentially be exposed to from the Proposed Action. The following conclusions 

have been reached for the Preferred Alternative (Alternative 1):

 Accessibility: Limits on accessibility to marine areas used by the public (e.g., fishing areas) in 

the Navy training and testing areas would be temporary and of short duration (hours). 

Restrictions would be lifted, and conditions would return to normal upon completion of 

training and testing activities. Minimal impacts on commercial and recreational fishing and 

tourism may occur; however, limits on accessibility would not result in a direct loss of 

income, revenue or employment, resource availability, or quality of experience. No impacts 

on sources for energy production and distribution, mineral extraction, commercial 

transportation and shipping, and aquaculture are anticipated.

 Airborne Acoustics: Because the majority of Navy training and testing activities are 

conducted far from where tourism and recreational activities are concentrated, the impact 

of airborne noise would be negligible. The public may intermittently hear noise from 

transiting ships or aircraft overflights if they are in the general vicinity of a training or testing 

activity, but these occurrences would be infrequent. The infrequent exposure to airborne 

noise would not result in a direct loss of income, revenue or employment, resource 

availability, or quality of experience. No impacts on sources for energy production and 

distribution, mineral extraction, commercial transportation and shipping, and aquaculture 

are anticipated.

 Physical Disturbance and Strikes: Because the majority of Navy training and testing activities 

are conducted farther from shore than where most recreational activities are concentrated, 

the potential for a physical disturbance or strike affecting recreational fishing or tourism is 

negligible. In locations where Navy training or testing occurs in nearshore areas (e.g., 

pierside), the Navy coordinates with civilian organizations to assure safe and unimpeded 

access and use of those areas. Based on the Navy’s standard operating procedures and the 

large expanse of the testing and training ranges, the likelihood of a physical disturbance or 

strike disrupting sources for energy production and distribution, mineral extraction, 

commercial transportation and shipping, commercial and recreational fishing, aquaculture, 

and tourism would be negligible. Therefore, direct loss of income, revenue or employment, 

resource availability, or quality of experience would not be expected.
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will discuss these effects on the human environment (40 Code of Federal Regulations [CFR] section

1508.14). The Council on Environmental Quality regulations state that the “human environment shall be 

interpreted comprehensively to include the natural and physical environment and the relationship of 

people with that environment.” To the extent that the ongoing and proposed Navy training and testing 

activities in the Study Area could affect the natural or physical environment, the socioeconomic analysis 

evaluates how elements of the human environment might be affected. The Navy identified six broad 

socioeconomic elements based on their association with human activities and livelihoods in the Study 

Area. Each of these socioeconomic resources is an aspect of the human environment that involves 

economics (e.g., employment, income, or revenue) and social conditions (e.g., enjoyment and quality of 

life) associated with the marine environment of the Study Area. Therefore, this evaluation considered 

potential impacts on six elements:

 sources for energy production and distribution (water, wind, oil and gas)

 mineral extraction

 commercial transportation and shipping

 commercial and recreational fishing

 aquaculture

 tourism

The baseline for identifying the socioeconomic conditions in the Study Area was derived using relevant 

published information from sources that included federal, state, regional, and local government 

agencies and databases, academic institutions, conservation organizations, technical and professional 

organizations, and private groups. Previous environmental studies were also reviewed for relevant

information.

The alternatives were evaluated based on the potential and the degree to which training and testing 

activities could impact socioeconomic resources. The potential for impacts depends on the likelihood 

that the training and testing activities would interface with public activities or infrastructure. Factors 

considered in the analysis include whether there would be temporal or spatial interfaces between the 

public or infrastructure and Navy training and testing. If there is potential for this interface, factors 

considered to estimate the degree to which an exposure could impact socioeconomics include whether 

there could be an impact on livelihood, quality of experience, resource availability, income, or 

employment. If there is no expected potential for the public to interface with an activity, the impacts 

would be considered negligible.

3.11.2 AFFECTED ENVIRONMENT

This section describes the six socioeconomic resources associated with human activities and livelihoods 

in the Study Area. The primary area of interest for assessing potential impacts on socioeconomic 

resources is the U.S. territorial waters in the North Atlantic Ocean and the Gulf of Mexico (seaward of 

the mean high water line to 12 nautical miles [NM]). Limited socioeconomic resources outside this area 

of interest (i.e., that portion of the U.S. Exclusive Economic Zone between 12 and 200 NM from shore) 

are also described when relevant to human activities.

3.11.2.1 Sources of Energy Production and Distribution

There are three primary sources of energy production in the Study Area: water, wind, and oil and gas. 

Each of these activities is described in this section.
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3.11.2.1.1Water

Hydropower is derived from the force of moving water. Hydrokinetic power is a type of hydropower that 

is derived from fast-moving marine or estuarine currents driven by waves, tides, or offshore ocean 

currents (U.S. Department of Energy, 2015b). The Federal Energy Regulatory Commission licenses 

hydropower projects. The Bureau of Ocean Energy Management has jurisdiction to issue leases, 

easements, and rights-of-way for hydrokinetic projects in Federal waters. 

The Wind and Water Power Technologies Office within the U.S. Department of Energy’s Office of Energy 

Efficiency and Renewable Energy provided over $133 million in funding for 97 marine and hydrokinetic 

projects from Fiscal Year 2008–2014, almost exclusively to private industry and universities or colleges. 

Projects in 24 states, including 11 states located adjacent to the AFTT Study Area, have received funding. 

Nearly 45 percent ($58 million) of the funding went to the Atlantic coast and Gulf coast geographic 

regions, with Maine receiving over $18 million. Some of the strongest wave and tidal resource potential 

in the continental United States resides off the coast of Maine (U.S. Department of Energy, 2015b). 

The Federal Energy Regulatory Commission has issued licenses for four hydrokinetic projects, two of 

which are tidal projects located on the Atlantic coast: the Cobscook Bay Tidal Project in Maine and the 

Roosevelt Island Tidal Energy Project in New York City. Neither of these projects are located within the 

AFTT Study Area, but both demonstrate the feasibility of similar projects located farther offshore. In 

2012, the Cobscook Bay Tidal Project in Maine marked the first time in U.S. history that a commercial 

tidal project connected to the electric power grid. Verdant Power, Inc. completed the Roosevelt Island 

Tidal Energy Project in New York City’s East River and continues to develop the technology. The 

Cobscook Bay license extends through January 31, 2020, and the Roosevelt Island license extends 

through December 31, 2022 (Federal Energy Regulatory Commission, 2015). A license allows the 

licensee to construct and operate a hydrokinetic electric generation facility for up to either 30 or 

50 years, depending on the type of license.

The United States has no commercial offshore hydrokinetic energy generating capacity at this time. As 

of April 2018, the Federal Energy Regulatory Commission had two active hydrokinetic preliminary 

permits. Both of the permitted projects are located on the Atlantic coast. The permit for the Western 

Passage Tidal Energy project located off the coast of Maine near the city of Eastport was issued on July

13, 2016, and expires on June 30, 2019. The project will test 15 hydrokinetic tidal devices, each 

consisting of a 500-kilowatt turbine-generator unit (MarineEnergy.biz, 2017). The Cape Cod Canal and 

Bourne Tidal project located in the Cape Cod Canal in Massachusetts was issued a permit on September 

22, 2016, and the permit expires on August 31, 2019 (Federal Energy Regulatory Commission, 2015, 

2018a, 2018b). Both projects are located in state waters. Although a preliminary permit does not 

authorize construction of a commercial device, it allows the applicant to conduct studies and secure 

data necessary to determine the feasibility of commercial development. The Fort Pierce Inlet Tidal 

project located off the Florida coast was active from May 2015 through April 2018 and was the first

lease issued to test ocean current energy equipment in Federal waters. The project study area and lease 

blocks permitted by the Bureau of Ocean Energy Management are within the Study Area; however, the 

project permit is no longer active.

The Navy is playing a role in the development of hydrokinetic technologies by allowing developers to 

test scale models of their wave energy converter equipment in the wave-making facility at Naval Surface 

Warfare Center, Carderock in Maryland (U.S. Department of Energy, 2015a). On a broader scale, the U.S.

Department of Agriculture and the Navy signed a Memorandum of Understanding in early 2010 to 
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advance the production of renewable energy by sharing technical, program management, and financial 

expertise (U.S. Department of the Navy, 2010).

A variety of other companies and academic institutions continue to conduct research on and develop

hydrokinetic technologies for deployment and eventual commercial use along the Atlantic and Gulf 

coasts. Their activities may include sea trials, small-scale prototype testing, and research that may use 

instruments such as acoustic Doppler profile current sensors, digital recording sonar, and underwater 

video and still photography taken from unmanned underwater vehicles.

3.11.2.1.2Wind

Wind energy is derived from the force of moving air that causes large wind turbine blades to rotate. The 

blades are connected to an electric generator that converts the mechanical energy from the wind into 

electricity, which is then transferred to the electrical power grid (U.S. Department of Energy, 2017). The 

first commercial offshore wind farm in the United States came online and reached commercial 

operation in December 2016. The Block Island Wind Farm, located in state waters off Block Island, 

Rhode Island, was developed by Deepwater Wind, LLC and is capable of generating 30 megawatts of 

power using five wind turbines (Deepwater Wind, 2018a, 2018b). 

A National Offshore Wind Strategy: Creating an Offshore Wind Energy Industry in the United States, was 

prepared in 2011 to support development of a world‐class offshore wind industry in the United States

(U.S. Department of Energy & U.S. Department of the Interior, 2011). The Bureau of Ocean Energy 

Management developed a regulatory framework to review proposed offshore wind projects in federal 

waters and launched the “Smart from the Start” initiative to facilitate siting, leasing, and construction of 

new projects (Bureau of Ocean Energy Management, 2013). In general, this process includes the 

following steps:

 Wind energy areas that appear most suitable for wind energy development are identified.

 Requests for interest and calls for information are issued for new wind energy areas to support 

lease sale environmental assessments.

 Environmental assessments are completed for the wind energy areas, allowing the lease sale 

process to move forward.

 A lease sale is held. Issuance of a commercial lease gives the lessee the exclusive right to 

subsequently seek Bureau of Ocean Energy Management approval for development of the 

leasehold. The lease does not grant the lessee the right to construct any facilities; rather, the 

lease grants the right to use the leased area to gather resource and site characterization 

information and develop plans, which must be approved by the Bureau of Ocean Energy 

Management before the lessee can move on to the next stage of the process.

 Project-specific National Environmental Policy Act review (typically an EIS) is conducted, and 

plans for construction and operation are approved before beginning construction of individual 

wind power facilities.

Since 2009, the Bureau of Ocean Energy Management’s Office of Renewable Energy Programs has issued 

13 commercial wind energy leases for offshore wind farm development to the following companies for 

projects located within or adjacent to the Study Area (Bureau of Ocean Energy Management, 2018):

 Cape Wind Associates, LLC, for an area totaling 29,425 acres (ac.) offshore of Massachusetts 

(2010).
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 Bluewater Wind Delaware, LLC, for an area totaling 96,430 ac. offshore of Delaware (2012). 

Assigned to Garden State Offshore Energy, LLC, in 2016.

 Deepwater Wind New England, LLC, for two lease areas totaling 164,750 ac. offshore of Rhode 

Island and Massachusetts (2013).

 Virginia Electric and Power Company (Dominion Virginia Power) for an area totaling 112,799 ac. 

offshore of Virginia (2013).

 US Wind, Inc. for an area totaling 183,353 ac. offshore of New Jersey (2016).

 US Wind Inc., for two lease areas totaling 79,707 ac. offshore of Maryland (2014).

 Offshore MW LLC for an area totaling 166,886 ac. offshore of Massachusetts (2015). Offshore 

MW LLC changed its name to Vineyard Wind LLC. In 2017.

 RES America Developments, Inc., for an area totaling 187,523 ac. offshore of Massachusetts 

(2015). Assigned to Bay State Wind LLC in 2016.

 RES America Developments, Inc. for an area totaling 160,480 ac. offshore of New Jersey (2016). 

Assigned to Ocean Wind LLC in 2016.

 Statoil Wind US LLC. for an area totaling 79,350 acres offshore of New York (2017).

 Avangrid Renewables, LLC. for an area totaling 122,405 acres offshore of North Carolina (2017).

The Bureau of Ocean Energy Management grants rights-of-way allowing developers to build electricity 

transmission lines connecting commercial windfarms and other offshore renewable energy installations 

to the on-shore electrical grid. The Bureau executed a right-of-way grant in 2014 for a cable project that 

will support the Block Island Wind Farm, a wind project located in Rhode Island state waters. The Bureau 

expects to receive additional unsolicited applications for right-of-way grants in the future (Bureau of 

Ocean Energy Management, 2015a). Other offshore windfarm projects are expected in the coming years 

for both research and commercial development in state and federal waters.

Approximately 3 NM offshore of Atlantic City, New Jersey, and within state waters, Fishermen’s Energy 

of New Jersey plans to install six four-megawatt turbines in support of a demonstration and research 

project. The Fishermen’s Energy project had been delayed but was revived by New Jersey state 

government legislation. The project will test new and developing technology and conduct research on 

potential environmental impacts associated with offshore windfarms (Post, 2018).

Two research lease requests were received from the Virginia Department of Mines, Minerals and 

Energy. In response to both requests, the Bureau determined there was no competing interest in the 

lease areas. One of the research leases, referred to as the Virginia Offshore Wind Technology 

Advancement Project, was executed in March 2015. This was the first research lease to be issued in U.S. 

federal waters (Bureau of Ocean Energy Management, 2015b). The Bureau finalized an Environmental 

Assessment and issued a Finding of No Significant Impact for the proposed project in July 2015. As part 

of this project, Dominion Virginia Power will install two six-megawatt direct-drive wind turbines 26 miles 

(mi.) off the coast of Virginia Beach, Virginia. 

3.11.2.1.3Oil and Gas

The Bureau of Ocean Energy Management administers Outer Continental Shelf Oil and Gas Leasing 

Programs. The Bureau divides the outer continental shelf into planning areas, which are further divided 

into lease blocks that can be leased from the government by the public (e.g., oil and gas companies) for 

resource extraction (Figure 3.11-1). 
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Notes: AFTT: Atlantic Fleet Training and Testing; OPAREA: Operating Area; BOEM: Bureau of Ocean Energy Management; SINKEX: Sinking Exercise; VACAPES: Virginia Capes 

Figure 3.11-1: Bureau of Ocean Energy Management Planning Areas
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As of January 1, 2016, there were 4,457 active oil and gas leases totaling 23,989,693 ac. in the Gulf of 

Mexico Continental Shelf Oil Region, which is divided into three planning areas (Bureau of Ocean Energy 

Management, 2016):

 Western Planning Area, 907 active leases and 5,143,073 ac. leased

 Central Planning Area, 3,505 active leases and 18,574,590 ac. leased

 Eastern Planning Area, 48 active leases and 264,030 ac. leased

There are 1,866 fewer active leases in the Gulf of Mexico than in 2011, which represents a decrease of 

9,916,106 leased acres (Bureau of Ocean Energy Management, 2011, 2016).

Drilling for oil and gas has taken place in offshore Canadian Atlantic waters since 1967; however, Canada 

has imposed a moratorium on drilling in the Canadian portion of the Georges Bank until December 31, 

2022 (Nova Scotia Canada, 2015). Gas was discovered in 1971 off of Sable Island approximately 

225 kilometers offshore of Nova Scotia, which is within the Study Area. Natural gas production began in 

1999 and continues today. Gas is transported through an undersea pipeline linking production wells 

with on-shore facilities. The Sable Offshore Energy Project produced over 112 million cubic meters of 

natural gas in November 2015. However, average monthly production has decreased steadily since 

2008, when approximately 400 million cubic meters were produced monthly. The project life expectancy 

was 25 years when drilling started in 1999, which, unless revised, means the project will end in 2024 

(Canada-Nova Scotia Offshore Petroleum Board, 2015).

The Gulf of Mexico is the only portion of the Study Area where energy production from oil and gas 

occurs in U.S. territorial waters. In 2014, total oil production in the Gulf of Mexico was nearly 395 million 

barrels and valued at $37 billion (National Ocean Economics Program, 2015a). Natural gas production in 

2014 totaled over 829 million Mcf (the unit “Mcf” is 1,000 [M] cubic feet [cf]), which was valued at $3.8 

billion. The majority of oil and gas structures and the pipelines linking those structures with on shore 

processing and refining facilities are located off of Louisiana and do not overlap with Navy testing ranges 

and Operating Areas (OPAREA) (Figure 3.11-2, Figure 3.11-3).

3.11.2.2 Mineral Extraction

Extraction of minerals along the Atlantic and Gulf coasts involves primarily hard minerals (e.g., sand, 

gravel, and other minerals) extracted from the outer continental shelf. Heavy minerals (e.g., titanium 

and zircon) used in a number of commercial industries are also potential offshore resources. The Bureau 

of Ocean Energy Management is responsible for assessing the mineral resources on the U.S. outer 

continental shelf to determine if they can be extracted in an environmentally sound manner. 
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Notes: AFTT: Atlantic Fleet Training and Testing; OPAREA: Operating Area

Figure 3.11-2: Oil and Gas Structures in the Gulf of Mexico
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Notes: AFTT: Atlantic Fleet Training and Testing; OPAREA: Operating Area

Figure 3.11-3: Active and Proposed Oil and Gas Pipelines in the Gulf of Mexico
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Two types of lease conveyances for sand and gravel and other non-energy minerals are used by the 

Bureau: (1) noncompetitive negotiated agreements, which can only be used for public works projects 

funded by federal, state, or local government agencies; and (2) competitive lease sales, for which any 

qualified person may submit a bid. Between 2009 and 2016, the Bureau executed 21 leases in six states: 

Florida, Louisiana, North Carolina, South Carolina, New Jersey, and Virginia (Bureau of Ocean Energy 

Management, 2015c). Projects include:

 New Jersey (Long Beach Island),

 Virginia (Dam Neck, Sandbridge, and Wallops Flight Facility),

 North Carolina (Bogue Banks),

 South Carolina (Charleston Offshore Dredged Material Disposal Site Sand Borrow Project, Folly

Beach),

 Florida (Patrick Air Force Base, Longboat Key, Martin County, Pinellas County, Duval County, and 

Brevard South Reach), and 

 Louisiana (Whiskey Island, Caminada Headlands, Cameron Parish, and Raccoon Island Phase B).

Sand and gravel transported from offshore sites are primarily used to restore coastal areas that have 

been eroded by storms or sea level rise. Over the past 20 years, more than 109 million cubic yards of 

sediment have been extracted and transported to coastal communities and federal agencies, including 

the Navy, for shoreline restoration projects (Bureau of Ocean Energy Management, 2015c). A number of 

areas along the U.S. Atlantic coast were severely damaged in 2012 by Hurricane Sandy. The Bureau has 

coordinated with other federal agencies, including the Federal Emergency Management Agency and the 

U.S. Army Corps of Engineers, on restoration projects at Sandbridge Beach, Virginia; Wallops Island, 

Virginia; Brevard County, Florida; and Long Beach Island, New Jersey (Bureau of Ocean Energy 

Management, 2015d).

In February 2014, the Bureau released its Final Programmatic EIS analyzing potential impacts of 

geological and geophysical surveys of the seafloor; the Record of Decision was signed in July 2014 

(Bureau of Ocean Energy Management, 2014). The survey region extends from Delaware Bay to Cape 

Canaveral, Florida. Geological and geophysical surveys are conducted prior to initiating mineral 

extraction or offshore development projects, such as windfarms, oil and gas exploration, or hydropower 

projects, to determine the best use of an area. The Bureau of Ocean Energy Management regulates 

offshore activities to protect the environment and ensure safety of personnel and the public (Bureau of 

Ocean Energy Management, 2015c).

3.11.2.3 Commercial Transportation and Shipping

Commercial transportation and shipping encompasses marine and air traffic within the Study Area. 

Military use of the offshore sea and air space is generally compatible with civilian use, with Navy ships 

accounting for less than 1 percent of the total ship presence in the Study Area (Mintz, 2012). Training 

and testing activities that are not compatible with commercial transportation and shipping 

(e.g., weapons firing) typically occur in Navy OPAREAs far from commercially used waterways and inside 

Special Use Airspace, as described in Section 3.11.2.3.2 (Air Transport). Upcoming training and testing 

activities are announced to commercial vessel and aircraft operators by use of Notices to Mariners 

issued by the U.S. Coast Guard, Notices to Airmen issued by the Federal Aviation Administration, and 

marine band radio, as needed. The Navy procedures for planning and management of activities are 
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provided in the Chief of Naval Operations Instruction 3770.2K, Airspace Procedures and Planning 

Manual (U.S. Department of the Navy, 2007). 

Scheduling and planning procedures for activities on range complexes (including testing activities in the 

Northeast Range Complexes) are issued through the Navy’s Fleet Area Control and Surveillance Facilities 

Virginia Capes in Virginia Beach, Virginia and the Fleet Area Control and Surveillance Facilities 

Jacksonville located in Jacksonville, Florida. Testing ranges have their own procedures for aviation 

safety, such as the Naval Surface Warfare Center, Panama City Division Instruction (U.S. Department of 

the Navy, 2008) and Naval Undersea Warfare Center Division, Newport Instruction (U.S. Department of 

the Navy, 2009).

3.11.2.3.1Ocean Transportation

Ocean transportation is the transit of commercial, private, and military vessels at sea, including 

submarines. The U.S. Atlantic coast and the Gulf of Mexico are heavily traveled by marine vessels, with 

numerous waterways and commercial shipping lanes traversing the range complexes (Figure 3.11-4).

Most of the waterways in the Study Area are accessible to commercial vessels; however, some areas are 

restricted. These restrictions can be permanent or temporary. The National Oceanic and Atmospheric 

Administration issues nautical charts that reflect designated restricted zones. In accordance with Title 33 

CFR part 72, the U.S. Coast Guard and Department of Homeland Security publish marine information 

pertaining to waterways (i.e., danger zones and restricted areas; see below). Notices to Mariners 

provide information to private and commercial vessels on temporary closures. These navigational 

warnings are disseminated by broadcast notices on maritime frequency radio, weekly publications by 

the appropriate U.S. Coast Guard Navigation Center, and global positioning system navigation charts. 

They provide information about duration and location of closures due to activities that are potentially 

detrimental to surface vessels. Vessels are responsible for being aware of designated danger areas in 

surface waters and any Notices to Mariners that are in effect. Operators of recreational or commercial 

vessels have a duty to abide by maritime requirements as administered by the U.S. Coast Guard.

The flow of vessel traffic in congested waters, especially near coastlines, is controlled by the use of 

directional shipping lanes for large vessels, including cargo ships, container ships, and tankers, and flow 

controls for all vessels in harbors, bays, and ports to ensure that ports-of-entry remain as uncongested 

as possible. Navy vessels and non-military vessels alike adhere to regulations governing shipping traffic 

in these areas. There are fewer restrictions controlling open-ocean vessel traffic. In most cases, the 

factors that influence vessel traffic include: adequate depth of water, weather conditions (primarily 

affecting smaller recreational vessels), availability and location of fish for commercial and recreational 

fishing vessels, and hazards to navigation. Large commercial shipping vessels generally follow 

well-established routes that enable efficient transport of goods between ports. Recreational boating 

activities fluctuate seasonally, with increased activity in summer when warmer weather and more 

daylight hours offer more opportunity for recreational boating activities.

Certain areas of surface water within the Study Area are designated as danger zones, safety zones, 

security zones, or restricted areas as described in the CFR and established by the U.S. Coast Guard and 

the U.S. Army Corps of Engineers. These areas may limit access to non-military activities on either a 

fulltime or temporary timeframe. Detailed information on these areas is provided in the CFR as 

referenced in the following brief descriptions.
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Notes: AFTT: Atlantic Fleet Training and Testing; OPAREA: Operating Area; SINKEX: Sinking Exercise

Figure 3.11-4: Commercially Used Waterways and Major Ports in the Study Area
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Information on danger zones and restricted areas is found in 33 CFR part 334 (Navigation and Navigable 

Waters, Danger Zone and Restricted Area Regulations). A danger zone is a defined water area (or areas) 

used for target practice, bombing, rocket firing, or other especially hazardous activities. Danger zones 

may be closed to the public on a fulltime or intermittent basis, as stated in the regulations specific to 

individual danger zones. A restricted area is a defined water area prohibiting or limiting public access to 

provide security for government property and to protect the public from risk of injury or damage to 

property arising from the government's use of the area.

Information on safety zones and security zones is found in 33 CFR part 165 (Regulated Navigation Areas 

and Limited Access Areas). Safety zones are specifically addressed in 33 CFR part 165.20 Subpart C 

(Safety Zones). A safety zone is defined as a water area, shore area, or a combination of water and shore 

area to which, for safety or environmental purposes, access is limited to authorized persons, vehicles, or 

vessels. A safety zone may be stationary and described by fixed limits, or it may be described as a zone 

around a vessel in motion. Security zones are defined in 33 CFR part 165.30 Subpart D (Security Zones). 

A security zone is defined as an area of land, water, or a combination of land and water areas that are 

designated by the Captain of the Port or District Commander for a time period deemed necessary to 

prevent damage or injury to any vessel or waterfront facility; to safeguard ports, harbors, territories, or 

waters of the United States; or to ensure that the rights and obligations of the United States are 

observed.

In addition to the regulations described above, a naval vessel protection zone as described in 33 CFR

part 165.20 Subpart G (Protection of Navy Vessels) states that no vessel or person is allowed within 

100 yards of a large U.S. Navy vessel unless authorized by the U.S. Coast Guard, the senior naval officer 

present in command, or an official patrol. 

Furthermore, all vessels shall operate at the minimum speed necessary to maintain a safe course, unless 

required to maintain a greater speed by navigational rules, and shall proceed as directed by the U.S. 

Coast Guard, the senior naval officer present in command, or the official patrol. 

When a vessel is within a naval vessel protection zone the following rules apply: 

 To request authorization to operate within 100 yards of a large U.S. Navy vessel, contact the U.S. 

Coast Guard, the senior naval officer present in command, or the official patrol on VHF-FM 

channel 16. 

When conditions permit, the U.S. Coast Guard, senior naval officer present in command, or the official 

patrol should: 

 Give advance notice on VHF-FM channel 16 of all large U.S. naval vessel movements; 

 Permit vessels constrained by their navigational draft or restricted in their ability to maneuver to 

pass within 100 yards of a large U.S. naval vessel in order to ensure a safe passage in accordance 

with the navigation rules; 

 Permit commercial vessels anchored in a designated anchorage area to remain at anchor when 

within 100 yards of passing large U.S. naval vessels; and 

 Permit vessels that must transit via a navigable channel or waterway to pass within 100 yards of 

a moored or anchored large U.S. naval vessel with minimal delay consistent with security.
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Danger zones, restricted areas, safety zones, and security zones located in the Study Area are described 

in Section 3.11.3.1 (Impacts on Accessibility). A representation of the density of commercial and military 

vessel traffic in the Study Area is shown in Figures 3.0-10 and 3.0-11 in Section 3.0 (Introduction). 

Sections 3.11.2.3.1.1 (Northeast Range Complex) through 3.11.2.3.1.12 (Pierside Locations [Gulf of 

Mexico]) provide more detailed information on ocean transportation within the range complexes 

located within the Study Area.

3.11.2.3.1.1 Northeast Range Complex

The Boston Range Complex, Narragansett Bay Range Complex, and Atlantic City Range Complex are 

referred to collectively as the Northeast Range Complexes. These range complexes include Special Use 

Airspace with associated warning areas and surface and subsurface sea space. See Chapter 2 

(Description of Proposed Action and Alternatives) for maps and additional details on range complexes in 

the Study Area.

Military Ocean Traffic

The Fleet Forces Atlantic Exercise Coordination Center is responsible for coordinating OPAREA training 

assignments, ranges, airspace, mobile sea range assets, fixed and mobile targets, Large Area Tracking 

Range, and electronic attack. Testing activities are conducted in accordance with Narragansett Bay 

Shallow Water Test Facility Instruction 8590.1E (U.S. Department of the Navy, 2009). The Fleet Forces 

Atlantic Exercise Coordination Center coordinates with all Department of Defense (DoD), government, 

and civilian agencies to ensure compliance with all requirements and regulations for the safe use of 

ranges, assets, and services. Detailed information on vessel types and the general distribution of vessels 

within the Study Area is provided in Section 3.0.3.3.4.1 (Vessels and In-Water Devices).

Civilian Ocean Traffic

The U.S. Atlantic coast has some of the busiest shipping lanes in the world, and a large volume of ship 

traffic transits the area. Maritime traffic includes ships traveling along the coastline between ports in 

New England and the mid-Atlantic as well as to ports in eastern Canada and across the Atlantic to 

Europe (Figure 3.11-4).

Commercial (domestic and international) shipping constitutes the majority of this traffic while 

commercial ferries operate from every coastal state from Maine to Maryland, with the exception of New 

Hampshire. One primary shipping lane is off northern New England, with many arteries leading to ports 

in Massachusetts, New Hampshire, and Maine. The majority of the eastern portion of the Boston Range 

Complex is free from commercial traffic, but commercial traffic can be expected in the western part of 

the OPAREA. Several primary shipping lanes crisscross the Narragansett Bay Range Complex, leading to 

the major ports of New York City, New York; Newark, New Jersey; and Providence, Rhode Island. 

Similarly, the Atlantic City Range Complex contains several primary shipping lanes leading from New 

York City and Newark to ports in Delaware Bay and the mid-Atlantic United States. It is therefore highly 

likely that commercial ship traffic would be encountered along shipping routes throughout the greater 

part of all the Northeast Range Complexes. 

Some of the busiest ports in the United States are located adjacent to the Northeast Range Complexes. 

The port complex of New York City/New Jersey was ranked third in total trade in the United States in 

2016. Over 133 million tons of goods passed through the port in 2016 (U.S. Army Corps of Engineers, 

2017). New England’s largest port, Boston, is ranked 37th in total trade with just over 17 million tons of 

imports and exports, and the Port of Boston is rapidly becoming one of the fastest-growing high-end 

cruise ship markets in the country. The port complex of New York City/New Jersey has more scheduled
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services to a wider variety of trade lanes than any other port in North America. The port complex also 

processes more 20-foot container units than any other port on the Atlantic coast of the United States. 

Only the California ports of Long Beach and Los Angeles process more containers (U.S. Maritime 

Administration, 2015). The port complex of Halifax, Canada, is closer to northern Europe than any other 

major North American port, and the complex is frequently used as the first inbound port or last 

outbound port for vessels transiting between Europe and in North America. Vessels traveling along this 

route will pass through the northern portion of the Study Area.

In 2016, there were over 11.8 million recreational vessels registered in the United States; approximately 

1.3 million (11 percent) were registered in the eight states along the coast from Maine to Maryland (U.S. 

Coast Guard, 2017). Over 90 percent of registered recreational vessels in United States in 2016 were 

26 feet (ft.) in length or less, suggesting that most of these vessels are unlikely to travel far from shore 

for extended periods of time (U.S. Coast Guard, 2017). Recreational boating trips originating along the 

coast from Maine to Maryland could potentially travel into the Northeast Range Complexes. Many sites 

known to be fishing hotspots attract both recreational fishers and divers depending on the species and 

season. These fishing and diving hotspots (including artificial reefs and shipwrecks) may be used 

throughout the year, but use is highest during summer. Most recreational boat traffic is within a few 

miles of shore, while potentially hazardous U.S. Navy activities occur farther offshore. 

Many popular dive sites are located at the mouth of Massachusetts Bay within the Gerry E. Studds 

Stellwagen Bank National Marine Sanctuary. The 638 square nautical miles (NM2) marine sanctuary also 

offers several submerged shipwrecks (National Oceanic and Atmospheric Administration, 2010).

3.11.2.3.1.2 Naval Undersea Warfare Center Division, Newport Testing Range

The Naval Undersea Warfare Center Division, Newport Testing Range includes the waters of 

Narragansett Bay, Rhode Island Sound, Block Island Sound, Buzzards Bay, Vineyard Sound, and Long 

Island Sound. Three restricted areas are within the Naval Undersea Warfare Center Division, Newport 

Testing Range: 

 The Coddington Cove restricted area (adjacent to Naval Undersea Warfare Center Division, 

Newport Testing Range) provides an area with piers and ships representative of a working 

harbor area for harbor/swimmer defense type testing. 

 The Narragansett Bay Restricted Area (6.1 NM2 area surrounding Gould Island) includes the Hole 

Test Area, which provides a deepwater test capability, and the Gould Island Acoustic 

Communications and Tracking Range, an undersea range, within the boundaries of the North 

Test Area. 

 The Rhode Island Sound Restricted Area is a rectangular box (27.2 NM2) in Rhode Island and 

Block Island sounds.

3.11.2.3.1.3 Virginia Capes Range Complex

Military Ocean Traffic

The Virginia Capes OPAREA covers approximately 27,661 NM2 of sea space off the coast of Delaware, 

Maryland, Virginia, and North Carolina. About 70 surface ships and submarines are homeported in 

Norfolk, Virginia. The Fleet Forces Atlantic Exercise Coordination Center is responsible for coordinating 

activities within the OPAREA, and with all DoD, government, and civilian agencies, to ensure compliance 

with all requirements and regulations for the safe use of range assets and services. The Fleet Area 

Control and Surveillance Facility, Virginia Capes has authority to coordinate services and firing notices, 
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issue weekly target and OPAREA schedules, and prescribe necessary additional regulations governing 

matters within the Virginia Capes Range Complex.

Civilian Ocean Traffic

Ships transiting the lower Chesapeake Bay area follow two primary commercially used shipping lanes: 

the Thimble Shoals Channel, which leads to Hampton Roads, Virginia; and the Chesapeake Channel, 

which leads to points north, including the Port of Baltimore. These two channels pass over the 

underwater (tunnel) sections of the Chesapeake Bay Bridge-Tunnel system, which connects the City of 

Virginia Beach to Cape Charles on the Eastern Shore. The Port of Baltimore was ranked 16th in total 

trade among U.S. ports in 2016, with over 38 million tons of goods passing through the port (U.S. Army 

Corps of Engineers, 2017). Over half of the shipments were foreign exports, which would pass through 

the Chesapeake Bay and into the Virginia Capes OPAREA on their way across the Atlantic Ocean or 

towards the Panama Canal.

The nearshore areas of the Virginia Capes OPAREA, in particular, are heavily traveled, because of their 

proximity to commercial ports in both Delaware and Virginia, including the port of Virginia in Norfolk, 

Virginia, the second-busiest port facility on the U.S. Atlantic coast, and the Port of Wilmington, 

Delaware, which is located on the Delaware River at the head of the Delaware Bay. In 2016, the Port of 

Virginia processed 54 million tons of imports and exports, ranking 13th among all U.S. ports and second 

among East Coast ports in total volume traded (U.S. Army Corps of Engineers, 2017). In 2017, the port 

handled 1,746 port calls, an average of about five per day and a decrease of near 10 percent over 2016 .

Assuming that each port call is associated with two vessel transits (inbound and outbound), nearly 4,000

vessel transits passed from the Port of Virginia (Norfolk) through the lower Chesapeake Bay and into the 

Virginia Capes OPAREA in 2016. In addition to commercial shipping vessels, commercial ferries operate 

off the shores of Delaware, Maryland, Virginia, and North Carolina. 

Recreational transportation activities offshore consist of game and sport fishing, charter boat fishing, 

sport diving, dolphin and whale watching, sailing, and power cruising. Approximately, 11.8 million 

recreational vessels were registered in the United States in 2016; over 90 percent are under 26 ft. and 

42 percent are under 16 ft. in length, suggesting that most of these vessels are unlikely to travel far from 

shore for extended periods of time. The five coastal states from Virginia to Florida maintained 

2.3 million registered recreational vessels in 2016, approximately 20 percent of all recreational vessels 

registered in the United States (U.S. Coast Guard, 2017).

3.11.2.3.1.4 Pierside Locations (mid-Atlantic area)

Military Pierside Locations

Eight pierside locations in the mid-Atlantic area are considered in this Final EIS/OEIS. The pierside 

locations are the Navy-contractor shipyard in Bath, Maine; Portsmouth Naval Shipyard in Kittery, Maine; 

the Navy-contractor shipyard and the Naval Submarine Base in Groton, Connecticut; the 

Navy-contractor shipyard in Newport News, Virginia; Naval Station Norfolk, Norfolk, Virginia; Joint 

Expeditionary Base Little Creek-Fort Story, Virginia Beach, Virginia; and Norfolk Naval Shipyard, 

Portsmouth, Virginia.

The shipyard in Bath, Maine is on the Kennebec River approximately 12 mi. above the mouth of the river 

in southern Maine. There is little waterborne traffic to Bath except barge traffic to the shipyard and 

vessels bound for repairs. Some fish carriers travel to a cannery north of Bath (Marine World Database, 

2009). The U.S. Coast Guard established a 150-yard radius safety zone around the dry dock associated 
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with the contractor facility. The safety radius is only activated when the dry dock is deployed in its 

dredged basin hole near the center of the Kennebec River.

The Portsmouth Naval Shipyard in Kittery, Maine is on Seavey Island in Portsmouth Harbor on the 

Piscataqua River. The Port of Portsmouth, located across the Piscataqua River in New Hampshire, is 

ranked 103rd among U.S. ports in total trade, but 48th in foreign imports, bringing in nearly 2 million 

tons of imported goods in 2016 (U.S. Army Corps of Engineers, 2017). The port received 96 port calls in 

2015, including 65 from tankers transporting petroleum fuels and oils, and 21 from bulk carriers, which 

transport cargo such as gypsum, salt, and asphalt (U.S. Maritime Administration, 2016). The primary 

mission of the Portsmouth Naval Shipyard is the overhaul, repair, and modernization of Los Angeles 

class-submarines. Military ocean traffic is composed of submarines entering and leaving the facility for 

maintenance. 

The Navy-contractor shipyard and the Naval Submarine Base New London in Groton, Connecticut, are 

on the Thames River, a short river and tidal estuary stretching 15 mi. and emptying in the New London 

Harbor and Long Island Sound. Military ocean traffic is from vessels traveling to and from the shipyard 

and the Naval Submarine Base. The U.S. Coast Guard operates a cutter and miscellaneous small craft in 

the Thames River and New London Harbor. Recreational boating, fishing vessels, and ferry services also 

use the Thames River. Hess Oil operates a privately owned dock that supports oil and chemical barges.

The Navy-contractor shipyard in Newport News, Virginia, designs, builds, and refuels the U.S. Navy’s 

nuclear-powered aircraft carriers and is one of two facilities within the United States that design and 

build nuclear-powered submarines. The shipyard is situated along 2 mi. of the James River, a tributary of 

the Chesapeake Bay.

Naval Station Norfolk, the largest naval complex in the world, supports the operational readiness of the 

U.S. Atlantic Fleet. Situated at the mouth of the Chesapeake Bay, this naval station is homeport to more 

than 70 surface and subsurface vessels. Joint Expeditionary Base Little Creek–Fort Story is used as a 

cantonment area and for outdoor training; it is also at the mouth of the Chesapeake Bay, 7 mi. east of 

Naval Station Norfolk. Joint Expeditionary Base West (Little Creek) is homeport to a variety of surface 

vessels. The Norfolk Naval Shipyard, situated along the Elizabeth River, is one of the largest shipyards in 

the world. It has the ability to overhaul and repair any ship in the U.S. Fleet. The shipyard also repairs, 

overhauls, and modernizes various submarine classes.

Civilian Pierside Locations

The Port of Virginia operates the Norfolk International Terminals, Portsmouth Marine Terminal, and 

Newport News Marine Terminal. In 2017, the Port of Virginia had 1,746 ship calls, transported 

2.8 million container units, and moved 22 million short tons of cargo. 

3.11.2.3.1.5 Navy Cherry Point Range Complex

Military Ocean Traffic

The Navy Cherry Point OPAREA sea space covers 18,617 NM2 off the east coasts of North Carolina and 

South Carolina. The Fleet Forces Exercise Atlantic Coordination Center is responsible for coordinating 

training OPAREA assignments, ranges, airspace, mobile sea range assets, fixed and mobile targets, Large 

Area Tracking Range, and electronic attack. The Fleet Forces Atlantic Exercise Coordination Center 

coordinates with all DoD, government, and civilian agencies to ensure compliance with all requirements 

and regulations for the safe use of ranges, assets, and services. The Fleet Area Control and Surveillance 

Facility, Virginia Capes has authority to coordinate services and firing notices, issue weekly target and 
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OPAREA schedules, and prescribe necessary additional regulations governing matters within the Navy 

Cherry Point Range Complex. 

Civilian Ocean Traffic

The southeast coast of the United States is heavily traveled by marine vessels, with several commercial 

ports near U.S. Navy OPAREAs like Wilmington, North Carolina; Charleston, South Carolina; Savannah, 

Georgia; and Jacksonville, Florida. Recreational vessels range throughout the coastal waters, depending 

on season and weather conditions. North Carolina had over 367,000 registered recreational vessels in 

2016, which ranked as the fourth highest total among Atlantic coast states (U.S. Coast Guard, 2017). 

There are over 200 free water access areas in North Carolina coast, the majority of which are located 

along or near the coastline (North Carolina Wildlife Resources Commission, 2016).

Travel between the most popular cruising destinations in the area does not require traversing OPAREAs; 

however, larger recreational vessels, in particular sailboats and motor cruisers in the 50 ft. and larger 

class, can travel considerable distances offshore and are capable of entering offshore OPAREAs.

Recreational dive vessels travel to shipwrecks that provide habitat suitable for development of artificial 

reefs and are popular destinations for divers. Divers frequent the Cape Hatteras offshore area because 

of its volume of artificial reefs provided by shipwrecks (Dive Hatteras, 2003). Billed as the “Graveyard of 

the Atlantic,” the waters of North Carolina, especially Cape Lookout, Cape Fear, Cape Hatteras, and 

Oregon Inlet, offer many opportunities for wreck diving (Thomas, 2011). For information on shipwrecks 

within the OPAREAs, see Section 3.10 (Cultural Resources).

The Monitor National Marine Sanctuary is a dive site approximately 16 mi. south-southeast of Cape 

Hatteras, North Carolina. This sanctuary was established in 1975 to protect the remains of the U.S.S.

Monitor. Maritime archaeological expeditions are conducted in the summer, and public diving at this 

site is available by permit. Waters surrounding the sanctuary are known to contain thousands of other 

shipwrecks (National Oceanic and Atmospheric Administration, 2015a).

3.11.2.3.1.6 Jacksonville Range Complex

Military Ocean Traffic

The Jacksonville and Charleston OPAREAs, within the Jacksonville Range Complex, cover 50,000 NM2 of 

sea space off the coasts of North Carolina, South Carolina, Georgia, and Florida. The Fleet Forces Atlantic 

Exercise Coordination Center is responsible for coordinating training OPAREA assignments, ranges, 

airspace, mobile sea range assets, fixed and mobile targets, the Large Area Tracking Range system, and 

electronic attack. The Fleet Forces Atlantic Exercise Coordination Center coordinates with all DoD, 

government, and civilian agencies to ensure compliance with all requirements and regulations for the 

safe use of ranges, assets, and services. The Fleet Area Control and Surveillance Facility, Jacksonville has 

authority to coordinate services and firing notices, issue weekly target and OPAREA schedules, and 

prescribe necessary additional regulations governing matters within the Jacksonville Range Complex. 

Civilian Ocean Traffic

The nearshore areas of the Jacksonville Range Complex, near the Jacksonville commercial port in 

particular, are heavily traveled. Recreational activities consist primarily of motor boating, game and 

sport fishing, jet skiing, waterskiing, shrimping, sailing, sport diving, and bird and whale watching. 

Recreational boats range throughout the coastal waters, depending on season and weather conditions. 

A commercial ferry crosses the St. Johns River between Mayport, Florida, and Fort George Island, 

Florida.
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Popular sport diving sites within the range complex consist of natural and artificial reefs. Off the South 

Carolina coast, these include shipwrecks (with about 30 wrecks in the Charleston OPAREA), as well as 

artificial and natural reefs. Popular shipwreck and submerged artificial reefs can be found at various 

depths from 13 to over 30 meters (m), both close to shore and at farther distances (Coastal Scuba, 

2007). One of the most popular dive sites off the Georgia coast is Gray’s Reef. The area is one of the 

largest nearshore live-bottom reefs of the southeastern United States (National Oceanic and 

Atmospheric Administration, 2015b). The associated Gray’s Reef National Marine Sanctuary, which is 

used little by divers because of depth, strong currents, and frequent high levels of turbidity, is 16 mi. off 

Sapelo Island, Georgia, and encompasses 22 NM2 of live-bottom habitat. Divers who do venture out to 

the sanctuary can access the reef from numerous facilities between Savannah and Brunswick, Georgia

(National Oceanic and Atmospheric Administration, 2014).

3.11.2.3.1.7 South Florida Ocean Measurement Facility Testing Range

The Naval Surface Warfare Center Carderock Division, South Florida Ocean Measurement Facility 

operates an offshore testing area in support of various Navy and non-Navy programs. The South Florida 

Ocean Measurement Facility Testing Range is adjacent to the Port Everglades entrance channel in Fort 

Lauderdale, Florida. This test area includes an extensive cable field within a restricted anchorage area, as 

well as two designated submarine OPAREAs.

The South Florida Ocean Measurement Facility Testing Range does not include identified Special Use 

Airspace. The airspace adjacent to South Florida Ocean Measurement Facility Testing Range is managed 

by the Fort Lauderdale International Airport. Air operations at the South Florida Ocean Measurement 

Facility Testing Range are coordinated with Fort Lauderdale International Airport by the air units 

involved in the test events.

3.11.2.3.1.8 Key West Range Complex

Military Ocean Traffic

The Key West OPAREA is 8,288 NM2 of offshore surface and subsurface area south of Key West, Florida

within the Straits of Florida between the United States and Cuba. Because the Key West Range Complex 

is offshore of mainland areas, air and boat travel are possible within the range complex. Commander, 

Submarine Force, U.S. Atlantic Fleet, is the Submarine Operations Control Authority for the Eastern 

Seaboard and, as such, controls all water-space management and prevention of mutual interference for 

subsurface activities in the Key West Range Complex (U.S. Department of the Navy, 2013). Units are 

required to obtain clearance for all hazardous or exclusive activities within the OPAREA from the 

Commanding Officer, Naval Air Station Key West.

Within the Key West OPAREA and warning areas, all units conducting firing or other hazardous activity 

must comply with Section 8, Chapter 1 of the U.S. Atlantic Fleet Instruction Manual 3120.26 and all Fleet 

Exercise Publications. Officers in charge of exercises are not permitted to fire munitions or jettison aerial 

targets unless the area is confirmed to be clear of non-participating civilian and military units (U.S. 

Department of the Navy, 2013). Naval Air Station Key West would coordinate with the U.S. Coast Guard 

on issuing Notices to Mariners and with the Federal Aviation Administration on issuing Notices to 

Airmen, as applicable. 

Civilian Ocean Traffic

Commercial and recreational boat traffic is common throughout the Florida Keys and the Gulf of Mexico. 

Cruise ships have regular routes in the area, and commercial fishing boats use this area frequently. 
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Commercial ferries cross the Florida Straits between Key West, Florida, and Dry Tortugas National Park, 

Florida. Additionally, dive and tourist boats cruise the waters and take visitors to the Dry Tortugas 

National Park.

Large cargo ships, including tankers and dry cargo carriers, cruise ships, fishing vessels, recreational 

vessels, and research vessels, operate in the Straits of Florida. Most of the cargo and cruise ships are 

foreign-flagged vessels, while the majority of recreational, fishing, and research vessels are domestic. 

Historically, the Straits of Florida have been the access route for all ships entering the Gulf of Mexico 

and those transiting from the north and east to the Panama Canal, making the Florida Straits one of the 

most heavily trafficked areas in the world (Roberts, 2007). According to the International Maritime 

Organization, approximately 8,000 large cargo ships and several hundred cruise ships transit the area on 

an annual basis (International Maritime Organization, 2016).

In 2002, the Florida Keys National Marine Sanctuary and surrounding waters were designated a 

Particularly Sensitive Sea Area under the International Maritime Organization (International Maritime 

Organization, 2016). As a result of this designation, some restrictions have been imposed on commercial 

maritime transit through the Straits of Florida. Commercial maritime vessels may be required to transit 

farther out to sea and within the boundaries of the Key West Range Complex.

3.11.2.3.1.9 Pierside Locations (Southeast Atlantic Area)

Three pierside locations in the southeast Atlantic area are considered in this EIS/OEIS: Naval Submarine 

Base Kings Bay, Kings Bay, Georgia; Naval Station Mayport, Jacksonville, Florida; and Port Canaveral, Port 

Canaveral, Florida.

Located near the mouth of the St. Mary’s River in Cumberland Sound, Naval Submarine Base Kings Bay is 

the east coast home to the Trident nuclear power submarines. Kings Bay is approximately 30 mi. from 

both the Port of Brunswick, Georgia, and the Port of Jacksonville, Florida. Traffic in the Cumberland 

Sound is primarily recreational boats, and some of the marine traffic in the area is submarine traffic to 

and from the Naval Submarine Base Kings Bay.

Naval Station Mayport is located where the St. Johns River meets the Atlantic Ocean. This facility is 

home to 22 U.S. Navy ships and can accommodate 34 ships in its harbor. The St. Johns River supports 

heavy recreational and commercial traffic, and it provides the Port of Jacksonville access to the Atlantic 

Ocean. Cruise lines offer passenger cruise service from the Port of Jacksonville to the Caribbean. 

Port Canaveral is the second-busiest port in the world for multiday passenger cruises, with six terminals 

exclusively for cruise passenger use (Port Canaveral, 2016). In 2016, Port Canaveral had 1,388 cruise ship 

port calls and serviced nearly 4 million passengers (American Association of Port Authorities, 2017b). In 

2015, Port Canaveral was ranked 91st in total trade, with 3.1 million tons passing through the port, and 

44th in foreign trade imports (U.S. Army Corps of Engineers, 2016). The port is shared with the Navy, 

which uses Trident Wharf and Poseidon Wharf to service U.S. Navy submarines.

3.11.2.3.1.10 Naval Surface Warfare Center, Panama City Division Testing Range

The Naval Surface Warfare Center, Panama City Division Testing Range is located off the panhandle of 

Florida and Alabama, extending from the shoreline to 120 NM seaward, and includes St. Andrew Bay. 

Special Use Airspace associated with Naval Surface Warfare Center, Panama City Division Testing Range 

includes warning areas overlying and east of the Pensacola and the Panama City OPAREAs. The warning 

areas include W-151, W-155, and W-470. This testing range includes the sea space within the Gulf of 

Mexico from the mean high tide line to 120 NM offshore.
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3.11.2.3.1.11 Gulf of Mexico Range Complex

Military Ocean Traffic

The OPAREAs associated with the Gulf of Mexico Range Complex, including the Panama City, Pensacola, 

New Orleans, and Corpus Christi OPAREAs, cover approximately 17,000 NM2 of sea space offshore of 

Florida, Alabama, Mississippi, Louisiana, and Texas. The Fleet Forces Atlantic Exercise Coordination 

Center is responsible for coordinating training OPAREA assignments, ranges, airspace, mobile sea range 

assets, fixed and mobile targets, Large Area Tracking Range, and electronic attack. The Fleet Forces 

Atlantic Exercise Coordination Center coordinates with all DoD, government, and civilian agencies to 

ensure compliance with all requirements and regulations for the safe use of ranges, assets, and services. 

The Fleet Area Control and Surveillance Facility, Jacksonville has authority to coordinate services and 

firing notices, issue weekly target and OPAREA schedules, and prescribe necessary additional regulations 

governing matters within the Gulf of Mexico Range Complex. The scheduling authority coordinates with 

the U.S. Coast Guard to issue Notices to Mariners and with the Federal Aviation Administration to issue 

Notices to Airmen, as applicable. Through close coordination, controlling authorities ensure that 

hazardous activities are carefully scheduled to avoid conflicts with civilian activities and that safety 

standards are maintained while allowing the maximum amount of civilian access to airspace and sea 

space. The Navy does not conduct as much vessel training in the Gulf of Mexico Range Complex as it 

does in other range complexes in the Study Area. Refer to Table 2.6-1 in Chapter 2 (Description of 

Proposed Action and Alternatives) for numbers of training activities expected to occur in the Gulf of 

Mexico Range Complex annually. 

Civilian Ocean Traffic

The Gulf of Mexico is heavily traveled by marine vessels, with several major commercial shipping ports 

located near U.S. Navy OPAREAs, including the ports of South Louisiana; New Orleans, Louisiana; 

Houston, Texas; and Corpus Christi, Texas. The Port of South Louisiana was the top ranked U.S. port by 

cargo tonnage with near 262 million tons of cargo processed in 2016 (American Association of Port 

Authorities, 2017a). The Port of Houston was ranked second among U.S. ports with just under 

248 million tons of total trade. Overall, 7 of the top 10 U.S. ports ranked by total trade (tonnage) in 2016 

are located in Gulf States. In addition to South Louisiana and Houston, the other five ports are New 

Orleans (fourth); Beaumont, Texas (fifth); Corpus Christi (sixth); Baton Rouge, Louisiana (eighth); and 

Mobile, Alabama (tenth) (American Association of Port Authorities, 2017a). 

Recreational activities offshore consist of game and sport fishing, charter boat fishing, sport diving, 

sailing, power cruising, and other boating activities. Commercial ferries operate off the shores of Texas 

(Corpus Christi and Galveston), Louisiana (Cameron), Mississippi (Ship Island and Gulfport), and Alabama 

(Dauphin Island and Fort Morgan). There are approximately 1.3 million recreational vessels registered in 

the Gulf States (excluding Florida vessels which were counted with southeast Atlantic states) (U.S. Coast 

Guard, 2017). The number of vessels is approximately 11 percent of all recreational vessels registered in 

the United States and is about the same as the number of vessels registered in coastal states from 

Maine to Maryland. Popular sport diving and fishing sites within the Gulf of Mexico consist of natural 

and artificial reefs, including shipwrecks. A popular diving destination in the Gulf is the Flower Garden 

Banks National Marine Sanctuary, which consists of the East and West Flower Garden Banks and Stetson 

Bank. The three areas in the 42 NM2sanctuary are approximately 130 mi. northeast of the Corpus Christi 

OPAREA and approximately 190 mi. west of the New Orleans OPAREA (National Oceanic and 

Atmospheric Administration, 2016b).
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3.11.2.3.1.12 Pierside Locations (Gulf of Mexico)

One pierside location in the Gulf of Mexico is considered in this Final EIS/OEIS. The Navy-contractor 

shipyard in Pascagoula, Mississippi, is strategically located where the Pascagoula River flows into the 

Mississippi Sound. Construction services for surface combatants, amphibious assault and transport, U.S.

Coast Guard cutters, and fleet support occur at this shipyard. The Port of Pascagoula, located at the 

mouth of the Pascagoula River, is the largest seaport in Mississippi. The port handled over 26 million 

tons of goods in 2016 and is ranked 24th in total trade and 21st in total foreign trade (imports and 

exports) among U.S. ports (American Association of Port Authorities, 2017a).

3.11.2.3.2Air Transport

Most of the airspace in the Study Area is accessible to general aviation (recreational, private, corporate) 

and commercial aircraft; however, like waterways, some areas are temporarily off limits to civilian and 

commercial use. The Federal Aviation Administration has established Special Use Airspace that refers to 

airspace of defined dimensions wherein activities must be confined because of their nature or in which 

limitations may be imposed upon aircraft operations that are not part of those activities (Federal 

Aviation Administration Order 7400.21). Special Use Airspace in the Study Area includes the following:

 Restricted Area Airspace: Areas where aircraft are subject to restriction due to the existence of 

unusual (often invisible) hazards to aircraft (e.g., release of munitions). Some areas are under 

strict control of the DoD, and some are shared with nonmilitary agencies. 

 Military Operations Area: Areas typically below 18,000 ft. used to separate or segregate certain 

nonhazardous military flight activities from instrument flight rules traffic and to identify visual 

flight rules traffic where these activities are conducted. 

 Warning Area: Areas of defined dimensions, extending from 3 NM outward from the coast of 

the United States that serve to warn non-participating aircraft of potential danger. 

 Air Traffic Controlled Assigned Airspace: Airspace established by the Federal Aviation 

Administration for the purpose of providing air traffic segregation between specified activities 

being conducted within the assigned airspace and other Instrument Flight Rules traffic.

Notices to Airmen are created and transmitted by government agencies and airport operators to alert 

aircraft pilots of any hazards en route or at a specific location. The Federal Aviation Administration 

issues Notices to Airmen to disseminate information on upcoming or ongoing military exercises with 

resulting airspace restrictions. Civilian aircraft operators are responsible for being aware of restricted 

areas in airspace and any Notices to Airmen in effect. Pilots have a duty to abide by aviation rules as 

administered by the Federal Aviation Administration.

Fleet Area Control and Surveillance Facility, Virginia Capes and Fleet Area Control and Surveillance 

Facility, Jacksonville provide instruction for training activities involving military air operations (including 

Naval Air Systems Command testing activities). Naval Surface Warfare Center, Panama City Division 

Testing Range and Naval Undersea Warfare Center Division, Newport Testing Range instructions provide 

guidance for testing activities, including air operations. The Federal Aviation Administration has 

established Special Use Airspace (Chapter 2, Description of Proposed Action and Alternatives) overlying 

the Study Area for military activities (i.e., restricted area airspace and warning areas). 

The Federal Aviation Administration has established commercial air corridors for commercial traffic. The 

use of commercial air corridors, along with the use of Notices to Airmen, provides for safe and efficient 

air traffic control.
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3.11.2.4 Commercial and Recreational Fishing

3.11.2.4.1Commercial Fishing

Commercial and recreational fishing takes place throughout much of the Study Area from waters 

adjacent to the mainland and offshore islands to offshore banks and deep waters far from land. Many 

different types of fishing gear are used by commercial and recreational fishers in the Study Area, such as 

gillnets, longline gear, troll gear, trawls, seines, traps or pots, harpoons, and hook and line (U.S. 

Department of the Navy, 2005, 2015). Many fishing activities are seasonal and occur at varying degrees 

of intensity and duration throughout the year. 

Commercial and recreational fishing is subject to state and federal regulations and laws. The U.S. Coast 

Guard enforces regulations of the U.S. commercial fishing fleet. The National Oceanic and Atmospheric 

Administration’s Office of Law Enforcement enforces domestic laws and international treaty 

requirements designed to ensure global fisheries resources are maintained at healthy levels for the

future. As part of that effort, the National Marine Fisheries Service assesses the status of fisheries stocks 

to assist marine resources managers in maintaining sustainable fisheries as well as healthy ecosystems 

and productive coastal communities. Fisheries stock assessment reports contain information on the 

status of the stock, such as the annual and historic catch, and, if a stock is depleted, the steps required 

to rebuild a healthy stock capable of sustaining commercial and recreational fisheries. 

The management of fisheries is conducted on a regional basis to allow participatory governance by 

knowledgeable people with a stake in fishery management. Eight regional fishery management councils 

are responsible for developing fishery management plans for the fisheries in their jurisdiction. The plans 

focus on the status of the fishery in waters seaward of state waters within each region. Each fishery 

management plan describes a variety of management tools, including geographic and seasonal fishery 

closures, catch limits and quotas, size and age limits, gear restrictions, and access controls to manage 

the fishery resources. Nationwide, 44 fishery management plans provide a framework for managing the 

harvest of 230 major fish stocks or stock complexes that make up 90 percent of the commercial harvest.

Other species, designated as highly migratory species in fisheries regulations, such as tunas, swordfish, 

sharks, and billfish are found throughout the Pacific Ocean and migrate across council jurisdictional 

boundaries. Regional offices of the National Marine Fisheries Service manage these species and engage 

stakeholders and governmental groups in the management of these species at both domestic and 

international levels.

Determining whether a catch is considered a commercial or recreational catch depends on how the 

catch is used. A catch is considered commercial if sold for profit at the port (e.g., to a processor). While a 

chartered recreational fishing trip results in a commercial gain for a charter boat captain, the catch is 

retained by the fisher and is not sold at the port for a profit. Therefore, the catch is considered 

recreational. Commercial fishers often target more than one species and land their catch in multiple 

ports, depending on the season, to maximize their economic return. Recreational fishers primarily use 

hook and line (also referred to as rod and reel or pole and line), and a small number also use 

spearfishing gear (Southwick Associates, 2013).

The National Marine Fisheries Service Office of Science and Technology maintains commercial landing 

data derived from comprehensive surveys of all coastal states’ landings (National Marine Fisheries 

Service, 2015c). The number of pounds of fish caught in the U.S. Atlantic region by commercial fishers

has been decreasing since a peak in 1956 (Figure 3.11-5), although the total value of fish caught has 

been steadily increasing since the early 1970s (National Marine Fisheries Service, 2015c). In 2005, the 
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price per pound for all species combined exceeded $1.00 for the first time, but then declined from 2007 

through 2009 during the economic recession. Since 2010, the value of the catch has trended upwards

(National Marine Fisheries Service, 2015c). 

Figure 3.11-5: Commercial Landings Since 1950 in Atlantic Coast States

In the Gulf of Mexico, the highest catch totals (pounds) occurred in the mid-1980s and have gradually 

declined since (Figure 3.11-6). Similar to the catch in the Atlantic, the value of commercial landings in 

the Gulf of Mexico increased steadily through the mid-1980s. With the exception of the year 2000, 

growth remained flat until 2010 and has since trended upwards, with the value of the 2014 catch 

exceeding $1 billion for the first time (National Marine Fisheries Service, 2015c). However, the value of 

the catch in 2015 and 2016 fell below $1 billion.
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Figure 3.11-6: Commercial Landings Since 1950 in Gulf Coast States

Commercial fishing occurs in federally managed waters (3–200 NM) and within state waters (out to 

3 NM; 9 NM for Texas and Florida’s west coast). Each state’s natural resources or wildlife management 

department manages fisheries in state waters using an organizational structure similar to the structure 

used by federal managers. Quotas can be placed on species at the federal or state level to manage 

landings and sustain the fishery. These may include seasonal closures or gear restrictions specific to a 

particular fishery. Table 3.11-1 shows the commercial species with the highest value in 2016 for each of 

the 18 coastal states in the Study Area. American lobster and sea scallops were the two most lucrative 

species both in the northeast and overall for all 18 coastal states. Combined these two species had a 

value of over $1 billion in 2016. Off the mid-Atlantic, blue crab is the most valuable species, and along 

the Atlantic coast from South Carolina to Florida, shrimp are the most valuable catch. In the Gulf of 

Mexico, over 1 billion pounds of menhaden were landed in Louisiana, and, combined with the total for 

Mississippi, menhaden were valued at over $140 million in 2016. Of all the species listed in Table 3.11-1, 

menhaden are the only vertebrate (“fish”) species. All other species are invertebrates, and most of 

those are benthic species (e.g., lobsters and crabs) (National Marine Fisheries Service, 2018a). Additional 

information on commercially important species is in Sections 3.4 (Invertebrates) and 3.6 (Fishes).

Table 3.11-1: Value of Top Commercial Catch in Atlantic and Gulf States, 2016

State Species Catch

(Pounds)

Value

(Dollars)

Maine American lobster 132,531,000 540,335,139

New Hampshire American lobster 5,781,837 30,370,906

Massachusetts Sea scallop 22,845,729 281,210,347

Rhode Island Longfin squid 22,508,475 28,423,823
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Table 3.11-1: Value of Top Commercial Catch in Atlantic and Gulf States, 2016 (continued)

State Species Catch

(Pounds)

Value

(Dollars)

Connecticut Sea scallops 530,242 5,880,876

New York Northern quahog (clam) 2,173,059 11,951,812

New Jersey Sea scallop 10,491,244 123,369,150

Delaware Blue crab 4,555,178 9,144,630

Maryland Blue crab 36,721,568 54,426,092

Virginia Sea scallop 4,529,495 51,325,283

North Carolina Blue crab 24,732,129 20,738,465

South Carolina Marine Shrimp 2,665,916 6,746,504

Georgia White shrimp 1,998,110 5,284,582

Florida (Atlantic coast) White shrimp 4,791,846 12,807,638

Florida (Gulf coast) Caribbean spiny lobster 5,014,422 41,249,030

Alabama Brown shrimp 12,830,091 32,760,985

Mississippi Menhaden 294,189,312 10,973,261

Louisiana Menhaden 1,068,689,545 132,105,452

Texas Brown shrimp 38,309,340 96,170,706

Source: National Marine Fisheries Service (2018a)

3.11.2.4.2Recreational Fishing

There were about 11.8 million registered recreational vessels in the United States in 2016. 

Approximately 42 percent of these vessels are registered in the 18 coastal states within the Study Area

(U.S. Coast Guard, 2017). Many of these vessels are used for saltwater sport fishing, which has long been 

one of America’s most popular recreational activities. Recreational fishing also influences the economies 

in many coastal communities by providing jobs, income, and sales. In 2015, approximately 9 million 

recreational anglers across the United States took 61 million saltwater fishing trips around the country. 

Approximately 90 percent of these recreational angler trips were off the U.S. Atlantic (56 percent) and 

Gulf (34 percent) coasts (National Marine Fisheries Service, 2016a). In 2015, 55 percent of the 

recreational catch (measured by numbers of fish) was taken from inland waters. Almost 35 percent 

came from state waters and just over 10 percent of the catch came from the U.S. territorial sea out to 

the Exclusive Economic Zone. The majority of trips in the Atlantic and Gulf of Mexico fished primarily in 

inland waters (i.e., estuaries) (National Marine Fisheries Service, 2016a).

Favored fishing areas change over time with fluctuations in fish populations and communities, preferred 

target species, or fishing modes and styles. Popular fishing sites are characterized by relative ease of 

access, ability to anchor or secure the boat, and abundant presence of target fish. Fishers focusing on 

areas of bottom relief not only catch reef-associated fish but also coastal open water species that may 

be attracted to the habitat. Popular fishing areas and dive sites are located throughout the coastal and 

nearshore waters of the Study Area and generally decrease in number with increasing distance from 

shore. Numerous fishing and diving sites are located along the Atlantic and Gulf coasts, in every state 

boarding the Study Area and in Puerto Rico and the U.S. Virgin Islands.

From 2012 through 2017, the marine recreational catch (total number of fish harvested + total released) 

in the Study Area ranged from a low of 301 million in 2017 to a peak of 413 million in 2013 (Figure

3.11-7). On average, over 60 percent of the catch is released each year. The catch has been trending 

downward since 2013, and the number of fish harvested has declined each year since 2013.
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Figure 3.11-7: Annual Recreational Catch of All Species for the 18 Coastal States (2012–2017)

The top five recreational species, measured by the total catch, in the Atlantic states between 2012 and 

2017 were black sea bass, summer flounder, Atlantic croaker, bluefish, and striped bass (National 

Marine Fisheries Service, 2018b) (Figure 3.11-8). Catch totals for Florida are included with the Gulf 

States; separate catch totals for Florida’s east and west coasts were not provided in National Marine 

Fisheries Service (2017). The species most commonly caught on Atlantic coast trips that fished primarily 

in federally managed waters (3 to 200 NM) were black sea bass, summer flounder, haddock, Atlantic 

cod, and Atlantic mackerel (National Marine Fisheries Service, 2017). Data on the total catch from only 

federal waters are not available; however, measured by the number of fish caught in all waters off the 

Atlantic coast in 2016, black sea bass ranked first (16.7 million fish), summer flounder second

(14.2 million), Atlantic mackerel seventh (6.5 million), haddock ranked 20th (1.7 million fish), and 

Atlantic cod 25th (1.2 million fish) (National Marine Fisheries Service, 2018b). Three of the top 10 

species most frequently caught in federal waters are among the most frequently caught species overall.
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Figure 3.11-8: Top Five Recreational Species Caught in the Atlantic States (2012–2017)

The top five recreational species, measured by the number of fish caught, in the Gulf states between 

2012 and 2017 were spotted seatrout, scaled sardine, pinfish, gray snapper, and hardhead catfish 

(National Marine Fisheries Service, 2018b) (Figure 3.11-9). Excluding bait fishes, the species most 

commonly caught in the Gulf of Mexico were spotted seatrout, gray snapper, hardhead catfish, red 

drum, and red snapper. The species most commonly caught on trips that fished primarily in federally

managed waters were red snapper, white grunt, red grouper, black seabass, and gray triggerfish

(National Marine Fisheries Service, 2017). Data on the total catch from only federal waters are not 

available; however, measured by the number of fish caught in all waters in the Gulf of Mexico in 2016, 

red snapper ranked eighth (4.9 million), white grunt ranked 16th (3.7 million fish), black seabass ranked 

23rd (2.2 million), gray triggerfish ranked 25th (1.9 million), and red grouper ranked 30th (1.4 million)

(National Marine Fisheries Service, 2018b). Only one species, red snapper, is among the top 10 species 

caught by recreational fishers in the Gulf of Mexico.
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Figure 3.11-9: Top Five Recreational Species Caught in the Gulf States (2012–2017)

Recreational fishing is a popular pastime in coastal areas of both the Atlantic Ocean and Gulf of Mexico. 

In 2015, more than 65.21 million residents of Atlantic coast states participated in marine recreational 

fishing. All participants, including visitors, took nearly 34 million trips and caught approximately

188 million fish. About 25 percent of the trips were made off Florida’s Atlantic coast, 14 percent off

North Carolina, almost 13 percent off New Jersey, almost 10 percent off New York, nearly 8 percent off

South Carolina shores, nearly 7 percent off Maryland, and more than 6 percent off Massachusetts. 

Together, Rhode Island, Connecticut, and Virginia, accounted for 13 percent of the trips, and Maine, 

New Hampshire, Delaware, and Georgia accounted for the remaining 4 percent of trips (National Marine 

Fisheries Service, 2016a).

In the Gulf of Mexico in 2015, nearly 2.7 million residents of Gulf Coast states participated in marine 

recreational fishing. All participants, including visitors, took 21 million trips and caught almost 

143 million fish. About 65 percent of the trips were made off Florida’s Gulf coast, nearly 12 percent off 

Louisiana, 11 percent off Alabama, more than 7 percent off Mississippi, and approximately 5 percent off

Texas shores (National Marine Fisheries Service, 2016a).

As reported above, approximately 10 percent of the recreational fishing catch is from federal waters 

(i.e., between 3 and 200 NM from shore) (National Marine Fisheries Service, 2016a). However, this 

approximation, based on the total number of fish caught, can vary considerably depending on the 

species targeted. For the top five species caught off the Atlantic and Gulf coasts in 2016, the percentage

caught in federal waters (nationally, not just in the Study Area) ranged from 0.01 percent for spotted 

seatrout to 15 percent for pinfish (Figure 3.11-10, Figure 3.11-11). Only 1 of the 10 top species caught in 

the Study Area exceeded the 10 percent national average in 2016 for the number of fish caught in 

federal waters (pinfish off the Gulf coast).
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Figure 3.11-10: Percent of Harvest in Federal Waters for Top Five Atlantic Coast Recreational 

Species (Measured By Number of Fish Caught) in 2016
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Figure 3.11-11: Percent of Harvest in Federal Waters for Top Five Gulf Coast Recreational 

Species (Measured By Number of Fish Caught) in 2016

The contribution of recreational fishing activities to the economy of coastal states is measured by state 

level impacts, including jobs, sales, income, and value added to the economy from expenditures on 

fishing trips and durable equipment. The economic impacts of recreational fishing for the five New 

England coastal states (Maine, New Hampshire, Massachusetts, Rhode Island, and Connecticut) are 

summarized in Table 3.11-2. The latest data available are from 2014.

Table 3.11-2: Economic Benefit of Recreational Fishing Expenditures in the Northeast in 2014

Economic Factor State

ME NH MA RI CT

Number of Recreational Fishing Trips (thousands) 539 252 3,397 1,099 1,364

Jobs Supported by Recreational Fishing 1,051 563 14,264 4,439 2,993

Sales (millions of dollars) 85 53 1,391 421 290

Income (millions of dollars) 36 25 688 199 138

Value-Added (millions of dollars) 56 35 996 301 216

Source: (National Marine Fisheries Service, 2016b)

Massachusetts receives the greatest economic benefit from recreational fishing in the New England 

region, followed by Rhode Island. New Hampshire benefits from recreational fishing the least, likely due 

to its relatively small expanse of coastline. 

The economic impacts of recreational fishing for the six Mid-Atlantic coastal states (New York, New 

Jersey, Delaware, Maryland, Virginia, and North Carolina) are summarized in Table 3.11-3. The latest 

data available are from 2014. New Jersey and North Carolina receive the greatest economic benefit from 

**All herrings other than Pacific herring
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recreational fishing in the Mid-Atlantic region, with over 15,000 jobs and approximately $1 billion added 

to each state’s economy. The economic benefit from recreational fishing to New Jersey’s economy is 

second only to Florida among U.S. coastal states. Delaware has the lowest economic benefit from 

recreational fishing expenditures in the region.

Table 3.11-3: Economic Benefit of Recreational Fishing Expenditures in the Mid-Atlantic 

in 2014

Economic Factor State

NY NJ DE MD VA NC

Number of Recreational Fishing Trips (thousands) 3,955 4,869 868 2,473 2,182 4,954

Jobs Supported by Recreational Fishing 9,561 19,962 1,562 7,721 5,218 16,007

Sales (millions of dollars) 976 2,037 142 727 474 1,529

Income (millions of dollars) 467 956 62 339 213 636

Value-Added (millions of dollars) 719 1,457 98 513 335 990

Source: (National Marine Fisheries Service, 2016b)

The economic impacts of recreational fishing for the southeast Atlantic coastal states (South Carolina, 

Georgia, and Florida’s Atlantic coast) are summarized in Table 3.11-4. The latest data available are 

from 2014.

Table 3.11-4: Economic Benefit of Recreational Fishing Expenditures in the Southeast Atlantic 

in 2014

Economic Factor State

SC GA FL (Atlantic)

Number of Recreational Fishing Trips (thousands) 2,221 827 9,644

Jobs Supported by Recreational Fishing 6,224 2,145 44,789

Sales (millions of dollars) 545 190 4,782

Income (millions of dollars) 220 88 2,022

Value-Added (millions of dollars) 344 136 3,122

Source: (National Marine Fisheries Service, 2016b)

As shown in Table 3.11-4, recreational fishing on the Florida’s Atlantic coast supports the greatest 

number of jobs and generates the highest sales value of all the states along the entire U.S. Atlantic 

coast. Recreational fishing in Monroe County and the City of Key West is a major generator of economic 

activity and contributes $500 million annually (National Oceanic and Atmospheric Administration, 2005). 

The diverse fishing opportunities are reflected in an abundance of tournaments offered year round. 

Fished species include sailfish, bonefish, kingfish, snook, redfish, tarpon, dolphinfish, grouper, snapper, 

blackfin tuna, marlin, wahoo, and others. Tournaments can take place on the weekends, but many occur 

during the week (Monroe County Tourist Development Council, 2010). 

The economic impacts of recreational fishing for the Gulf States (Florida’s Gulf coast, Alabama, 

Mississippi, Louisiana, and Texas) are summarized in Table 3.11-5. The latest data available are from 

2014. Florida’s Gulf coast benefits tremendously from recreational fishing, with nearly $16 billion in 

sales, income, and value added from recreational fishing expenditures. Florida’s Gulf coast recreational 

fishing industry supports more jobs and more trips that any other state bordering the Study Area. 

Excluding Florida’s Atlantic coast, Texas and Louisiana generate the third- and fourth-most sales from 

expenditures of all U.S. coastal states, respectively.
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Table 3.11-5: Economic Benefit of Recreational Fishing Expenditures in the Gulf of Mexico 

in 2014

Economic Factor

State

Florida 

(Gulf) AL MS LA TX

Number of Recreational Fishing Trips (thousands) 15,179 2,169 1,480 2,188 --

Jobs Supported by Recreational Fishing 70,109 14,124 4,174 15,241 16,496

Sales (millions of dollars) 7,468 1,071 374 1,620 1,825

Income (millions of dollars) 3,161 540 158 662 757

Value-Added (millions of dollars) 4,869 828 247 1,029 1,205

Note: (--) Data Not Available 

Source: (National Marine Fisheries Service, 2016b)

Various organizations host recreational fishing tournaments throughout the year in the 18 coastal 

states, although, recreational fishing in the New England and the Mid-Atlantic states occur primarily in 

summer and into early fall when temperatures are warmer and there are more daylight hours. Most 

tournaments take place on weekends (Friday through Sunday) or from the middle of the week through 

the weekend (Wednesday to Sunday). Most fishing takes place at hotspots like canyons and seamounts. 

It is unlikely that a substantial amount of recreational fishing occurs on the high seas (greater than 

200 NM from shore). The size of a ship capable of safely transiting into the high seas would exceed the 

size of most recreational vessels registered with the U.S. Coast Guard (U.S. Coast Guard, 2017).

3.11.2.5 Aquaculture

Aquaculture is the farming of aquatic organisms such as fish, shellfish, and plants. Aquaculture 

operations are often in coastal environments and can be on land with a nearby water source or in bays, 

estuaries, or marine waters (National Marine Fisheries Service, 2015a). The National Oceanic and 

Atmospheric Administration regulates offshore marine aquaculture and crafted the National Offshore 

Aquaculture Act of 2007, which charges National Oceanic and Atmospheric Administration with 

establishing stringent standards and coordination of offshore efforts with states (Carlowicz, 2007).

The U.S. marine aquaculture industry is relatively small compared with world aquaculture production. In 

2013, U.S. aquaculture production totaled 100 million pounds of fish, molluscs, and crustaceans valued 

at $400 million (National Marine Fisheries Service, 2015b). World aquaculture production generates

over $70 billion in annually. Only about one-third of U.S. aquaculture production is marine species. The 

largest sector of the U.S. marine aquaculture industry is molluscs (oysters, clams, mussels), which 

accounts for about two-thirds of total U.S. marine aquaculture production. Atlantic salmon is the leading 

species for marine finfish aquaculture (42 million pounds), while oysters have the highest volume 

(44 million pounds) for marine shellfish production. Shellfish aquaculture industries can be found in all 

coastal regions of the United States; the Pacific Coast states produce more shellfish by value 

($112 million), while the Gulf coast states produce more by volume (24 million pounds) (National Marine 

Fisheries Service, 2015b). Current production takes place mainly on land, in ponds, and in coastal waters 

under state jurisdiction.

Aquaculture has become a fast-growing food industry because of consumer demands. The U.S. 

Department of Agriculture maintains a database on sales value from aquaculture. In 2013, sales of 

aquaculture products in the United States accounted for $1.4 billion. The production of molluscs

(oysters, mussels, and clams) was 23 percent of the total sales, and fin fish raised as a source of food 
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(e.g., catfish and salmon) accounted for 52 percent of total sales. The 18 coastal states in the Study Area 

contributed approximately 57 percent of total aquaculture sales in 2013. These data include all 

aquaculture sales (inland, freshwater, and marine). However, the importance of the industry to the 

coastal states is evident, and saltwater aquaculture production has been increasing over the past several 

years, even as freshwater production is declining (U.S. Department of Agriculture, 2014). 

Most aquaculture farms within the Study Area are located in state waters. Based on 2013 census data 

compiled by the U.S. Department of Agriculture (2014), aquaculture operations occur in the 18 states of 

the Study Area. Florida and Massachusetts have the greatest number of saltwater farms with 169 and 

133, respectively.

Massachusetts and New Hampshire conducted aquaculture research projects in offshore federal waters. 

In 2007, both states received funding for these projects from the National Oceanic and Atmospheric 

Administration (National Oceanic and Atmospheric Administration, 2007a). The University of New 

Hampshire’s Atlantic Marine Aquaculture Center was established in 2006 after completion of the Open 

Ocean Aquaculture Demonstration Project, which in cooperation with the National Oceanic and 

Atmospheric Administration raised finfish in the open ocean for noncommercial purposes (University of 

New Hampshire, 2016). The site is located 6 NM off the coast of New Hampshire. Two projects were 

funded in Massachusetts. The Massachusetts Institute of Technology developed a self-propelled, 

open-ocean drifter for fish farming. The pilot study attempted to assess the effects of movement of the 

drifter cage on fish behavior. The second project, conducted by the Marine Biological Laboratory at 

Woods Hole, worked to condition black sea bass to respond to an acoustic signal when being fed in a

controlled, laboratory environment, so that they could be released into an open-ocean environment and 

recaptured at a later date (National Oceanic and Atmospheric Administration, 2007b). The National 

Oceanic and Atmospheric Administration continues to fund aquaculture projects in several states along 

the U.S. Atlantic and Gulf coasts (National Oceanic and Atmospheric Administration, 2016a). 

Atlantic salmon are cultivated in coastal waters off the coast of Maine. The 2011 harvest of 24 million 

pounds contributed revenue of $55 million. Maine also cultivated blue mussels, American and European 

oysters, Atlantic cod, quahogs, sea scallops, and green sea urchins (Maine Department of Marine 

Resources, 2012). The dominant industry along the northeastern coastline is shellfish production in 

estuaries, bays, and wetlands (Morse & Pietrak, 2009). The only estuary that falls in part of the 

Northeast Range Complexes is Narragansett Bay, on the north side of Rhode Island Sound. Rhode Island 

cultivates eastern oysters and northern quahogs. About 123 ac. (50 hectares) are leased for aquaculture 

production (Rice & Leavitt, 2009).

In the mid-Atlantic area, aquaculture is composed of shellfish production in estuaries, bays, and 

wetlands. In 1980, the lower Chesapeake Bay, near the Virginia Capes Range Complex, accounted for 

50 percent of the U.S. oyster harvest. However, in recent years, overharvesting and disease have 

depleted the oyster beds to less than 1 percent of their peak abundance (Kearney, 2003). States in the 

area are encouraging shellfish aquaculture to aid in the restoration (Webster et al., 2009). Virginia 

cultivates eastern oysters and hard clams using bottom cultivation. However, methods of cultivation for 

the oyster are evolving from the traditional planting on the bottom to a more intensive method using 

cages, racks, and floats (Murray & Oesterling, 2009). Virginia accounts for 30 percent of eastern oyster 

aquaculture sales (U.S. Department of Agriculture, 2014).The mine warfare training areas in the 

Chesapeake Bay are not in the immediate vicinity of shellfish aquaculture.
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Aquaculture in the southeast region includes farms for hybrid striped bass, red drum, saltwater shrimp, 

and eastern oysters. Louisiana accounts for 42 percent of all crustacean (e.g., shrimp and crabs) sold in 

the country. Combined, Alabama and Mississippi produced 43 percent of food fish sales from 

aquaculture in 2013 (U.S. Department of Agriculture, 2014).

3.11.2.6 Tourism

Coastal tourism and recreation include the full range of tourism, leisure, and recreationally oriented 

activities that take place in the coastal zone and the offshore coastal waters. These activities include 

coastal tourism development (e.g., hotels, resorts, restaurants, food industry, vacation homes, and 

second homes) and the infrastructure supporting coastal development (e.g., retail businesses, marinas, 

fishing tackle stores, dive shops, fishing piers, recreational boating harbors, beaches, and recreational 

fishing facilities). Also included are ecotourism and recreational activities such as recreational boating, 

cruises, swimming, surfing, snorkeling, diving, and sightseeing (National Oceanic and Atmospheric 

Administration, 1998).

Tourism is a component of the regional economy of coastal states included in the Study Area. Although 

there is no comprehensive database for tourism, available data show that tourist activities bring billions 

of dollars to communities within the coastal states. Benefits from tourism include direct spending as 

well as indirect benefits from contributions to key business sectors such as food, lodging, arts, culture, 

and music. The National Ocean Economics Program provides a range of socioeconomic information 

along the U.S. coast and in coastal waters. The National Ocean Economics Program defines the ocean 

economy as the economic activity that indirectly or directly uses the ocean as an input. Table 3.11-6

presents ocean economy data by state specific to the tourism and recreation sector for 2014. The table 

shows the impact of the marine tourism and recreation industry in coastal counties on states’ 

employment and gross domestic product. The impact of tourism and recreation varies widely among the 

states, from 1 percent of ocean industries in Texas up to 83 percent in New York and South Carolina 

(New York includes data from the Great Lakes region). For 15 of the 18 coastal states, the tourism and 

recreation industry accounts for more than half of ocean industry jobs. Texas and Louisiana have the 

lowest percentage of ocean industry jobs dependent on tourism and recreation. Industries associated 

with offshore mineral extraction are the largest contributor to employment and gross domestic product 

in those states (National Ocean Economics Program, 2015b).

The tourist and recreation industry surrounding recreational boating is significant along the coast of the 

Atlantic Ocean and the Gulf of Mexico. Self-contained underwater breathing apparatus (SCUBA) diving is 

a popular recreational activity in this area due to the occurrence of numerous reefs and shipwrecks. 

Typical considerations for recreational self-contained underwater breathing apparatus (SCUBA) divers 

relevant to all portions of the Study Area are dive depth limitations. Specifically, the Professional 

Association of Diving Instructors (one of several scuba diving instructional organizations) suggests that 

certified open-water divers limit their dives to 60 ft. More experienced divers are generally limited to 

100 ft. (Professional Association of Diving Instructors, 2011). Many shipwrecks and artificial reefs that 

are popular diving spots in Florida are at depths ranging from 50 to 90 ft. (Associated Oceans LLC, 2011).

Marine mammal watching, often referred to as whale watching, includes any cetacean species such as 

dolphins, whales, and porpoises. Tours are conducted by boat, aircraft, or from land. This type of marine 

tourism includes any of these activities, formal or informal, that possess at least some commercial 

component whereby consumers view, swim with, or listen to any of these approximately 83 cetacean 
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species (Hoyt, 2001). Cruises for seal watching are also available in Maine (New Harbor), Massachusetts 

(Cape Cod), and Rhode Island (Newport) and Connecticut (Groton, Stony Creek, and Niantic).

Hoyt conducted the most recent, comprehensive survey of the whale-watching industry (Hoyt, 2001). In 

the northeast, the industry focuses on the various whales summering in waters off New England. Whale 

watching occurs in 22 communities in New England. The majority of operations occur within 

Massachusetts, where 17 operators conduct whale watching out of popular ports such as Gloucester, 

Provincetown, Boston, Barnstable, and Plymouth. The 25-year focus of whale watching on the 

Stellwagen Bank area contributed to its popularity and helped establish the Gerry E. Studds Stellwagen 

Bank National Marine Sanctuary, which sits at the mouth of Massachusetts Bay. In the southeast, 

concentrations of the whale watching industry are highest in Hilton Head Island, South Carolina; St. 

Petersburg, Florida; Panama City, Florida; and Jupiter, Florida. Numerous single operators exist in cities 

extending along the entire west coast of Florida, all the way to Key West. During a comprehensive 

survey, approximately 4.3 million people participated in the industry, contributing nearly $357 million in 

sales to operators of whale watching tours (Hoyt, 2001).

Table 3.11-6: Ocean Economy Data for the Tourism and Recreation Sector by State, 2014

State

Gross Domestic 

Product: Tourism 

and Recreation

(Dollars)

Percent of all 

Ocean Industries 

Gross Domestic 

Product

Tourism and 

Recreation 

Employment

(Number of 

Jobs)

Percent of all 

Ocean Industries 

Employment

Alabama 507,870,525 22 15,138 56

Connecticut 1,519,176,670 36 34,032 72

Delaware 577,779,055 73 17,530 87

Florida 16,822,577,569 66 365,831 84

Georgia 518,405,327 42 14,847 62

Louisiana 1,882,346,306 8 45,116 41

Maine 1,176,551,058 48 29,785 65

Maryland 2,741,572,336 42 64,976 72

Massachusetts 3,078,180,777 51 67,117 79

Mississippi 400,452,144 23 13,221 43

New Hampshire 279,656,760 20 6,931 51

New Jersey 3,117,260,812 40 82,392 68

New York* 18,296,430,382 83 285,525 91

North Carolina 1,076,758,010 60 36,468 88

Rhode Island 1,365,241,796 68 32,967 83

South Carolina 2,645,396,646 83 61,175 90

Texas 1,470,544,931 1 43,584 22

Virginia 1,809,539,194 22 58,669 51

Shows percent of tourism and recreation employment and gross domestic product compared to all other ocean 

industries: construction, living resources, minerals, ship and boat building, transportation, and tourism and 

recreation. 

*Includes data from counties adjacent to the Great Lakes.

Source: National Ocean Economics Program (2015b)

3.11.3 ENVIRONMENTAL CONSEQUENCES

This section evaluates how and to what degree the activities described in Chapter 2 (Description of 

Proposed Action and Alternatives) could impact socioeconomic resources of the Study Area. Tables 2.6-1

through 2.6-4 present the baseline and proposed training and testing activity locations for each 
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alternative including the number of events occurring annually and over a five-year period. Each 

socioeconomic resource stressor is introduced, analyzed by alternative, and analyzed for training and 

testing activities. Appendix B (Activity Stressor Matrices) shows the stressors that were considered for 

analysis of socioeconomic resources. The stressors vary in intensity, frequency, duration, and location 

within the Study Area. The primary stressors applicable to socioeconomic resources in the Study Area 

and that are analyzed include the following:

 Accessibility (availability of access on the ocean and in the air)

 Airborne acoustics (weapons firing, aircraft, and vessel noise)

 Physical disturbance and strikes (aircraft, vessels and in-water devices, military expended 

materials)

Secondary stressors resulting in indirect impacts on socioeconomic resources are discussed in 

Section 3.11.4 (Secondary Stressors). This section evaluates the impacts of the alternatives on the 

economy of the region of influence as well as social impacts. The evaluation addresses how the action 

alters the way individuals live, work, play, relate to one another, and function as members of society. 

Because proposed AFTT activities are predominantly offshore, socioeconomic impacts would be 

associated with economic activity, employment, income, and social conditions (i.e., enjoyment and 

quality of life) of industries or operations that use the ocean resources within the Study Area. Although

there are no permanent population centers in the region of influence and the typical socioeconomic 

considerations such as population, housing, and employment are not applicable, this section will analyze 

the potential for economic impacts on marine-based activities and coastal communities. When 

considering impacts on recreational activities such as fishing, boating, and tourism, both the economic 

impact associated with revenue from recreational tourism and public enjoyment of recreational 

activities are considered.

The proposed AFTT training and testing activities were evaluated to identify specific components that 

could act as stressors by directly or indirectly affecting sources of energy generation, mineral extraction, 

commercial transportation and shipping, commercial and recreational fishing, aquaculture, and tourism. 

For each stressor, a discussion of impacts on these sources is included for each alternative. The analysis 

includes consideration of mitigations that the Navy will implement to the benefit of high-value 

socioeconomic resources in the Study Area. 

The evaluation indicated that the relative potential for socioeconomic impacts would be similar across 

various areas and marine ecosystems in the Study Area. Therefore, the analysis of environmental 

consequences was not broken down by large marine ecosystem. Based on an initial screening of 

potential impacts of sonar maintenance and testing, pierside locations have been eliminated from 

detailed consideration in the analysis of impacts on energy, mineral extraction, and transportation and 

shipping. Elimination of these resources was based on the extremely limited potential for active sonar to 

damage infrastructure or interfere with transportation operations.

3.11.3.1 Impacts on Accessibility

Navy training and testing activities have the potential to temporarily change access to the ocean or 

airspace for a variety of human activities associated with sources of energy generation, mineral 

extraction, commercial transportation and shipping, commercial and recreational and fishing, 

aquaculture, tourism, and other recreational activities in the Study Area. Warning Areas, Restricted 

Areas, and Danger Zones are designated along the Atlantic and Gulf coasts. These designated areas are 
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shown in Figure 3.11-12 through Figure 3.11-15. These small areas may be used for especially hazardous 

activities and are defined to prohibit or limit public access to the area. They generally provide security or 

protection for the public from risks of damage or injury arising from activities occurring in that area. 

Danger zones and restricted areas listed in the CFR and presented by section number in Figure 3.11-12

through Figure 3.11-15 may be closed to the public full time or intermittently, as stated in the 

regulations (33 CFR section 334). 

When training or testing activities are scheduled that require specific areas to be free of 

non-participating vessels and aircraft due to public safety concerns, the Navy requests that the U.S. 

Coast Guard and Federal Aviation Administration issue Notices to Mariners and Notices to Airmen, 

respectively, to warn the public of upcoming Navy activities. Many training and testing activities occur in 

established restricted areas or danger zones as published on navigational and aeronautical charts. Some 

frequently used areas have standing Notices to Mariners and Notices to Airmen to allow real-time, 

immediate use.

Limits on accessibility to certain areas of the Study Area due to Navy training and testing would 

essentially remain unchanged from the current conditions. If access by the public to an area is hindered 

to the extent that equipment (e.g., fishing gear) cannot be monitored or used, then there would be an 

impact if this condition would directly contribute to loss of income, revenue, or employment. 

Disturbance to human activities associated with payrolls, revenue, or employment is quantified by the 

amount of time the activity may be halted or rerouted and the ability to perform the task in 

another location.

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. Many of the restricted areas identified on 

these figures are artifacts of past military activities and are not currently scheduled (e.g., Small Point 

Mining Range off the coast of Maine).

Accessibility, or restrictions to the availability of air and ocean space, would be a temporary condition. 

While mariners and pilots have a responsibility to be aware of conditions on the ocean and in the air, it 

is not expected that direct conflicts in accessibility would occur. The locations of restricted areas are 

published and available to mariners and pilots, who typically review such information before boating or 

flying in any area. Restricted areas are typically avoided by experienced mariners and pilots. Prior to 

initiating a training activity, the Navy would follow standard operating procedures to visually scan an 

area to ensure that nonparticipants are not present. If nonparticipants are present, the Navy delays, 

moves, or cancels its activity. Accessibility is no longer restricted once the activity concludes. In addition, 

project review and approval processes for many ongoing and planned offshore projects in the Study 

Area (i.e., oil and gas leasing, and wind energy projects) have integrated Navy input and review to 

reduce the potential for conflicts to air and ocean space. Therefore, there would be minimal potential 

for access to the ocean and airspace to directly impact human activities.

The Federal Aviation Administration is responsible for all of the national airspace, and the DoD and the 

Federal Aviation Administration cooperate in managing the airspace used by the military to support training 

and testing requirements. Special Use Airspace (Military Operations Areas and Restricted Areas over land, 

and Warning Areas over the ocean) is scheduled by the military and is released to the Federal Aviation 

Administration when not in use by the military. For special use airspace that is below 18,000 ft., non-military 

air routes already overlay Special Use Airspace. The Navy accommodates the needs of commercial and 

civilian aviation by maintaining a working relationship with the Federal Aviation Administration.
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Notes: (1) AFTT: Atlantic Fleet Training and Testing; OPAREA: Operating Area (2) The numerical labels refer to the part of 33 CFR 

Section 334 defining the danger zone or restricted area

Figure 3.11-12: Danger Zones and Restricted Areas in the Northeast Atlantic Ocean
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Notes: (1) AFTT: Atlantic Fleet Training and Testing; OPAREA: Operating Area; VACAPES: Virginia Capes; SINKEX: Sinking Exercise 

(2) The numerical labels refer to the part of 33 CFR Section 334 defining the danger zone or restricted area

Figure 3.11-13: Danger Zones and Restricted Areas in the Mid-Atlantic Ocean
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Notes: (1) AFTT: Atlantic Fleet Training and Testing; OPAREA: Operating Area (2) The numerical labels refer to the part of 33 CFR 

Section 334 defining the danger zone or restricted area

Figure 3.11-14: Danger Zones and Restricted Areas in the Southeast Atlantic Ocean and 

Eastern Gulf of Mexico
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Notes: (1) AFTT: Atlantic Fleet Training and Testing; OPAREA: Operating Area (2) The numerical labels refer to the part of 33 CFR 

Section 334 defining the danger zone or restricted area

Figure 3.11-15: Danger Zones and Restricted Areas in the Western Gulf of Mexico
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3.11.3.1.1Impacts on Socioeconomic Activities from Limiting Accessibility

3.11.3.1.1.1 Sources of Energy Production and Distribution

Water

Water-related energy generation facilities are planned in state waters along the east coast, and 

preliminary permits have been issued by the Federal Energy Regulatory Commission for production of 

renewable energy (tidal and wave energy), including a residential tidal energy project for underwater 

turbines along the shoreline near the shipyard in Bath, Maine. In accordance with the 2010 

Memorandum of Understanding between the U.S. Department of Agriculture and the U.S. Navy (U.S. 

Department of the Navy, 2010), the Navy participates in the siting and review of renewable energy 

projects by sharing technical information with the objective of ensuring compatibility and minimizing 

conflicts in shared space. Research and testing activities by academic institutions for water energy 

technology is conducted along the Atlantic coast and Florida and would continue to be conducted in 

consideration of existing restricted areas on the ocean. Therefore, access to water-related sources of 

energy generation in the Study Area would not be hindered and there would be no change to operations 

during AFTT training or testing activities.

Wind

While the United States has no offshore wind energy generating capacity at this time, such projects are 

in the early planning stages. The U.S. Department of the Interior has approved an ocean lease to Cape 

Wind Associates, LLC to construct 130 wind turbines in Nantucket Sound within the Study Area. There 

are no Navy activities at or immediately near the Cape Wind Associates, LLC lease blocks. Access to this 

future wind energy site would not be hindered, and there would be no change to operations during 

AFTT training or testing activities. 

Similar projects have been proposed along the East Coast. In November 2010, the Department of the 

Interior announced the “Smart from the Start” initiative to accelerate development of wind energy 

along the Atlantic Outer Continental Shelf. The initiative calls for the identification of areas on the 

Atlantic Outer Continental Shelf that appear most suitable for commercial wind energy and for the 

opening of these areas for leasing and site assessment. Areas from Maine to Florida have been 

identified for offshore wind energy development. The resultant wind energy areas will be developed and 

refined through extensive consultation with other federal agencies, to include the Navy and the 

Intergovernmental Renewable Energy Task Force of each affected state. 

Future offshore wind energy projects projected along the Atlantic coast and Florida will be proposed and 

developed in consideration of existing DoD restricted area airspace and sea space required in support of 

military operations. Therefore, access to future offshore wind energy sites would not be hindered, and 

there would be no change to operations during AFTT training or testing activities.

Oil and Gas Production

While there are many oil and natural gas leases and an extensive oil and natural gas pipeline network in 

the Gulf of Mexico, conflicts with military activities are avoided through cooperative efforts between the 

DoD and oil and gas operators. Because the DoD plays an active role in the oversight of proposed oil and 

gas lease areas on the outer continental shelf, lease areas would generally not be approved in, or in 

conflict with, established or otherwise restricted offshore military use areas. In cases where such areas 

are leased, stipulations to the leases are established to resolve conflicts. Future oil and natural gas 

production interests along the Atlantic coast and Gulf of Mexico would operate in consideration of 

existing restricted areas on the ocean and in the air. Therefore, access to future oil and natural gas 
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infrastructure would not be hindered, and there would be no change to operations during AFTT training 

or testing activities.

3.11.3.1.1.2 Mineral Extraction

Mineral extraction sites operate with the use of vessels and equipment that traverse the open ocean or 

are stationary (e.g., suction hopper dredges). Extraction of sand and gravel can be accomplished with 

the use of submerged or floating pipelines. Any changes in accessibility to offshore sites would not be 

expected to result in rerouting of vessels or postponing of operations. Any changes in accessibility for 

sand and gravel mining, or borrow sites, would have a short-term duration (typically one and one-half to 

four hours per location). Direct impacts on mineral extraction activities would be negligible.

3.11.3.1.1.3 Commercial Transportation and Shipping

There are no anticipated impacts on commercial shipping activities in the Study Area since naval vessels 

conducting hazardous activities generally occur away from commercially used waterways.

Any direct impacts on private civilian transportation activities from rerouting or postponing activities 

would be negligible due to advance public notification through the use of Notices to Mariners and 

Notices to Airmen and the primarily short-term duration (typically one and one-half to four hours per 

location) of military activities.

3.11.3.1.1.4 Commercial and Recreational Fishing

Favored fishing areas change over time with fluctuations in fish populations and communities, preferred 

target species, or fishing modes and styles. Popular fishing sites are characterized by relative ease of 

access (most recreational fishing trips occur in state waters), ability to anchor or secure the boat, and 

abundant presence of target fish. Impacts on commercial and recreational fishing may result when Navy 

activities restrict access to fishing areas or if Navy activities cause fish to abandon a popular fishing site. 

Refer to Section 3.6.3.1.1.4 (Physiological Stress) in Section 3.6 (Fishes) for analysis and discussion of 

potential population-level impacts Navy training and testing may have on fishes. The Navy strives to 

conduct its operations in a manner compatible with commercial and recreational ocean users by 

minimizing temporary access restrictions. Notices to Mariners allow commercial and recreational fishing 

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 fishing are minimal 

because the majority of fishing 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 fishing 

activities would be noticeably affected by Navy activities requiring area restrictions. 

3.11.3.1.1.5 Aquaculture

As discussed for commercial and recreational fishing, the federal government, through the U.S. Army 

Corps of Engineers, U.S. Coast Guard, U.S. Fish and Wildlife Service, the National Marine Fisheries 

Service, and U.S. Environmental Protection Agency, implements an assurance that U.S. navigational 

routes are maintained when approving aquaculture lease stipulations. Thus, it is assumed that whenever 

possible, close coordination between all users of the waterway would be required under the 

aquaculture lease stipulations. Navy activities that could impact aquaculture would not be planned close 

to inshore or offshore areas with aquaculture activities. 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, there would be no direct effect on the use of remotely operated feed 
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buoys at the University of New Hampshire offshore demonstration site or on divers who monitor the 

growth cages at shellfish or vegetation aquaculture sites. 

3.11.3.1.1.6 Tourism

Tourism activities make an appreciable contribution to the overall economy within the Study Area. The 

Navy strives to conduct its operations in a manner compatible with recreational ocean users by 

minimizing temporary access restrictions. Published notices allow recreational users to adjust their 

routes to avoid temporary restricted areas. 

Mariners and pilots engaged in tourism-related activities have a responsibility to be aware of conditions 

on the ocean and in the air. The locations of restricted areas are published and available to mariners and 

pilots, who typically review such information before boating or flying in any area. Restricted areas are 

typically avoided by mariners and pilots. The Navy would follow standard operating procedures to 

visually scan an area to ensure that nonparticipants are not present. If nonparticipants are present, the 

Navy delays, moves, or cancels its activity. Accessibility is no longer restricted once the activity 

concludes. Any changes to accessibility of air and ocean space would be a temporary condition for 

marine-related tourist and recreational activities. The revenues listed in Tables 3.11-2 through 3.11-5

would not be impacted by limiting access because restrictions on access would be temporary. The 

proposed activities would not lead to a noticeable change in Navy presence, and the proposed locations 

for these activities do not differ much from historical use; therefore, it is unlikely tourism would be 

noticeably affected by Navy activities requiring area restrictions.

The Navy has received comments on previous EISs expressing concern that marine mammals could be 

extirpated from areas where they have been observed or otherwise available for whale watching and 

similar recreational or tourist activities. As described in detail in Section 3.7 (Marine Mammals), Navy 

training and testing has been occurring in the same areas for decades, and there are no data or other 

information to indicate that populations of any marine mammals, including those popular with whale 

watchers, have been or would be affected. This assessment is based on four indicators from areas in the 

Pacific where Navy training and testing has continued for decades: (1) evidence suggesting or 

documenting increases in the numbers of marine mammals present in areas where Navy operates, 

(2) examples of documented presence and site fidelity of species and long-term residence by individual 

animals of some species, (3) use of training and testing areas for breeding and nursing activities, and 

(4) eight years of comprehensive monitoring data indicating a lack of any observable effects to marine 

mammal populations as a result of Navy training and testing activities. Therefore, no effects on wildlife 

viewing and other wildlife-dependent recreational activities and no economic effects on tourism (such 

as whale watching) and related businesses dependent on observing wildlife in their natural habitats are

anticipated.

3.11.3.1.1.7 Impacts on Accessibility under Alternative 1

Impacts on Accessibility under Alternative 1 for Training Activities

Under Alternative 1, potential accessibility issues would be associated primarily with air warfare, surface 

warfare, anti-submarine warfare, mine warfare, amphibious warfare, and expeditionary warfare. 

Training activities in these warfare areas would continue at current levels and within established ranges 

and training locations, including the Virginia Capes, Navy Cherry Point, Jacksonville, Key West, and Gulf 

of Mexico Range Complexes and Other AFTT Areas. There would be no anticipated impacts on energy 

production, mineral extraction, commercial transportation and shipping, commercial and recreational 

fishing, aquaculture, or tourism because inaccessibility to areas of co-use would be temporary and of 
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short duration (typically one and one-half to four hours per location). Based on the Navy’s standard 

operating procedures and the large expanse of the training ranges, accessibility issues would be

negligible.

Impacts on Accessibility under Alternative 1 for Testing Activities

Under Alternative 1, potential accessibility issues would be associated primarily with air warfare, surface 

warfare, anti-submarine warfare, mine warfare, amphibious warfare, expeditionary warfare, sea trials, 

shock trials, and other weapons platform testing. Testing activities would continue at current levels and 

within established training and testing ranges, including the Northeast, Virginia Capes, Navy Cherry 

Point, Jacksonville, Key West, and Gulf of Mexico Range Complexes; Naval Undersea Warfare Center 

Division, Newport Testing Range; Naval Surface Warfare Center, Panama City Testing Range; and Other 

AFTT Areas. There would be no anticipated impacts on energy production, mineral extraction, 

commercial transportation and shipping, commercial and recreational fishing, aquaculture, or tourism 

because inaccessibility to areas of co-use would be temporary and of short duration (typically one and 

one-half to four hours per location). Based on the Navy’s standard operating procedures and the large 

expanse of the training ranges, accessibility impacts would be negligible.

3.11.3.1.1.8 Impacts on Accessibility under Alternative 2

Alternative 2 consists of the activities described under Alternative 1 but with a nominal increase in the 

use of some sonar systems, explosives, and associated vessel and aircraft activity. The locations of these 

activities would remain the same as described under Alternative 1. Alternative 2 also includes the 

training and testing of personnel required for proficiency with these systems. 

Impacts on Accessibility under Alternative 2 for Training Activities

Under Alternative 2, potential accessibility issues would be the same as those associated with 

Alternative 1. There would be no changes to the Navy’s standard operating procedures for public access 

to ocean and airspace. There would be no anticipated impacts from Alternative 2 training activities on

energy production, mineral extraction, commercial transportation and shipping, commercial and 

recreational fishing, aquaculture, or tourism, because inaccessibility to areas of co-use would be 

temporary and of short duration (typically one and one-half to four hours per location). Based on the 

Navy’s standard operating procedures and the expansion of the Study Area, accessibility issues would be

minor.

Impacts on Accessibility under Alternative 2 for Testing Activities

Under Alternative 2, potential accessibility issues would be the same as those associated with 

Alternative 1. Testing of some sonar systems would increase nominally within the Study Area. There 

would be no changes to the Navy’s standard operating procedures for public access to testing ranges 

and other areas used for testing. There would be no anticipated impacts from Alternative 2 testing 

activities on energy production, mineral extraction, commercial transportation and shipping, 

commercial and recreational fishing, aquaculture, or tourism because inaccessibility to areas of co-use 

would be temporary and short duration (typically one and one-half to four hours per location). Based on 

the Navy’s standard operating procedures and the expansion of the Study Area, accessibility issues 

would be minor.

3.11.3.1.1.9 Impacts on Accessibility under the No Action Alternative

Under the No Action Alternative, the Navy would not conduct the proposed training and testing 

activities in the AFTT Study Area. Various accessibility stressors (e.g., limits on access to desirable fishing 
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locations) would not be introduced into the marine environment. Training and testing activities have 

occurred throughout the Study Area for decades, resulting in and sustaining increases in jobs, military 

and civilian infrastructure, and population growth in numerous towns, cities, and regions located along 

the Atlantic and Gulf coasts. While it is reasonable to assume that ceasing training and testing activities 

associated with the Proposed Action would make certain areas where the Navy has conducted training 

and testing more accessible (i.e., available to the public more often), Navy OPAREAs and testing ranges 

are used for other purposes and would likely remain in place for the foreseeable future. Military 

activities would continue to occur in some of the same areas. Furthermore, the Navy has implemented a 

number of methods to communicate upcoming activities that would result in temporary restrictions on 

access to training and testing areas. These methods, which include Notices to Mariners, Notices to 

Airmen, broadcasts on marine band radio, website postings, and direct communication with the public 

through media and local organizations, serve to reduce impacts of limits on accessibility.

Ceasing training and testing activities may reduce the number and types of jobs available in locations 

where the Navy is a vital or even the primary economic driver sustaining local communities. For 

example, the use of munitions and other equipment used for training and testing activities under the 

Proposed Action would no longer be needed and, consequently, the number of jobs supporting those 

industries may be reduced or, alternatively, some jobs may be relocated. The secondary effects from

reducing personnel who support Navy training and testing activities could include a decline in local 

business and a decrease in the need for infrastructure, such as schools. If jobs are relocated, a smaller 

population may no longer be able to sustain the local economy that developed to support the larger 

population. While more complex studies at the local level would need to be conducted to quantify 

potential socioeconomic impacts from ceasing training and testing activities, it is highly likely that many 

coastal communities would be impacted.

3.11.3.1.2Summary of Potential Impacts on Accessibility

Access restrictions in the Navy training and testing areas would be temporary, and these conditions 

would return to normal upon completion of training and testing activities. These conditions would not 

result in a direct loss of income, revenue, employment, resource availability, or quality of experience.

3.11.3.2 Impacts from Airborne Acoustics

As an environmental stressor, loud noises, sonic booms, and vibrations generated from Navy training 

and testing activities such as weapons firing, in-air explosions, and aircraft transiting have the potential 

to disrupt wildlife and humans in the Study Area. The public might intermittently hear noise from ships 

or aircraft overflights if they are in the general vicinity of a training or testing event, but there would be 

no impact on public health and safety because of the infrequency and duration of events (Section 3.12, 

Public Health and Safety). 

3.11.3.2.1Impacts on Socioeconomic Activities from Airborne Acoustics

Airborne noise would not impact energy production and distribution, mineral extraction, commercial 

transportation and shipping, or aquaculture. Based on the analysis of impacts from the Proposed Action, 

fish would not experience substantial impacts from airborne acoustics (Section 3.6, Fishes). Marine 

invertebrates (Section 3.4, Invertebrates), also important commercial fishery resources, would not be 

affected by airborne acoustics because most marine species are limited in their ability to detect airborne 

sound. Therefore, airborne noise from Navy activities would not impact the availability of commercially 

and recreationally valuable species.
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Noise interference could decrease public enjoyment of recreational activities. These effects would occur 

on a temporary basis, only when weapons firing, in-air explosions, and aircraft transiting occur. Of these 

activities, Navy activities involving weapons firing and in-air explosions would only occur when the Navy 

can confirm the area is clear of commercial and recreational boaters and other nonparticipants, 

reducing the likelihood these activities would be a disturbance. 

An aircraft traveling at supersonic speeds has the potential to generate sonic booms heard at ground 

level. A sonic boom is the “thunder-like” noise a person on the ground hears when an aircraft flies 

overhead faster than the speed of sound (i.e., supersonic). Not all supersonic flights generate sonic 

booms that are detectable on the ground. When a sonic boom reaches ground level it may vary widely 

in intensity. The factors that influence the occurrence and intensity of a sonic boom include the weight, 

size, and shape of the aircraft; the altitude, attitude, and flight path of the aircraft; and the weather or 

atmospheric conditions where the boom is generated and at ground level. 

Sonic booms shall not be intentionally generated below 30,000 ft. of altitude unless over water and 

more than 30 NM from inhabited coastal areas or islands, although deviation from these guidelines may 

be authorized for tactical missions that require supersonic speeds, phases of formal training requiring 

supersonic speeds or research, test and operational suitability test flights that require supersonic speeds 

(U.S. Department of the Navy, 2016). Supersonic test flights regularly occur in airspace, referred to as 

the supersonic Test Track, located at least 3 NM offshore and within W-386 in the Virginia Capes Range 

Complex. The test track extends along the coastline of the Delmarva Peninsula, which separates the 

Chesapeake Bay to the west and the Atlantic Ocean to the east, and includes portions of Delaware, 

Maryland, and Virginia. The majority of supersonic flights are in support of Naval Air Systems Command 

Research Development Acquisition Testing & Evaluation activities, but Navy training flights may also use 

the Test Track. In addition, other military aircraft and even commercial test flights have used the Test 

Track in the past. Supersonic test flights in the Test Track are conducted under highly controlled 

conditions to enable the collection of empirical data that are used to evaluate the performance, 

reliability, and safety of new aircraft systems under high airspeed conditions. 

NAVAIR has received noise complaints from coastal residents in Virginia, Maryland, Delaware and as far 

north as New Jersey, associated with 15 Navy supersonic flights over a three-year period, for an average 

of five supersonic flights per year. Therefore, due to the infrequent occurrence of sonic booms, they are 

unlikely to deter a resident or tourist from participating in a recreational activity (e.g., a fishing trip) in 

near shore or offshore areas. Most naval aircraft training and testing would occur well out to sea, while 

civilian recreational activities are concentrated within a few miles of shore, resulting in minimal overlap 

and negligible impacts. Tourism and recreational activity revenue (Table 3.11-6) is not expected to be 

impacted by airborne noise.

3.11.3.2.1.1 Impacts from Airborne Acoustics under Alternative 1

Impacts from Airborne Acoustics under Alternative 1 for Training Activities

Under Alternative 1, potential airborne noise impacts would be associated primarily with air warfare, 

surface warfare, anti-submarine warfare, mine warfare, and amphibious warfare. Training activities in 

these warfare areas would continue at current levels and within established ranges and training 

locations, including the Northeast, Virginia Capes, Navy Cherry Point, Jacksonville, Key West, and Gulf of 

Mexico Range Complexes. There would be no anticipated impacts on energy production and 

distribution, mineral extraction, commercial transportation and shipping, commercial and recreational 

fishing, and aquaculture, because acoustic conditions would have no effect on these activities and the 
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training area would be free of nonparticipants. Navy operational procedures and practices are already in 

place to avoid impacts on civilian activities in the training areas. Navy training activities producing 

airborne noise typically occur infrequently and have a short duration (hours). Therefore, airborne noise 

impacts on tourism and recreational activity would be negligible.

Impacts from Airborne Acoustics under Alternative 1 for Testing Activities

Under Alternative 1, potential airborne noise impacts would be associated primarily with air warfare, 

surface warfare, anti-submarine warfare, mine warfare, amphibious warfare, sea trials, and other 

weapons platform testing. Testing activities would continue at current levels and within established 

training and testing ranges, including the Northeast, Virginia Capes, Navy Cherry Point, Jacksonville, Key 

West, and Gulf of Mexico Range Complexes; Naval Undersea Warfare Center Division, Newport Testing 

Range; and Naval Surface Warfare Center, Panama City Division Testing Range. There would be no 

anticipated impacts on energy production and distribution, mineral extraction, commercial 

transportation and shipping, commercial and recreational fishing, and aquaculture, because acoustic 

conditions would have no effect on these activities and the testing area would be free of 

nonparticipants. Navy operational procedures and practices are already in place to avoid impacts on

civilian activities in the testing areas. Navy testing activities producing airborne noise typically occur 

infrequently and have a short duration (hours).

When the airspace is available and testing requirements allow, supersonic flights are scheduled offshore 

to avoid potential impacts from sonic booms. However, in some instances, supersonic flights cannot be 

moved due to mission requirements or airspace congestion. Since atmospheric conditions can affect the 

intensity of a sonic boom, the wind speed, wind direction, air temperature, and atmospheric pressure 

are all monitored prior to a supersonic testing event to help determine the likelihood that a sonic boom 

would be detected at ground level. However, atmospheric conditions can change rapidly in the offshore 

environment, which can affect the intensity of a sonic boom at ground level. While the pre-flight check 

of atmospheric conditions may have indicated that there would be a low probability of a sonic boom 

reaching the coastline, if conditions change during the flight an unexpectedly intense sonic boom may 

be detected at ground level. To help limit impacts from supersonic test flights, test pilots receive annual 

noise mitigation training to maintain their awareness of the potential noise impacts resulting from their 

flights. Based on the analysis presented in the sections above, any infrequent and brief airborne noise 

impacts on tourism and recreational activity would be negligible.

3.11.3.2.1.2 Impacts from Airborne Acoustics under Alternative 2

Alternative 2 consists of the activities described under Alternative 1 but with a nominal increase in the 

use of some sonar systems, explosives, and associated vessel and aircraft activity. The locations of these 

activities would remain the same as described under Alternative 1. Alternative 2 also includes the 

training and testing of personnel required for proficiency with these systems. 

Impacts from Airborne Acoustics under Alternative 2 for Training Activities

Under Alternative 2, airborne noise issues would be the same as those associated with Alternative 1, 

with the exception of a nominal increase in vessel and aircraft activity associated with an increase in the 

use of some sonar systems. However, the increase in airborne noise would be negligible. There would be 

no anticipated impacts from Alternative 2 training activities on energy production and distribution, 

mineral extraction, commercial transportation and shipping, commercial and recreational fishing, 

aquaculture, or tourism, because acoustic conditions would have no effect on these activities and the 

training area would be free of nonparticipants. Navy operational procedures and practices are already in 
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place to avoid impacts on ongoing activities in the testing areas. Navy training activities producing 

airborne noise typically occur infrequently and have a short duration (hours). Therefore, airborne noise 

impacts on tourism and recreational activity would be negligible.

Impacts from Airborne Acoustics under Alternative 2 for Testing Activities

Under Alternative 2, airborne noise issues would be the same as those associated with Alternative 1, 

with the exception of a nominal increase in vessel and aircraft activity associated with an increase in the 

use of some sonar systems and explosives. However, the increase in airborne noise would be negligible. 

There would be no anticipated impacts from Alternative 2 testing activities on energy production and 

distribution, mineral extraction, commercial transportation and shipping, commercial and recreational 

fishing, and aquaculture, because acoustic conditions would have no effect on these activities and the 

testing area would be free of nonparticipants. Navy operational procedures and practices are already in 

place to avoid impacts on ongoing activities in the testing areas. Navy testing activities producing 

airborne noise typically occur infrequently and have a short duration (hours). Therefore, airborne noise 

impacts on tourism and recreational activity would be negligible.

3.11.3.2.1.3 Impacts from Airborne Acoustics under the No Action Alternative

Under the No Action Alternative, the Navy would not conduct the proposed training and testing 

activities in the AFTT Study Area. Various airborne acoustic stressors (e.g., noise affecting tourism) 

would not be introduced into the marine environment. Training and testing activities have occurred 

throughout the Study Area for decades, resulting in and sustaining increases in jobs, military and civilian

infrastructure, and population growth in numerous towns, cities, and regions located along the Atlantic 

and Gulf coasts. While it is reasonable to assume that ceasing training and testing activities associated 

with the Proposed Action would reduce airborne noise, the effect would be negligible, because other 

commercial and non-military activities (e.g., shipping and recreational boating) that produce airborne 

noise occur at a higher tempo and closer to shore than Navy training and testing activities.

Ceasing training and testing activities may reduce the number and types jobs available in locations 

where the Navy is a vital or even the primary economic driver sustaining local communities. For 

example, the use of munitions and other equipment used for training and testing activities would no 

longer be needed and, consequently, the number of jobs supporting those industries may be reduced or 

alternatively, some jobs may be relocated. The secondary effects from reducing personnel who conduct 

and support Navy training and testing activities could include a decline in local business and a decrease 

in the need for infrastructure, such as schools. If jobs are relocated, a smaller population may no longer 

be able to sustain the local economy that developed to support the larger population. While more 

complex studies at the local level would need to be conducted to quantify potential socioeconomic 

impacts from ceasing training and testing activities, it is highly likely that many coastal communities 

would be impacted.

3.11.3.2.2Summary of Potential Impacts from Airborne Acoustics

Because the majority of Navy training and testing activities are conducted far from where tourism and 

recreational activities are concentrated, the impact of airborne noise would be negligible. The public 

might intermittently hear noise from transiting ships or aircraft overflights if they are in the general 

vicinity of a training or testing activity, but these occurrences would be infrequent. The infrequent 

exposure to airborne noise would not result in a direct loss of income, revenue or employment, 

resource availability, or quality of experience.
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3.11.3.3 Physical Disturbance and Strike Stressors

The evaluation of impacts on socioeconomic resources from physical stressors focuses on direct physical 

encounters or collisions with objects moving through the water or air (e.g., vessels, aircraft, unmanned 

devices, and towed devices), dropped or fired into the water (non-explosive practice munitions, other 

military expended materials, and seafloor devices), or resting on the ocean floor (anchors, mines, and 

targets) that may damage or encounter civilian equipment. Physical disturbances that damage 

equipment and infrastructure could disrupt the collection and transport of products, which may impact 

industry revenue or operating costs.

Navy training and testing equipment and vessels moving through the water could collide with non-Navy 

vessels and equipment. Most of the training and testing activities involve vessel movement and use of 

towed devices. However, the likelihood that a Navy vessel would collide with a non-Navy vessel is 

remote, because of the use of navigational aids or buoys separating vessel traffic, shipboard lookouts, 

radar, and marine band radio communications by both Navy and civilians. Therefore, the potential to 

impact commercial transportation and shipping by physical disturbance or strike is negligible and 

requires no further analysis.

Aircraft conducting training or testing activities in the Study Area operate in designated military special 

use airspace (e.g., warning areas, military operations areas, and restricted areas). All aircraft, military 

and civilian, are subject to Federal Aviation Administration regulations, which define permissible uses of 

designated airspace, and are implemented to control those uses. These regulations are intended to 

accommodate the various categories of aviation, whether military, commercial, or general aviation. By 

adhering to these regulations, the likelihood of civilian aircraft coming into contact with military aircraft 

or munitions is remote. In addition, Navy aircraft follow procedures outlined in Navy air operations 

manuals, which are specific to a warning area or other special use airspace, and which describe 

procedures for operating safely when civilian aircraft are in the vicinity.

Military expended materials can physically interact with civilian equipment and infrastructure. Many of 

the training and testing activities use military expended materials including chaff, flares, projectiles, 

casings, target fragments, missile fragments, rocket fragments, ballast weights, and mine shapes.

3.11.3.3.1Impacts on Socioeconomic Activities from Physical Disturbance and Strike 

Stressors

3.11.3.3.1.1 Sources of Energy Production and Distribution

The evaluation of impacts on energy production and distribution in the Study Area from physical 

disturbances or strikes focuses on objects moving through the water or air, dropped into the water, or 

resting on the ocean floor that may damage equipment or otherwise inhibit production. Military 

expended materials that damage equipment and infrastructure could disrupt energy production and 

distribution, which may impact industry revenue and operating costs. The Navy does not perform 

activities that would release military expended materials near known, submerged equipment or 

infrastructure. Therefore, the probability that Navy activities would disrupt energy production and 

distribution or damage infrastructure by physical strikes would be negligible.

3.11.3.3.1.2 Mineral Extraction

Similar to the potential impacts on sources of energy production, physical disturbances or strikes could 

damage equipment and inhibit extraction processes. Military expended materials that inadvertently 

snag, entangle, or damage sand and gravel extraction equipment or disrupt the sand and gravel 
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extraction process may impact industry revenue and operating costs. The Navy implements standard 

operating procedures for clearing training and testing areas before initiating hazardous activities. Navy 

activities that expend materials that ultimately reside on the seafloor are typically conducted in offshore 

waters beyond the location of accessible sand and gravel sources. If military expended materials were 

encountered during the extraction process, they would first encounter the dragheads, which are the 

first point of contact with bottom materials on a suction dredger. The dragheads and the extraction 

process are designed with the expectation that debris may be encountered during the extraction 

process. The dragheads aid in filtering out debris to reduce the likelihood of a blockage from debris 

encountered during the dredging or extraction process. The Navy would avoid conducting training and 

testing in areas of mineral extraction, and it is unlikely that military expended materials from training 

and testing activities would be transported onto sand and gravel sources. Therefore, the potential for 

Navy activities to disrupt or disturb mineral extraction vessels or equipment by physical disturbances or 

strikes would be negligible.

3.11.3.3.1.3 Commercial Transportation and Shipping

There would be no anticipated impacts on commercial transportation activities in the Study Area, 

because naval vessels and aircraft conducting training and testing generally conduct these activities far 

from commercially used waterways and airways. While physical disturbances or strikes could damage 

commercial marine vessels or aircraft, the Navy implements standard operating procedures for clearing 

training and testing areas of all nonparticipants before initiating hazardous activities. Therefore, the 

potential for Navy activities to disrupt or disturb commercial vessels or aircraft by physical disturbances 

or strikes would be negligible.

3.11.3.3.1.4 Commercial and Recreational Fishing

The majority of commercial and recreational fishing in the Study Area takes place in state waters, less 

than 3 NM from shore, where the Navy conducts very limited training and testing activities. 

Approximately 10 percent of fish caught during recreational fishing trips are caught in federal waters, 

which extend seaward beyond 3 NM from shore (9 NM for Texas, Puerto Rico, and Florida’s Gulf coast). 

Therefore, most recreational fishing would occur far from physical disturbances and strikes associated 

with training and testing activities. Some commercial fishing may occur beyond state waters in Navy 

training and testing areas and could be affected by the proposed activities if those activities were to 

alter fish population levels in those areas to such an extent that commercial fishers would no longer be 

able to find their target species. As described in Section 3.6.3 (Fishes, Environmental Consequences), the 

behavioral responses that could occur from various types of physical stressors associated with training 

and testing activities would not compromise the general health or condition of fishes or populations of

fishes.

Section 3.6.3 (Fishes, Environmental Consequences) also evaluated potential impacts on fish habitat 

from physical disturbances, strikes (by small-, medium-, and large-projectiles), and the use of 

electromagnetic and towed devices. Physical disturbances and strikes would be concentrated within 

designated gunnery box areas, resulting in localized disturbances of hard bottom areas, but could occur 

anywhere in the Study Area. Direct and indirect impacts on the fishes using hard bottom habitat in the 

Study Area could occur. The use of electromagnetic devices would not harm fishes, result in behavioral 

responses, or affect habitat. The use of towed devices may result in short-term and localized movement 

of fishes to avoid the device; however, long-term avoidance of an area is not anticipated. Impacts on 

populations of fishes in the Study Area would not be expected, and, therefore, loss of revenue or 
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employment by commercial fishers would not occur. No impacts on recreational fishing in the Study 

Area would be anticipated.

Commercial fishing activities have the potential to be impacted by military equipment placed in the 

water column or on the seafloor for use during Navy training and testing activities. This equipment could

include ship anchors; moored or bottom-mounted targets, mines, and mine shapes; bottom-mounted 

tripods; and the use of towed system and attachment cables. Many different types of commercial 

fishing gear are used in the Study Area, including gillnets, longline gear, troll gear, trawls, seines, and 

traps or pots. Bottom fishing gear is the most common type of fishing gear used in the Study Area and is 

used to capture some of the most valued species (Table 3.11-1), and commercial bottom-fishing 

activities, such as dredging, bottom trawling, long lines, and pots and traps have the greatest potential 

to be impacted by materials expended during training and testing activities and that ultimately reside on 

the seafloor. For example, military expended materials, such as decelerators/parachutes, cables, and 

guidance wires, would ultimately sink to the seafloor and could inadvertently snag, entangle, and 

damage fishing equipment. Interaction with bottom-fishing gear could result in the loss of or damage to 

commercial fishing gear and Navy equipment. If events such as these were to occur, they could result in

loss of income, revenue, and employment. Entanglement by fiber optic cables and guidance wires 

expended during training and testing activities would not result in destruction or adverse modification 

of fish habitat and is unlikely to be encountered by commercial fishers. Even if encountered, fiber optic 

cables are brittle and are likely to break easily if entangled with fishing gear.

The Navy recovers many of the targets (e.g., mines and mine shapes) and target fragments used in 

training and testing activities, and would continue to do so to minimize the potential for interaction with 

fishing gear and fishing vessels. Unrecoverable items are typically small, constructed of soft materials 

(e.g., cardboard boxes or tethered target balloons), or are intentionally designed to sink to the bottom 

after serving their purpose (such as expended 55-gallon steel drums), so that they would not represent a 

collision risk to vessels, including commercial fishing vessels. Although larger expended items, such as 

55-gallon drums, may pose a risk to certain types of fishing gear used for bottom fishing, the probability 

of encountering such an item is remote given the large area over which expended materials would be 

distributed; the depth of the water where most activities using expended materials would occur; and 

the tendency for larger, heavier materials to become embedded in soft sediments, making them less 

likely to be snagged by fishing gear.

Based on the large size of the Study Area, the limited areas of concentrated military activity, and the 

advance release of Notices to Mariners prior to conducting activities, impacts on commercial or 

recreational fishing from physical disturbances and strikes in the Study Area would be rare; were they to 

occur, they would have a negligible economic impact on the commercial or recreational fishing

industries.

3.11.3.3.1.5 Aquaculture

There are no anticipated direct impacts from physical stressors on the aquaculture industry, because 

there are no aquaculture farms in any of the range complexes or testing ranges, the directional 

waterways used by naval vessels, or the training areas in the Chesapeake Bay. There is a limited 

possibility that physical disturbances on the ocean floor such as ship anchoring, expended material 

residing on the seafloor, moored mines, bottom-mounted tripods, and the use of towed systems and 

attachment cables could inadvertently damage aquaculture gear. However, the shallow water, 
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nearshore locations of most aquaculture activities would not coincide with the locations of training and 

testing activities that have the potential to impact aquaculture. 

3.11.3.3.1.6 Tourism

While Navy training and testing activities can occur throughout the Study Area, most (especially 

hazardous) activities occur well out to sea. Most civilian recreational activities engaged in by both 

tourists and residents take place within a few miles of land or in many cases along the shoreline.

Recreational diving and snorkeling activities within the Study Area take place primarily at known diving 

sites, including shipwrecks and artificial reefs. The locations of these popular sites are well documented, 

boats are typically well marked, and diver-down flags would be visible from, and avoided by, Navy ships 

conducting training and testing activities. As a result, conflicts between training and testing activities 

within the offshore areas and recreational diving and snorkeling would not occur. 

Other tourism activities such as whale watching, boating, or use of other watercraft or aircraft may 

occur farther offshore. Activities occurring farther from shore would usually be conducted from larger 

boats that are typically well marked and visible to Navy ships conducting training and testing activities. 

Individual boaters engaged in tourism activities such as whale watching monitor navigational 

information to avoid Navy training and testing areas. Vessel operators are responsible for being aware 

of designated danger zones in surface waters and any Notices to Mariners that are in effect. Operators 

of recreational or commercial vessels are responsible for abiding by U.S. Coast Guard maritime 

regulations. In conjunction with these responsibilities, Navy standard operating procedures require Navy 

vessels to ensure that an area is clear of nonparticipants before initiating training and testing activities. 

Conflicts between Navy training and testing in offshore areas and whale watching or other offshore 

recreational activities would not occur. The Navy would continue to recover larger pieces of targets used 

in certain training and testing activities so that target debris would not pose a collision risk to civilian 

vessels. Unrecoverable pieces of targets are typically small, constructed of soft materials such as 

cardboard, are pieces of a tethered target balloons, or are designed to sink to the seafloor after use and 

would not damage civilian vessels if encountered.

Changes to offshore tourism activities in the Study Area would not be expected, and, therefore, loss of 

revenue or employment associated with tourism would not be expected as a result of training and 

testing activities. 

3.11.3.3.1.7 Impacts from Physical Disturbance and Strike Stressors under

Alternative 1

Impacts from Physical Disturbance and Strike Stressors under Alternative 1 from Training 

Activities

Under Alternative 1, potential physical disturbance and strike impacts would be associated primarily 

with air warfare, surface warfare, anti-submarine warfare, mine warfare, and amphibious warfare. 

Training activities in these warfare areas would continue at current levels and within established ranges 

and training locations, including the Northeast, Virginia Capes, Navy Cherry Point, Jacksonville, Key 

West, and Gulf of Mexico Range Complexes. 

There would be no anticipated impacts on energy production and distribution, mineral extraction, 

commercial transportation and shipping, commercial and recreational fishing, aquaculture, or tourism, 

because of the large size of the Study Area, the limited areas of operations, and implementation of the 

Navy’s standard operating procedures, which includes ensuring that an area is clear of all 

non-participating vessels before training activities take place. In addition, the Navy provides advance 
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notification of training activities to the public through Notices to Mariners and postings on Navy 

websites. Damage to or loss of commercial equipment, such as fishing gear, energy production 

equipment, and mineral extraction equipment, from interaction with Navy vessels, equipment, or other 

expended materials is unlikely. The Navy recovers many practice munitions (e.g., mines and mine 

shapes) for reuse following the activity. The Navy also recovers larger floating objects or materials, such 

as targets or target fragments, to avoid having them become hazards to navigation. Smaller objects that 

remain in the water column would be unlikely to pose a risk to commercial equipment. Furthermore, 

the Navy will implement mitigation to avoid impacts from explosives and physical disturbance and strike 

stressors on seafloor resources in mitigation areas throughout the Study Area (Section 5.4.1, Mitigation 

Areas for Seafloor Resources). The mitigation areas will benefit shallow-water coral reefs, live hard 

bottom, artificial reefs, and shipwrecks, which are valuable components of the snorkeling, diving, and 

fishing industries. Considering the expansive size of the Navy’s OPAREAs, the disbursement of military 

expended materials over these large areas, and the Navy’s standard operation procedures and existing 

mitigation measures (Chapter 5, Mitigation), impacts from physical disturbances and strikes on energy 

production and distribution, mineral extraction, commercial transportation and shipping, commercial 

and recreational fishing, aquaculture, and tourism would be negligible.

Impacts from Physical Disturbance and Strike Stressors under Alternative 1 from Testing 

Activities

Under Alternative 1, potential physical disturbance and strike would be associated primarily with air 

warfare, surface warfare, anti-submarine warfare, mine warfare, amphibious warfare, sea trials, and 

other weapons platform testing. Testing activities would continue at current levels and within 

established training and testing ranges, including the Northeast, Virginia Capes, Navy Cherry Point, 

Jacksonville, Key West, and Gulf of Mexico Range Complexes; Naval Undersea Warfare Center Division, 

Newport Testing Range; and Naval Surface Warfare Center, Panama City Division Testing Range. 

There would be no anticipated impacts on energy production and distribution, mineral extraction, 

commercial transportation and shipping, commercial and recreational fishing, aquaculture, or tourism, 

because the Navy’s standard operating procedures require that a testing area is clear of nonparticipants 

before initiating testing activities. Furthermore, the Navy will implement mitigation to avoid impacts 

from explosives and physical disturbance and strike stressors on seafloor resources in mitigation areas 

throughout the Study Area (Section 5.4.1, Mitigation Areas for Seafloor Resources). The mitigation areas 

will benefit shallow-water coral reefs, live hard bottom, artificial reefs, and shipwrecks, which are 

valuable components of the snorkeling, diving, and fishing industries. Considering the expansive size of 

the Navy’s OPAREAs and testing ranges, the wide distribution of military expended materials over these 

large areas, implementation of standard operating procedures and mitigation, and impacts from 

physical disturbances and strikes on commercial and recreational fishing, the likelihood of a physical 

disturbance or strike disrupting commercial or recreational activities in the Study Area would be 

negligible. Therefore, loss of revenue or employment changes to socioeconomic activities and resources 

in the Study Area would not be expected.

3.11.3.3.1.8 Impacts from Physical Disturbance and Strike Stressors under

Alternative 2

Alternative 2 consists of the activities described under Alternative 1 but with a nominal increase in the 

use of some sonar systems and explosives associated vessel and aircraft activity. The locations of these 

activities would remain the same as described under Alternative 1. Alternative 2 also includes the 

training and testing of personnel required for proficiency with these systems. 
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Impacts from Physical Disturbance and Strike Stressors under Alternative 2 from Training 

Activities

Under Alternative 2, potential physical disturbance and strike impacts would be the same as described 

under Alternative 1, with the exception of a nominal increase in vessel and aircraft activity associated 

with an increase in the use of some sonar systems. However, the increase in the probability of a physical 

disturbance or strike would be negligible. There would be no anticipated impacts on energy production 

and distribution, mineral extraction, commercial transportation and shipping, commercial and 

recreational fishing, aquaculture, or tourism, because of the large size of the Study Area, the limited 

areas of operations, and implementation of the Navy’s standard operating procedures, which includes 

ensuring that an area is clear of all non-participating vessels before training activities take place. In 

addition, the Navy provides advance notification of training activities to the public through Notices to 

Mariners and postings on Navy websites. Damage to or loss of commercial equipment, such as fishing 

gear, energy production equipment, and mineral extraction equipment, from interaction with Navy 

equipment or other expended materials is unlikely. The Navy recovers many practice munitions 

(e.g., mines and mine shapes) for reuse following the activity. The Navy also recovers larger floating 

objects or materials, such as targets or target fragments, to avoid having them become hazards to 

navigation. Smaller objects that remain in the water column would be unlikely to pose a risk to 

commercial equipment. Considering the expansive size of the Navy’s OPAREAs, the disbursement of 

military expended materials over these large areas, and the Navy’s standard operation procedures and 

mitigation measures (Chapter 5, Mitigation), impacts from physical disturbances and strikes on energy 

production and distribution, mineral extraction, commercial transportation and shipping, commercial 

and recreational fishing, aquaculture, and tourism would be negligible.

Impacts from Physical Disturbance and Strike Stressors under Alternative 2 from Testing 

Activities

Under Alternative 2, potential physical disturbance and strike impacts would be the same as described 

under Alternative 1, with the exception of a nominal increase in vessel and aircraft activity associated 

with an increase in the use of some sonar systems and explosives. However, the increase in the 

probability of a physical disturbance or strike would be negligible. There would be no anticipated 

impacts on energy production and distribution, mineral extraction, commercial transportation and 

shipping, commercial and recreational fishing, aquaculture, or tourism, because of the large size of the 

Study Area, the limited areas of operations, and implementation of the Navy’s standard operating 

procedures, which includes ensuring that an area is clear of all non-participating vessels before testing 

activities take place. In addition, the Navy provides advance notification of testing activities to the public 

through Notices to Mariners and postings on Navy websites. Damage to or loss of commercial 

equipment, such as fishing gear, energy production equipment, mineral extraction equipment, from 

interaction with Navy equipment or other expended materials is unlikely. The Navy recovers many 

practice munitions (e.g., mines and mine shapes) for reuse following the activity. The Navy also recovers 

larger floating objects or materials, such as targets or target fragments, to avoid having them become 

hazards to navigation. Smaller objects that remain in the water column would be unlikely to pose a risk 

to commercial equipment. Considering the expansive size of the Navy’s OPAREAs, the disbursement of 

military expended materials over these large areas, and the Navy’s standard operation procedures and 

mitigation measures (Chapter 5, Mitigation), impacts from physical disturbances and strikes energy 

production and distribution, mineral extraction, commercial transportation and shipping, commercial 

and recreational fishing, aquaculture, and tourism would be negligible.
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3.11.3.3.1.9 Impacts from Physical Disturbance and Strike Stressors under the No 

Action Alternative

Under the No Action Alternative, the Navy would not conduct the proposed training and testing 

activities in the AFTT Study Area. Various physical disturbance and strike stressors (e.g., disruption to 

fishing) would not be introduced into the marine environment. Training and testing activities have 

occurred throughout the Study Area for decades, resulting in and sustaining increases in jobs, military 

and civilian infrastructure, and population growth in numerous towns, cities, and regions located along 

the Atlantic and Gulf coasts. While it is reasonable to assume that ceasing training and testing activities 

associated with the Proposed Action would reduce the potential for disruption of civilian activities from 

physical disturbances or strikes, the effect would be negligible, because the likelihood of a disturbance, 

as described under Alternative 1, is already negligible.

Ceasing training and testing activities may reduce the number and types of jobs available in locations 

where the Navy is a vital or even the primary economic driver sustaining local communities. For 

example, the use of munitions and other equipment used for training and testing activities would no 

longer be needed, and, consequently, the number of jobs supporting those industries may be reduced 

or, alternatively, some jobs may be relocated. The secondary effects from reducing personnel who 

support Navy training and testing activities could include a decline in local business and a decrease in 

the need for infrastructure, such as schools. If jobs are relocated, a smaller population may no longer be 

able to sustain the local economy that developed to support the larger population. While more complex 

studies at the local level would need to be conducted to quantify potential socioeconomic impacts from 

ceasing training and testing activities, it is highly likely that many coastal communities would be 

impacted to varying degrees.

3.11.3.3.2Summary of Potential Impacts from Physical Disturbance and Strike Stressors

Because the majority of Navy training and testing activities are conducted far from where commercial 

and recreational activities are concentrated, the potential for a physical disturbance or strike would be 

negligible. The public might intermittently observe a transiting ship or aircraft flying overhead if they are 

in the general vicinity of a training or testing activity, but these occurrences would be infrequent and of 

short duration. The Navy does not typically train or test in areas close to civilian infrastructure and 

activities and, based on the Navy’s standard operating procedures and the large expanse of the testing 

and training ranges, the likelihood of a physical disturbance or strike disrupting commercial or 

recreational activities in the Study Area would be negligible. Therefore, loss of revenue or employment 

changes to socioeconomic activities and resources in the Study Area would not be expected.

3.11.4 SECONDARY STRESSORS

Socioeconomics could be indirectly impacted by training and testing activities if changes to physical and 

biological resources were to alter the way energy production and distribution, mineral extraction, 

commercial transportation and shipping, commercial and recreational fishing, aquaculture, or tourism 

were conducted.

Impacts on sediment and water quality, fishes, invertebrates, and marine mammals were considered to 

be potential secondary stressors to socioeconomic resources. Impacts on sediment and water quality

have the potential to affect habitat for fishes and invertebrates that are of vital importance to the 

commercial fishing industry, as well as recreational fishes and aquaculture and the local industries that 

support those activities. A portion of the tourism industry is also dependent on coastal and 

marine-based activities in both the Atlantic and Gulf coast regions and could be affected by impacts on 
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fisheries. No indirect or secondary impacts on energy production and distribution and commercial 

transportation and shipping are anticipated.

Mineral extraction activities could be impacted if training and testing activities alter marine habitats in a 

way that reduces the availability of sand for beach nourishment projects. Long-term deposition of Navy 

expended materials on the ocean bottom was examined as a condition that could diminish availability of 

suitable sand for extraction. Mineral extraction operations could also be impacted if there were 

increases in costs due to the need to find alternate sites or if removal of military expended materials 

from active sites was required before extraction could commence. Because of the large size of the Study 

Area, the availability of offshore mineral resources along the Atlantic and Gulf coasts, and the likelihood 

that training and testing activities that expend materials would occur farther offshore, loss of revenue 

would not be expected. As discussed in Section 3.2 (Sediments and Water Quality), military expended 

materials would not impact sediment quality and availability or the cost of extracting mineral resources. 

Therefore, there would be no indirect socioeconomic impacts associated with training and testing 

activities on mineral extraction. 

Commercial and recreational fishing, aquaculture, and tourism could be impacted if the proposed

training and testing activities impacted fish or invertebrate populations to such an extent that species 

abundance was no longer sufficient to support these socioeconomic activities. Disturbances to marine 

mammal populations that result in abandonment of areas where whales are known to occur could 

impact the whale watching industry. However, no secondary impacts on socioeconomic resources would 

occur based on the results of analyses presented in Sections 3.4 (Invertebrates), 3.6 (Fishes), and 3.7

(Marine Mammals). These sections concluded that there would be no population-level impacts on 

marine species from training and testing activities, including from the use of sonar and other 

transducers. Therefore, indirect or secondary impacts on energy production and distribution, mineral 

extraction, commercial transportation and shipping, commercial and recreational fishing, aquaculture, 

and tourism are not anticipated.

3.11.5 SUMMARY OF POTENTIAL IMPACTS ON SOCIOECONOMICS

This section evaluates the potential impacts on socioeconomic resources from all stressors combined. 

The analysis and conclusions for the potential impacts from each of the individual stressors are 

discussed in the sections above. Stressors associated with Navy training and testing activities do not 

typically occur in isolation but rather occur in some combination. For example, anti-submarine warfare 

activities can include elements of airborne acoustics, physical disturbance and strike, and accessibility 

restrictions that are all coincident in space and time. An analysis of the combined impacts of all stressors 

considers the potential consequences of aggregate exposure to all stressors and the repetitive or 

additive consequences of exposure over multiple years. The stressors from the proposed training and 

testing activities that have the potential to impact socioeconomic resources include limits on 

accessibility to air and sea space within the Study Area, airborne acoustics, physical disturbances and 

strikes, and indirect impacts resulting from availability of resources (e.g., mineral resources and

fisheries). 

3.11.5.1 Combined Impacts of All Stressors under Alternative 1

Under Alternative 1, training and testing activities would be widely dispersed throughout the Study 

Area, limiting the potential for co-occurrence of stressors from multiple training or testing activities 

being conducted at the same time but in a different location. Certain training and testing activities may 

return to a specific geographic location to use its unique physical characteristics. Repeatedly using the 
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3.11 Socioeconomics

same area may limit accessibility to that area for commercial or recreational activities relative to a lessfrequently used area. The Navy typically uses established ranges, warning areas, and danger zones for 

training and testing activities that are conducted repeatedly over time. Many commercial and 

recreational users in the region are familiar with the locations of Navy activities, which allows for better 

planning and fewer instances of conflict. When an area needs to be temporarily closed to the public, the 

Navy notifies the public through Notices to Mariners and Notices to Airmen issued by the U.S. Coast 

Guard and the Federal Aviation Administration, respectively, ahead of time to avoid potential conflicts 

with the public. If multiple, incompatible training or testing activities need to use a specific location, the 

activities would not be scheduled at the same time, and stressors associated with each activity would 

not occur at the same time. Therefore, an increase in impacts resulting from a combination of stressors 

occurring simultaneously is not expected.

3.11.5.2 Combined Impacts of All Stressors under Alternative 2

The number and types of training and testing activities that would be conducted under Alternative 2 is 

similar to those described under Alternative 1 (see Chapter 2, Description of Proposed Action and 

Alternatives). Therefore, the combined impacts of all stressors under Alternative 2 would be the same as 

described under Alternative 1. 

3.11.5.3 Combined Impacts of All Stressors under the No Action Alternative

Under the No Action Alternative, the Navy would not conduct the proposed training and testing 

activities in the AFTT Study Area. Therefore, training and testing activities would not limit accessibility to 

air and sea space (although other Navy activities would still use established ranges, warning areas, and 

danger zones), generate airborne noise, or cause physical disturbances and strikes. No impacts on 

socioeconomic resources from these stressors would occur.

Ceasing the proposed training and testing activities may reduce the number and types of jobs available 

in locations where the Navy is a vital or even the primary economic driver sustaining local communities. 

For example, the use of munitions and other equipment used for training and testing activities would no 

longer be needed, and, consequently, the number of jobs supporting those industries may be reduced 

or, alternatively, some jobs may be relocated. The secondary effects from reducing personnel who 

support Navy training and testing activities could include a decline in local business and a decrease in 

the need for infrastructure, such as schools. If jobs are relocated, a smaller population may no longer be 

able to sustain the local economy that developed to support the larger population. While more complex 

studies at the local level would need to be conducted to quantify potential socioeconomic impacts from 

ceasing training and testing activities, it is highly likely that many coastal communities would be 

impacted to varying degrees.
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Table of Contents

Final

Environmental Impact Statement/Overseas Environmental Impact Statement 

Atlantic Fleet Training and Testing

TABLE OF CONTENTS

3.12 Public Health and Safety .......................................................................................3.12-1

3.12.1 Introduction ......................................................................................................3.12-1

3.12.2 Affected Environment.......................................................................................3.12-2

3.12.2.1 General Background .........................................................................3.12-2

3.12.2.2 Safety and Inspection Procedures....................................................3.12-4

3.12.3 Environmental Consequences ..........................................................................3.12-8

3.12.3.1 In-Water Energy................................................................................3.12-9

3.12.3.2 In-Air Energy ...................................................................................3.12-12

3.12.3.3 Physical Interactions.......................................................................3.12-13

3.12.3.4 Secondary (Sediments and Water Quality) ....................................3.12-16

3.12.4 Summary of Potential Impacts on Public Health and Safety ..........................3.12-17

3.12.4.1 Combined Impacts of All Stressors Under Alternative 1 ................3.12-17

3.12.4.2 Combined Impacts of All Stressors Under Alternative 2 ................3.12-17

3.12.4.3 Combined Impacts of All Stressors Under the No Action 

Alternative......................................................................................3.12-17

List of Figures

This section does not contain figures.

List of Tables

This section does not contain tables.
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3.12 Public Health and Safety

3.12 PUBLIC HEALTH AND SAFETY

3.12.1 INTRODUCTION

This section provides the analysis of potential impacts on public health and safety within the Atlantic 

Fleet Training and Testing (AFTT) Study Area. 

The affected environment provides the context for evaluating the effects of the Navy training and 

testing on public health and safety. Generally, the greatest potential for a proposed activity to impact 

the public is in nearshore areas because that is where public activities are most concentrated. Proposed 

training and testing in nearshore areas could be close to dive sites and other recreational areas where 

the collective health and safety of groups of individuals would be of concern. Most commercial and 

recreational marine activities (with the exception of commercial shipping) occur close to the shore, 

usually limited by the capabilities of the vessel or equipment used. 

The Navy employs standard operating procedures to provide for the safety of personnel and equipment 

as well as the success of the training and testing activities. Standard operating procedures designed to 

prevent public health and safety impacts are discussed in detail in Section 2.3.3 (Standard Operating 

Procedures). The following subsections discuss established safety protocols and standard operating 

procedures associated with the sea space and airspace environment, as well as specific procedures 

associated with aviation safety, submarine navigation safety, surface vessel navigation safety, sonar 

safety, electromagnetic energy safety, and munitions safety. 

Methods

The requirements for public health and safety were derived from federal regulations, Department of 

Defense (DoD) directives, and Navy instructions for training and testing. The directives and instructions 

provide specifications for mission planning and execution, including criteria for public health and safety 

considerations. 

PUBLIC HEALTH AND SAFETY SYNOPSIS

The United States Department of the Navy considered all potential stressors that public health and safety 

could potentially be exposed to from the Proposed Action. The following conclusions have been reached 

for the Preferred Alternative (Alternative 1):

 In-Water Energy: Because of the Navy’s standard operating procedures, impacts on public health 

and safety would be unlikely.

 In-Air Energy: Because of the Navy’s standard operating procedures, impacts on public health and 

safety would be unlikely.

 Physical Interactions: Because of the Navy’s standard operating procedures, impacts on public 

health and safety would be unlikely.

 Secondary Stressors (sediments and water quality): Because water and sediment quality impacts 

would be minimal and temporary and the Navy would not exceed state or federal water quality 

standards, impacts on public health and safety would be unlikely.
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3.12 Public Health and Safety

The Study Area is shared by 

military, commercial, institutional, 

and recreational users. The Navy is 

committed to ensuring public 

safety during training and testing 

activities. To protect public safety, 

access to certain ocean areas must 

be temporarily limited during 

certain training and testing 

activities.

The alternatives were evaluated based on two factors: the potential for specific training or testing 

activities to impact public health and safety and the degree to which those activities could have an 

impact. The likelihood that members of the public would be near a training or testing activity 

determined the potential for exposure to the activity. If the potential for exposure existed, the degree of 

the potential impacts on public health and safety, including increased risk for injury or loss of life, was 

determined. If the potential for exposure did not exist, it was determined that there would be no 

impacts on public health and safety.

3.12.2 AFFECTED ENVIRONMENT

3.12.2.1 General Background

The area of interest for assessing potential impacts on public 

health and safety is the U.S. territorial waters of the east and 

Gulf coasts (seaward of the mean high water line to 12 nautical 

miles [NM]), including bays, harbors, and inshore waterways of 

the east coast where training and testing occur. Military, 

commercial, institutional, and recreational activities take place 

simultaneously in the Study Area and have coexisted safely for 

decades. These activities coexist safely because established rules 

and practices lead to safe use of the waterways and airspace. 

The following paragraphs briefly discuss the rules and practices 

for recreational, commercial, and military use in sea surface areas and airspace. 

3.12.2.1.1 Sea Space

Most of the sea space in the Study Area is accessible for recreational and commercial activities; 

however, some activities are prohibited or restricted in certain areas (e.g., danger zones and restricted 

areas). 

In accordance with Title 33 Code of Federal Regulations (CFR) part 165 (Regulated Navigation Areas and 

Limited Access Areas), these restrictions can be permanent or temporary. Nautical charts issued by the 

National Oceanic and Atmospheric Administration include these federally designated zones and areas. 

Operators of recreational and commercial vessels have a duty to abide by maritime regulations 

administered by the U.S. Coast Guard.

In accordance with 33 CFR part 72 (Aids to Navigation), the U.S. Coast Guard informs private and 

commercial vessels about temporary closures via Notices to Mariners. These notices provide 

information about durations and locations of closures because of activities that are potentially 

hazardous to surface vessels. Broadcast notices on maritime frequency radio, weekly publications by the 

appropriate U.S. Coast Guard Navigation Center, and global positioning system navigation charts 

disseminate these navigational warnings.

3.12.2.1.2 Airspace

Most of the airspace in the Study Area is accessible to general aviation (recreational, private, corporate) 

and commercial aircraft; however, like waterways, some areas are temporarily off-limits to civilian and 

commercial use. The Federal Aviation Administration has established special use airspace, which is 

airspace of defined dimensions wherein activities must be confined because of their nature or wherein 

limitations may be imposed upon aircraft operations that are not part of those activities (Federal 

Aviation Administration Order 7400.2L, Procedures for Handling Airspace Matters, Special Use Airspace,
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3.12 Public Health and Safety

Part 5, Chapters 21 to 28, effective April 27, 2017). Special use airspace in the Study Area includes the 

following:

 Restricted airspace: Areas where aircraft are subject to restriction due to the existence of 

unusual (often invisible) hazards to aircraft (e.g., release of munitions). Some areas are under 

strict control of DoD, and some are shared with non-military agencies (Federal Aviation 

Administration Order 7400.2L, Chapter 23).

 Military Operations Areas: Airspace designated outside of Class A airspace to separate or

segregate certain non-hazardous military activities from Instrument Flight Rules traffic and 

identify for Visual Flight Rules traffic where these activities are conducted (Federal Aviation 

Administration Order 7400.2L, Chapter 25).

 Warning areas: Areas of defined dimensions, extending from 3 NM outward from the coast of 

the United States, that serve to warn non-participating aircraft of potential danger (Federal 

Aviation Administration Order 7400.2L, Chapter 24).

Additionally, Air Traffic Control Assigned Airspace is airspace with defined vertical/lateral limits, 

implemented by Letter of Agreement between the user and the concerned an Air Route Traffic Control 

Center, and assigned by Air Traffic Control for the purpose of providing air traffic segregation between 

the specified activity being conducted within the assigned airspace and other Instrument Flight Rules 

traffic. Air Traffic Control Assigned Airspace should not be established to contain activities for which a 

specific type of special use airspace should be designated (i.e., should not be used as a substitute for a 

more appropriate special use airspace designation).

Notices to Airmen are created and transmitted by government agencies and airport operators to alert 

aircraft pilots of any hazards en route to or at a specific location. Notices to Airmen contain information 

(not known sufficiently in advance to publicize by other means) concerning the establishment, 

condition, or change in any component (facility, service, procedure, or hazard in the National Airspace 

System) the timely knowledge of which is essential to personnel concerned with flight operations. The 

Federal Aviation Administration issues Notices to Airmen to disseminate information on upcoming or 

ongoing military exercises with resulting airspace restrictions. Civilian aircraft operators are responsible 

for being aware of restricted areas in airspace and any Notices to Airmen in effect. Pilots have a duty to 

abide by aviation rules as administered by the Federal Aviation Administration.

Weather conditions dictate whether an aircraft (general aviation, commercial, or military) can fly under 

Visual Flight Rules or Instrument Flight Rules. Under Visual Flight Rules, the weather is favorable and the 

pilot is required to remain clear of clouds by specified distances to ensure separation from other aircraft 

under the concept of “see and avoid.” Pilots flying under Visual Flight Rules must be able to see outside 

of the cockpit, control the aircraft’s attitude, navigate, and avoid obstacles and other aircraft based on 

visual cues. Pilots flying under Visual Flight Rules assume responsibility for their separation from all 

other aircraft and are generally not assigned routes or altitudes by air traffic control. 

During unfavorable weather, pilots must follow Instrument Flight Rules. Factors such as visibility, cloud 

distance, cloud ceilings, and weather phenomena cause visual conditions to drop below the minimum 

required to operate by visual flight referencing. Instrument Flight Rules are the regulations and 

restrictions a pilot must comply with when flying in weather conditions that restrict visibility. Pilots can 

fly under Instrument Flight Rules in Visual Flight Rules weather conditions; however, pilots cannot fly 

under Visual Flight Rules in Instrument Flight Rules weather conditions.
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3.12.2.2 Safety and Inspection Procedures

In accordance with Navy instructions presented in this chapter, safety and inspection procedures 

discussed in this section are designed to ensure public health and safety. Through the Naval Safety 

Center and Fleet Safety Center, the Navy promotes a proactive and comprehensive safety program

designed to reduce, to the greatest extent possible, any potential adverse impacts on public health and 

safety from training and testing activities.

As previously stated, the greatest potential for training or testing activities to impact the public is in

nearshore areas, because public activities are concentrated in those areas. When planning a training or 

testing activity, the Navy considers proximity of the activity to public areas in choosing a location. 

Important factors considered include the ability to control access to an area; schedule (time of day, day 

of week); frequency, duration, and intensity of activities; range safety procedures; operational control of 

activities; and safety history.

The Navy’s Fleet Area Control and Surveillance Facilities provide support and training resources for DoD, 

Homeland Defense, and foreign military units by coordinating, scheduling, and monitoring activities in 

U.S. Fleet Forces Command operating areas and special use airspace. At Navy ranges, Range Control is 

responsible for hazard area surveillance and clearance and the control of all range operational areas. 

Although operations in special use airspace are scheduled through the Navy Fleet Area Control and 

Surveillance Facilities, Range Control coordinates the real-time control of ranges in coordination with 

the Federal Aviation Administration and other military users and communicates with the operations 

conductors and all participants entering and leaving the range areas. The Federal Aviation

Administration and the U.S. Coast Guard issue Notices to Airmen and Notices to Mariners, respectively.

During training and testing activities in the Study Area, the Navy ensures that the appropriate safety 

zone is clear of non-participants before engaging in certain activities, such as weapon firing. Inability to 

obtain a “clear range” could result in the delay, cancellation, or relocation of an event. This approach 

ensures public safety during Navy activities that otherwise could harm non-participants. Current Navy 

practices employ the use of sensors and other devices (e.g., radar and big-eye binoculars) to ensure 

public health and safety while conducting training and testing activities. The following subsections 

outline the current requirements and practices for human safety as they pertain to range safety 

procedures, range inspection procedures, exercise planning, and scheduling and coordinating 

procedures for the Navy.

Training activities must comply with Fleet Area Control and Surveillance Facility procedures. Fleet Area 

Control and Surveillance Facilities, Virginia Capes and Jacksonville, have published safety procedures for 

activities conducted both nearshore and offshore (U.S. Department of the Navy, 2011a). These 

guidelines (and others) apply to range users as follows:

 Navy personnel are responsible for ensuring that impact areas and targets are clear before 

commencing hazardous activities.

 The use of in-water munitions must be coordinated with submarine operational authorities. The 

coordination also applies to towed sound navigation and ranging (sonar) arrays and torpedo 

countermeasures.

 Aircraft or vessels expending munitions shall not commence firing without the permission of the 

Range Safety Officer for their specific range area.

 Firing units and targets must remain in their assigned areas, and units must fire in accordance 

with current safety instructions.
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 Aircraft carrying munitions to or from ranges shall avoid populated areas to the maximum 

extent possible.

 Strict on-scene procedures include the use of ship sensors, visual surveillance of the range from 

aircraft and range safety boats, and radar and acoustic data to confirm the firing range and 

target area are clear of civilian vessels, aircraft, or other non-participants.

Comprehensive safety planning instructions exist for specific testing activities, such as laser and 

electromagnetic energy testing (U.S. Department of the Navy, 2009). These instructions provide 

guidance on how to identify the hazards, assess the potential risk, analyze risk control measures, 

implement risk controls, and review safety procedures. They apply to all testing activities, including 

ground, waterborne, and airborne testing activities involving personnel, aircraft, inert minefields, 

equipment, and airspace. The guidance applies to system program managers, program engineers, test 

engineers, test directors, and aircrews that are responsible for incorporating safety planning and review 

when conducting test programs.

3.12.2.2.1 Aviation Safety

The Navy procedures regarding planning and management of special use airspace are provided in the 

Chief of Naval Operations Instruction 3770.2L, Airspace Procedures and Planning Manual (U.S. 

Department of the Navy, 2007).

Scheduling and planning procedures for air operations on range complexes (including testing activities in 

the Northeast Range Complexes) are issued through the Navy’s Fleet Area Control and Surveillance 

Facility, Virginia Capes (U.S. Department of the Navy, 2015a). 

Testing activities have their own procedures that require that safety be considered in any testing event. 

For example, the Navy’s Operational Test Director’s Manual prescribes policies and procedures for the 

planning, conduct, and reporting of Operational Test and Evaluation of new and improved naval 

weapons and warfare support systems (U.S. Department of the Navy, 2016). 

Aircrews involved in training or testing exercises must be aware that non-participating aircraft and ships 

are not precluded from entering the area and may not comply with Notices to Airmen or Notices to 

Mariners. Aircrews are required to maintain a continuous lookout for non-participating aircraft while 

operating in warning areas under Visual Flight Rules. In general, aircraft carrying munitions are not 

allowed to fly over public or commercial boats or ships.

3.12.2.2.2 Submarine Navigation Safety

Submarine crews use various methods to avoid collisions while they are surfaced, including visual and 

radar scanning, acoustic depth finders, and state-of-the-art satellite navigational systems. During 

submerged transit, submarines use all available ocean navigation tools, including inertial navigation 

charts that calculate position based on the submerged movements of the submarine. Submarines use 

these systems to avoid surface vessels as well as all other hazards to navigation.

3.12.2.2.3 Surface Vessel Navigation Safety

The Navy practices the fundamentals of safe navigation. As specified in Section 2.3.3 (Standard 

Operating Procedures), ships operated by or for the Navy have personnel assigned to stand watch at all 

times, day and night, when underway. Watch personnel undertake extensive training in accordance with 

the Navy Lookout Training Handbook or civilian equivalent, including on-the-job instruction and a formal 

Personal Qualification Standard program (or equivalent program for supporting contractors or civilians), 

to certify that they have demonstrated all necessary skills (such as detection and reporting of floating or 
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partially submerged objects). While on watch, personnel employ visual search techniques, including the 

use of binoculars and scanning techniques in accordance with the Navy Lookout Training Handbook or 

civilian equivalent. After sunset and prior to sunrise, watch personnel employ night visual search 

techniques, which could include the use of night vision devices. Watch personnel are primarily posted 

for safety of navigation, range clearance, and man-overboard precautions. For some specific testing 

activities, such as unmanned surface vehicle testing, a support boat would be used in the vicinity of the 

test to ensure safe navigation. Before firing or launching a weapon or radiating a non-eye-safe laser, 

Navy surface vessels are required to determine that all safety criteria have been satisfied. When 

applicable, the surface vessel would use aircraft and other boats to aid in navigation.

3.12.2.2.4 Sonar Safety

Surface vessels and submarines may use active sonar in the pierside locations listed in Chapter 2 

(Description of Proposed Action and Alternatives) and during transit to training or testing exercise 

locations. To ensure safe and effective sonar use, the Navy applies the same safety procedures for 

pierside sonar use as described under Section 3.12.2.2 (Safety and Inspection Procedures).

The U.S. Navy Diving Manual, Appendix 1A, Safe Diving Distances from Transmitting Sonar, is the Navy’s 

governing document for protecting divers during active sonar use (U.S. Department of the Navy, 2011b). 

The manual provides procedures for calculating safe distances from active sonar. These procedures are 

derived from experimental and theoretical research conducted at the Naval Submarine Medical 

Research Laboratory and the Navy Experimental Diving Unit. Safety distances vary based on conditions 

that include diver dress, type of sonar, and duration of time in the water. These safety distances would 

also be applicable to recreational swimmers and divers. Some safety procedures include measurements 

to be taken during testing activities to identify an exclusion area for non-participating swimmers and 

divers.

3.12.2.2.5 Electromagnetic Energy Safety

This section discusses electromagnetic energy transmitted through the air as a result of proposed 

activities. All frequencies (or wavelengths) of electromagnetic energy are referred to as the 

electromagnetic spectrum and include electromagnetic energy and radio frequency radiation. 

Communications and electronic devices such as radar, electronic warfare devices, navigational aids, twoway radios, cell phones, and other radio transmitters produce electromagnetic radiation. While such 

equipment emits electromagnetic energy, some of these systems are the same as, or similar to, civilian 

navigational aids and radars at local airports and television weather stations. Radio waves and 

microwaves emitted by transmitting antennas are another form of electromagnetic energy, collectively 

referred to as radio frequency radiation. Radio frequency energy includes frequencies ranging from 0 to 

3,000 gigahertz. Exposure to radio frequency energy of sufficient intensity at frequencies between 

3 kilohertz and 300 gigahertz can adversely affect people, munitions, and fuel.

To avoid excessive exposures from electromagnetic energy, military aircraft are operated in accordance 

with standard operating procedures that establish minimum separation distances between 

electromagnetic energy emitters and people, munitions, and fuels (U.S. Department of Defense, 2009). 

Thresholds for determining hazardous levels of electromagnetic energy to humans, munitions, and fuel 

have been determined for electromagnetic energy sources based on frequency and power output, and 

practices are in place to protect the public from electromagnetic radiation hazards (U.S. Department of 

Defense, 2002, 2009). These procedures include setting the heights and angles of electromagnetic

energy transmissions to avoid direct exposure, posting warning signs, establishing safe operating levels, 
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activating warning lights when radar systems are operational, and not operating some platforms that 

emit electromagnetic energy within 15 NM of shore. Safety planning instructions provide clearance 

procedures for non-participants in operational areas before conducting training and testing activities 

that involve in-water electromagnetic energy (e.g., mine warfare) (U.S. Department of the Navy, 2008a, 

2009, 2015a).

3.12.2.2.6 Laser Safety

Lasers produce a coherent beam of light energy. The Navy uses lasers for precision range finding, as 

target designation/illumination devices for engagement with laser-guided weapons, and for mine 

detection and mine countermeasures, as well as for non-lethal deterrents. Testing activities include 

high-energy laser weapons tests to evaluate the specifications, integration, and performance of a vesselor aircraft-mounted, high-energy laser. The high-energy laser would be used as a weapon to disable 

small surface vessels. Office of the Chief of Naval Operations Instruction 5100.27B/Marine Corps Order 

5104.1C, Navy Laser Hazards Control Program, prescribes Navy and Marine Corps policy and guidance in 

the identification and control of laser hazards. The Navy observes strict precautions and has written 

instructions in place for laser users to ensure that non-participants are not exposed to intense light 

energy. Laser safety procedures for aircraft require an initial pass over the target before laser activation 

to ensure that target areas are clear. During actual laser use, aircraft run-in headings are also restricted 

to avoid unintentional contact with personnel or non-participants. Personnel participating in laser 

training activities are required to complete an annual laser safety course (U.S. Department of the Navy, 

2008b).

3.12.2.2.7 Explosive Munitions Detonation Safety

Pressure waves from in-water detonations can pose a physical hazard in surrounding waters. Before 

conducting an in-water explosive training or testing activity, Navy personnel establish an appropriately 

sized exclusion zone to avoid exposing non-participants to the harmful intensities of pressure waves. 

The U.S. Navy Diving Manual, Section 2.7, Underwater Explosions, provides procedures for determining 

safe distances from in-water explosions (U.S. Department of the Navy, 2011b). In accordance with 

training and testing procedures for safety planning related to detonations (Section 3.12.2.2.8, Weapons 

Firing and Munitions Expenditure Safety), the Navy uses the following detonation procedures:

 Navy personnel are responsible for ensuring that impact areas and targets are clear before 

commencing hazardous activities.

 The use of in-water munitions must be coordinated with submarine operational authorities.

 Aircraft or vessels expending munitions shall not commence firing without permission of the 

Range Safety Officer or Test Safety Officer for their specific range area.

 Firing units and targets must remain in their assigned areas, and units must fire in accordance 

with current safety instructions.

 Detonation activities would be conducted during daylight hours.

3.12.2.2.8 Weapons Firing and Munitions Expenditure Safety

Navy explosives safety policy is based on the requirements of DoD 6055.9-STD, Ammunition and 

Explosives Safety Standards. This DoD standard establishes uniform safety requirements applicable to 

ammunition and explosives and to associated and unrelated personnel and property exposed to the 

potentially damaging effects of an accident involving ammunition and explosives during, among other 
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things, usage during training, testing, transportation, handling, storage, maintenance, and disposal (U.S. 

Department of Defense, 2012).

Safety is a primary consideration for all training and testing activities. The range must be able to safely 

contain the hazard area of the weapons and equipment employed. The hazard area is based on the size 

and net explosive weight of the weapon, and it includes a safety buffer around the target to account for 

items going off-range or malfunctioning. The size of the buffer zone is determined by the type of 

activity. For activities with a large hazard area, special sea and air surveillance measures are 

implemented to make sure the area is clear before the activities commence. Before aircraft can drop 

munitions, they are required to make a preliminary pass over the intended target area to ensure that it 

is clear of boats, divers, or other non-participants. Aircraft carrying munitions are not allowed to fly over 

surface vessels. 

Training and testing activities are delayed, moved, or cancelled if there is a question about the safety of 

the public. Target areas must be clear of non-participants before conducting training and testing. When 

using munitions with flight termination systems (which terminate the flight of airborne missiles or 

launch vehicles when they veer from their targeted path), the Navy is required to follow standard 

operating procedures to ensure public health and safety. In those cases where a weapons system does 

not have a flight termination system, the size of the target area that needs to be clear of nonparticipants is based on the flight distance of the weapon plus an additional distance beyond the 

system’s performance capability.

3.12.3 ENVIRONMENTAL CONSEQUENCES

This section evaluates how and to what degree the activities described in Chapter 2 (Description of 

Proposed Action and Alternatives) would potentially impact public health and safety. Table 2.6-1 

(Proposed Training Activities per Alternative) through Table 2.6-4 (Office of Naval Research Proposed 

Testing Activities per Alternative) present the existing and proposed training and testing activity 

locations for each alternative (including the annual number of events). Each public health and safety 

stressor is introduced, and analyzed by alternative for both training and testing activities. Tables B-1

(Stressors by Training Activity) and B-2 (Stressors by Testing Activity) in Appendix B (Activity Stressor 

Matrices) show the warfare areas and associated stressors that were considered for analysis of public 

health and safety. The stressors vary in intensity, frequency, duration, and location within the Study 

Area. The stressors applicable to public health and safety are the following:

 In-water energy (sonar and in-water explosions)

 In-air energy (radar and lasers)

 Physical interactions (aircraft, vessels, in-water devices/targets, munitions, seafloor devices)

 Secondary stressors (impacts to water quality from explosives and explosive byproducts, 

metals, chemicals other than explosives, and other materials)

As discussed in Chapter 2 (Description of Proposed Action and Alternatives), the majority of the training 

and testing activities that would be conducted under Alternatives 1 and 2 are the same as or similar to 

those currently being conducted or that have been conducted in the past. 

The potential for impacts on public health and safety were evaluated assuming the implementation of 

the Navy’s standard operating procedures, as discussed in Section 2.3.3 (Standard Operating 

Procedures). Training and testing activities in the Study Area are conducted in accordance with guidance 

provided in Fleet Area Control and Surveillance Facility Instructions (U.S. Department of the Navy, 
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2015a, 2015b) and/or Test and Safety Planning Instructions (U.S. Department of the Navy, 2009). These 

instructions provide standard operating procedures for all range events. They also provide users with 

information that is necessary to operate safely and avoid affecting non-military activities such as 

shipping, recreational boating, diving, and commercial or recreational fishing. Ranges are managed in 

accordance with standard operating procedures that ensure public health and safety.

3.12.3.1 In-Water Energy

In-water energy can come from acoustic sources or electromagnetic devices. Active sonar, in-water

explosions, air guns, and vessel movements produce in-water acoustic energy. Sound travels from air to 

water during aircraft overflights. Electromagnetic energy can enter the water from mine warfare 

training devices and unmanned underwater vehicles. The potential for the public to be exposed to these 

stressors would be limited to individuals such as recreational swimmers or scuba divers who are 

underwater and within unsafe proximity of a training or testing event.

In-water acoustic energy is generated from many of the proposed activities; however, not all would be 

considered in detail in this environmental impact statement/overseas environmental impact statement 

(EIS/OEIS) in terms of their impact on public health and safety because the public safety risks from some 

activities are deemed to be negligible. The public might intermittently hear noise from ships if they are 

in the general vicinity of a training or testing event, but there would be no impact on public health and 

safety because of the infrequency and short duration of events. In addition, air guns are used during 

some pierside integrated swimmer defense training and testing activities, but public health and safety 

would not be put at risk because access to pierside locations by non-participants is controlled. Active 

sonar and in-water explosions are the only sources of in-water acoustic energy evaluated for potential 

impacts on public health and safety.

The proposed activities that would result in in-water acoustic energy include activities such as 

amphibious warfare, surface warfare, anti-submarine warfare, mine warfare, surface warfare testing, 

sonar maintenance, pierside sonar testing, and unmanned underwater vehicle testing. A limited amount 

of active sonar would be used during transit between range complexes and training and testing 

locations.

The effect of active sonar on humans varies with the frequency of sonar involved. Of the four types of 

sonar (very high-, high-, mid-, and low-frequency), mid-frequency and low-frequency sonar have the 

greatest potential to impact humans due to the range of human hearing capabilities. 

In-water explosives cause a physical shock front that compresses the explosive material, and a pressure 

wave that passes into the surrounding water. Generally, the pressure wave would be the primary cause 

of injury. The effects of an in-water explosion depend on several factors, including the size, type, and 

depth of the explosive charge and where it is in the water column.

Electromagnetic energy is associated with systems such as the Organic Airborne and Surface Influence 

Sweep System that emit an electromagnetic field to simulate the presence of a ship. Electromagnetic 

energy can also be used in a defensive mode to cause nearby mines to explode. Unmanned underwater 

vehicles, some unmanned surface vehicles, and towed devices use electromagnetic energy, either for 

navigation or as a means to be targeted. 

Electromagnetic energy dissipates quickly with distance from the source. Scientific literature does not 

conclude that there are adverse health effects from most levels of electromagnetic energy, which is why 

no federal standards have been set for occupational exposures to this type of energy. DoD Instruction 
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3222.03 provides guidance regarding management and implementation of the electromagnetic 

environmental effects program, including hazards of electromagnetic radiation to personnel (U.S. 

Department of Defense, 2015). 

As previously stated, the potential for the public to be exposed to these stressors would be limited to 

individuals who are underwater and within unsafe proximity to an event. Scuba diving is a popular 

recreational activity that is typically concentrated around known dive attractions, such as reefs and 

shipwrecks. The Professional Association of Diving Instructors (one of several scuba diving instruction 

organizations) suggests that no recreational diver should exceed 130 feet (ft.) of depth (Professional 

Association of Diving Instructors, 2011). These depths typically limit this activity’s distance from shore. 

Navy operations overlapping with recreational swimmers or divers would be unlikely. Recreational 

swimmers and divers are not precluded from operating in public boat lanes or adjoining areas near Navy 

pierside locations (which include shipyards); however, Navy operators are diligent in identifying 

recreational swimmers and divers to ensure that these would be avoided. Additionally, recreational 

divers would not be expected near Navy ships at sea. The locations of popular offshore diving spots are 

well-documented, and dive boats (typically well-marked) and diver-down flags would be visible from the 

ships conducting the training and testing. The U.S. Navy Diving Manual (U.S. Department of the Navy, 

2011b) contains methodologies to determine appropriate safety distances associated with sonar use 

near Navy divers. These safety distances would also be used as safety buffers to protect public health 

and safety. If any unauthorized personnel are detected within the sonar activity safety buffer, the 

activity would be temporarily halted until the area is again cleared.

3.12.3.1.1 Impacts from In-Water Energy Under Alternative 1

Impacts from In-Water Energy Under Alternative 1 for Training Activities

Under Alternative 1, the Navy would conduct active sonar training activities such as anti-submarine 

warfare, mine warfare, and sonar maintenance in the Northeast, Virginia Capes, Navy Cherry Point, 

Jacksonville, and Gulf of Mexico Range Complexes. Activities involving in-water explosions, such as 

surface warfare and mine warfare, would be conducted at established ranges and training locations. The 

Navy would conduct these activities throughout the Study Area. 

As previously discussed, the Navy implements operating procedures designed to protect public health 

and safety. These procedures include the following:

 ensuring that training areas are clear before commencing hazardous activities

 conducting all activities in accordance with established safety instructions

 conducting in-water detonations only at established and approved locations

 posting Navy Lookouts at all times during an exercise to ensure non-participants do not enter 

the area

 coordinating with the U.S. Coast Guard to issue Notices to Mariners notifying the public about 

durations and locations of potentially hazardous activities

Consequently, the potential for training activities using in-water energy to impact public health and 

safety under Alternative 1 would be unlikely.

Impacts from In-Water Energy Under Alternative 1 for Testing Activities

Under Alternative 1, the Navy would conduct active sonar testing activities such as anti-submarine 

warfare, mine warfare, pierside sonar testing, unmanned underwater vehicle testing, and sonar 
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maintenance in the Gulf of Mexico, Jacksonville, Navy Cherry Point, Northeast, and Virginia Capes Range 

Complexes; Naval Undersea Warfare Center Division, Newport Testing Range; South Florida Ocean 

Measurement Facility; and Fort Pierce, Florida. The Navy would conduct pierside testing of active sonar 

in Bath, Maine; Groton, Connecticut; Kings Bay, Georgia; Newport, Rhode Island; Norfolk, Virginia; 

Pascagoula, Mississippi; Port Canaveral, Florida; and Portsmouth, New Hampshire. 

The Navy would conduct testing activities involving in-water detonations, such as surface warfare, antisubmarine warfare, mine warfare, and surface combatant sea trials in specific training areas in the 

Virginia Capes, Navy Cherry Point, Jacksonville, and Gulf of Mexico Range Complexes.

As discussed in the subsection above, Impacts from In-Water Energy Under Alternative 1 for Training 

Activities, the Navy implements operating procedures designed to protect public health and safety. 

Under this alternative, these procedures would be implemented. Consequently, the potential for testing 

activities using in-water energy to impact public health and safety under Alternative 1 would be unlikely.

3.12.3.1.2 Impacts from In-Water Energy Under Alternative 2

Impacts from In-Water Energy Under Alternative 2 for Training Activities

Alternative 2 reflects an increase in sonar training over that presented in Alternative 1. Training 

locations would remain the same as those of Alternative 1. This alternative would also include a 

maximum of four Composite Training Unit Exercises each year in the Gulf of Mexico. The Navy would 

implement standard operating and safety procedures, as discussed previously. Therefore, potential for 

impacts on public health and safety beyond those identified for Alternative 1 would be unlikely.

The Navy would conduct activities involving in-water explosions, such as surface warfare, mine warfare, 

and civilian port defense at current locations. In this case also, the Navy would implement standard 

operating and safety procedures. Therefore, potential for impacts on public health and safety beyond 

those identified for Alternative 1 would be unlikely.

Impacts from In-Water Energy Under Alternative 2 for Testing Activities

Under Alternative 2, the Navy would conduct sonar testing activities (both at-sea and pierside) in the 

same areas and at the same levels identified under Alternative 1. The Navy would implement standard 

operating and safety procedures. Therefore, an increased potential for impacts on public health and 

safety beyond those identified for Alternative 1 would be unlikely.

The Navy would conduct testing activities involving in-water explosions, such as air warfare, surface

warfare, anti-submarine warfare, mine warfare, surface combatant sea trials, littoral combat ship 

testing, ship shock trials, combat ship qualifications, at-sea explosive testing, and sonobuoy lot 

acceptance testing in the same areas identified under Alternative 1, although under Alternative 2, the 

Navy would increase the number of some testing activities involving in-water explosions. The Navy 

would implement standard operating and safety procedures. Therefore, an increased potential for 

impacts on public health and safety beyond those identified for Alternative 1 would be unlikely.

3.12.3.1.3 Impacts from In-Water Energy Under the No Action Alternative

Impacts from In-Water Energy Under the No Action Alternative for Training and Testing

Activities

Under the No Action Alternative, the Navy would not conduct the proposed training and testing 

activities in the AFTT Study Area. Various in-water energy stressors (e.g., acoustic and electromagnetic) 

would not be introduced into the marine environment. Therefore, baseline conditions of the existing 
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environment would either remain unchanged or would improve slightly after cessation of ongoing 

training and testing activities. However, with regard to diminished military readiness, the No Action 

Alternative would have adverse impacts on public health and safety.

3.12.3.2 In-Air Energy

In-air energy stressors include sources of electromagnetic energy and lasers. The sources of 

electromagnetic energy include radar and electronic warfare systems. These systems operate similarly 

to other navigational aids and radars at civilian airports and television weather stations throughout the 

United States. Electronic warfare systems emit electromagnetic energy similar to that from cell phones, 

handheld radios, commercial radio stations, and television stations. The Navy follows documented 

safety procedures to protect Navy personnel and the public from electromagnetic energy hazards. These 

procedures include setting the heights and angles of electromagnetic energy transmissions to avoid 

direct human exposure, posting warning signs, establishing safe operating levels, and activating warning 

lights when radar systems are operational. 

High-energy lasers are used as weapons to disable surface targets. The Navy would operate high-energy

laser equipment in accordance with procedures defined in Chief of Naval Operations Instruction 

5100.23G, Navy Safety and Occupational Health Program Manual (U.S. Department of the Navy, 2011a). 

These high-energy light sources can cause eye injuries and burns. A comprehensive safety program 

exists for the use of lasers. Current Navy safety procedures protect individuals from the hazard of 

injuries caused by laser energy. Laser safety requirements for aircraft and vessels mandate verification 

that target areas are clear before commencement of an exercise. In the case of aircraft, during actual 

laser use, the aircraft run-in headings are restricted to preclude inadvertent lasing of areas where the 

public may be present.

Training and testing activities involving electromagnetic energy include electronic warfare activities that 

use airborne and surface electronic jamming devices to defeat tracking and communications systems. 

Training activities involving low-energy lasers include surface warfare and mine warfare; there are no 

training activities that use high-energy lasers. 

3.12.3.2.1 Impacts from In-Air Energy Under Alternative 1

Impacts from In-Air Energy Under Alternative 1 for Training Activities

Under Alternative 1, the Navy would conduct electronic warfare training activities involving 

electromagnetic energy sources in the Virginia Capes, Navy Cherry Point, Jacksonville, and Gulf of 

Mexico Range Complexes. The Navy would conduct laser targeting activities and mine detection 

activities using lasers within the Virginia Capes and Jacksonville Range Complexes.

It is unlikely that the public would be exposed to electromagnetic energy sources or lasers from training 

activities under Alternative 1, because the Navy would not conduct these activities in proximity to the 

public. Additionally, the Navy would employ strict safety procedures for the use of lasers and other 

electromagnetic energy sources, as discussed in Sections 3.12.2.2.5 (Electromagnetic Energy Safety) and 

3.12.2.2.6 (Laser Safety). Consequently, the potential for training activities to impact public health and 

safety under Alternative 1 would be unlikely.

Impacts from In-Air Energy Under Alternative 1 for Testing Activities

Under Alternative 1, the Navy would conduct electronic warfare testing activities involving 

electromagnetic energy sources and lasers at locations identified under Alternative 1. High-energy laser 
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weapons testing activities (the only testing activities using high-energy lasers) would occur only in the 

Virginia Capes Range Complex. 

The Navy would not conduct these testing activities in proximity to the public. Additionally, the Navy 

would employ strict safety procedures for the use of lasers and other electromagnetic energy sources, 

as discussed in Section 3.12.2.2.5 (Electromagnetic Energy Safety) and Section 3.12.2.2.6 (Laser Safety). 

Consequently, the potential for testing activities to impact public health and safety would be unlikely.

3.12.3.2.2 Impacts from In-Air Energy Under Alternative 2

Impacts from In-Air Energy Under Alternative 2 for Training Activities

Alternative 2 would involve the same locations and number of training activities described under 

Alternative 1 for electromagnetic energy and lasers. The Navy would implement standard operating and 

safety procedures. Therefore, an increased potential for impacts on public health and safety beyond 

those identified for Alternative 1 would be unlikely.

Impacts from In-Air Energy Under Alternative 2 for Testing Activities

Alternative 2 would involve the same locations and number of testing activities described under 

Alternative 1 for electromagnetic energy and lasers. The Navy would implement standard operating and 

safety procedures. Therefore, an increased potential for impacts on public health and safety beyond 

those identified for Alternative 1 would be unlikely for testing activities.

3.12.3.2.3 Impacts from In-Air Energy Under the No Action Alternative

Impacts from In-Air Energy Under the No Action Alternative for Training and Testing 

Activities

Under the No Action Alternative, the Navy would not conduct the proposed training and testing 

activities in the AFTT Study Area. In-air energy stressors (e.g., laser and electromagnetic) would not be 

introduced into the marine environment. Therefore, baseline conditions of the existing environment 

would either remain unchanged or would improve slightly after cessation of ongoing training and testing 

activities. However, with regard to diminished military readiness, the No Action Alternative would have 

adverse impacts on public health and safety.

3.12.3.3 Physical Interactions

This section evaluates potential impacts associated with the interaction of Navy aircraft, vessels, and 

equipment with the general public. Public health and safety could be impacted by physical collisions 

between Navy assets and the public. As described in Section 3.0.3.3.4 (Physical Disturbance and Strike 

Stressors), Navy aircraft, vessels, targets, munitions, towed devices, seafloor devices, and other training 

and testing expended materials could be directly, physically encountered by recreational, commercial, 

institutional, and governmental aircraft, vessels, and individuals such as swimmers, divers, and anglers.

Like private aircraft, Navy aircraft are required to observe and avoid other aircraft. In addition, the

Federal Aviation Administration issues Notices to Airmen advising private and commercial pilots about 

scheduled Navy training and testing activities. Finally, Navy personnel are required to verify that the 

range is clear of non-participants before initiating any activity that could be potentially hazardous to the 

public. Together, these procedures would minimize the potential for adverse interactions between Navy 

and non-participant aircraft. Application of standard operating procedures would minimize the potential 

for interaction between private or commercial aircraft with Navy training or testing activities employing 

aircraft, munitions, and aerial targets.
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Private and commercial vessels traversing the Study Area during training or testing activities may 

interact with Navy vessels, munitions, and surface targets. Naval Vessel Protection Zones established by 

U.S. Coast Guard regulations (33 CFR section 165.2010) require other (non-Navy) vessels to slow down 

to a minimum speed within 500 yards of a Navy vessel greater than 100 ft. long; they are prohibited 

from approaching within 100 yards of a Navy vessel greater than 100 ft. long. Both Navy and public 

vessels operate under maritime navigational rules requiring them to observe and avoid other vessels. In 

addition, Notices to Mariners advise vessel operators about when and where Navy training and testing 

activities are scheduled. Finally, Navy personnel are required to verify that the range is clear of nonparticipants before initiating any potentially hazardous activity. Together, these procedures minimize 

the potential for adverse interactions between Navy and nonparticipant vessels.

Recreational diving within the Study Area takes place primarily at known diving sites such as shipwrecks 

and reefs. The locations of these popular dive sites are well-documented, dive boats are typically wellmarked, and diver-down flags are visible from a distance. As a result, dive sites would be easily avoided 

by ships conducting training or testing activities. Interactions between training and testing activities and 

recreational divers, thus, would not be expected. Similar knowledge and avoidance of popular fishing 

areas would minimize interactions between training and testing activities and recreational fishing.

Commercial and recreational fishing activities could encounter military expended materials that could 

entangle fishing gear and pose a safety risk. The Navy recovers many surface targets after they are used 

to avoid them becoming a collision risk or entanglement risk. Unrecoverable pieces of military expended 

materials are typically small (such as sonobuoys), constructed of soft materials (such as target cardboard 

boxes or tethered target balloons), or intended to sink to the bottom after their useful function is 

completed, so they would not pose a collision or entanglement risk to civilian vessels or equipment. 

Thus, these targets do not pose a safety risk to individuals using the area for recreation because the 

public would not likely be exposed to these items before they sank to the seafloor. 

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). Figure 3.5-15 (Alternative 1 – Annual Proportional Impact 

(Acres) from Military Expended Materials by Substrate Type for Training and Testing Compared to Total 

Habitat Within the Study Area) and Figure 3.5-16 (Alternative 2 – Annual Proportional Impact (Acres) 

from Military Expended Materials by Substrate Type for Training and Testing Compared to Total 

Vulnerable Habitat Within the Range Complexes of the Large Marine Ecosystems Within the Study Area) 

illustrate the very small percentage of marine substrate (much less than 1 percent of the total area of 

documented soft bottom, intermediate, or hard bottom in their respective training or testing areas). 

Given the small footprint of military expended materials estimated here, it is unlikely the public would 

encounter military expended materials during recreational or commercial fishing activities. 

Section 3.2 (Sediments and Water Quality) discusses the low failure rate of munitions, which indicates 

that most munitions operate as intended. While fishing activities may encounter undetonated 

munitions, it would be unlikely because of the deep waters and low density of munitions within the 

large size of the Study Area. Depending on the circumstances (i.e., emergency or imminent threat), Navy 

Explosive Ordnance Disposal support or other resources could be asked to respond and safely dispose of 

any munitions.

Additionally, the public may encounter military expended materials, such as pieces of plastic or fabric 

that wash up on the seashore. Most of this material does not pose a potential for safety impacts; 

however, other items, such as flares may pose potential safety impacts. Flares, such as the ones 
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3.12 Public Health and Safety

dropped into the ocean by military planes to use as markers, contain chemicals designed to burn at high 

intensity, allowing them to be visible from long distances. The chemicals (e.g., phosphorous) in 

unexpended or partially-burned flares can reignite when exposed to air or water, resulting in severe 

burns if handled. The presence of any flares should be reported to appropriate agencies, such as the 

police or U.S. Coast Guard, who would then contact experienced personnel for their proper disposal. 

The analysis focuses on the potential for a direct physical interaction with aircraft, vessels, targets, or 

other expended materials. A vessel or aircraft transiting through the water or air (as would be involved 

in the vast majority of proposed activities) inherently involves the risk of collision with other vessels or 

aircraft. But this risk is greatly diminished by a shared set of international navigational rules for vessels 

and aircraft. The greatest potential for a physical interaction would be along the coast and near 

populated areas, because that is where public activities are concentrated.

3.12.3.3.1 Impacts from Physical Interactions Under Alternative 1

Impacts from Physical Interactions Under Alternative 1 for Training Activities

Under Alternative 1, the Navy would conduct training activities at current locations. The potential for a 

direct physical interaction between the public and aircraft, vessels, targets, or expended materials 

would not change from current conditions. The Navy implements strict operating procedures that 

protect public health and safety. These operating procedures include ensuring clearance of the area 

before commencing training activities. 

As discussed in Section 3.12.3.3 (Physical Interactions), there would be no impact on public health and 

safety from physical interactions with training activities, based on the Navy’s implementation of 

standard operating procedures that protect public health and safety. These operating procedures 

include ensuring clearance of the area before commencing training activities involving physical 

interactions. Because of the Navy’s safety procedures, the potential for training activities to impact 

public health and safety under Alternative 1 would be unlikely.

Impacts from Physical Interactions Under Alternative 1 for Testing Activities

Because the potential for a physical interaction is not activity or location specific, the analysis for the 

training activities above applies to testing activities under Alternative 1. As concluded above, because of 

the Navy’s safety procedures, the potential for testing activities to impact public health and safety under 

Alternative 1 would be unlikely.

3.12.3.3.2 Impacts from Physical Interactions Under Alternative 2

Impacts from Physical Interactions Under Alternative 2 for Training Activities

Under Alternative 2, the Navy would increase the number of at-sea training activities over that 

presented in Alternative 1. While Alternative 2 would adjust locations and number of some training 

activities, the Navy would implement standard operating procedures, as discussed in Section 3.12.3.3

(Physical Interactions). Therefore, the potential for impacts on public health and safety would remain 

unlikely.

Impacts from Physical Interactions Under Alternative 2 for Testing Activities

Under Alternative 2, the Navy would increase some types of testing activities. Because the potential for 

a physical interaction is not activity-specific or location-specific, the analysis for the training activities 

above applies to testing activities under Alternative 2. As concluded above, because of the Navy’s safety 
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3.12 Public Health and Safety

procedures, the potential for testing activities to impact public health and safety under Alternative 2 

would remain unlikely.

3.12.3.3.3 Impacts from Physical Interactions Under the No Action Alternative

Impacts from Physical Interactions Under the No Action Alternative for Training and 

Testing Activities

Under the No Action Alternative, the Navy would not conduct the proposed training and testing 

activities in the AFTT Study Area. Physical interaction stressors (e.g., collision with a vessel, interaction 

with a military expended material) would not be introduced into the marine environment. Therefore, 

baseline conditions of the existing environment would remain either unchanged or would improve 

slightly after cessation of ongoing training and testing activities. However, with regard to diminished 

military readiness, the No Action Alternative would have adverse impacts on public health and safety.

3.12.3.4 Secondary (Sediments and Water Quality)

Secondary stressors are defined as those stressors that could pose indirect impacts on public health and 

safety through degradation in water quality or changes to sediment. These stressors include the use of 

explosives, explosive chemical byproducts, and other materials potentially generated (marine markers, 

flares, chaff, targets, and miscellaneous components of other materials). 

3.12.3.4.1 Impacts from Sediments and Water Quality Under Alternative 1

Impacts from Sediments and Water Quality Under Alternative 1 for Training Activities

Section 3.2 (Sediments and Water Quality) considers the impacts on marine sediments and water quality 

from these stressors. The analysis in Section 3.2 (Sediments and Water Quality) determined that any 

impacts to water quality would be temporary and minimal. No state or federal standards or guidelines 

would be violated. Consequently, training under Alternative 1 would result in no indirect impacts on 

public health and safety associated with sediments and water quality.

Impacts from Sediments and Water Quality Under Alternative 1 for Testing Activities

The analysis in Section 3.2 (Sediments and Water Quality) determined that any impacts to water quality 

would be temporary and minimal. No state or federal standards or guidelines would be violated. 

Consequently, testing under Alternative 1 would result in no indirect impacts on public health and safety

associated with sediments and water quality.

3.12.3.4.2 Impacts from Under Alternative 2

Impacts from Sediments and Water Quality Under Alternative 2 for Training Activities

The analysis in Section 3.2 (Sediments and Water Quality) determined that any impacts to water quality 

would be temporary and minimal. No state or federal standards or guidelines would be violated. 

Consequently, training under Alternative 2 would result in no indirect impacts on public health and 

safety associated with sediments and water quality.

Impacts from Sediments and Water Quality Under Alternative 2 for Testing Activities

The analysis in Section 3.2 (Sediments and Water Quality) determined that any impacts to water quality 

would be temporary and minimal. No state or federal standards or guidelines would be violated. 

Consequently, testing under Alternative 2 would result in no indirect impacts on public health and safety

associated with sediments and water quality.
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3.12.3.4.3 Impacts from Sediments and Water Quality Under the No Action Alternative

Impacts from Sediments and Water Quality Under the No Action Alternative for Training 

and Testing Activities

Under the No Action Alternative, the Navy would not conduct the proposed training and testing 

activities in the AFTT Study Area. Secondary stressors (e.g., chemicals affecting water or sediment 

quality) would not be introduced into the marine environment. Therefore, baseline conditions of the 

existing environment would either remain unchanged or would improve slightly after cessation of 

ongoing training and testing activities. However, with regard to diminished military readiness, the No 

Action Alternative would have adverse impacts on public health and safety.

3.12.4 SUMMARY OF POTENTIAL IMPACTS ON PUBLIC HEALTH AND SAFETY

3.12.4.1 Combined Impacts of All Stressors Under Alternative 1

Activities described in this EIS/OEIS that have potential to impact public health and safety include those 

that release in-water energy or in-air energy or those that result in physical interactions, as well as those 

that have indirect impacts from changes to sediments and water quality. As described throughout this 

section, the Navy promotes a proactive and comprehensive safety program designed to reduce to the 

greatest extent possible any potential impacts on public health and safety from training and testing 

activities. Elements of this program include implementing strict navigation rules, coordinating and 

disseminating information on potentially hazardous activities, and the use of remote sensing 

technologies (e.g., radar, sonar) and/or trained Navy Lookouts to ensure that training and testing areas 

are clear of non-participants. Navy safety considerations are appropriate to the location and type of 

activity being conducted, irrespective of the number of activities occurring concurrently; consequently, 

no elevated impacts from the combined effect of all stressors are expected. 

3.12.4.2 Combined Impacts of All Stressors Under Alternative 2

As with Alternative 1, no elevated impacts under Alternative 2 are expected from the combined effect of 

all stressors. Navy safety considerations are appropriate to the location and type of activity being 

conducted, irrespective of the number of activities concurrently conducted.

3.12.4.3 Combined Impacts of All Stressors Under the No Action Alternative

Although Navy at-sea training and testing activities within the Study Area would cease under the No 

Action Alternative, with respect to combined impacts of stressors, there would be no appreciable 

change in potential impacts on public health and safety, as these activities (currently or as proposed) 

would be unlikely to affect public health and safety. However, diminished military readiness under the 

No Action Alternative would adversely affect public health and safety.
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3.12 References

References

Professional Association of Diving Instructors. (2011). Scuba Certification Frequently Asked Questions. 

Retrieved from http://www.padi.com/scuba/scuba-diving-guide/start-scuba-diving/scubacertification-faq/default.aspx.

U.S. Department of Defense. (2002). Electromagnetic Environmental Effects: Requirements for Systems. 

(MIL-STD-464A). Wright-Patterson Air Force Base, OH: U.S. Air Force/Aeronautical Systems 

Center.

U.S. Department of Defense. (2009). Protecting Personnel from Electromagnetic Fields. (DoD Instruction 

6055.11). Washington, DC: Under Secretary of Defense for Acquisition, Technology, and 

Logistics.

U.S. Department of Defense. (2012). Department of Defense Manual 6055.09-M, DoD Ammunition and 

Explosives Safety Standards: General Explosives Safety Information and Requirements. 

Washington, DC: Department of Defense.

U.S. Department of Defense. (2015). Department of Defense Instruction 3222.03, DoD Electromagnetic 

Environmental Effects (E3) Program. Washington, DC: Department of Defense.

U.S. Department of the Navy. (2007). Airspace Procedures and Planning Manual (OPNAVINST 370.2J). 

Washington, DC: U.S. Department of the Navy.

U.S. Department of the Navy. (2008a). Test and Safety Planning. (NSWC PCD Instruction 5100.30D).

U.S. Department of the Navy. (2008b). Navy Laser Hazards Control Program OPNAVINST 5100.27B / 

Marine Corps Order 5104.1C. Washington, DC: Office of the Chief of Naval Operations and 

Headquarters United States Marine Corps.

U.S. Department of the Navy. (2009). Narragansett Bay Shallow Water Test Facility. Retrieved from 

https://www.fbo.gov/?s=opportunity&mode=form&tab=core&id=5fbacfbaa49a922882285d9b3

bf3eef7&_cview=1.

U.S. Department of the Navy. (2011a). Navy Safety and Occupational Health Program Manual. 

(OPNAVINST 5100.23G CH-1). Washington, DC: U.S. Department of the Navy.

U.S. Department of the Navy. (2011b). U.S. Navy Dive Manual. Washington, DC: Commander, Naval Sea 

Systems Command.

U.S. Department of the Navy. (2015a). Manual for the Utilization of Fleet Area Control and Surveillance 

Facility, Virginia Capes Operations Areas. (FACSFACVACAPESINST 3120.1N). Virginia Beach, VA: 

Department of the Navy.

U.S. Department of the Navy. (2015b). Fleet Area Control and Surveillance Facility Jacksonville 

Instruction 3001.G, Operations Manual. Jacksonville, FL: Department of the Navy.

U.S. Department of the Navy. (2016). Commander Operational Test and Evaluation Force Instruction 

3980.2G, Operational Test Directors Manual. Norfolk, VA: Department of the Navy.
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Table of Contents

Final 

Environmental Impact Statement/Overseas Environmental Impact Statement 

Atlantic Fleet Training and Testing

TABLE OF CONTENTS

4 CUMULATIVE IMPACTS ___________________________________________________________4-1

4.1 Principles of Cumulative Impacts Analysis ..................................................................4-1

4.1.1 Determination of Significance................................................................................4-1

4.1.2 Identifying Region of Influence or Geographical Boundaries for 

Cumulative Impacts Analysis ................................................................................4-2

4.2 Projects and Other Activities Analyzed for Cumulative Impacts...................................4-2

4.3 Cumulative Impacts on Environmental Resources.....................................................4-29

4.4 Resource-Specific Cumulative Impacts......................................................................4-29

4.4.1 Air Quality ............................................................................................................4-29

4.4.2 Sediments and Water Quality..............................................................................4-31

4.4.3 Vegetation............................................................................................................4-34

4.4.4 Invertebrates........................................................................................................4-35

4.4.4.1 Region of Influence..............................................................................4-35

4.4.4.2 Resource Trends ..................................................................................4-35

4.4.4.3 Impacts of Other Actions.....................................................................4-35

4.4.4.4 Impacts of the Proposed Action That May Contribute to 

Cumulative Impacts.............................................................................4-37

4.4.4.5 Cumulative Impacts on Invertebrates .................................................4-37

4.4.5 Habitats................................................................................................................4-38

4.4.6 Fishes ...................................................................................................................4-39

4.4.7 Marine Mammals.................................................................................................4-41

4.4.7.1 Region of Influence..............................................................................4-41

4.4.7.2 Resource Trends ..................................................................................4-42

4.4.7.3 Impacts of Other Actions.....................................................................4-42

4.4.7.4 Impacts of the Proposed Action That May Contribute to 

Cumulative Impacts.............................................................................4-49

4.4.7.5 Cumulative Impacts on Marine Mammals...........................................4-51

4.4.8 Reptiles ................................................................................................................4-52

4.4.8.1 Region of Influence..............................................................................4-52

4.4.8.2 Resource Trends ..................................................................................4-52

4.4.8.3 Impacts of Other Actions.....................................................................4-53
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Table of Contents

4.4.8.4 Impacts of the Proposed Action That May Contribute to 

Cumulative Impacts.............................................................................4-57

4.4.8.5 Cumulative Impacts on Reptiles..........................................................4-59

4.4.9 Birds and Bats ......................................................................................................4-60

4.4.10 Cultural Resources...............................................................................................4-61

4.4.11 Socioeconomics ...................................................................................................4-61

4.4.12 Public Health and Safety ......................................................................................4-62

4.5 Summary of Cumulative Impacts..............................................................................4-62

List of Figures 

This section does not contain figures.

List of Tables

Table 4.2-1: Past, Present, and Reasonably Foreseeable Actions .............................................................4-4

Table 4.2-2: Ocean Pollution and Ecosystem Alteration Trends .............................................................4-26

Table 4.4-1: Entanglements by Year: Summary of the Confirmed Human-Caused Mortality 

and Serious Injury Events Involving Baleen Whale Stocks along the Gulf of 

Mexico Coast, United States East Coast and Atlantic Canadian Provinces, 

2010–2014 .............................................................................................................4-45

Table 4.4-2: Vessel Collisions by Year: Summary of the Confirmed Human-Caused Mortality 

and Serious Injury Events Involving Baleen Whale Stocks along the Gulf of 

Mexico Coast, United States East Coast and Atlantic Canadian Provinces, 

2010–20142.............................................................................................................4-47
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4.0 Cumulative Impacts

4 CUMULATIVE IMPACTS

4.1 PRINCIPLES OF CUMULATIVE IMPACTS ANALYSIS

The approach taken herein to analyze cumulative effects meets the objectives of the National 

Environmental Policy Act (NEPA) of 1969, Council on Environmental Quality regulations, and Council on 

Environmental Quality guidance. Council on Environmental Quality regulations (40 Code of Federal 

Regulations [CFR] 1500-1508) provide the implementing procedures for NEPA. The regulations define 

“cumulative effects” as: 

...the impact on the environment which results from the incremental impact of the action when 

added to other past, present, and reasonably foreseeable future actions regardless of what 

agency (Federal or non-Federal) or person undertakes such other actions. Cumulative impacts 

can result from individually minor but collectively significant actions taking place over a period of 

time (40 CFR 1508.7).

The Council on Environmental Quality provides guidance on cumulative impacts analysis in Considering 

Cumulative Effects Under the NEPA (Council on Environmental Quality, 1997). This guidance further 

identifies cumulative effects as those environmental effects resulting “from spatial and temporal 

crowding of environmental perturbations. The effects of human activities will accumulate when a 

second perturbation occurs at a site before the ecosystem can fully rebound from the effects of the first 

perturbation.” Noting that environmental impacts result from a diversity of sources and processes, this 

Council on Environmental Quality guidance observes that “no universally accepted framework for 

cumulative effects analysis exists,” while also noting that certain general principles have gained 

acceptance. One such principle provides that “cumulative effects analysis should be conducted within 

the context of resource, ecosystem, and community thresholds—levels of stress beyond which the 

desired condition degrades.” Thus, “each resource, ecosystem, and human community must be analyzed 

in terms of its ability to accommodate additional effects, based on its own time and space parameters.” 

Therefore, cumulative effects analysis normally will encompass a region of influence or geographic 

boundaries beyond the immediate area of the proposed action, and a time frame including past actions 

and foreseeable future actions, to capture these additional effects. Bounding the cumulative effects 

analysis is a complex undertaking, appropriately limited by practical considerations. Thus, Council on 

Environmental Quality guidelines observe that 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.”

4.1.1 DETERMINATION OF SIGNIFICANCE

Per the Council on Environmental Quality’s Considering Cumulative Effects Under the NEPA (Council on 

Environmental Quality, 1997), the “levels of acceptable change used to determine the significance of 

effects will vary depending on the type of resource being analyzed, the condition of the resource, and 

the importance of the resource as an issue.” Furthermore, “this change is evaluated in terms of both the 

total threshold beyond which the resource degrades to unacceptable levels and the incremental 

contribution of the proposed action to reaching that threshold.” In practice, “the analyst must 

determine the realistic potential for the resource to sustain itself in the future and whether the 

proposed action will affect this potential.” In other words, for a proposed action to have a cumulatively 

significant impact on an environmental resource, two conditions must be met. First, the combined 

effects of all identified past, present, and reasonably foreseeable projects, activities, and processes on a 

resource, including the effects of the proposed action, must be significant. Second, the proposed action 

must make a measurable or meaningful contribution to that significant cumulative impact.
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4.1.2 IDENTIFYING REGION OF INFLUENCE OR GEOGRAPHICAL BOUNDARIES FOR 

CUMULATIVE IMPACTS ANALYSIS

The region of influence or geographic boundaries for analyses of cumulative impacts can vary for 

different resources and environmental media. Council on Environmental Quality guidance (Council on 

Environmental Quality, 1997) indicates that geographic boundaries for cumulative impacts almost 

always should be expanded beyond those for the project-specific analyses. This guidance continues, 

indicating that one way to evaluate geographic boundaries is to consider the distance an effect can 

travel, and it identifies potential cumulative assessment boundaries accordingly. For air quality, the 

potentially affected air quality regions are generally the appropriate boundaries for assessment of 

cumulative impacts from releases of pollutants into the atmosphere; however, greenhouse gases impact 

the entire atmosphere. For water resources and land-based effects, watershed boundaries may be the 

appropriate regional boundary. For wide-ranging or migratory wildlife, specifically marine mammals, 

fish, turtles, and sea birds, any impacts of the Proposed Action might combine with the impacts of other 

activities or processes within the range of the population. 

A region of influence for evaluating the cumulative impacts of the Proposed Action is defined for each 

resource in Section 4.4 (Resource-Specific Cumulative Impacts). The basic region of influence or 

geographic boundary for the majority of resources analyzed for cumulative impacts in this 

Environmental Impact Statement (EIS)/Overseas Environmental Impact Statement (OEIS) is the entire 

Atlantic Fleet Training and Testing (AFTT) Study Area (Figure 2.1-1), although the geographic boundaries 

for cumulative impacts analysis for some resources are expanded to include activities outside the Study 

Area that might impact migratory or wide-ranging animals. Other activities potentially originating from 

outside the Study Area that are considered in this analysis include impacts associated with maritime 

traffic (e.g., vessel strikes and underwater noise) and commercial fishing (e.g., bycatch and 

entanglement).

4.2 PROJECTS AND OTHER ACTIVITIES ANALYZED FOR CUMULATIVE IMPACTS

Cumulative analysis includes consideration of past, present, and reasonably foreseeable future actions. 

For past actions, the cumulative impacts analysis only considers those actions or activities that have had 

ongoing impacts that may be additive to impacts of the Proposed Action. Likewise, present and 

reasonably foreseeable future actions selected for inclusion in the analysis are those that may have 

effects additive to the effects of the Proposed Action as experienced by specific environmental 

receptors.

The cumulative impacts analysis makes use of the best available data, quantifying impacts where 

possible and relying on qualitative description and best professional judgement where detailed 

measurement is unavailable. Because specific information and data on past projects and actions are 

typically scarce, the analysis of past effects is often qualitative (Council on Environmental Quality, 1997). 

Likewise, analysis for ongoing actions is often inconsistent or unavailable. All likely future development

or use of the region is considered to the greatest extent possible, even when foreseeable future action is 

not planned in sufficient detail to permit complete analysis (Council on Environmental Quality, 1997).

The cumulative impacts analysis is not bounded by a specific future timeframe. The Proposed Action 

includes general types of activities addressed by this EIS/OEIS that are expected to continue indefinitely, 

and the associated impacts could occur indefinitely. Likewise, some reasonably foreseeable future 

actions and other environmental considerations addressed in the cumulative impacts analysis are 

expected to continue indefinitely (e.g., oil and gas production, maritime traffic, commercial fishing). 
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4.0 Cumulative Impacts

While Navy training and testing requirements change over time in response to world events, it should be 

recognized that available information, uncertainties, and other practical constraints limit the ability to 

analyze cumulative impacts for the indefinite future. Navy environmental planning and compliance for 

training and testing activities is an ongoing process, and the Navy anticipates preparing new or 

supplemental environmental planning documents covering changes in training and testing activities in

the Study Area as necessary. These future environmental planning documents would include cumulative 

impacts analysis based on information available at that time. 

Table 4.2-1 describes other actions that have had, continue to have, or would be expected to have some 

impact upon resources also impacted by the Proposed Action within the Study Area and surrounding 

areas. These activities are selected based on information obtained during the scoping process and Draft 

EIS/OEIS public comment period (Appendix H, Public Comment Responses), communications with other 

agencies, a review of other military activities, literature review, previous NEPA analyses, and other 

available information. Table 4.2-1 focuses on identifying past and reasonably foreseeable future actions

(military mission, testing, and training; offshore energy development; ocean-dependent commercial 

industries; and research). Table 4.2-2 focuses on other major environmental stressors or trends that 

tend to be widespread and arise from routine human activities and multiple past, present, and future 

actions. For perspective of general project locations, please refer to Figure 3.0-1 and Figures 3.0-4 

through 3.0-6, which depict the Study Area, boundaries of individual training and testing locations, and 

large marine ecosystems and open ocean areas within and adjacent to the Study Area. Many of the 

commercial stressors are also depicted in Figure 3.11-1 through Figure 3.11-11.
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Table 4.2-1: Past, Present, and Reasonably Foreseeable Actions

Project Location Project Description

Summary ofImpact

Minimization and 

Mitigation 

Measures

1

Project Timeframe

C = Construction 

O = Operation

X=Other

Past Present Future

Military Mission, Testing, and Training Activities

Training 

Activities at 

Eglin Gulf Test 

and Training 

Range

Warning Areas 

(W-151, W168, and 

W-470) and 

Eglin Water 

Test Areas 

WTA-1 through 

WTA-6

Undersea, 

Surface, 

Airspace, 

Valparaiso, 

Florida

The Eglin Gulf Test and Training Range supports a variety of air operations 

and ordnance training and testing activities accomplished predominately 

over the Gulf of Mexico (Eglin Air Force Base, 2015). Eglin Gulf Test and 

Training Range warning areas are adjacent to Navy-operated W-155 

offshore Pensacola and W-174 west of the Florida Keys. Overall, training 

and testing at Eglin Gulf Test and Training Range includes detonation and 

live munitions that have the potential for causing harassment, injury, or 

mortality to marine mammals and sea turtles. The Air Force has consulted 

with the National Marine Fisheries Service (NMFS) regarding these effect 

and determined Level A takes to the bottlenose dolphin and the Atlantic 

spotted dolphin would be avoided and Level B takes would be reduced to 

the greatest extent possible through mitigation measures NMFS has issued 

a Letter of Authorization under the Marine Mammal Protection Act 

(MMPA), valid from February 2018 to February 2023, for taking of marine 

mammals incidental to the following activities: 

 86th Fighter Weapons Squadron Maritime Weapons System Evaluation 

Program test missions involve the use of multiple types of live and inert 

munitions (bombs and missiles detonated above, at, or slightly below the 

water surface)

 Advanced Systems Employment Project actions that involve deployment of 

a variety of pods, air-to-air missiles, bombs, and other munitions (all inert 

ordnance types)

 Air Force Special Operations Command training, including air-to-surface 

gunnery missions involving firing live gunnery rounds at targets on the 

water surface in the Eglin Gulf Test and Training Range, small diameter 

bomb, and Griffin/Hellfire missile training involving the use of live missiles 

and small diameter bombs in the Test and Training Range against small 

towed boats, and CV-22 tiltrotor aircraft training involving the firing of 

0.50 caliber/7.62 mm ammunition at flares floating on the water surface

Pre- and post-event 

monitoring; visual 

and acoustic 

observation for 

marine mammals 

and turtles 

(including 

indicators such as 

Sargassum rafts 

and large schools 

of fish, jellyfish, 

and diving birds);

ceasing of activities 

in response to 

sightings.

0 0 0
Atlantic Fleet

Training and Testing Final EIS/OEIS September 2018

4-5

4.0 Cumulative Impacts

Table 4.2-1: Past, Present, and Reasonably Foreseeable Actions (continued)

Project Location Project Description

Summary of Impact 

Minimization and 

Mitigation

Measures1

Project Timeframe

C = Construction 

O = Operation

X = Other

Past Present Future

Training 

Activities at 

Eglin Gulf Test 

and Training 

Range

(continued)

 413th Flight Test Squadron Precision Strike Program activities involving firing 

munitions at flare targets on the water surface of the Test and Training 

Range and Stand-Off Precision Guided Munitions testing involving captivecarry, store separation, and weapon employment tests

 780th Test Squadron activities involving precision strike weapon test 

missions (launch of munitions against targets in the Test and Training Range) 

and Longbow Littoral Testing (data collection on tracking and impact ability 

of the Longbow missile on small boats)

 96th Test Wing Inert Missions (developmental testing and evaluation for wide 

variety of air-delivered weapons and other systems using inert bombs)

 96 Operations Group missions, which involve the support of air-to-surface 

missions for several user groups within Test and Training Range (National 

Marine Fisheries Service, 2018b)

0 0 0

Construction of 

the Undersea 

Warfare 

Training Range

500 square 

nautical miles 

(NM2) of Naval 

Air Station

Jacksonville, 

Florida Operating 

Area (OPAREA)

Undersea (120 to 

900 feet [ft.]

deep)

Includes the installation of undersea cables and up to 300 transducer nodes 

linked to Naval Air Station Jacksonville, approximately 50 NM offshore from 

Mayport, Florida (U.S. Department of the Navy, 2009b, 2009c). The use of the 

range for anti-submarine warfare training and testing activities is analyzed in 

this EIS/OEIS as part of the Proposed Action (Section 2.0, Description of the 

Proposed Action and Alternatives). Construction began in Fiscal Year 2014, 

and initial operational capability is anticipated in Fiscal Year 2019.

Short-term sedimentation/turbidity may occur with construction activities; 

however, no long-term impacts on any biological receptors are anticipated 

from the development of the Undersea Warfare Training Range. Existing 

conservation measures in place at Mayport beach minimize or eliminate 

potential adverse impacts to the nesting activities of loggerhead and green 

sea turtles.

Construction not to 

occur during calving 

months to avoid

disturbance to the 

North Atlantic right 

whale. 

C C O
Atlantic Fleet

Training and Testing Final EIS/OEIS September 2018

4-6

4.0 Cumulative Impacts

Table 4.2-1: Past, Present, and Reasonably Foreseeable Actions (continued)

Project Location Project Description

Summary of Impact 

Minimization and 

Mitigation

Measures1

Project Timeframe

C = Construction 

O = Operation

X = Other

Past Present Future

Homeporting 

of Littoral 

Combat Ships 

Naval Station 

Mayport, 

Jacksonville, 

Florida

Includes the construction of facilities and establishment of functions required 

to support the homeporting of up to 14 Littoral Combat Ships (U.S. 

Department of the Navy, 2013a).

The first ships began to arrive in 2016 and the action is scheduled to be 

completed by 2020. Aircraft systems and personnel associated with the 

Littoral Combat Ships were analyzed in previous documents and are already 

established and based at Navy installations on the East Coast. Vessel transport 

and training activities were analyzed in the Navy’s 2009 Virginia Capes, Navy 

Cherry Point, and Jacksonville Range Complex EIS/OEIS (U.S. Department of 

the Navy, 2009a). Littoral Combat Ships transits, training, and testing activities 

were analyzed in the AFTT Phase II EIS/OEIS (U.S. Department of the Navy, 

2013a). 

No long-term impacts are anticipated from construction and demolition 

activities.

C O O

Joint Logistics 

Over-the-Shore 

Training 

Joint 

Expeditionary 

Base Little CreekFort Story, 

Virginia or 

Marine Corps 

Base Camp 

Lejeune, North 

Carolina

Joint Logistics Over-the-Shore Training may be conducted jointly by the Navy, 

Marine Corps, and Army and consists of loading/unloading of cargo and 

personnel onto ships without fixed port facilities. Training includes in-water 

and land-based activities such as ferrying cargo to land from anchored ships, 

construction and use of an elevated causeway system from beach to water, 

use of water purification and liquid (fuel) transfer systems from shore to 

watercraft, and establishment of onshore temporary tent encampments (U.S. 

Department of the Navy, 2015). 

Impacts from Joint Logistics Over-the-Shore Training are mitigated to the

greatest extent possible and include the potential to contribute minimal inwater noise from pile driving and removal (up to 30 days annually);

temporary, localized impacts on soft bottom habitat and shoreline

Dune and seabeach 

amaranth 

avoidance; soft 

starts (pile driving); 

observation for 

marine mammals 

and turtles; ceasing 

of activities in 

response to 

sightings.

O O O
Atlantic Fleet

Training and Testing Final EIS/OEIS September 2018

4-7

4.0 Cumulative Impacts

Table 4.2-1: Past, Present, and Reasonably Foreseeable Actions (continued)

Project Location Project Description

Summary of Impact 

Minimization and 

Mitigation

Measures1

Project Timeframe

C = Construction 

O = Operation

X = Other

Past Present Future

Joint Logistics 

Over-the-Shore 

Training

(continued)

environment; and temporary physiological or behavioral impacts on individual 

birds, sea turtles, and marine mammals. Activities may affect, but are not 

likely to adversely affect, the fin whale, the North Atlantic right whale, and

West Indian manatee, and a MMPA Letter of Authorization was requested for 

the Level B take of bottlenose and Atlantic spotted dolphins (U.S. Department 

of the Navy, 2014). The project would not be expected to result in any Level A 

incidental takes. Note that the pile driving component of this EA has been 

added to the AFTT Proposed Action and is, therefore, analyzed in the 

environmental consequences analysis of this EIS/OEIS rather than this 

cumulative impacts analysis.

Training 

Conducted by 

U.S. Army 

Vessels from

Joint Base

Langley-Eustis

Virginia Capes 

Range Complex 

(Warning Area 

50), Hampton, 

Virginia

The Army conducts approximately 10 surface-to-surface gunnery training 

events per year in the Virginia Capes Range Complex, which generally includes 

firing approximately 2,400 rounds (.50 caliber) from a Landing Craft Utility 

vessel at floating, plastic drum targets that are recovered after use. 

Although this action has the potential to affect marine mammals and sea 

turtles, analysis of potential for strikes of military expended material on 

marine mammals or sea turtles in Chapters 3.7 and 3.8 indicate that this is a 

low risk, and it is likely that these similar Army activities would have a similarly 

low risk.

Requires standard 

200 yard safety zone

O O O

Demolition/

Replacement of 

Pier 32/

Demolition of 

Pier 10

At existing piers

in the Thames 

River, Naval

Submarine Base 

New London, 

Groton, 

Connecticut

The Proposed Action would demolish Piers 32 and 10 and replace them with 

one pier that meets all current Navy nuclear-powered fast attack submarine 

pier standards to accommodate Virginia Class submarines (U.S. Department of 

the Navy, 2017a). Sediment under the piers, alongside the proposed new pier, 

and in the navigation channel would be dredged. The quay wall north of Pier 

32 may be upgraded to support a crane weight testing area. 

Construction impacts on marine mammals, benthic invertebrates, shellfish,

and fish would be temporary in nature and include sediment suspension,

Dredge window 

avoids impacts to 

Essential Fish 

Habitat for Atlantic 

sturgeon.

C
Atlantic Fleet

Training and Testing Final EIS/OEIS September 2018

4-8

4.0 Cumulative Impacts

Table 4.2-1: Past, Present, and Reasonably Foreseeable Actions (continued)

Project Location Project Description

Summary of Impact 

Minimization and 

Mitigation

Measures1

Project Timeframe

C = Construction 

O = Operation

X = Other

Past Present Future

Demolition/

Replacement of 

Pier 32/

Demolition of 

Pier 10

(continued)

especially from dredging, and underwater noise from demolition and pile 

driving. Underwater noise effects from demolition and pile driving are 

expected to occur periodically for up to 35 non-consecutive months (2018 to 

2022), and harbor and gray seals may be exposed to Level A and Level B 

thresholds for marine mammals. The Navy has requested a MMPA Letter of 

Authorization from NMFS for incidental take of harbor and gray seal in the 

vicinity of the proposed action.

Navy Atlantic 

Fleet Training

and Testing

Approximately 

2.6 million 

square nautical 

miles over the air 

and seaspace in 

the Atlantic 

Ocean along the 

eastern coast of 

the United 

States, in the 

Gulf of Mexico, 

and in portions 

of the Caribbean 

Sea – at existing 

at-sea range 

complexes and 

testing ranges, in 

high seas areas, 

and at Navy pier 

side locations, 

within port 

transit channels, 

near 

The Navy At-Sea Policy directs the Navy to develop a comprehensive, 

programmatic approach to environmental compliance for exercises and 

training at sea (U.S. Department of the Navy, 2000). The Navy has evaluated 

impacts from past activities as well as present training and testing activities 

based on changing operational requirements, new platforms, and new 

systems. The Navy uses these analyses to support incidental take 

authorizations under the MMPA.

Prior to this EIS/OEIS, the 2013 Phase II AFTT EIS/OEIS provided the most 

recent comprehensive analysis of the full geographic scope of areas where 

Navy training and testing activities have historically occurred as well as those 

projected for a 5-year range(U.S. Department of the Navy, 2013b). The full 

breadth of activities, and their potential impacts, were similar in nature to 

those analyzed in this EIS/OEIS, and 49,225 hours of hull-mounted midfrequency sonar use were estimated to occur between 2013 and 2018; 

although, in practice the actual hours of sonar were significantly lower 

(Figures 2.5-1 through 2.5-3). Likewise, the detonation of a maximum of 

177,749 explosives was evaluated over a 5-year period, 85% of which were 

Explosive Class 1 (0.1 to 0.25 lb) (Section 2.5.4, Comparison of Proposed Sonar 

and Explosive Use in the Action Alternatives to the 2013 – 2018 MMPA Permit 

Allotment). 

During the 2013 AFTT Phase II EIS/OEIS effort, MMPA incidental take

Mitigation measures 

established for most 

in-water activities, 

including specific 

lookout procedures 

and recommended 

mitigation zones and 

protection focus.

A Scientific Advisory 

Group of leading 

marine mammal 

scientists assisted 

the development of 

an Integrated 

Comprehensive 

Monitoring 

Program, which

coordinated

monitoring efforts 

across all regions 

where the Navy 

trains.

O O
Atlantic Fleet

Training and Testing Final EIS/OEIS September 2018

4-9

4.0 Cumulative Impacts

Table 4.2-1: Past, Present, and Reasonably Foreseeable Actions (continued)

Project Location Project Description

Summary of Impact 

Minimization and 

Mitigation

Measures1

Project Timeframe

C = Construction 

O = Operation

X = Other

Past Present Future

Navy Atlantic 

Fleet Training

and Testing 

(continued)

civilian ports, and 

in bays, harbors, 

and inland 

waterways (see 

Figure 1.2-1)

authorizations and incidental take statements under the Endangered Species

Act (ESA) were issued by NMFS to the Navy for range complexes on the East 

Coast and in the Gulf of Mexico and the Naval Surface Warfare Center, 

Panama City Division testing range in the Gulf of Mexico. Negligible to no 

impacts have been observed to populations of marine mammals, sea turtles 

and other marine reptiles, birds, marine vegetation, marine invertebrates, and 

fish from acoustic, energy, physical disturbance and strike, entanglement, 

ingestion, and other secondary stressors associated with Navy training and 

testing activities. Monitoring occurred during training and testing events and 

generally through the Integrated Comprehensive Monitoring Program.

Surveillance 

Towed Array 

Sensor System 

Low Frequency 

Active Sonar

Pacific, Atlantic

(including the 

Study Area), and 

Indian Ocean, 

and 

Mediterranean 

Sea. Undersea, 

12 NM away 

from any 

coastline, 400 ft. 

below surface

Although the operation of Surveillance Towed Array Sensor System Low

Frequency Active Sonar systems has been analyzed for potential 

environmental effects in the Study Area, the activity has never been used in 

the Study Area. The Navy utilizes Surveillance Towed Array Sensor System Low 

Frequency Active Sonar systems onboard several stalwart-class auxiliary 

general ocean surveillance ships in the western and central North Pacific 

Ocean, not including polar waters, and the southwestern Indian Ocean. The 

Navy is currently conducting covered Surveillance Towed Array Sensor System 

Low Frequency Active Sonar activities pursuant to a National Defense 

Exemption (under the MMPA). This exemption expires in August of 2019 and 

the Navy is in the process of updating its relevant environmental planning and 

compliance documents. 

The Navy has been operating Surveillance Towed Array Sensor System Low 

Frequency Active Sonar systems since 2002 in ocean areas outside of the Study 

Area and plans to continue the operation of up to four systems for use in 

routine training, testing, and military operations (U.S. Department of the Navy, 

2016). These Low Frequency Active/Compact Low Frequency Active sonar 

occur less than 255 hours per vessel (1,020 total) over 240 days per year.

NMFS consultation has not occurred specific to the Study Area as the activity

Monitoring (visual, 

passive acoustic, 

and active acoustic) 

and enforcing delay/ 

suspension 

protocols. Use of 

“fish finder” (HF/M3 

sonar) detects, 

locates, and tracks 

marine mammals 

and, to an extent, 

sea turtles, that may 

pass close enough to 

the Surveillance 

Towed Array Sensor 

System Low 

Frequency Active 

sonar’s transmit 

array to enter the 

mitigation zone.
Atlantic Fleet

Training and Testing Final EIS/OEIS September 2018

4-10

4.0 Cumulative Impacts

Table 4.2-1: Past, Present, and Reasonably Foreseeable Actions (continued)

Project Location Project Description

Summary of Impact 

Minimization and 

Mitigation

Measures1

Project Timeframe

C = Construction 

O = Operation

X = Other

Past Present Future

Surveillance 

Towed Array 

Sensor System 

Low Frequency 

Active Sonar

(continued)

does not and is not likely to occur in this location. In general, the operation of 

Surveillance Towed Array Sensor System Low Frequency Active Sonar has low 

to moderate potential to affect marine mammals, sea turtles, and fishes. 

Anticipated impacts on turtles include ESA harassment, including nonauditory, auditory, behavioral, masking, or physiological stress impacts when 

turtles are in close proximity. Impacts to marine mammals are anticipated to 

be Level B harassment, including auditory or behavioral impacts. These 

impacts do not occur in the Study Area and are not likely to affect wideranging individuals that traverse the Study Area. 

U.S. Coast 

Guard 

Activities 

U.S. Coast Guard 

District 1 (Maine 

to New York), 

District 5 (New 

Jersey to North 

Carolina), District 

7 (South Carolina 

to Florida, 

including the 

Caribbean), and 

District 8 

(Alabama to New 

Mexico)

The U.S. Coast Guard performs maritime humanitarian, law enforcement, and 

safety services in estuarine, coastal, and offshore waters. U.S. Coast Guard 

training and mission activities include boat and ship exercises; fixed-wing 

aircraft and helicopter activities; gunnery, including munitions and other 

expendables such as signal flares and marine markers; and the use of high 

frequency and ultra-high frequency sonar detection systems.

U.S. Coast Guard mission and training activities contribute vessel noise and 

could result in collisions with marine mammals and sea turtles. Sonar 

detection systems could have impacts on marine mammals, including toothed 

whales and pinnipeds, but only short-term, minor, adverse effects would be 

expected as the high frequency is not unlike common commercial fish finder 

systems (U.S. Coast Guard, 2013). Gunnery activities could contribute military 

expended material to the benthic environment; however, results of Navy 

modeling efforts discussed for the Proposed Action indicate a low risk that 

marine mammals or sea turtles would be struck by military expended material 

during training activities, and it is likely that similar U.S. Coast Guard activities 

would have a similarly low risk.

Observation for 

marine mammals 

and turtles; ceasing 

of activities in 

response to 

sightings.

O O O
Atlantic Fleet

Training and Testing Final EIS/OEIS September 2018

4-11

4.0 Cumulative Impacts

Table 4.2-1: Past, Present, and Reasonably Foreseeable Actions (continued)

Project Location Project Description

Summary of Impact 

Minimization and 

Mitigation

Measures1

Project Timeframe

C = Construction 

O = Operation

X = Other

Past Present Future

National 

Aeronautics 

and Space 

Administration

Offshore Wallops 

Flight Facility, 

Virginia and 

Kennedy Space 

Center at Cape 

Canaveral, 

Florida

National Aeronautics and Space Administration has designated downrange 

danger zones and restricted areas that include hazard and debris areas from 

rocket tests, satellite launches, and other range mission activities. 

These activities are likely to have temporary, isolated impacts on local 

ecosystems, including the addition of marine debris, noise, and potential for 

take or harassment of individual marine mammals and sea turtles. NMFS

concluded that Wallops operations are infrequent enough to not warrant the 

need for an Incidental Take Statement for marine mammals or sea turtles 

from over-ocean rocket operations (U.S. Army Corps of Engineers, 2012).

O O O

U.S. Outer Continental Shelf Energy Development

Oil and Gas 

Leasing 

Programs

(Section 

3.11.2.1.3, Oil 

and Gas)

Federal Waters: 

Gulf of Mexico

Outer 

Continental 

Shelf, 

approximately 

200 to 350 NM 

seaward from 

state (Texas, 

Louisiana, 

Alabama, Florida) 

jurisdictional 

boundary

(Figures 3.11-1 

through 3.11-3)

Six million of the 160 million acres (ac) in the Gulf of Mexico Outer Continental 

Shelf are producing oil and natural gas (Bureau of Ocean Energy Management, 

2017c). There are over 2,400 facilities and 27,000 miles (mi.) of pipeline 

(Bureau of Safety and Environmental Enforcement, 2017a). Oil and gas leasing 

activities may occur on a given lease tract for 40 to 70 years and include 

geophysical (sonar) surveys, drilling of exploration, development and 

production wells; installation and operation of platforms and pipelines and 

support facilities; transport of hydrocarbons using pipelines or tankers to 

processing locations; and decommissioning.

The number of active leases and wells fluctuates regularly, but on average, the 

Gulf of Mexico has more than 2,400 production platforms and a weekly 

average of 37 drilling rigs (Bureau of Safety and Environmental Enforcement, 

2017a). The majority of active platforms are located in water depths from 0 to 

200 meters (m) (Bureau of Safety and Environmental Enforcement, 2017c). 

Specifically, as of March 1, 2017 there were 3,108 active oil and gas leases 

over 16,493,252 ac in the Gulf of Mexico Outer Continental Shelf Region 

(Western Area-Texas: 484 leases over 2,738,322 ac; Central Area- Alabama, 

Louisiana: 2,587 leases over 13,554,260 ac; and Eastern Area- Florida: 37

leases over 200,670 ac) (Bureau of Ocean Energy Management, 2017d).

Avoidance/ 

protection of 

sensitive benthic 

communities, 

including no activity 

zone within 500 feet 

of live bottom 

habitat, 1,000 feet 

of deepwater live 

corals, and 500 feet 

of chemosynthetic 

habitats. Avoidance 

of impacts within 

National Marine 

Sanctuaries. Sitespecific mitigation 

measures evaluated

per project at lease 

sale offering.

C/O C/O C/O
Atlantic Fleet

Training and Testing Final EIS/OEIS September 2018

4-12

4.0 Cumulative Impacts

Table 4.2-1: Past, Present, and Reasonably Foreseeable Actions (continued)

Project Location Project Description

Summary of Impact 

Minimization and 

Mitigation

Measures1

Project Timeframe

C = Construction 

O = Operation

X = Other

Past Present Future

Oil and Gas 

Leasing 

Programs

(Section 

3.11.2.1.3, Oil 

and Gas)

(continued)

Through March 2014, 51,305 productive wells had been drilled in the Gulf of 

Mexico Planning Areas, including 7,800 in the Western Area; 43,400 in the 

Central Area; and 105 in the Eastern Area (Bureau of Ocean Energy 

Management, 2015b). (See Figures 3.11-1 and 3.11-2 for locations of Bureau 

of Ocean Energy Management planning areas and oil and gas exploration 

activities.) The Final Five-Year Program schedules an additional 10 potential 

lease sales in all three Gulf of Mexico Planning Areas from 2017 through 2022 

(Bureau of Ocean Energy Management, 2017e). Up to 4,275 exploratory 

drilling wells are anticipated. Existing activities would continue in the Pacific 

and Atlantic Outer Continental Shelf (see Figures 3.11-1 and 3.11-2 for 

locations of Bureau of Ocean Energy Management planning areas and oil and 

gas exploration activities). Ten oil and gas lease sales were held in the Atlantic 

between 1976 and 1983 (Bureau of Ocean Energy Management, 2014b). Fiftyone wells were drilled on the Atlantic Outer Continental Shelf between 1975 

and 1984, including one well in the Mid-Atlantic Planning Area and seven wells 

in the South Atlantic Planning Area.

In 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 require the 

immediate development of a new 5-Year Outer Continental Shelf Oil and Gas 

Leasing Program with full consideration of areas currently withdrawn from 

exploration, leasing, and development (including the Atlantic Ocean and Gulf 

of Mexico). Additionally, the Executive and Secretarial Orders require the 

expedited consideration of NMFS Incidental Take Authorization requests and 

seismic permitting applications; review of costs, opportunity costs, and 

adequacy of previous consultations for National Marine Sanctuaries and 

Marine Monuments; reconsideration of the Bureau of Safety and 

Environmental Enforcement Oil and Gas and Sulfur Operations in the Outer 

Continental Shelf-Blowout Preventer Systems and Well Control Rule (April

2016); and ceasing all promulgation of the Offshore Air Quality Control,
Atlantic Fleet

Training and Testing Final EIS/OEIS September 2018

4-13

4.0 Cumulative Impacts

Table 4.2-1: Past, Present, and Reasonably Foreseeable Actions (continued)

Project Location Project Description

Summary of Impact 

Minimization and 

Mitigation

Measures1

Project Timeframe

C = Construction 

O = Operation

X = Other

Past Present Future

Oil and Gas 

Leasing 

Programs

(Section 

3.11.2.1.3, Oil 

and Gas)

(continued)

Reporting, and Compliance Proposed Rule (2016). Additionally, the Executive

and Secretary Orders require a review with intent to rescind or revise the 

National Oceanic and Atmospheric Administration (NOAA) Technical 

Memorandum NMFS-OPR-55, Technical Guidance for Assessing the Effects of 

Anthropogenic Sound on Marine Mammal Hearing (July 2016).

The majority of oil and gas structures and the pipelines linking those 

structures with onshore processing and refining facilities are located off of 

Louisiana and do not overlap with Navy testing ranges and OPAREAs 

(Figures 3.11-2 and 3.11-3).

Potential impacts associated with Outer Continental Shelf federal oil and gas 

leasing activities include those associated with noise, traffic, waste discharges, 

sediment disturbance, and risk of accidental spills (Bureau of Ocean Energy 

Management, 2016c). These impacts are generally assumed to be negligible 

due to the dispersed and relatively small footprint of normal operations. In 

the event of small to catastrophic spills, however, impacts grow increasingly 

detrimental to marine life.

State Waters: Gulf 

of Mexico Outer 

Continental Shelf, 

0 to 10 mi. 

offshore Texas, 0 

to 3 mi. offshore 

Louisiana, 

Alabama, and 

Florida (Figure 

3.11-1 through 

3.11-3)

Texas, Alabama, and Louisiana operate robust oil and gas leasing programs in 

state offshore waters (Bureau of Ocean Energy Management, 2016d). There 

are no leases in Mississippi state waters. Activities and potential impacts for 

these programs are similar as described above for the federal program.

C/O C/O C/O

Floating, 

Production, 

Storage, and 

Gulf of Mexico 

Outer 

Continental 

Floating oil and gas production systems occur in deepwater environments, 

storing crude oil in tanks in the hulls of vessels and periodically offloading the 

crude oil to shuttle tankers or ocean-going barges for transport to shore 

No Floating, 

Production, Storage, 

and Offloading 

O O O
Atlantic Fleet

Training and Testing Final EIS/OEIS September 2018

4-14

4.0 Cumulative Impacts

Table 4.2-1: Past, Present, and Reasonably Foreseeable Actions (continued)

Project Location Project Description

Summary of Impact 

Minimization and 

Mitigation

Measures1

Project Timeframe

C = Construction 

O = Operation

X = Other

Past Present Future

Offloading

Systems

Shelf, Western 

and Central 

Planning Areas 

Deepwater

(greater than 

650 ft.) 

(Minerals Management Service, 2001). At this time two systems occur in the 

Walker Ridge area of the Gulf of Mexico: (1) Petrobras America, Inc., located 

165 mi. from Louisiana in approximately 2,500 m of water, produces oil and 

gas (gas is transported to shore by pipeline) (Bureau of Ocean Energy 

Management & Regulation and Enforcement, 2011)and (2) Royal Dutch Shell, 

located 200 mi. southwest of New Orleans in 2,900 m of water (The TimesPicayune, 2015). 

Resources impacted by Floating, Production, Storage, and Offloading systems

include air quality from platform and vessel emissions and water and 

sediment quality especially in the event of a spill (Minerals Management 

Service, 2001). 

Marine mammals, such as the sperm whale, sea turtles, and commercial 

fisheries may also be impacted due to noise from helicopters, service vessels, 

and shuttle tankers and vessel and shuttle tanker traffic may also increase 

collisions with marine mammals. It is anticipated that Floating, Production, 

Storage, and Offloading systems have similar, negligible anticipated 

environmental effects and mitigation measures as those expected for other oil 

development and production systems. Further site-specific, technical and 

environmental evaluation is required for specific Floating, Production, 

Storage, and Offloading proposals.

systems permitted 

within 100 

kilometers (km) of 

the Breton NWA 

Class 1 Air Quality 

area; emission 

restrictions; security 

and safety controls 

for spill prevention 

and damage 

minimization

Liquefied 

Natural Gas 

Terminals

Atlantic Ocean 

and Gulf of 

Mexico, coast 

and nearshore

Liquefied Natural Gas terminals function to regasify liquid natural gas for 

distribution via pipeline networks. Liquefied Natural Gas is imported and 

exported through both offshore and nearshore/ onshore terminals. The 

following Liquefied Natural Gas terminals are within the Study Area:

 12 Existing Import/Export: 6 Gulf of Mexico, 6 Atlantic (Federal Energy 

Regulatory Commission, 2017a)

 15 Approved Import/Export: 12 Gulf of Mexico, 3 Atlantic (Federal Energy 

Regulatory Commission, 2017d)

 14 Proposed Export: 13 Gulf of Mexico, 1 Atlantic (Federal Energy Regulatory 

Commission, 2017c)

C/O C/O C/O
Atlantic Fleet

Training and Testing Final EIS/OEIS September 2018

4-15

4.0 Cumulative Impacts

Table 4.2-1: Past, Present, and Reasonably Foreseeable Actions (continued)

Project Location Project Description

Summary of Impact 

Minimization and 

Mitigation

Measures1

Project Timeframe

C = Construction 

O = Operation

X = Other

Past Present Future

Liquefied 

Natural Gas 

Terminals 

(continued)

 2 Proposed Import: Atlantic (Federal Energy Regulatory Commission, 2017b)

Potential environmental impacts include those associated with additional ship 

traffic, underwater noise from construction and operation, seawater intakes 

and discharges, and potential releases of liquefied natural gas. 

Oil and Gas 

Structure 

Removal 

Operations

Gulf of Mexico

Outer 

Continental 

Shelf, all water 

depths 

Decommissioning seafloor obstructions (wellheads, caissons, casing strings, 

platforms, and mooring devices) includes the explosive and non-explosive 

severing of structures and subsequent salvage and site-clearance operations

(Minerals Management Service, 2005). Decommissioning operations generally 

occur after lease expiration, when the well or facility is no longer deemed 

economically viable, or when the physical condition of the structure becomes 

unsafe or a navigation hindrance. Roughly 108 oil and gas structures are 

removed annually in the Gulf of Mexico. Of these about 66 percent are 

removed using explosives, which are detonated inside pilings and well 

conductors at a depth of 15 ft. below the seafloor.

Potential environmental impacts, such as injury or death to marine mammals, 

fish, sea turtles, and other animals due to nearby underwater blasts and siteclearance trawling activities would be mitigated to negligible most of the time, 

with occasional impacts being potentially adverse but not significant (Minerals 

Management Service, 2007). The effects of bottom-disturbing activities, such 

as anchoring and toppling structures, on sensitive benthic habitat and 

resources may include physical damage to hard bottom features, increased 

turbidity, and covering or smothering of sensitive habitats with re-suspended 

sediments. Site-specific NEPA analyses will be conducted on individual 

applications specifying supplementary mitigation.

General blasting 

criteria and 

scenario-specific 

requirements such 

as avoidance of hard 

bottom habitats and 

anchor restrictions

for support vessel 

and transport use; 

use of turtle 

exclusion devices 

and 30 minute limits 

for site-clearance 

trawling; and 

observation for 

marine mammals 

and turtles, pausing 

activities in response 

to sightings

C C C

Wind Energy 

Development

(Section 

3.11.2.1.2, 

Wind)

Atlantic Ocean 

Outer 

Continental Shelf 

Federal waters

(approximately

200 to 350 NM

Commercial-scale offshore wind facilities are similar to onshore wind facilities, 

and, depending on rotor size and spacing requirements, can include from 14 

(110 m rotor diameter) to 40 (150 m rotor diameter) turbines in one Outer 

Continental Shelf block (3 statute miles by 3 statute miles) (Bureau of Ocean 

Energy Management, 2013b). Average leaseholds are 8 blocks and current 

technology limits development to waters no deeper than 100 m. Development

Implementation of 

proper siting and 

mandatory design 

criteria; sonic 

pingers and/or turtle 

exclusion devices to
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4.0 Cumulative Impacts

Table 4.2-1: Past, Present, and Reasonably Foreseeable Actions (continued)

Project Location Project Description

Summary of Impact 

Minimization and 

Mitigation

Measures1

Project Timeframe

C = Construction 

O = Operation

X = Other

Past Present Future

Wind Energy 

Development

(Section 

3.11.2.1.2, 

Wind)

(continued)

seaward from 

state 

jurisdictional 

boundary)

includes installing the substructure, which is typically a large steel tube (up to 

20 ft. diameter) driven 80 to 100 ft. below the mudline in 15 to 100 ft. water 

depths, with the pole and turbine mounted on top (Minerals Management 

Service, 2007). Each turbine is connected by power cable to an electric service 

platform/substation, typically located somewhere within the turbine array, 

from which buried high voltage cables transmit the power to an onshore 

substation for integration into the onshore grid. Total heights can reach 

upwards of 460 feet with blade tip speeds from 140 to 180 miles per hour 

over a rotor-swept area between 1.1 and 3.3 acres (American Wind Wildlife 

Institute, 2017).

minimize 

entanglement and 

entrainment 

potential; adherence 

to U.S. Coast Guard 

oil spill response 

plans; use of 

environmentally 

friendly chemicals.

Atlantic Ocean 

State waters (0 

to 3 NM from 

shoreline of 

Florida, Georgia, 

South Carolina, 

North Carolina, 

Virginia, 

Maryland, 

Delaware, New 

Jersey, Rhode 

Island, Maine, 

New York, and 

Massachusetts)

Five wind turbines are established and active at Block Island, Rhode Island. 

Thirteen commercial wind energy leases have been issued in federal waters 

on the Outer Continental Shelf, including those offshore Delaware, 

Massachusetts, Maryland, New Jersey, Rhode Island, Virginia, New York, and 

North Carolina (Bureau of Ocean Energy Management, 2017b). Various state 

offshore wind energy programs are also under development. NMFS has issued 

or is in the process of issuing multiple Incidental Harassment Authorizations 

for the take of marine mammals incidental to marine site characterization 

surveys associated with planning for expanded offshore wind energy 

development in the Outer Continental Shelf. For example, Deepwater Wind 

New England has requested marine mammal take authorization that would be 

incidental to seafloor surveys performed to support the siting of potential 

future offshore wind projects in areas off the coast of Rhode Island and

Massachusetts (Lease Area OCS–A-0486) and along potential submarine cable 

routes to a landfall location in Rhode Island, Massachusetts, or New York 

(Federal Register 83(87): 19711-19736 May 4, 2018). Additional offshore 

windfarm projects are expected in the coming years for both research and 

commercial development in state and federal waters.

Site characterization activities include geophysical surveys, sub-bottom
Atlantic Fleet

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4.0 Cumulative Impacts

Table 4.2-1: Past, Present, and Reasonably Foreseeable Actions (continued)

Project Location Project Description

Summary of Impact 

Minimization and 

Mitigation

Measures1

Project Timeframe

C = Construction 

O = Operation

X = Other

Past Present Future

Wind Energy 

Development

(Section 

3.11.2.1.2, 

Wind)

(continued)

sampling, and biological surveys. In particular, extensive aerial and boat 

reconnaissance baseline surveys have been performed specific to Maryland 

and from Cape Cod, Massachusetts, to Cape Hatteras, North Carolina, that 

catalog distribution and abundance of sealife potentially impacted by wind 

energy development in the region (Williams et al., 2015). Site assessment 

activities include installation of meteorological towers and meteorological 

buoys, data collection, and decommissioning of the towers and buoys (Bureau 

of Ocean Energy Management, 2012). 

Most impacts occur during the construction phase, which involves the highest 

amount of vessel traffic, noise generation (pile driving), seafloor disturbance 

(transmission cabling), and air emissions; however, ongoing impacts would 

occur from vessel and turbine strikes; moderate operational noise; 

disturbance of nesting areas; alteration of key habitat; or potential fuel, oil, or 

dielectric fluid spills (Bergström et al., 2014). Potential population-level 

impacts on marine mammals, fish, birds, bats, and sea turtles are mitigated in 

site-specific environmental review and permitting processes. In particular, 

impacts on sea turtles could be minor to moderate because of the 

technologies’ potential to impede sea turtle movement and the potential of 

entrainment in overtopping devices. Additionally, if related onshore facilities 

are located in nesting areas, operation could cause minor to moderate 

adverse impacts on sea turtles due to hatchling disorientation from lighting, 

with possible major impacts if turtle nests or aggregates of hatchlings are 

destroyed. Proper siting, design, and other mitigation measures would 

minimize potential impacts on coastal sediment transport processes, marine 

navigation, commercial shipping, fishing activities, seafloor habitats, marine 

life, areas of special concern, archaeological sites, and U.S. Department of 

Defense (DoD) training and exercise activities.

Marine 

Hydrokinetic 

Power 

Atlantic and Gulf 

Coast, especially 

coastal Maine 

Hydrokinetic power is a type of hydropower that is derived from fast-moving 

marine or estuarine currents driven by waves, tides, or offshore ocean 

currents (U.S. Department of Energy, 2015a). Although offshore hydrokinetic 

No industrystandard impact 

minimization 

C/O
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4.0 Cumulative Impacts

Table 4.2-1: Past, Present, and Reasonably Foreseeable Actions (continued)

Project Location Project Description

Summary of Impact 

Minimization and 

Mitigation

Measures1

Project Timeframe

C = Construction 

O = Operation

X = Other

Past Present Future

Generation 

(Section 

3.11.2.1.1, 

Water)

energy is not generated in the U.S. at this time, it is anticipated that 

widespread testing and deployment of these technologies is possible. There 

are two existing licensed hydrokinetic projects on the Atlantic coast: the 

Cobscook Bay Tidal Project in Maine and the Roosevelt Island Tidal Energy 

Project in New York City. There are two hydrokinetic preliminary permits: the 

Western Passage Tidal Energy project located off the coast of Maine (which 

includes testing 15 500kW turbine-generator hydrokinetic tidal devices), and 

the Cape Cod Canal and Bourne Tidal projects are located in the Cape Cod 

Canal in Massachusetts state waters. Commercial developers are also testing 

scale models of Navy wave energy technology in the wave-making facility at 

Naval Surface Warfare Center Carderock in Maryland (U.S. Department of 

Energy, 2015b). 

Research activities may include sea trials, small-scale prototype testing, and 

research that may use instruments such as acoustic Doppler profile current 

sensors, digital recording sonar, and underwater video and still photography 

taken from unmanned underwater vehicles. Potential environmental 

impactsof testing and deployment are anticipated to be minimal and well 

mitigated, but are largely unknown at this time.

measures yet 

developed as 

technologies are still 

being engineered.

Other Commercial Industries

Undersea 

Communications Cables

Oceans 

worldwide

Submarine cables provide the primary means of voice, data, and Internet 

connectivity between the mainland United States and the rest of the world 

(Federal Communications Commission, 2017). The Federal Communications 

Commission grants licenses authorizing cable applicants to install, own, and 

operate submarine cables and associated landing stations in the United States. 

Cables are installed by specialized boats across flat ocean surfaces and dug 

into the seabed in shallow areas. Over 550,000 mi. of cables currently exist in 

the world’s oceans.
Atlantic Fleet

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4.0 Cumulative Impacts

Table 4.2-1: Past, Present, and Reasonably Foreseeable Actions (continued)

Project Location Project Description

Summary of Impact 

Minimization and 

Mitigation

Measures1

Project Timeframe

C = Construction 

O = Operation

X = Other

Past Present Future

Undersea 

Communications Cables

(continued)

Potential impacts of installation and maintenance activities would include 

noise and vessel strikes from boat traffic and increased seafloor disturbance 

and sedimentation in localized areas where the cable is installed. Likewise, 

electromagnetic fields are generated by some cables that may be sensed by 

and affect the migration behavior of some fish, sharks, rays, and eels (Bureau 

of Ocean Energy Management, 2016b). 

C/O O O

Marine Mineral 

Extraction 

(Section 

3.11.2.2, 

Mineral 

Extraction)

U.S. Outer 

Continental Shelf 

and shoreline, 

including Florida, 

Louisiana, 

Mississippi, New

Jersey, North 

Carolina, South 

Carolina, 

Maryland, and 

Virginia

Extraction of minerals involves primarily hard minerals (e.g., sand and gravel), 

although heavy minerals (e.g., titanium and zircon) are also potential offshore 

resources. Between 2009 and 2016, 21 leases were executed in six states

(Florida, Louisiana, North Carolina, South Carolina, New Jersey, and Virginia

(Bureau of Ocean Energy Management, 2015a). Sand and gravel are dredged 

from leased marine areas and applied to coastal restoration projects, 

including beach nourishment and coastal habitat restoration (Bureau of Ocean 

Energy Management, 2016a). Marine mammals, fish, and sea turtles may be 

impacted directly by dredge operations (including vessel strikes or dredge 

entrainment) or indirectly by noise, turbidity, water quality, and benthic 

habitat alteration produced by such (Bureau of Ocean Energy Management, 

2013a). Beach nourishment activities may impact nearshore habitat, including 

estuaries and bird and turtle nesting areas; however, site/project-specific 

NEPA analysis, mitigation measures, and other stipulations are established for 

each project that are specifically protective of local sensitive physical, 

biological, and cultural resources.

Dredge timing and 

location constraints; 

lighting protocols; 

specialized 

equipment 

requirements; 

monitoring; buffer 

establishment 

surrounding cultural 

resources and hard

bottom habitat 

(Bureau of Ocean 

Energy 

Management, 

2017a).

C/O C/O C/O

Commercial 

Fishing (Section 

3.11.2.4, 

Commercial 

Fishing)

Greater Atlantic

region (Main 

through Cape 

Hatteras, North 

Carolina)

Southeast Region 

(North Carolina 

to Texas)

There are 48 different fisheries in the Greater Atlantic region (National Marine 

Fisheries Service, 2016b). In the Southeast Region there are 21 separate 

fisheries. The National Oceanic and Atmospheric Administration provides 

bycatch data for 50 percent of the Greater Atlantic fisheries and 48 percent of 

those that occur in the Southeast. Figure 3.11-5 illustrates the decline of total 

fish caught in the Atlantic since 1956; Figure 3.11-6 shows a similar decline in 

the Gulf of Mexico. The NMFS issues fishing vessel, dealer, and commercial 

operator permits and fishing authorizations as required under the various 

Federal Fishery Regulations. 

Various bycatch 

mitigation 

technologies, 

quotas, and 

seasonal restrictions

required per the 

fishery-specific 

permit process.

O O O
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4.0 Cumulative Impacts

Table 4.2-1: Past, Present, and Reasonably Foreseeable Actions (continued)

Project Location Project Description

Summary of Impact 

Minimization and 

Mitigation

Measures1

Project Timeframe

C = Construction 

O = Operation

X = Other

Past Present Future

Commercial 

Fishing (Section 

3.11.2.4, 

Commercial 

Fishing)

(continued)

Commercial fishing can adversely affect fish populations, non-target species, 

and habitats. Ecological extinction caused by overfishing precedes all other 

pervasive human disturbance of coastal ecosystems (Jackson et al., 2001). 

Approximately 30 percent of the U.S. managed stocks are overfished (National 

Marine Fisheries Service, 2009b). Bycatch includes the unintentional capture 

of fish, marine mammals, sea turtles, seabirds, and other non-targeted species 

that occur incidental to normal fishing operations. Fisheries bycatch has been 

identified as a primary driver of population declines in several groups of 

marine species, including sharks, mammals, seabirds, and sea turtles (Wallace 

et al., 2010). Commercial fishing often includes the use of mobile fishing gear, 

such as bottom trawls, which increases turbidity, alters surface sediment and 

bottom habitats, removes prey (leading to declines in predator abundance), 

removes predators, and generates marine debris. Ghost fishing occurs when 

lost and abandoned fishing gear, such as gill nets, purse seines, and long-lines, 

continue to ensnare fish and other marine animals without human oversight 

and removal. Lost gear fouls and disrupts bottom habitats and has the 

potential to entangle or be ingested by marine animals.

Recreational 

Fishing (Section 

3.11.2.4.2, 

Recreational 

Fishing)

In 2015, more than 5.2 million residents of Atlantic coast states participated in 

marine recreational fishing. All participants, including visitors, took nearly 34

million trips and caught approximately 188 million fish (National Marine 

Fisheries Service, 2015c). In the Gulf of Mexico in 2015, nearly 2.7 million 

residents of Gulf Coast states participated in marine recreational fishing, 

taking 21 million trips and catching almost 143 million fish. Approximately 10 

percent of the recreational fishing catch is from federal waters, and most 

recreational fishing occurs in estuarine areas.

Recreational fishing includes impacts from vessel traffic (strike, noise, water 

pollution, marine debris) and can compound impacts on fish stocks already 

experiencing exploitation. Recreational fishing and boat traffic usually occurs 

nearshore rather than in the deeper open ocean, and recreational traffic 

O O O
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4.0 Cumulative Impacts

Table 4.2-1: Past, Present, and Reasonably Foreseeable Actions (continued)

Project Location Project Description

Summary of Impact 

Minimization and 

Mitigation

Measures1

Project Timeframe

C = Construction 

O = Operation

X = Other

Past Present Future

Recreational 

Fishing (Section 

3.11.2.4.2, 

Recreational 

Fishing)

(continued)

typically frequents popular locations, which can concentrate damage in these 

areas from anchors or other bottom-disturbing equipment.

Aquaculture 

(Section 

3.11.2.5, 

Aquaculture)

State waters

bordering 

Atlantic Ocean 

and Gulf of 

Mexico 

Aquaculture is the farming of aquatic organisms such as fish, shellfish, and 

plants. Globally, 29 percent of stocks are fished at biologically unsustainable 

levels, and aquaculture helps meet demand and offsets stress to wild 

populations (National Marine Fisheries Service, 2015d). Aquaculture 

production reached an all-time high of 97 million metric tons in 2013 and is 

the fastest growing form of food production, at 6 percent per year globally.

Species are typically farmed in U.S. state waters and include mollusks (oysters, 

clams, mussels) and Atlantic Salmon (National Marine Fisheries Service, 

2015c). Although present throughout the Study Area, Florida and 

Massachusetts have the greatest number of saltwater farms in the Study Area, 

with 169 and 133, respectively (U.S. Department of Agriculture, 2014).

The threats of aquaculture operations on wild fish populations include 

reduced water quality, competition for food, predation by escaped or released 

farmed fishes, spread of disease and parasites, and reduced genetic diversity

(Kappel, 2005). These threats become apparent when farmed fish escape and 

enter the natural ecosystem (Hansen & Windsor, 2006; Ormerod, 2003). The 

Marine Aquaculture Policy provides direction to enable the development of 

sustainable marine aquaculture (National Marine Fisheries Service, 2015d).

C/O C/O C/O

Coastal Land 

Development 

and Tourism 

(Section 

3.11.2.6, 

Tourism)

States bordering 

Atlantic Ocean 

and Gulf of 

Mexico 

Coastal land development adjacent to the Study Area is both intensive and 

extensive, including development of homes, businesses, recreation, vacation, 

and ship traffic at port facilities and marinas. The Study Area coastline also 

includes extensive coastal tourism (hotels, resorts, restaurants, food industry, 

and vacation homes) and its supporting infrastructure (retail businesses, 

marinas, fishing tackle stores, dive shops, fishing piers, recreational boating 

Site-specific 

mitigation often 

determined during 

Coastal Consistency 

Review by the 

respective state’s 

C C C
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4.0 Cumulative Impacts

Table 4.2-1: Past, Present, and Reasonably Foreseeable Actions (continued)

Project Location Project Description

Summary of Impact 

Minimization and 

Mitigation

Measures1

Project Timeframe

C = Construction 

O = Operation

X = Other

Past Present Future

Coastal Land 

Development 

and Tourism 

(Section 

3.11.2.6, 

Tourism)

(continued)

harbors, beaches, and recreational fishing and whale-watching). New 

development in the coastal zone requires a permit from the state or local 

government per the Coastal Zone Management Act. (Chapter 6, Regulatory 

Considerations).

Coastal development intensifies use of coastal resources through dune and 

nearshore habitat loss and disturbance, point and nonpoint source water 

pollution, entrainment in outflows and other structures, and air quality 

degradation. Self-contained underwater breathing apparatus (SCUBA) diving 

and snorkeling has the potential to degrade reef systems through disturbance 

and specimen collecting, and collisions between whale-watching ships and 

whales are common.

Coastal Zone 

Management 

Program

Maritime 

Traffic (Section 

3.11.2.3.1, 

Ocean 

Transportation)

U.S. East Coast

(Figure 3.11-4)

The East Coast of the U.S. is heavily traveled by commercial, recreational, and 

government marine vessels with several commercial ports near Navy 

OPAREAs (see Figure 3.11-4 for commercially used waterways in the Study 

Area). The United States has grown increasingly dependent on international 

trade over the past 50 years. As a result, the number of active ports in the 

Study Area increased, ship traffic increased, and ships are larger. In 2015, 

there were over 23,000 port calls at Atlantic ports (including Puerto Rico and 

the U.S. Virgin Islands) and over 34,000 at Gulf of Mexico ports (U.S. Maritime 

Administration, 2015).

Primary environmental concerns regarding increased maritime traffic include 

vessels striking marine mammals and sea turtles, introduction of non-native 

species through ballast water, and underwater sound from ships and other 

vessels. Additionally, air and water quality in busy ports can be diminished due 

to engine emissions and fuel leaks. Secondary impacts include development 

and maintenance of port infrastructure, which often include dredging 

requirements to maintain channel depths.

O O O
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4.0 Cumulative Impacts

Table 4.2-1: Past, Present, and Reasonably Foreseeable Actions (continued)

Project Location Project Description

Summary of Impact 

Minimization and 

Mitigation

Measures1

Project Timeframe

C = Construction 

O = Operation

X = Other

Past Present Future

Maritime 

Traffic 

(Section 

3.11.2.3.1, 

Ocean 

Transportation) 

(continued)

Panama Canal A project to widen and expand the capacity of the Panama Canal was 

completed in June 2016 that allows larger vessels access to the East Coast 

ports of the U.S. (The Canal Connection, 2017). Ports of Charleston, 

Philadelphia, Savannah, Virginia, and Baltimore have experienced record 

growth in cargo volume as the larger ships traversed the Canal in 2016. Port 

Miami and the Port of New York and New Jersey are significantly investing in 

infrastructure to accommodate big ships, including deep dredging projects. 

(Impacts are similar to those discussed for U.S. East Coast Maritime traffic.)

C O O

Atlantic coast 

Port Access

The Atlantic Coast Port Access Route Study is an ongoing endeavor intended

to enhance navigational safety and reduce vessel collisions (U.S. Coast Guard, 

2016). The Study focuses on shipping routes and near coast users between 

U.S. Atlantic coastal ports, approaches to coastal ports, and future uses of 

those ports. Establishing specific lanes and safety zones concentrates traffic, 

which decreases the extent of disturbance across the landscape but can 

increase the incidence of vessel strike, underwater noise, and air and water 

pollution in the concentrated traffic areas.

O

Research

Geological and 

Geophysical Oil 

and Gas Survey 

Activities

Atlantic Ocean 

Outer 

Continental Shelf, 

Delaware Bay to 

south of Cape 

Canaveral, 

Florida, seaward 

from State 

jurisdictional 

boundary to 

403 mi. offshore

Offshore geological and geophysical activities includes seismic air gun surveys 

and high resolution geophysical surveys supporting oil and gas, renewable 

energy, and marine minerals exploration (Bureau of Ocean Energy 

Management, 2014b). Seismic surveys are accomplished by towing a sound 

source such as an air gun array that emits acoustic energy in timed intervals 

behind a research vessel. Seismic pulses are typically emitted at intervals of 5 

to 60 seconds and source levels are 230.7 decibels (dB) re 1 μPa for the large 

air gun array and 210.3 dB re 1 μPa for the small array (Bureau of Ocean 

Energy Management, 2014b). Seismic air gun surveys are loud enough to 

penetrate hundreds of km into the ocean floor, even after going through 

thousands of meters of ocean (Weilgart, 2013). Between May 2012 and April 

2015, the Bureau of Ocean Energy Management received 14 applications 

Establishing and 

monitoring (visual, 

passive acoustic, and 

active acoustic) safety 

and acoustic exclusion 

zones and enforcing 

delay/ suspension and 

spacing protocols. 

Seasonal 

management includes 

avoidance of North 

Atlantic right whale 

O O O
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4.0 Cumulative Impacts

Table 4.2-1: Past, Present, and Reasonably Foreseeable Actions (continued)

Project Location Project Description

Summary of Impact 

Minimization and 

Mitigation

Measures1

Project Timeframe

C = Construction 

O = Operation

X = Other

Past Present Future

Geological and 

Geophysical Oil 

and Gas Survey 

Activities

(continued)

from 6 different permittees for Atlantic Outer Continental Shelf seismic survey 

activities (Bureau of Safety and Environmental Enforcement, 2015).

Vessel strikes and especially seismic sound production in excess of 180 dB 

could cause adverse impacts on marine mammals, including North Atlantic 

right whales, dolphins, and sea turtles (Bureau of Ocean Energy Management, 

2014a). Additionally, air guns are known to kill zooplankton for at least 0.75 

miles from the point of origination (Tollefson, 2017). All seismic surveys 

conducted by U.S. vessels are subject to required mitigation measures, the

MMPA authorization process administered by the NMFS, as well as the NEPA 

process associated with issuing MMPA authorizations.

and sea turtle 

breeding season and 

critical habitat. 

Maximum sound 

level thresholds 

established and 

enforced.

Academic 

Research

Wide-scale academic research is conducted in the region of influence by 

federal entities, such as the Navy and the National Oceanic and Atmospheric 

Administration/NMFS, as well as state and private entities and other 

partnerships. Academic geologists use seismic surveys/air gun arrays to study 

the ocean floor and beyond, including plate tectonics and volcanic activity. For 

example, research vessel Marcus G. Langseth is owned by the National Science 

Foundation and operated by the Lamont-Doherty Earth Observatory at 

Columbia University for use by academic researchers from universities around 

the world.

Although academic research aims to capture data without disturbing the 

ambient conditions of the ocean environment, vessels contribute traffic, 

noise, and strike hazard; seismic activity contributes noise; and various other 

collection methods, such as trawling, could be disruptive to the ecosystems 

under observation. Impacts from academic research operations can be similar 

to the impacts expected from oil and gas air gun survey activities.

NMFS and states 

manage scientific 

research permits for 

certain activities.

O O O

Field 

Operations at

Sanctuaries 

located in the 

NOAA conducts field operations within Marine Sanctuaries and Monuments, 

which include vessel operations; vessel maintenance; aircraft operations; nonMitigation measures are determined on a 

O O O
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4.0 Cumulative Impacts

Table 4.2-1: Past, Present, and Reasonably Foreseeable Actions (continued)

Project Location Project Description

Summary of Impact 

Minimization and 

Mitigation

Measures1

Project Timeframe

C = Construction 

O = Operation

X = Other

Past Present Future

National 

Marine 

Sanctuaries and 

Marine 

National 

Monuments

(see Section 

6.1.2, Marine 

Protected 

Areas)

Northeast/ Great 

Lakes, and

Southeast/ Gulf 

of Mexico.

motorized craft operations; SCUBA or snorkel operations; onshore field work; 

deployment of autonomous underwater vehicles, remotely operated vehicles, 

gliders, or drifters; deployment of remote sensing equipment (including 

sonar); deployment of equipment on the seafloor; and other sampling

activities (Federal Register 83(102): 38684-38685, August 7, 2018). The field

operations primarily support resource protection, research, and education 

objectives of the National Marine Sanctuaries Act. 

The Programmatic EA of Field Operations in the Southeast and Gulf of Mexico 

National Marine Sanctuaries (National Oceanic and Atmospheric 

Administration, 2018b) and the Programmatic EA of Field Operations in the 

Northeast and Great Lakes National Marine Sanctuaries (National Oceanic and 

Atmospheric Administration, 2018a) analyze the options of maintaining the 

status quo and existing level of operations in National Marine Sanctuaries and 

Monuments for the next 5 years, or increasing the number of small boat 

operations and stopping the requirement for small boat best management 

practices in some locations. These discontinued management practices may 

include existing actions such as vessel speed restrictions, night operation 

prohibitions, on-board marine mammal and other species observer (unless 

specified as required or recommended mitigation measures), restriction of 

navigation to within marked channels, and safe distance requirements from 

whales.

project-by-project 

basis in accordance 

with the ESA, MMPA, 

Essential Fish Habitat 

provisions of the 

Magnuson-Stevens 

Fishery Conservation 

Management Act, 

and the National 

Historic Preservation 

Act.
Atlantic Fleet

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4.0 Cumulative Impacts

Table 4.2-2: Ocean Pollution and Ecosystem Alteration Trends

Stressor Location Description

Hypoxic Zones 

(Section 3.6.2.1.5, 

Water Quality)

Global Hypoxia, or low oxygen, is an environmental phenomenon where the concentration of dissolved oxygen in the water 

column decreases to a level that can no longer support living aquatic organisms. Hypoxia occurs from the rapid 

growth and decay of algal blooms in response to excess nutrient loading (primarily nitrogen and phosphorus from 

agriculture runoff, sewage treatment plants, bilge water, and atmospheric deposition). Animals that encounter the 

Dead Zones flee, experience physiological stress, or suffocate (National Oceanic and Atmospheric Administration, 

2016; Texas A&M University, 2011, 2014). Hypoxic zones can be natural phenomena but are occurring in increasing 

size and frequency due to human-induced nonpoint source water pollution (National Oceanic and Atmospheric 

Administration, 2016, 2017d).

Gulf of Mexico The northern Gulf of Mexico adjacent to the Mississippi River has the largest hypoxic zone in the U.S. and the second 

largest hypoxic zone worldwide. The average size of the hypoxic zone in the northern Gulf of Mexico varies year to 

year but from 1985 to 2014 was an average of about 5,300 square miles (mi.2); in 2016 the hypoxic zone was 5,898 

mi.2 an area about the size of Connecticut (National Oceanic and Atmospheric Administration, 2016).

Harmful Algal 

Blooms (Section 

3.6.2.1.5, Water 

Quality)

Global Elevated nutrient loading has also been identified as a potential contributing cause of the increased incidence of 

harmful algal blooms, proliferations of certain marine and freshwater toxin-producing algae (National Oceanic and 

Atmospheric Administration, 2016, 2017d). Of the 5,000 known species of phytoplankton, there are about 100 species 

known to be toxic or harmful. Harmful algal blooms cause human illness and animal mortalities, including fish, bird, 

and marine mammals (Anderson et al., 2002; Corcoran et al., 2013; Sellner et al., 2003). Harmful algal blooms can be 

natural phenomena but are occurring in increasing size and frequency due to human-induced nonpoint source water 

pollution (National Oceanic and Atmospheric Administration, 2016, 2017d). With the projection of warming ocean 

waters, these harmful blooms may become more prevalent - beginning earlier, lasting longer, and covering larger 

geographic areas (Edwards, 2013; Moore et al., 2008).

Gulf of Mexico In Florida, the deaths of 107 bottlenose dolphins in 2004 and 277 manatees in 2013 were linked to harmful algal 

blooms (Edwards, 2013; Flewelling et al., 2005). 

Atlantic Ocean In the Saint Lawrence Estuary, unprecedented mass mortalities of multiple species including marine fish, birds, and 

marine mammals were linked to a harmful algal bloom that occurred in 2008 (Starr et al., 2017).

Major Spill Events Global Oil and other chemical spills related to oil and gas production activities are common throughout the Gulf of Mexico 

and Atlantic. 
Atlantic Fleet

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4.0 Cumulative Impacts

Table 4.2-2: Ocean Pollution and Ecosystem Alteration Trends (continued)

Stressor Location Description

Major Spill Events

(continued)

Gulf of Mexico In the Gulf of Mexico from 2009 to 2016 there were a total of 5,084 spills, 50 of which were over 50 barrels (2,100 

gallons) of oil (Bureau of Safety and Environmental Enforcement, 2017b). The biggest of these was in April 2010 when 

the Deepwater Horizon offshore drill rig, 41 mi. southeast of the Louisiana coast, exploded and sank during 

exploratory well drilling. This was the largest accidental marine oil spill in U.S. history releasing 4.9 million barrels (210 

million gallons) of crude oil into the Gulf of Mexico (National Commission on the BP Deepwater Horizon Oil Spill and 

Offshore Drilling, 2011). 

Environmental impacts continue to be observed, including those arising from direct exposure of marine life to oil and 

oil dispersants, habitat degradation, and disturbances caused by cleanup activities. There has been extensive 

documentation of negative effects of the spill to deep sea corals and benthos, fish, marine mammals, sargassum, sea

turtles, and other shoreline species and habitats (National Oceanic and Atmospheric Administration, 2017b).

Marine Debris 

(Section 3.2.2.6 

Marine Debris and 

Water Quality)

Global Marine debris is any anthropogenic object intentionally or unintentionally discarded, disposed of, or abandoned that 

enters the marine environment. An estimated 75 percent or more of marine debris consists of plastic (Hardesty & 

Wilcox, 2017). Approximately 80 percent of marine debris originates onshore and 20 percent from offshore sources. 

Marine debris is governed internationally by the 1972 London Convention and 1996 London Protocol and regulated in 

the U.S. through the Marine Protection, Research, and Sanctuaries Act. Marine debris has been discovered to be 

accumulating in gyres throughout the oceans, and two major accumulation zones exist in the Pacific Ocean and in the 

Atlantic east of Bermuda. Marine debris degrades marine habitat and water quality and poses ingestion and 

entanglement risks to marine life and birds (National Marine Fisheries Service, 2006).

Noise Global Ambient noise is the collection of ever-present sounds of both natural and human origin. Ambient noise in the ocean 

is generated by sources that are natural physical (earthquakes, rainfall, waves breaking, and lightning hitting the 

ocean); natural biological (snapping shrimp and the vocalizations of marine mammals), and anthropogenic (humangenerated) sources. Anthropogenic sources have substantially increased ocean noise since the 1960s, and include 

commercial shipping, oil and gas exploration and production activities (including airgun, drilling, and explosive 

decommissioning), commercial and recreational fishing (including vessel noise, fish-finding sonar, fathometers, and 

acoustic deterrent and harassment devices), military (testing, training and mission activities), shoreline construction 

projects (including pile driving), recreational boating and whale-watching activities, offshore power generation 

(including offshore windfarms), and research (including sound from air guns, sonar, and telemetry).
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Table 4.2-2: Ocean Pollution and Ecosystem Alteration Trends (continued)

Stressor Location Description

Climate Change 

(Section 3.1, Air 

Quality)

Global Predictions of long-term negative environmental impacts due to climate change include sea level rise; changes in 

ocean surface temperature, acidity/alkalinity, and salinity; changing weather patterns with increases in the severity of 

storms and droughts; changes to local and regional ecosystems (including the potential loss of species); shrinking 

glaciers and sea ice; thawing permafrost; a longer growing season; and shifts in plant and animal ranges, fecundity, 

and productivity. 

Anthropogenic greenhouse gas emissions have changed the physical and chemical properties of the oceans, including 

a 1 degree Celsius temperature rise, increased carbon dioxide absorption, decreased pH, alteration of carbonate 

chemistry, decline in dissolved oxygen, and disruption of ocean circulation (Poloczanska et al., 2016). Observations of 

species responses that have been linked to anthropogenic climate change are widespread, and trends include shifts in 

species distribution to higher latitudes and to deeper locations, earlier onset of spring and later arrival of fall, declines

in calcification, and increases in the abundance of warm-water species. 

Climate change is likely to negatively impact the Study Area and will contribute added stressors to all resources in the 

Study Area (as noted in the discussion for each resource in the Sections to follow).
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4.3 CUMULATIVE IMPACTS ON ENVIRONMENTAL RESOURCES

Since the information available on past, present, and reasonably foreseeable actions varies in quality 

and level of detail, impacts of these actions were quantified where available data made it possible; 

otherwise, professional judgment and experience were used to make a qualitative assessment of 

impacts. Due to the large-scale of the Study Area and multiple activities and stressors interacting in the 

ocean environment (Table 4.2-1 and Table 4.2-2), the analysis for the incremental contribution to 

cumulative stress that the Proposed Action may have on a given resource is largely qualitative and 

speculative. Chapter 3 (Affected Environment and Environmental Consequences) includes a robust 

discussion of the “general threats”, an analysis of aggregate project effects, and a broader level analysis 

specific to areas where impacts are concentrated (i.e., ranges / OPAREAS). Therefore, the Chapter 3

(Affected Environment and Environmental Consequences) analysis is referenced and briefly summarized 

in each section below to provide context and perspective to the rationale for the conclusions that the 

Proposed Action will have an insignificant contribution to the cumulative stress experienced by these 

resources when specific past, present, and reasonably foreseeable future actions are added to the 

analysis. 

In this chapter, cumulative impacts were analyzed for each resource addressed in Chapter 3 (Affected 

Environment and Environmental Consequences) for the Proposed Action. Analysis was not separated by 

Alternative because the data available for the cumulative effects analysis was mostly qualitative in 

nature and, from a landscape-level perspective, these qualitative impacts are expected to be generally 

similar. 

Under Alternative 1 or Alternative 2 of the Proposed Action, the Navy will implement the mitigation 

detailed in Chapter 5 (Mitigation) to avoid or reduce potential impacts on biological, socioeconomic, and 

cultural resources in the Study Area.

4.4 RESOURCE-SPECIFIC CUMULATIVE IMPACTS

In accordance with Council on Environmental Quality guidance (Council on Environmental Quality, 1997),

the following cumulative impacts analysis focuses on impacts that are “truly meaningful.” The level of 

analysis for each resource is commensurate with the intensity of the impacts identified in Chapter 3 

(Affected Environment and Environmental Consequences) or the level to which impacts from the 

Proposed Action are expected to mingle with similar impacts from existing activities. A full analysis of 

potential cumulative impacts is provided for marine mammals, reptiles, and invertebrates. Rationale is 

also provided for an abbreviated analysis of the following resources: air quality, sediments and water 

quality, vegetation, habitat, fishes, birds and bats, cultural resources, socioeconomics, and public health 

and safety.

4.4.1 AIR QUALITY

As described in Section 3.1.2.1.1 (Region of Influence), the region of influence for air quality is 

dependent on the type of pollutant, emission rates, other emission sources, and meteorology. For inert 

pollutants, the region of influence is generally limited to a few miles downwind from the source. For a 

photochemical pollutant, such as ozone, the region of influence may extend much farther downwind.

The concentration of many small emission sources in a particular airshed, under the right circumstances,

could incrementally contribute to regional air quality degradation. 

The context for air quality analysis provided in Section 3.1 (Air Quality) includes adherence to state and 

federal plans enacted to achieve and maintain air quality, and these plans were developed with direct, 
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indirect, and cumulative impacts in mind. As the plans are developed, the establishment of significance 

criteria includes an inventory of existing emissions and the development of thresholds that ensure new 

activities avoid or mitigate significant air quality impacts. A majority of the activities included in the 

Proposed Action are ongoing, and any emissions associated with these activities that reach land are 

captured in any ambient air monitoring data collected and used to quantify area air quality.

Unlike other resource areas, the analytical construct for this air quality analysis in Section 3.1 (Air 

Quality) is effectively a quantified look at applicable training and testing activity emissions and a region’s 

ability to maintain or recover air quality as measured by the criteria air pollutants in light of other,

existing emissions. As a whole, the air quality throughout the Study Area is generally very good as shown 

by ongoing monitoring of all criteria pollutants against National Ambient Air Quality Standards and State 

Ambient Air Quality Standards (Section 3.1.2.3, Existing Air Quality). A small proportion of 

nonattainment and maintenance areas are generally concentrated in the inland, urban, industrialized 

areas of northeastern states and a few isolated coastal areas (Table 3.1-1 through Table 3.1-4 and Figure 

3.1-1 through Figure 3.1-4). The good quality of the ocean atmosphere results from the relatively low 

number of air pollutant sources, as well as the size, topography, and prevailing meteorological 

conditions throughout the Study Area.

Other activities in the Study Area that contribute to emissions of criteria air pollutants include other 

vessel traffic and oil and gas production activities. Oil and gas production is regulated under state and 

federal programs to ensure new activities avoid or mitigate significant air quality impacts (Bureau of 

Ocean Energy Management, 2016d). Sulfur dioxide, nitrogen dioxide, and particulate matter air 

emissions from non-military vessel operations operating within 200 miles of coastal areas off the U.S. 

and Canada and the U.S. Caribbean Sea area (around Puerto Rico and the U.S. Virgin Islands) are 

regulated by the International Maritime Organization. These areas are known as Emission Control Areas 

and were created because of the ability of these pollutant emissions to travel long distances, thus 

potentially impacting coastal zones and further inland. 

As noted above, the majority of proposed activities are ongoing and would be captured in most states’

air quality measurements. As detailed in Section 3.1 (Air Quality) sources of emissions from the 

proposed alternatives would include Navy vessels, aircraft, and to a lesser extent, munitions training and 

testing activities conducted throughout the Study Area. The Proposed Action would result in localized 

and temporarily elevated emissions, but criteria pollutant emissions in nonattainment or maintenance 

areas would not exceed de minimis thresholds. A few areas where ongoing training activities routinely 

occur are locations with greater emissions. These primarily include the lower Chesapeake Bay and 

surrounding tributaries where riverine training occurs. They are all attainment areas and the training in 

state waters is not anticipated to result in significant impacts to air quality. Hazardous air pollutant 

emissions are anticipated to be small and they were dismissed as a stressor of impact. 

It is anticipated that the majority of emissions resulting from the Proposed Action would be released 

outside of state waters and would quickly disperse in the ocean environment. These emissions would

largely disperse rather than concentrate due to meteorological and air chemistry processes, and these 

emissions could mix with emissions from other vessel traffic and oil and gas production activities. 

Additionally, activities occurring in state waters would likely impact onshore areas to a greater extent 

than more distant activities. The incremental additive impacts from combined emissions occurring 

beyond state water boundaries would be minor, localized, intermittent, and unlikely to contribute to 

future degradation of the ocean atmosphere in a way that would harm ocean ecosystems or nearshore 

communities. Thus, based on the analysis presented in Section 3.1 (Air Quality) and given the 
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meteorology of the Study Area, the frequency and isolation of proposed training and testing activities 

(Tables 2.6-1 through 2.6-4), and the quantities of expected emissions, it is anticipated that the 

incremental contribution of the Proposed Action beyond state waters, when added to the impacts of all 

other past, present and reasonably foreseeable future actions will not result in measurable additional 

impacts on air quality in the Study Area or beyond.

Activities occurring within state waters can be considered as localized with greater frequency and higher 

probability of combining with past, present and reasonably foreseeable future actions in and adjacent to 

the areas where the training or testing activity is occurring. With the exception of areas around 

Jacksonville, Florida where training would occur on the St. Johns River and Naval Station Mayport, these 

areas are all in attainment. The Jacksonville (Florida)-Brunswick (Georgia) Interstate Air Quality Control 

Region currently contains a small area designated as nonattainment for sulfur dioxide. An analysis of the 

emissions from the Proposed Action activities occurring in the Jacksonville, Florida area demonstrated 

that emissions are well below General Conformity thresholds (Section 3.1 Air Quality). It is anticipated 

that the incremental contribution of the Proposed Action in the state waters in the Jacksonville, Florida 

area, when added to the impacts of all other past, present and reasonably foreseeable future actions, 

would not result in measurable additional impacts on air quality in the Jacksonville (Florida)-Brunswick 

(Georgia) Interstate Air Quality Control Region. 

The area of greatest emissions in state waters is near the Virginia Capes Operational Area, specifically in 

the lower Chesapeake Bay, the York River, the James River, and their attendant tributaries. Training 

activities using small riverine boats and other vessels in this area were not analyzed in prior NEPA

documents and account for approximately 2,600 tons per year of nitrogen oxide emissions. This 

represents about 21% of nitrogen oxide emissions for non-road and miscellaneous area sources in the 

Hampton Roads Intrastate Air Quality Control Region, which covers Isle of Wight, James City, 

Nansemond, Southampton, and York counties and the cities of Chesapeake, Franklin, Hampton, 

Newport News, Norfolk, Portsmouth, Suffolk, Virginia Beach, and Williamsburg (U.S. Environmental 

Protection Agency, 2016). While the riverine training activities account for a substantial percentage of 

non-road emissions in the region, the area is in attainment for all criteria pollutants and the level of 

activity has not changed appreciably over time. It is anticipated that these emissions, when added to the 

impacts of all other past, present and reasonably foreseeable future actions, would not result in 

measurable additional impacts on air quality in the Study Area or beyond.

A comparative analysis of greenhouse gas emissions and climate change is provided in Section 3.1, Air 

Quality.

4.4.2 SEDIMENTS AND WATER QUALITY

The region of influence for sediments and water quality includes estuaries, nearshore areas, and the 

open ocean. Although most impacts from anthropogenic sources tend to be geographically isolated in 

proximity to the source, more widespread impacts can extend into the offshore ocean environment due 

to transport through currents, storms, and persistent winds as well as vertical mixing in the water 

column. The environmental fate of materials deposited in the marine environment and the formation of 

degradation or corrosion products depends on geochemical conditions that may influence precipitation 

by chemical reaction, adsorption, and biodegradation. Transport mechanisms, such as advection by 

currents, dispersion, and dissolution can cause wide distribution of chemicals and small, buoyant 

particle debris. While this dynamic movement generally causes chemical contaminants to degrade or 

dilute, it can also concentrate materials in areas of the seafloor or water column where predictable 
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currents, eddies, or gyres result in convergence zones (such as the “garbage patch” in the North Pacific 

Ocean or east of Bermuda where debris, particularly plastics, has accumulated and persists in the 

marine environment).

In order to protect sediment and water quality, several U.S. and international laws govern the discharge 

of fouling materials into the marine environment. Both nearshore discharge as well as discharges from 

open ocean activities and vessels in federal waters are regulated by the U.S. Environmental Protection 

Agency and state environmental programs through the Clean Water Act National Pollutant Discharge 

Elimination System. The deliberate disposal of waste or other matter into the ocean is governed 

internationally by the 1972 London Convention and 1996 London Protocol, implemented in the U.S. 

through the Marine Protection, Research, and Sanctuaries Act. The International Convention for the 

Prevention of Pollution from Ships is incorporated into U.S. law and addresses pollution generated by 

normal vessel operations (see Section 3.2.1.2.2, Federal Standards and Guidelines). Section 3.2.1.2

(Methods) lists applicable water quality and sediment standards, regulations, and guidelines. 

Sections 3.2.2.1 (Sediments) and 3.2.2.2 (Water Quality) further describe sediment and water quality 

trends and impacts. Sediment quality of the Study Area is generally rated as very good with most 

instances of lower quality in nearshore waters adjacent to population centers or areas with 

concentrated past or present industrial activities (Table 3.2-1; Figures 3.2-2 through 3.2-4). Water 

quality in the open ocean portion of the Study Area tends to be rated as good, but in the nearshore 

areas water quality is generally fair or compromised due to increased use and development in coastal 

waters (see Figures 3.2-6 through 3.2-8). Turbidity, dissolved oxygen, solids, and chemical components 

from land-based urban, agricultural, and industrial point and nonpoint sources in the coastal watershed 

are typical stressors to sediment and water quality. Persistent organic pollutants such as polycyclic 

aromatic hydrocarbons, polychlorinated biphenyls, and pesticides; nutrients; bacteria; and some metals

are typical components of discharge. The major pollutant encountered in the open ocean is oil from 

accidental spills (including chemical dispersants used in response to spills) as well as natural seeps.

All past, present, and reasonably foreseeable activities listed in Table 4.2-1 and the stressors listed in 

Table 4.2-2 affect marine sediments and water quality. In particular, activities contributing to climate 

change, continued runoff and discharge from nearshore land uses and coastal land development, 

maritime traffic, leakages and spills from oil and gas development, commercial fishing, mineral 

extraction, offshore energy development and removal operations, and marine trash impact water and 

sediment quality. Commercial, recreational, and institutional vessels discharge water pollutants into the 

AFTT Study Area as part of normal operations. Shipboard waste-handling procedures governing the 

discharge of nonhazardous waste streams have been established for commercial and Navy vessels. 

These categories of wastes include solids (garbage) and liquids, including “black water” (sewage); “grey 

water” (water from deck drains, showers, dishwashers, laundries, etc.); and oily wastes (oil-water 

mixtures). Global climate change is linked with increasing ocean acidity (pH), increasing sea surface 

temperatures, and increasing frequency and intensity of storms. These factors influence marine 

chemistry and the transport and persistence of chemical contaminants within sediment and the water 

column. Chemicals that remain in particulate form below a certain temperature may dissolve into the 

water column at a higher rate as water temperatures rise, and they may become more widely dispersed

due to storms or changing currents. Particularly in nearshore areas and bays, the concentration of Navy 

stressors in designated ranges and ports may combine with non-Navy stressors, which may also be 

concentrated in these areas, to exacerbate already impacted sediments and water quality.
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The analysis in Section 3.2 (Sediments and Water Quality) indicates that certain training and testing

activities could result in localized, short- and long-term impacts on sediment and water quality. Activities 

that use explosive munitions would introduce explosion byproducts, metals, and other constituent 

chemicals directly into the water column when the munition detonates or into marine sediments if an 

explosive munition fails to detonate. Explosion byproducts are expected to disperse rapidly near the 

water’s surface after detonation. Explosive materials and metal corrosion products would be released 

into adjacent sediments (within a few feet) over the long term (years to decades). However, analysis of 

decades-old munitions dump sites in multiple locations indicates that chemical contaminant 

concentrations in impacted sediment would not be expected to differ substantially from the chemical 

composition of control sediments located within the general area of impact (See Section 3.2.3, 

Environmental Consequences). 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 temperature 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.

Short-term impacts from activities using vessels may include increased turbidity and suspension of 

sediments in the water column (dependent on water depth). Most explosion constituents are fully 

consumed in detonation, and chemical, physical, or biological changes to sediments or water quality 

would be below applicable standards, regulations, and guidelines and would be within existing 

conditions or designated uses. Military expended materials associated with the Proposed Action do not 

generally include the same chemical constituents typically affecting coastal water quality (such as 

pesticides). With the exception of the few training and testing activities that occur in bays and harbors,

it is unlikely that short-term increases in turbidity from training and testing activities would overlap in 

time and space with other past, present, or future actions. For example, training and testing with 

explosives would not occur near an oil rig structure removal operation that could use explosives or at 

the same time or place as other bottom-disturbing activities such as trawling or laying electrical

transmission or communications cables. 

It is possible that Navy stressors would combine with non-Navy stressors, particularly in nearshore areas 

and bays, such as Narragansett Bay or the Lower Chesapeake Bay, to exacerbate already impacted 

sediments and water quality. Although impacts may temporarily intermingle with other inputs in areas 

with degraded existing conditions, most of the Navy impacts to water quality and turbidity are expected 

to be negligible, isolated, and short term, with disturbed sediments and particulate matter quickly 

dispersing within the water column or settling to the seafloor and turbidity conditions returning to 

background levels. The Proposed Action could incrementally contribute persistent metal and plastic

materials primarily to offshore ocean ecosystems. However, these relatively minute concentrations of 

Navy stressors are not likely to meaningfully contribute to sediment or water quality degradation, and it 

is anticipated that the incremental contribution of the Proposed Action when added to the impacts of all 

other past, present and reasonably foreseeable future actions would not result in measurable additional 

impacts on sediment or water quality in the Study Area or beyond.
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4.4.3 VEGETATION

The region of influence for vegetation includes the sunlit portions of the open ocean, coastal, and 

inshore waters, including the surface, water column and benthic habitat to a maximum depth of roughly 

200 m. Vegetation of the Study Area includes algae (phytoplankton and seaweeds), and vascular plants 

that include seagrasses, emergent marsh vegetation such as cordgrass, and mangroves. Commercial 

activities are conducted under permits and regulations that require companies to avoid and minimize 

impacts on sensitive vegetation, and some harvested seaweeds are managed under Fishery 

Management Plans.

Seagrasses are susceptible to damage from storms and human activities but can regrow quickly if the 

root structure is intact and the substrate is not eroded away. Stressors include decreased light 

penetration and impacts on photosynthesis, particularly from sustained turbidity and nutrient loading, 

which can cause algal blooms. They are also susceptible to changes in environmental factors such as 

salinity, pH, and water temperature and physical damage. Section 3.3.2.1.2 (General Threats) includes 

an extensive discussion of the existing stressors to marine vegetation, including diminished water quality 

from excessive nutrient input, siltation, pollution (from oil, oil spills, and cleanup chemicals; sewage; and 

trash), climate change, fishing practices (trawling and raking), anchoring, shading from structures, 

propeller/vessel traffic, construction and dredging, and introduced or invasive species. Many of these 

stressors are components of other activities in the Study Area described in Table 4.2-1. The coverage of 

seagrass in the Study Area has decreased over time; from 1879 to 2006 global seagrass coverage 

decreased by 75 percent (Waycott et al., 2009). By comparison, algae includes a much greater diversity 

of species, forms, life histories, and environmental tolerances, and are thus resilient to stressors and 

able to rapidly recolonize disturbed environments (Levinton, 2009). 

Mitigation measures within the Navy’s seafloor resource mitigation areas would help avoid impacts of 

the Proposed Action on vegetation species that are associated with shallow-water coral reefs and live 

hard bottom habitats, and pre-activity observations monitor for the occurrence and avoidance of 

Sargassum mats and detached floating kelp. However, even with these mitigation measures, vegetation 

may be impacted directly by explosions, interactions with vessels, in-water and seafloor devices, and 

military expended materials. The analysis presented in Section 3.3 (Vegetation) indicates that impacts 

on marine vegetation are limited to destroying or damaging individual plants, and no persistent or largescale effects on the growth, survival, distribution, or structure of vegetation are anticipated due to 

relatively fast growth, resilience, and abundance of the most affected species in anticipated activity 

areas. Likewise, the short-term, localized nature of most activities further diminishes the potential 

effects on marine vegetation.

The effects of other past, present, and reasonably foreseeable actions on vegetation occur primarily in 

the coastal and inshore waters and are associated with coastal development, maritime commerce, and 

the discharge of sediment and other pollutants. The Proposed Action is not expected to substantially 

contribute to losses of vegetation that would interfere with recovery in these regions. The incremental 

contribution of the Proposed Action would be insignificant as most of the proposed activities would 

occur in the open ocean and other areas where seagrasses and other attached marine vegetation do not 

grow; impacts would be localized; recovery would occur quickly; and none of the alternatives would 

compound impacts that have been historically significant to marine vegetation (loss of habitat due to 

development; nutrient loading; shading; turbidity; or changes in salinity, pH, or water temperature).

Although vegetation is impacted by stressors throughout the Study Area, the Proposed Action is not 

likely to incrementally contribute to population- or ecosystem-level changes in the resource, and it is
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anticipated that the incremental contribution of the Proposed Action when added to the impacts of all 

other past, present and reasonably foreseeable future actions would not result in measurable additional

impacts on vegetation in the Study Area or beyond. 

4.4.4 INVERTEBRATES

4.4.4.1 Region of Influence

The region of influence for invertebrates includes the entire Study Area as invertebrates occur in all 

habitats and depths, including both the water column and benthic habitat. Invertebrates include 

microscopic zooplankton that drift with currents (e.g., invertebrate larvae, copepods, protozoans), larger 

invertebrates living in the water column (e.g., jellyfish, shrimp, squid), and benthic invertebrates that 

live on or in the seafloor (e.g., clams, corals, crabs, worms). Shallow-water corals typically occur in water 

depths less than 30 m. Deep-water corals occur at depths below 50 m (164 ft) (potentially extending to 

about 3,000 m [9,843 ft]) where there is no or low sunlight penetration. Deep-water corals typically do 

not form biogenic reefs, but rather form mounds of intermediate substrate over hard bottom areas. 

Corals may also occur in a transition zone of reduced light levels, called the mesophotic zone, between 

the water depths typically associated with shallow-water and deep-water species.

4.4.4.2 Resource Trends

As discussed in Section 3.4.2.1 (General Background) marine invertebrates are ecologically and 

economically crucial, performing essential ecosystem services such as coastal protection, nutrient 

recycling, food for other animals, and habitat formation, as well as providing income from tourism and 

commercial fisheries. The health and abundance of marine invertebrates are vital to the marine 

ecosystem and the sustainability of the world’s fisheries. Invertebrates are fished for food (e.g., shrimps, 

lobsters, and crabs, scallops, clams, and oysters, sea urchins, sea cucumbers, squids, and octopuses); 

harvested for jewelry, curios, and the aquarium trade; and some are known to secrete medicinal 

compounds of interest to the health industry.

Seven shallow-water coral species found in the Study Area are listed as threatened under the ESA, and 

one deep-water coral species is designated as a Species of Concern under the ESA (Table 3.4-1). All 

Endangered and Special Status corals in the Study Area are located in the Gulf of Mexico, the 

Southeastern U.S. Continental Shelf, and the Caribbean Sea and in bays, harbors, and inshore waterways 

within Florida and Biscayne Bay. NOAA Fisheries maintains a species website that provides additional 

information on the biology, life history, species distribution (including maps), and conservation of 

invertebrates in the Study Area (accessible at: https://www.fisheries.noaa.gov/invertebrates).

4.4.4.3 Impacts of Other Actions

Section 3.4.2.1.4 (General Threats) includes an extensive discussion of the existing stressors to marine 

invertebrates, including overexploitation and destructive fishing practices, habitat degradation resulting 

from pollution and coastal development, disease, invasive species, oil spills, oil and gas seismic air gun 

exploration, global climate change and ocean acidification, human-generated noise, and bioprospecting 

for pharmaceutical products. Stressors specific to reef-building corals, which are generally located in 

more shallow zones with adequate sunlight penetration and a mean annual water temperature greater 

than about 64 degrees Fahrenheit, include thermal stress, disease, tropical storms, coastal development 

and pollution, erosion and sedimentation, tourism/recreation, fishing, trade in coral and live reef 

species, vessel anchoring or groundings, marine debris, predation, invasive species, military and other 

security-related activities, and hydrocarbon exploration. Primary threats to deep-water or cold-water 
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corals include bottom fishing, marine debris, hydrocarbon exploration, petroleum contamination, cable 

and pipeline placement, waste disposal (such as lost fishing equipment or dredged sediments), and 

other various bottom-disturbing activities. Deep corals are susceptible to physical disturbance due to 

the branching and fragile growth form of some species, slow growth rate (colonies can be hundreds of 

years old), and low reproduction and recruitment rates. All activities described in Table 4.2-1 and 

stressors described in Table 4.2-2 have the potential to impact marine invertebrates due to their 

ubiquitous presence and relative vulnerability.

Climate Change. Specific effects of climate change on invertebrates are detailed in Section 3.4.2.1.4.2 

(Climate Change). The effects of climate change include increased water temperature, ocean 

acidification, increased frequency or intensity of cyclonic storm events, and sea level rise, which can 

cause direct damage to these crucial and sensitive species well as increase their susceptibility to and 

resilience from encounters with all other threats, including disease, pathogens, and genetic disorders. 

The primary threat to corals is the occurrence of global climate change, which has and is projected to 

continue to seriously impact coral reefs in the near and known future. Some coral invertebrate species 

may be more tolerant of changing temperatures and acidity levels than other species, but changing 

physical factors in ocean environments will result in altered invertebrate ecosystems. Increases in ocean 

temperature can lead to coral stress, bleaching, and mortality. Coral bleaching, which occurs when 

corals expel the symbiotic algae living in their tissues, is a stress response often tied to atypically high 

sea temperatures or changes in light availability but also can be attributed to nutrients, toxicants, and 

pathogens (National Oceanic and Atmospheric Administration, 2017c). Bleaching events have increased 

in frequency in recent decades and coral bleaching on a global scale has occurred during the summers of 

2014, 2015, and 2016. A widespread bleaching event occurred throughout the Caribbean Sea, extending 

to Florida and the Gulf of Mexico, in 2005 and in portions of the Caribbean Sea and off the coast of 

Florida in 2015. A mass die-off of corals and other invertebrates (e.g., sponges, urchins, brittle stars, and 

clams) of unknown origin was documented in the Flower Garden Banks National Marine Sanctuary in 

the Gulf of Mexico in 2016, and a large disease outbreak was documented in numerous coral species off 

southeastern Florida in 2014. The results of one modeling study suggest that severe coral bleaching 

could occur annually at reefs off southern Florida and in the Caribbean Sea beginning between 2040 and 

2050, depending on the specific location (van Hooidonk et al., 2014).

As further discussed in Section 3.4.2.1.4.2 (Climate Change), in addition to elevated sea temperatures, 

atypically low sea temperatures may also cause mortality to corals and most other reef organisms, 

suggesting that widening climate extremes could proliferate bleaching events. Likewise, ocean 

acidification has the potential to reduce calcification and growth rates in species with calcium carbonate 

skeletons, including shellfish, corals, and sponges, certain kinds of algae, and possibly even lobsters and 

sea cucumbers. In addition to physical effects, increased acidity may result in behavioral changes in 

some species, such as burrowing behavior and juvenile dispersal patterns of the soft-shell clam and 

reduction in the loudness and number of snaps in snapping shrimp. 

Additionally, although the potential effects that climate change could have on future storm activity are 

uncertain, numerous researchers suggest that rising temperatures could result in little change to the 

overall number of storms, but that storm intensity could increase. Increased storm intensity could result 

in increased physical damage to individual corals and reefs constructed by the corals (which support 

numerous other invertebrate taxa), overturning of coral colonies, and a decrease in structural

complexity (due to disproportionate breakage of branching species). However, large storms such as 
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hurricanes may also have positive impacts on corals, such as lowering the water temperature and 

removing less resilient macroalgae from reef structures, which can overgrow corals. 

Sea level rise could affect invertebrates by modifying or eliminating habitat, particularly estuarine and 

intertidal habitats bordering steep and artificially hardened shorelines. Likewise, changes in ocean 

circulation patterns could affect the planktonic food supply of filter- and suspension-feeding 

invertebrates. Cumulative effects of threats from fishing, pollution, and other human disturbance may 

reduce the tolerance of corals and other invertebrates to global climate change.

4.4.4.4 Impacts of the Proposed Action That May Contribute to Cumulative Impacts

The analysis presented in Section 3.4 (Invertebrates) indicates that the proposed alternatives could 

impact marine invertebrates through acoustic stressors (sonar and other transducers, air guns, pile 

driving, vessel noise, weapons noise), explosives (explosions in water), energy stressors (in-water 

electromagnetic devices, high energy lasers), physical disturbance or strikes (vessels and in-water 

devices, military expended materials, seafloor devices, pile driving), entanglement (wires and cables, 

decelerators/parachutes, biodegradable polymers), and ingestion of military expended materials. 

Potential impacts include short-term behavioral and physiological responses (Celi et al., 2015; Edmonds 

et al., 2016; Roberts et al., 2016). Some stressors could also result in injury or mortality to a relatively 

small number of individuals. The potential for impacts on ESA-listed corals (Table 3.4-1) would be 

avoided by mitigation designed to avoid seafloor resource mitigation areas where shallow-water corals 

are located. For example, the Navy will not conduct certain activities within a specified distance of 

shallow-water coral reefs, live hard bottom, artificial reefs, and shipwrecks (Chapter 5, Mitigation).

These measures will help avoid potential impacts on invertebrates that inhabit these areas, including 

several areas inhabited by ESA-listed species. In addition, procedural mitigations include the 

requirement to avoid jellyfish aggregations during sinking exercises, ship shock trials, and the use of 

explosive torpedoes.

4.4.4.5 Cumulative Impacts on Invertebrates

Some direct impacts on invertebrates are expected, and the impacts of the Proposed Action could be 

cumulative with other actions that cause disturbance and mortality of marine invertebrates. However, it 

is anticipated that the incremental contribution of the proposed alternatives would be insignificant for 

the following reasons:

 Invertebrates are generally abundant and relatively short-lived, thus, with the exception of 

sessile species located near areas of repeated Navy activities (e.g., pierside locations, 

established channels near large naval port facilities), few individuals would likely be affected 

repeatedly by the same event.

 With the exception of some species such as deep-water corals, invertebrates generally have 

high reproductive rates, short reproductive cycles, and resilient dispersal mechanisms; thus, 

local communities are likely to reestablish quickly.

 Most of the proposed activities would impact small, dispersed, deep-water areas where marine 

invertebrates are more sparsely distributed. Navy activities may occur in the same general area 

(ranges), but do not occur at the same specific point each time and would therefore be unlikely 

to affect the same individual invertebrates.

 Marine invertebrates are not particularly susceptible to energy, entanglement, or ingestion 

stressors resulting from Navy activities, and none of the alternatives would result in or interact 
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with impacts that have been historically significant to marine invertebrates, such as overfishing, 

nutrient loading, disease, or the presence of invasive species. 

 None of the alternatives would result in long-term or widespread changes in environmental 

conditions such as turbidity, salinity, pH, or water temperature that could impact marine 

habitats.

 The Navy will not conduct certain activities within a specified distance of shallow-water coral 

reefs, live hard bottom, artificial reefs, or shipwrecks. All these features that have been 

identified are included in Chapter 5.0 (Mitigation).

Although marine invertebrates are impacted by other stressors in the ocean environment, particularly 

the effects of global climate change on corals, the Proposed Action is not likely to incrementally 

contribute to population-level stress and decline of the resource. Due to the effects of global climate 

change, corals may be less resilient to additional stressors; however, it is not anticipated that the Navy 

will cause direct effects to surveyed reef systems. As impacts would be isolated, localized, and not likely 

to overlap with other relevant stressors, it is anticipated that the incremental contribution of the 

Proposed Action when added to the impacts of all other past, present and reasonably foreseeable future 

actions would not result in measurable additional impacts on invertebrates in the Study Area or beyond. 

4.4.5 HABITATS

Habitats refers to the marine and estuarine nonliving (abiotic) substrates found throughout the Study 

Area, which are often colonized by biotic (vegetation and invertebrate) communities. Habitats vary 

according to geographic location, underlying geology, hydrodynamics, atmospheric conditions, and 

suspended particulate matter. There are basically three types of abiotic substrates based on the grain 

size of unconsolidated material, referred to as soft, intermediate, and hard. The soft habitats are 

generally comprised of fine grains that are more fluid and dynamic, whereas hard substrate does not 

repair and thus is susceptible to long-term scarring and damage. Artificial structures, such as shipwrecks 

and oil and gas platforms, underwater cables, and outflows also provide habitat for many marine 

organisms. Additionally, as detailed in Chapter 6, Other Regulatory Considerations, there are 13,000 

square km of designated National Marine Sanctuaries in the total AFTT Study Area (0.12% of total study 

Area), and 2,600 square km or 0.22% of Study Area within Range Complexes, Testing Ranges, or 

OPAREAs.

Section 3.5.2.1.4 (General Threats) includes an extensive discussion of the existing stressors to abiotic 

marine habitats, including urbanization (modification of shorelines and estuaries, dredging and 

maintenance of ports and harbors, and creation of artificial structure habitats such as breakwaters, 

jetties, rock groins, seawalls, oil and gas platforms, docks, piers, wharves, underwater cables and 

pipelines, and artificial reefs); accumulation of marine debris; and commercial activities (oil/gas 

development, telecommunications infrastructure, steam and nuclear power plants, desalinization 

plants, alternative energy development, shipping and cruise vessels, commercial fishing, aquaculture, 

and tourism operations). The impact of commercial fishing trawling practices has a significant impact on 

bottom habitats. Most activities in Table 4.2-1 are conducted under permits and regulations that require 

the avoidance and minimization of impacts on marine habitats, especially shoreline and sensitive hard 

bottom and biogenic habitats (e.g., coral reefs and shellfish beds).

The analysis presented in Section 3.5 (Habitats) indicates that marine habitats could be affected by 

underwater detonations, interactions with vessels (including wave erosion and sediment suspension), 

military expended materials, or seafloor devices. Potential impacts include localized disturbance of the 
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seafloor, cratering of soft bottom sediments, and structural damage to hard bottom habitats. Although 

some direct impacts on abiotic habitats are expected, it is anticipated that the incremental contribution 

of the proposed alternatives would be cumulatively insignificant for the following reasons:

 Most detonations would occur at or near the water surface and would not affect bottom 

habitats. 

 Impacts to soft bottom habitat from bottom-laid explosives would be confined to a limited area, 

and it is anticipated that soft bottom habitats would recover (fill in) quickly.

 Proposed Action activities are not likely to occur at the same time/place as other activities in the 

Study Area, including commercial fishing operations, which have a large effect on bottom 

habitats. Thus, it is likely that soft bottom habitats would have the opportunity to recover from 

the Proposed Action before impacts from fishing or other operations could interact or 

compound additional stress to the ecosystems.

 Per analysis detailed in Section 3.5.3.2.2 (Impacts from Explosives) and Appendix F (Military 

Expended Materials and Direct Strike Calculations), the area of hard bottom potentially 

impacted represents a negligible percentage (less than 0.01 percent) of the total hard bottom 

habitat in the Study Area (Figures 3.5-1 through 3.5-4). The Navy will implement mitigation to 

avoid impacts from explosives, physical disturbance, and strike stressors on seafloor resources, 

including shallow-water coral reefs, live hard bottom, and artificial reefs, and shipwrecks, as 

described in Chapter 5 (Mitigation) and National Marine Sanctuaries, as described in Chapter 6 

(Other Regulatory Considerations). Training and testing units are reminded of the presence of 

potentially sensitive areas through the Protective Measures Assessment Protocol program, 

which limits certain activities in these areas within the AFTT Study Area.

Although it is anticipated that damage to abiotic soft bottom habitat resulting from the Proposed Action 

would be limited and would recover, many other activities in the ocean are also impacting ocean bottom 

habitat. However, it is not likely that past, present, and future impacts would overlap Proposed Action 

activities in place or time before the craters or other impressions in soft bottom substrate fill in. Based 

on the analysis presented in Section 3.5 (Habitats) and the reasons summarized above, it is anticipated 

that the incremental contribution of the Proposed Action, when added to the impacts of all other past, 

present and reasonably foreseeable future actions, would not result in measurable additional impacts 

on habitats, including National Marine Sanctuaries, in the Study Area or beyond. 

4.4.6 FISHES

The general region of influence for fishes extends beyond the Study Area boundaries for some species 

because the Study Area represents only a portion of the available habitat during its lifecycle. Fishes are 

usually not distributed uniformly throughout the Study Area, but are typically associated with a specific 

habitat type (e.g., soft bottom, reef, or open water) or can utilize a variety of habitats at different life 

stages. The distribution and specific habitats in which an individual of a single fish species occurs may 

also be influenced by its size, sex, reproductive condition, and other factors such as water temperature 

and depth. The highest number and diversity of fishes typically occur where the habitat is most diverse; 

thus, coastal ecosystems tend to support a greater diversity of species than oceanic and deep sea 

habitats (Moyle & Cech, 2004). 

Fishes are the most numerous and diverse of the major vertebrate groups (Moyle & Cech, 2004). It is 

estimated that there are currently over 34,000 species of fish worldwide (Eschmeyer & Fong, 2017), 

with greater than half that number of species inhabiting the oceans. As discussed in Section 3.6.1 

(Introduction), approximately 78 percent of all marine fish species occur in waters less than 200 m deep 
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and in close association with land, while 13 percent are associated with the open ocean (Moyle & Cech, 

2004). Table 3.6-2 lists the groups of fishes known to occur in the Study Area.

Table 3.6-1 lists the regulatory status and occurrence of ESA-listed fishes known to occur in the Study 

Area. Within the Study Area, eight fish species are listed as endangered or threatened under the ESA, of 

which three are anadromous (Atlantic salmon, Atlantic sturgeon, and Gulf sturgeon), one primarily 

inhabits its natal river and estuary (shortnose sturgeon); two primarily inhabit estuarine and coastal 

waters (largetooth sawfish and smalltooth sawfish); one that is generally considered a marine fish after 

early life stages in estuarine environments (scalloped hammerhead); and one that is fully deep-water 

marine (Nassau grouper). Additionally, there are two species proposed for ESA-listing (giant manta ray 

and oceanic whitetip shark), three ESA-candidates species (Alabama shad, cusk, and dwarf seahorse), 

and 14 species listed as Species of Concern. Fishes are protected by the ESA, the Magnuson-Stevens 

Fishery Conservation and Management Act, and the Sustainable Fisheries Act. Despite regulation, 

oversight, and technological improvements, the commercial fishing industry continues to have 

significant impacts on fish populations, including overfishing and bycatch of non-target species. The 

current aggregate impacts of past and present human activities are significant for some fish species, 

especially those that are globally in serious decline. Very few ocean habitats remain unaffected by 

human influence, and these stressors have shaped the condition of marine fish populations, particularly 

those species with large body size, late maturity ages, and/or low fecundity. 

Section 3.6.2.1.4 (General Threats) includes an extensive discussion of the existing stressors, which often 

act on fish populations simultaneously, including habitat alteration (coastal development, deforestation, 

road construction, dam development, water control structures, and agricultural activities), exploitation 

and bycatch (commercial and recreational fisheries), vessel strikes, diseases and parasites (susceptibility 

and incidence increases with habitat alteration and exposure to individuals that escaped sea farms), 

introduction of non-native species, pollution (oil spills, marine debris, noise, hypoxia, and harmful algal 

blooms), and climate change. The additional threat of living in a noisy environment, such as produced by 

offshore wind energy developments, construction noise within inshore waters such as pile driving, 

sonar, seismic activity, shipping, and offshore construction projects, may contribute to cumulative stress 

as experienced by fish populations.

It is anticipated that the Proposed Action would affect fish species within the Study Area, including ESAlisted fish species. The analysis presented in Section 3.6 (Fishes) indicates that fishes could be affected 

by acoustic stressors (sonar and other transducers, air guns, pile driving, vessel noise, and weapons 

noise), explosives, energy stressors, physical disturbance or strikes (vessels and in-water devices, 

military expended materials, seafloor devices, pile driving), entanglement (wires and cables, 

decelerators/parachutes), and ingestion of military expended materials. The majority of potential 

impacts include short-term behavioral and physiological responses. For example, fish species that are 

exposed to sonar and other transducers within their hearing range or that are within close proximity to 

vessel or weapons noise may experience brief periods of masking or behavioral reactions, such as startle 

or avoidance responses, or no reaction at all. Other stressors (such as explosives) could also result in 

injury or mortality to a relatively small number of individuals. Overall, long-term consequences for most 

individual fishes or populations are unlikely because exposures from the majority of stressors are 

intermittent, transient, and unlikely to repeat over short periods. Some ESA-listed fish species that are 

known to occur within inshore water areas would be at higher risk during training and testing activities

in these locations. 
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An individual fish could be exposed to a combination of stressors from multiple activities over the course 

of its life, and multiple stressors may have synergistic effects such as reducing its overall fitness and 

ability to quickly recover from additional, compounding stressors. If the health of an individual fish is 

compromised, it is possible this condition could alter the animal’s expected response to stressors 

associated with the Proposed Action. Exposure to multiple stressors is most likely to occur in nearshore 

areas where training and testing activities are more concentrated and overlap the other nearshore 

stressors listed in Table 4.2-1 and Table 4.2-2. Likewise, animals with a home range intersecting 

concentrated Navy activities may be subjected to elevated exposure risks compared to those fishes that 

simply transit the area. Fishes that are malnourished, diseased, or experience temporary hearing loss,

injury, or disorientation from acoustic stressors could suffer behavioral and physiological consequences 

such as decreased ability to detect and avoid predators, oncoming vessels, or entanglement risks. 

The aggregate impacts of past, present, and other reasonably foreseeable future actions contributing 

multiple water quality, noise, and physical risks to fishes will likely continue to have significant effects on 

individual fishes and fish populations. However, Navy training and testing activities are generally 

isolated from other activities in space and time and the majority of the proposed training and testing 

activities occur in well known, previously established training range areas; are spatially distributed and 

not generally concentrated in any one location for any extended period of time; have few participants;

and are of a short duration. Thus, although it is possible that the Proposed Action could contribute 

incremental stressors to a small number of individuals, which would further compound effects on a 

given individual already experiencing stress, it is not anticipated that the Proposed Action has the 

potential to put additional stress on entire populations. Therefore, it is anticipated that the incremental 

contribution of the Proposed Action, when added to the impacts of all other past, present and 

reasonably foreseeable future actions, would not result in measurable additional significant impacts on

fishes in the Study Area or beyond.

4.4.7 MARINE MAMMALS

4.4.7.1 Region of Influence

Four main types of marine mammals are generally recognized: cetaceans (whales, dolphins, and 

porpoises), pinnipeds (seals, sea lions, and walruses), sirenians (manatees and dugongs), and other 

marine carnivores (sea otters, marine otters, and polar bears). Table 3.7-1 lists the current abundance of 

marine mammal species that utilize the Study Area and describes the locations within the Study Area 

that they may be encountered. Populations are varied; whereas the average population of certain 

dolphin and some whale populations can exceed the hundreds of thousands, other stock populations 

are unknown or estimated to be in the hundreds. As with other marine resources, distribution is patchy 

and can be temporarily concentrated in specific areas depending on the species. The size and structures 

of these groups are dynamic and, based on the species, can range from several to several thousand 

individuals. 

The general region of influence for marine mammals extends beyond the Study Area boundaries as for 

some species the Study Area represents only a portion of the full extent of the species’ ranges during 

their lifecycle. Most of the baleen whales migrate great distances, while the toothed whales and 

dolphins have a smaller-scale, seasonal dispersal. Pinnipeds occur mostly in coastal habitats or over 

continental shelves. Manatees and polar bears are strongly associated with coastal waters as habitat for 

reproducing, resting, and, in some cases, feeding although polar bears can also range far offshore. 
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Activities are evaluated for their potential impact on individual marine mammals, on stocks and 

populations as appropriate, and on species or distinct population segments listed under the ESA.

4.4.7.2 Resource Trends

Relevant information on the status, distribution, population trends, and ecology is presented for each 

species and stock in the AFTT Study Area in Section 3.7.2 (Affected Environment). The current aggregate 

impacts of past human activities are significant for some marine mammal species, many of which were

in serious decline across the world’s oceans. A general summary in this regard is presented in Section 

3.7.2.1.5 (General Threats). Other populations, such as the humpback whale, are increasing in 

abundance in much of their range (National Marine Fisheries Service, 2015b). All marine mammals in the 

U.S. are protected under the MMPA, and some species receive additional protection under the ESA. Of 

the 48 species of marine mammals known to exist within the Study Area, there are six populations listed 

as endangered under ESA and classified as strategic stocks under MMPA (bowhead whale, North 

Atlantic right whale, blue whale, fin whale, sei whale, and sperm whale), two are listed as threatened 

under ESA and classified as strategic stocks under the MMPA (West Indian manatee and polar bear), one 

is proposed for listing under the ESA (Bryde’s whale), and the Artic ringed seal may be relisted as 

threatened under the ESA pending final judgement of the District Court for the District of Alaska. In 

addition, the pygmy sperm whale and some bottlenose dolphin stocks are classified as MMPA strategic 

stocks. Polar bears and Arctic ringed seals occur in a very limited portion of the Study Area and the 

locations where the majority of activities are proposed to occur do not overlap with those areas; thus, it 

is anticipated that the Proposed Action would have no effect on polar bears or the Arctic ringed seal and 

they are not discussed further in this cumulative effects analysis.

4.4.7.3 Impacts of Other Actions

4.4.7.3.1 Overview

Section 3.7.2.1.5 (General Threats to Marine Mammals) discusses the specific stressors within the 

affected environment that impact marine mammal populations in the Study Area, which include water 

quality degradation (chemical pollution), commercial industries (fisheries bycatch and other 

interactions), noise, hunting, vessel strike, power plant entrainment, disease and parasites, climate 

change, and marine debris. Potential impacts of actions that affect marine mammals include mortality, 

injury, disturbance, and reduced fitness, including reproductive, foraging, and predator avoidance 

success. The susceptibility of marine mammals to these outcomes often depends on proximity, severity, 

or vulnerability to the stressor, and vulnerability can be increased as multiple stressors compound on an 

individual. The abundance of the species in large part determines whether a fatality from any stressor 

would have population-level impacts on that species, and for species with small populations, such as the 

North Atlantic right whale, individual fatalities could have considerable population-level impacts (Laist et 

al., 2001).

Stranded marine mammals include alive or dead individuals that swim or float to shore and are 

incapable of returning to sea or individuals that have wandered outside of their “normal” habitat. 

Investigations of stranded marine mammals can provide indications of the general threats to marine 

mammals in a given location, and causes of strandings include navigation error, predator avoidance, 

population and climate shifts, infectious disease, parasite infestation, starvation, pollution exposure, 

trauma (e.g., injuries from ship strikes or fishery entanglements), sound (human-generated or natural), 

harmful algal blooms and associated biotoxins, tectonic events such as underwater earthquakes, and 

ingestion or interaction with marine debris (National Marine Fisheries Service, 2016a). 
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The activities as described in Table 4.2-1 each potentially contribute multiple stressors in the Study Area 

experienced by marine mammals, including vessel traffic, underwater noise, and water pollution. For 

example, most actions include the operation of marine vessels, which contribute to vessel strikes and 

underwater noise. Many of the actions also contribute underwater noise from sources other than 

vessels, including use of explosives for oil rig removal, seismic surveys, construction activities, and other 

military operations. Bycatch and entanglement, the main threats to marine mammal populations, are 

chiefly associated with fishing. Other threats or the synergistic effect of multiple stressors are unknown, 

such as the cause of the 2017 North Atlantic right whale Unusual Mortality Event that occurred 

throughout their range along the Atlantic coast (National Marine Fisheries Service, 2017). While Table 

4.2-1 discusses these stressors for individual actions, their aggregate impacts specific to marine 

mammals are detailed in Section 3.7.2.1.5 (General Threats to Marine Mammals) and further described

below. Data availability is inconsistent between species and activities, but quantitative estimations are 

presented where available.

4.4.7.3.2 Commercial Fishing and Entanglement

Past and present commercial fishing activities have had a profound effect on some marine mammal 

species and, despite continued improvements in bycatch avoidance and the implementation of 

regulatory efforts, fisheries interactions continue to be the primary human-related source of mortality 

for most marine mammal stocks (Knowlton et al., 2012; Roman et al., 2013; Van der Hoop et al., 2013). 

This mortality could result in or contribute to continued population declines for some species, including 

ESA-listed species such as the North Atlantic right whale. 

4.4.7.3.2.1 Bycatch

Potential impacts from commercial fishing activities include marine mammal injury and mortality from 

bycatch, which refers to when animals are caught in commercial fishing operations targeting a different 

species. Total bycatch interactions are difficult to estimate as numbers are based on observations by 

NMFS staff or on numbers received from individual operations that self-report bycatch interactions. 

Although marine mammal bycatch has generally declined since the implementation of take reduction 

measures, and new management practices and regulatory oversight could result in future reductions, 

bycatch is expected to remain a leading cause of mortality for the reasonably foreseeable future (Geijer 

& Read, 2013; Hamer et al., 2010; Northridge, 2008; Read et al., 2006; Read, 2008).

Sixty-nine commercial fisheries, divided into groups defined by the type of gear, location, and/or target 

species for reporting purposes, operate in the Study Area (National Marine Fisheries Service, 2016b). In 

the Northern Atlantic Region (Maine to North Carolina) 6 fishery groups impact 13 marine mammal 

stocks. From 2011-2013 the average total marine mammal bycatch estimate in this region was 2,960 

animals per year. Gillnet gear continues to be the largest contributor to total marine mammal bycatch, 

taking an average 2,102 and 386 animals annually in the New England and Mid-Atlantic fisheries, 

respectively. In 2013 these effects were as follows:

 Western North Atlantic gray seal (1,086 animals)

 Gulf of Maine/Bay of Fundy stock of harbor porpoise (640 animals)

 Western North Atlantic harbor seal (442 animals)

 Short-beaked common dolphin (287 animals)

 Western North Atlantic white-sided dolphin (116 animals). 

In the Southeast Region (North Carolina through the Gulf of Mexico) one fishery (HMS pelagic longline) 

impacts two main species, short-finned pilot whales (Western North Atlantic) and bottlenose dolphins
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(National Marine Fisheries Service, 2016a). From 2011-2013 the total marine mammal bycatch estimates 

from this fishery were 350, 293, and 145, respectively. In 2013 the total bycatch included 124 shortfinned pilot whales and 62 bottlenose dolphins. Additionally, the bycatch rate of the shrimp otter trawl 

fishery is estimated to likely be exceeding 10% of the Potential Biological Removal for some marine 

mammal species, particularly various stocks of Gulf of Mexico common bottlenose and Atlantic spotted 

dolphins (Soldevilla et al., 2016). The Potential Biological Removal level is the number of animals that 

can be removed each year without preventing a stock from reaching or maintaining its optimal 

sustainable population-level. 

The impacts of bycatch on marine mammal populations vary based on removal rates, population size, 

and reproductive rates. Small populations with relatively low reproductive rates are most susceptible. 

Bycatch rates for about 12 percent of United States marine mammal stocks (almost all cetaceans) 

exceed their Potential Biological Removal levels (Read, 2008). 

The operations of fisheries also result in profound changes to the structure and function of marine 

ecosystems that adversely affect marine mammals, including loss of prey species and alteration of 

benthic structure. Overfishing of many fish stocks results in significant changes in trophic structure, 

species assemblages, and pathways of energy flow in marine ecosystems (Jackson et al., 2001; Myers & 

Worm, 2003). These ecological changes may have important, and likely adverse, consequences for 

populations of marine mammals (DeMaster et al., 2001). For instance, depletion of preferred prey could 

lead to a less nutritional diet and decreased reproductive success.

4.4.7.3.2.2 Entanglement and Ingestion

As discussed in Section 3.7.2.1.5 (General Threats to Marine Mammals), interactions between marine 

mammals and marine debris, including derelict fishing gear and plastics, are significant sources of injury 

and mortality (Baulch & Perry, 2014), and the percentage of marine mammal species with documented 

records of entanglement in or ingestion of marine debris increased from 43 to 66 percent between 1997

and 2015 (Bergmann et al., 2015). Ingestion of plastic bags and Styrofoam has been identified as a cause 

of injury or death of minke whales and deep-diving odontocetes, including beaked whales, pygmy sperm 

whales, and sperm whales. Manatee rescue records from 1993 to 2007 found that 27 percent of the 

cases were directly or indirectly associated with entanglement in or ingestion of marine debris, making 

entanglement and ingestion the top reason for rescuing manatees (Reinert et al., 2011). Table 4.4-1

provides entanglement data specific to baleen whales in the region of influence from 2010 through 2014

(Henry et al., 2016). 
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Table 4.4-1: Entanglements by Year: Summary of the Confirmed Human-Caused Mortality 

and Serious Injury Events Involving Baleen Whale Stocks along the Gulf of Mexico Coast, 

United States East Coast and Atlantic Canadian Provinces, 2010–2014

Stock

Annual Injury and 

Mortality Rate (U.S. 

Waters /

Canadian Waters / 

Unassigned Waters)

Confirmed Mortalities 

(2010, 2011, 2012, 2013, 

2014)

Confirmed Injury Events 

(2010, 2011, 2012, 2013, 

2014)

Western North Atlantic 

Fin Whale 2.0 / 0 / 0 10(2, 1, 4, 1, 2)

2

(1, 0, 0, 0, 1)

Gulf of Maine Humpback 

Whale1

1.8 / 0 / 0 9

(3, 3, 0, 2, 1)

13

(1, 4, 0, 3, 5)

Canadian East Coast 

Minke Whale 1.2 / 0.4 / 0 8(1, 3, 1, 0, 3) 0

Western North Atlantic 

Right Whale 0.81 / 0 / 0.2 2(1, 2, 0, 0, 0)

21

(4, 7, 6, 3, 1)

Nova Scotian Sei Whale 0.8 / 0 / 0 4

(0, 1, 0, 0, 3) 0

Unidentified Whale spp. 0.2 / 0.2 / 0 1

(1, 0, 0, 0, 0)

2

(0, 0, 1, 1, 0)

Northern Gulf of Mexico 

Bryde’s Whale 0 / 0 / 0 0 0

Western North Atlantic 

Blue Whale 0 / 0 / 0 0 0

1 Excludes events involving confirmed members of a stock other than the Gulf of Maine feeding stock

2 Opportunistic reports were provided by members of the U.S. and Canadian regional stranding networks, whale survey and 

disentanglement teams, the U.S. and Canadian Coast Guards, and the general public. With the exception of minke 

whales, the incidental takes of baleen whales recorded by fisheries observer programs are also included here as 

opportunistic reports because the numbers of observed takes were not sufficient to calculate bycatch rate estimates. 

All available information for each reported injury or mortality was collected by the NMFS Greater Atlantic Regional 

Fisheries Office, Southeast Regional Office, and Northeast Fisheries Science Center.

Source: Henry et al. (2016)
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4.4.7.3.3 Maritime Traffic and Vessel Strikes

Maritime traffic has increased over the past 50 years, and vessel traffic is expected to continue to 

increase in the Study Area in response to continued economic globalization, widening of the Panama 

Canal, and increases in energy development and other offshore activities. While increased risks come 

with increased vessel traffic, risks of vessel strikes could be minimized by ongoing and future education 

and awareness, marine mammal reporting, ship speed reduction measures, and maritime traffic 

planning and management (e.g., Atlantic Coast Port Access Study (U.S. Coast Guard, 2016)). Within the 

AFTT Study Area, commercial vessel traffic is heaviest along the entire United States East Coast and 

along the northern coast of the Gulf of Mexico while Navy vessel traffic is primarily concentrated along 

the United States East Coast between the mouth of the Chesapeake Bay and Jacksonville, Florida (Mintz, 

2012). An examination of vessel traffic within the AFTT Study Area determined that Navy vessel 

occurrence is two orders of magnitude lower than that of commercial traffic. The study also revealed 

that while commercial traffic is relatively steady throughout the year, Navy vessel usage is episodic and

based on specific exercises being conducted at different times of the year (Mintz, 2012); however, Navy 

vessel use within inshore waters occurs regularly and routinely consists of high-speed small vessel 

movements.

Most reported marine mammal vessel strikes involve commercial vessels and occur over or near the 

continental shelf (Laist et al., 2001). However, West Indian manatees are very susceptible to vessel 

strikes within inshore and coastal waters due to the overlap with their distribution and high levels of 

small vessel traffic, making vessel strike the leading anthropogenic cause of manatee mortality (Rommel 

et al., 2007). The most vulnerable marine mammals are thought to be those that spend extended 

periods at the surface or species whose unresponsiveness to vessel sound makes them more susceptible 

to vessel collisions (Gerstein, 2002; Laist & Shaw, 2006; Nowacek et al., 2004). Marine mammals such as 

dolphins, porpoises, and pinnipeds that can move quickly throughout the water column are not as 

susceptible to vessel strikes. 

The following percentage of strikes by species were observed during the period from 1995 through 2011 

(National Marine Fisheries Service, 2011a): humpback whale (28 percent), North Atlantic right whale 

(19 percent), fin whale (17 percent), unknown species (16 percent), sei whale (6 percent), minke whale 

(5 percent), Cuvier’s beaked whale (3 percent), Bryde’s whale (2 percent), sperm whale (2 percent), 

Blainville’s beaked whale (1 percent), and Gervais’ beaked whale (1 percent). West Indian manatees are 

also highly susceptible to boat strikes, but the data were not readily available to calculate a comparable 

percentage. Vessel strike data for tracked baleen whale stocks in the region of influence from 2010 to 

2014 are provided in Table 4.4-2.
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Table 4.4-2: Vessel Collisions by Year: Summary of the Confirmed Human-Caused Mortality and 

Serious Injury Events Involving Baleen Whale Stocks along the Gulf of Mexico Coast, United States 

East Coast and Atlantic Canadian Provinces, 2010–20142

Stock

Annual Injury and Mortality 

Rate (U.S. Waters /Canadian 

Waters / Unassigned Waters)

Confirmed Mortalities 

(2010, 2011, 2012, 2013, 

2014)

Confirmed Injury Events 

(2010, 2011, 2012, 2013, 

2014)

Western North Atlantic Fin 

Whale 2.0 / 0 / 0 10(2, 1, 4, 1, 2)

2

(1, 0, 0, 0, 1)

Gulf of Maine Humpback 

Whale1

1.8 / 0 / 0 9

(3, 3, 0, 2, 1)

13

(1, 4, 0, 3, 5)

Canadian East Coast Minke 

Whale 1.2 / 0.4 / 0 8(1, 3, 1, 0, 3) 0

Western North Atlantic Right 

Whale 0.81 / 0 / 0.2 2(1, 2, 0, 0, 0)

21

(4, 7, 6, 3, 1)

Nova Scotian Sei Whale 0.8 / 0 / 0 4

(0, 1, 0, 0, 3) 0

Unidentified Whale spp. 0.2 / 0.2 / 0 1

(1, 0, 0, 0, 0)

2

(0, 0, 1, 1, 0)

Northern Gulf of Mexico 

Bryde’s Whale 0 / 0 / 0 0 0

Western North Atlantic Blue 

Whale 0 / 0 / 0 0 0

1 Excludes events involving confirmed members of a stock other than the Gulf of Maine feeding stock

2 Opportunistic reports were provided by members of the U.S. and Canadian regional stranding networks, whale survey and 

disentanglement teams, the U.S. and Canadian Coast Guards, and the general public. With the exception of minke whales, the 

incidental takes of baleen whales recorded by fisheries observer programs are also included here as opportunistic reports because 

the numbers of observed takes were not sufficient to calculate bycatch rate estimates. All available information for each reported 

injury or mortality was collected by the NMFS Greater Atlantic Regional Fisheries Office, Southeast Regional Office, and Northeast 

Fisheries Science Center.

Source: Henry et al. (2016)

4.4.7.3.4 Ocean Noise

Ocean noise as a general stressor in modern oceans is described in Table 4.2-2 and specific to marine 

mammals in Section 3.7.2.1.5 (General Threats). Noise is of particular concern to marine mammals 

because many species use sound as a primary sense for navigating, finding prey, avoiding predators, and 

communicating with other individuals. Noise can cause behavioral disturbances; mask other sounds 

(including their own vocalizations); and may result in injury, including hearing loss in the form of 

temporary threshold shift (TTS) or permanent threshold shift (PTS) and, in some cases, death.

Anthropogenic noise is generated from a variety of sources throughout the region of influence, including 

commercial shipping, oil and gas exploration and production activities (including air gun, drilling, and 

explosive decommissioning), commercial and recreational fishing (including vessel noise, fish-finding 

sonar, fathometers, and acoustic deterrent and harassment devices), shoreline construction projects 

(including pile driving), recreational boating and whale-watching activities, offshore power generation 

(including offshore windfarms), and research (including sound from air guns, sonar, and telemetry). 

The military activities addressed in Table 4.2-1 include various training and testing operations that 

contribute vessel noise, underwater and surface explosions, and sonar. Use of mid-frequency sonar 

between 1950 and 2001 has been correlated with 12 of 126 beaked whale mass strandings during five 
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separate exercises (U.S. Department of the Navy, 2017b). Of these exercises, four were multi-nation 

(North Atlantic Treaty Organization countries) and one was solely an U.S. Navy exercise occurring near 

the Bahamas. In the Bahamas event, seven stranded animals died, and ten returned to the water. 

Although sonar activity has historically been correlated to various negative impacts on marine 

mammals, with the implementation of required mitigation measures, sonar operations are not expected 

to result in mortality to any stock of marine mammals and minimal injury or behavioral changes are 

anticipated. Although various other military training and testing activities involve surface or undersea 

detonations or gunnery exercises, these are generally mitigated through monitored exclusion zones, and 

are infrequent, isolated events. As described in Table 4.2-1, many activities incorporate best 

management practices or standard operating procedures to minimize noise generation. Likewise, any inwater construction that may occur at naval piers would utilize dampening and attenuation technologies 

and other practices that reduce impacts on bottlenose dolphins and other sensitive receptors in the 

vicinity of pile driving activities.

4.4.7.3.5 Ocean Pollution

As discussed in Table 4.2-1 and Table 4.2-2, multiple pollutants from multiple sources are present in, and 

continue to be released into, the oceans. Section 3.7.2.1.5 (General Threats to Marine Mammals) 

provides an overview of these potential impacts, which include morbidity and mortality from acute 

toxicity; disruption of endocrine cycles and developmental processes causing reproductive failures or 

birth defects; suppression of immune system function; and metabolic disorders resulting in cancer or 

genetic abnormalities (Deepwater Horizon Natural Resource Damage Assessment Trustees, 2016). The 

effects of exposure to and concentration of persistent organic pollutants in marine mammals, especially 

from pesticides, includes the accumulation of dichlorodiphenyltrichloroethane and polychlorinated 

biphenyls in certain species, and high concentrations of organochlorines in tissues appear to have 

occurred with increasing frequency among marine mammals infected with secondary diseases. In 

addition, experimental and other evidence has shown that persistent contaminants often found in the 

tissues of marine mammals have deleterious effects on reproduction and the immune system (O'Shea et 

al., 1999). 

The Deepwater Horizon oil spill is associated with an Unusual Mortality Event that killed over 1,000 

marine mammals between 2010 and 2014. The majority of affected mammals are bottlenose and other 

dolphins but the spill has also impacted the Gulf of Mexico stock of sperm, Blainville’s, Cuvier’s, and 

Gervais’ beaked whales and the Northern Gulf of Mexico stocks of Byrd’s, short-finned pilot, melonheaded, pygmy and false killer, and dwarf and pygmy sperm whales, off the coasts of Louisiana, 

Alabama, and Mississippi since the spill occurred (National Oceanic and Atmospheric Administration, 

2017b). Although marine mammal deaths associated with the spill were highest during this period, 

many populations continue to experience chronic illnesses and mortalities related to the spill (National 

Marine Fisheries Service, 2018a).

4.4.7.3.6 Power Plant Entrainment

Coastal power plants use seawater as a coolant during power plant operation. Intakes into these plants 

can sometimes trap (i.e., entrain) marine animals that swim too close to the intake pipe. Power plant 

entrainment contributes to human-related mortalities for gray seals. Conversely, Florida manatees rely 

on warm-water refuges typically associated with warm-water discharges from coastal power plants for 

winter habitats.
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4.4.7.3.7 Disease, Parasites, and Algae

Section 3.7.2.1.5.3 (Disease and Parasites) discusses the effects of disease and parasites in marine 

mammals. Just like humans, older animals are more susceptible to disease, and disease can spread 

through a population affecting a significant number of otherwise healthy individuals. Mass bottlenose 

dolphin die-off events have occurred since July 2013 along the Atlantic coast due to cetacean 

morbillivirus. Additionally, the spread of certain parasites (toxoplasmosis, hookworms, lungworms, and 

thorny-headed worms) can cause serious health issues and death, especially if multiple stressors have 

decreased the potential immunity and resilience of a given individual. Mortalities can also occur as a 

result of toxic algal blooms, such as the 2008 Alexandrium tamarense algal bloom that resulted in 

unprecedented mass mortalities of fish, birds, and marine mammals and Karenia brevis blooms affecting 

bottlenose dolphins and Florida manatee in the Gulf of Mexico and along the Florida Atlantic coast. 

4.4.7.4 Impacts of the Proposed Action That May Contribute to Cumulative Impacts

Impacts of the Proposed Action are detailed in Section 3.7 (Marine Mammals). Impacts that may 

contribute to cumulative impacts on marine mammals can be generally categorized as mortality, injury 

(Level A harassment under the MMPA), and behavioral responses and TTS (Level B harassment under 

the MMPA). These impacts would be associated with certain acoustic (sonar and other transducers), 

physical disturbance, and strike stressors. Although behavioral impacts are possible from the remaining 

acoustic stressors (noise from air guns, weapons firing/launch/impact, aircraft, and vessels), energy 

stressors (in-water electromagnetic devices and high energy lasers), physical disturbance and strike 

stressors (in-water devices, military expended materials, and seafloor devices), entanglement stressors 

(wires and cables, decelerators/parachutes, and biodegradable polymers), ingestion stressors 

(munitions and military expended materials other than munitions), and secondary stressors, these 

stressors are not expected to result in behavioral harassment, TTS, PTS, injury, or mortality of marine 

mammals.

The analysis presented in Section 3.7 (Marine Mammals) concluded that some stressors associated with 

the Proposed Action could impact individuals of certain marine mammal species, but impacts are not 

expected to decrease the overall fitness of any marine mammal population. Species most likely to be 

impacted by training and testing activities are those that are most abundant in the Study Area, primarily 

including the common dolphin, Atlantic spotted dolphin, striped dolphin, bottlenose dolphin, clymene 

dolphin, harbor porpoise, Atlantic white-sided dolphin, Risso's dolphin, pantropical spotted dolphin, and 

pilot whale that have stocks with tens to hundreds of thousands of animals. From a cumulative 

perspective, any potential impacts on species with small populations, especially ESA-listed species such 

as the North American right whale, are of particular concern, and the Navy has consulted with the 

NMFS, as required by section 7(a)(2) of the ESA, in that regard. The Navy will implement mitigation to 

avoid impacts from acoustic, explosive, and physical disturbance and strike stressors on marine 

mammals, as described in Chapter 5 (Mitigation).

As determined in Section 3.7.4 (Summary of Potential Impacts on Marine Mammals), it is not anticipated 

that the Proposed Action will result in measurable impacts to marine mammal populations. The majority 

of the proposed activities are unit level training and small testing activities, which are conducted in the 

open ocean. Unit level events occur over a small spatial scale (one to a few square miles) and with few 

participants (usually one or two) or short duration (the order of a few hours or less). Additionally, 

training and testing activities are generally separated in space and time in such a way that it would be 

unlikely that any individual marine mammal would be exposed to stressors from multiple Navy activities 

within a short timeframe. Furthermore, research and monitoring efforts have included before, during, 
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and after-event observations and surveys; data collection through conducting long-term studies in areas 

of Navy activity; occurrence surveys over large geographic areas; biopsy of animals occurring in areas of 

Navy activity; and tagging studies where animals are exposed to Navy stressors. To date, the findings 

from the research and monitoring (U.S. Department of the Navy, 2017b) and the regulatory conclusions 

from previous analyses by NMFS (National Marine Fisheries Service, 2015a; National Oceanic and 

Atmospheric Administration, 2013) are that the majority of Navy training and testing activities are not 

expected to have deleterious impacts on the fitness of any individuals or long-term consequences to 

populations of marine mammals.

4.4.7.4.1 Mortality

NMFS has previously concluded that the use of sonar and other transducers under the Proposed Action

is possible but not expected to result in marine mammal mortality (National Marine Fisheries Service, 

2015a; National Oceanic and Atmospheric Administration, 2013). Mitigation measures discussed in 

Chapter 5 (Mitigation) are designed to avoid potential impacts of explosives, especially higher-order 

impacts such as injury and death. However, the acoustic analysis indicates that certain marine mammal 

species could be exposed to underwater pressure waves from explosive detonations that may lead to

mortality (Tables 3.4-26 through 3.4-33). The protections afforded by mitigation measures cannot be 

fully quantified. For a general discussion of strandings and their causes, as well as strandings in 

association with U.S. Navy activity, see the technical report titled Marine Mammal Strandings Associated 

with U.S. Navy Sonar Activities (U.S. Department of the Navy, 2017b).

Abundant species including the common dolphin, Atlantic spotted dolphin, striped dolphin, bottlenose 

dolphin, clymene dolphin, harbor porpoise, Atlantic white-sided dolphin, Risso's dolphin, pantropical 

spotted dolphin, and pilot whale could have the highest chance of being killed by an explosion. The 

acoustic analysis also suggests that small numbers (three or less) of minke whales, melon-headed 

whales, white-beaked dolphins, spinner dolphins, and the ESA-listed sperm whale could be exposed to 

pressure waves from explosive detonations that may lead to mortality (Tables 3.4-22 through 3.4-29). 

Potentially lethal impacts were not predicted for other ESA-listed marine mammals.

Large ship shock trials occurring once per five-year period and small ship shock trials occurring three 

times per five-year period represent the greatest risk for marine mammal mortality based on the high 

net explosive weight charges used during these testing activities (up to 58,000 lb. net explosive weight). 

These testing events may occur in the Virginia Capes OPAREA, the Jacksonville OPAREA, or the Gulf of 

Mexico OPAREA in waters deeper than 650 feet. Specific mitigation measures discussed in Chapter 5 

(Mitigation) would be applied during shock trials and would greatly lower the likelihood of killing or 

injuring any marine mammals. If mortality were to occur, it is likely that the affected individuals would 

be from delphinid stocks or populations that number in the tens of thousands of animals.

Vessel strikes could also result in mortality of certain marine mammal species under the Proposed 

Action. Based on historical records and the probability analysis presented in Section 3.7.3.4 (Physical 

Disturbance and Strike Stressors), the Navy predicts that large whales may potentially be struck by a 

large vessel as a result of training and testing activities in the offshore portion of the Study Area. While 

the species involved in a strike cannot be quantifiably predicted, the affected animals may include the 

following species: fin whale, minke whale, sei whale, sperm whale, blue whale, or beaked whales. The 

Navy does not anticipate it would strike a North Atlantic right whale or West Indian manatee. For small 

vessel use within inshore waters, there have been zero reported strikes; therefore, the Navy predicts 

that no marine mammals would be struck by small vessels.
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4.4.7.5 Cumulative Impacts on Marine Mammals

In general, bycatch, vessel strikes, and entanglement are leading causes of injury and direct mortality to 

marine mammals throughout the region of influence. Although mitigated to the greatest extent 

practicable, the Proposed Action could result in injury and mortality to individuals of some marine 

mammal species from underwater explosions and vessel strikes, and potential auditory injury (i.e. PTS) 

from sonar. Implementation of measures discussed in Chapter 5 (Mitigation) would help avoid, but not 

absolutely eliminate, the risk for potential impacts, and any incidence of injury and mortality that might 

occur under the Proposed Action could be additive to injury and mortality associated with other actions

in the region of influence. While it is more likely that an individual of an abundant, common stock or 

species would be affected, there is a chance that a less abundant stock could be affected. 

Ocean noise is already significantly elevated over historic, natural levels, and acoustic stressors 

(underwater explosions and sonar as well as increased Navy vessel noise) associated with the Proposed 

Action could also result in additive acoustic impacts on marine mammals. However, sonar is known to 

be neither a major threat to marine mammal populations nor a significant portion of the overall ocean 

noise budget (Bassett et al., 2010; Baumann-Pickering et al., 2010; International Council for the 

Exploration of the Sea, 2005; McDonald et al., 2006). Other current and future actions such as 

construction and operation of liquefied natural gas terminals; characterization, construction, and 

operation of offshore wind energy projects; seismic surveys; and construction, operation, and removal 

of oil and gas facilities could result in underwater sound levels that could cause behavioral harassment, 

TTS, PTS, or injury. Additionally, the constant elevation in ambient noise may produce physiological 

stress in individuals to which the Proposed Action would contribute.

Sounds from many of these sources travel over long distances, and it is possible that some would 

overlap in time and space with sounds from underwater explosions or Navy sonar use, in particular 

distant shipping noise, which is more widespread and continuous. It is not known whether the cooccurrence of shipping noise and sounds associated with underwater explosions and sonar use would 

result in harmful additive impacts on marine mammals. However, these activities are widely dispersed, 

the sound sources are intermittent, and mitigation measures would be implemented. Furthermore, 

safety, security, and operational considerations would preclude some training and testing activities in 

the immediate vicinity of other actions, further reducing the likelihood of simultaneous or overlapping 

exposure. For these reasons, it is unlikely that an individual marine mammal would be simultaneously 

exposed to sound levels from multiple actions that could cause behavioral harassment, TTS, PTS, or 

injury.

If the health of an individual marine mammal were compromised, it is possible this condition could alter 

the animal’s expected response to stressors associated with the Proposed Action. The behavioral and 

physiological responses of any marine mammal to a potential stressor, such as underwater sound, could 

be influenced by various factors, including disease, dietary stress, body burden of toxic chemicals, 

energetic stress, percentage body fat, age, reproductive state, and social position. Synergistic impacts 

are also possible; for example, animals exposed to some chemicals may be more susceptible to noiseinduced loss of hearing sensitivity (Fechter & Pouyatos, 2005). While the response of a previously 

stressed animal might be different from the response of an unstressed animal, no data is available at 

this time to accurately predict how stress caused by various ocean pollutants would alter a marine 

mammal’s response to stressors associated with the Proposed Action.
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In summary, the aggregate impacts of past, present, and other reasonably foreseeable future actions 

continue to have significant impacts on some marine mammal species in the Study Area. The Proposed 

Action could contribute incremental stressors to individuals, which would further compound effects on a 

given individual already experiencing stress. However, with the implementation of standard operating 

procedures reducing the likelihood of overlap in time and space with other stressors and the 

implementation of mitigation measures reducing the likelihood of impacts, the incremental stressors 

anticipated from the Proposed Action are not anticipated to be significant.

Furthermore, the regulatory process administered by NMFS, which includes Stock Assessments for all 

marine mammals and a 5-year reviews for all ESA-listed species, provides a backstop that informs 

decisions on take authorizations and Biological Opinions. Stock Assessments include estimates of 

Potential Biological Removal that stocks of marine mammals can sustainably absorb. MMPA take 

authorizations require that the proposed action have no more than a negligible impact on species or 

stocks, and that the proposed action imposes the least practicable adverse impact on the species. 

MMPA authorizations are reinforced by monitoring and reporting requirements so that NMFS is kept 

informed of deviations from what has been approved. Biological Opinions for federal and non-federal 

actions are similarly grounded in status reviews and conditioned to avoid jeopardy and to allow 

continued progress toward recovery. These processes help to ensure that, through compliance with 

these regulatory requirements, the Navy’s Proposed Actions would not have a measurable effect on the 

resource. 

4.4.8 REPTILES

4.4.8.1 Region of Influence

The general region of influence for reptiles is the open ocean and coastal regions throughout the 

tropical to temperate latitudes of the Study Area. Reptiles that occur within the boundaries of the Study 

Area include sea turtles (green turtles [Chelonia mydas], hawksbill turtle [Eretmochelys imbricate], 

Kemp’s ridley turtle [Lepidochelys kempii], leatherback turtle [Dermochelys coriacea], and loggerhead 

turtle [Caretta caretta]) and crocodilians (the American crocodile [Crocodylus acutus], the American 

alligator [Alligator mississippiensis]), and various subspecies of diamondback terrapin (Malaclemys 

terrapin) In general, sea turtles spend most of their time at sea, with female turtles returning to land to 

nest and often migrating long distances between feeding grounds and nesting beaches. Alligators and 

crocodiles spend most of their time in fresh or brackish water, with individuals occasionally briefly 

sighted in nearshore marine waters, and terrapin generally occupy brackish swamps along the Atlantic 

and Gulf coasts. As with other marine resources, reptile distribution is patchy and can be concentrated 

in specific areas depending on the species, season, habitat, activity, and age of the individuals.

4.4.8.2 Resource Trends

All reptiles in the Study Area have experienced significant decline in population numbers over the past 

hundred years and are ESA-listed (Table 3.8-1). Because turtles are so long-lived, and because reliable 

data is only available for approximately the past 20 years, it is not possible to determine a reliable trend 

in abundance for most species; however, recent data show an increase in nesting trends within the 

Study Area (Mazaris et al., 2017). Since listing, alligator and crocodile populations are recovering in the 

U.S. and distributions have expanded; alligator populations have largely rebounded but are still 

protected under the ESA due to their similarity in appearance to crocodiles.
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4.4.8.3 Impacts of Other Actions

4.4.8.3.1 Overview

Section 3.8.2.1.5 (General Threats) discusses the specific stressors within the affected environment that 

impact sea turtle populations in the Study Area, which include water quality (marine debris and 

chemical contaminants), commercial industries (fisheries bycatch and other interactions, 

hunting/exploitation, vessel strike, oil and gas development, wind and hydrokinetic energy 

development, shoreline development and recreation, dredging, military activities, invasive species, 

disease, habitat destruction (loss of seagrass habitat and nesting beaches), and climate change. 

Potential impacts of actions that affect reptiles include mortality, injury, disturbance, and reduced 

fitness, including reproductive, foraging, and predator avoidance success. Crocodiles are largely 

impacted by habitat loss, specifically coastal development in Florida that restricts breeding areas as well 

as freshwater flow into swamps and estuaries. Car collisions and competition and predation pressure 

from introduced species are also threats. Alligators are sensitive to prey availability and water quality 

parameters, including metal and pharmaceutical contamination.

The susceptibility of sea turtles to these outcomes often depends on proximity, severity, or vulnerability 

to the stressor, and vulnerability can be increased as multiple stressors compound on an individual. The 

abundance of the species, potential impacts that may affect localized nesting locations (e.g., Kemp’s 

ridley nesting in the Gulf of Mexico), and individual fatalities could have considerable impacts in 

localized populations.

The activities described in Table 4.2-1 each potentially contribute multiple stressors in the Study Area 

experienced by reptiles, including vessel traffic, underwater noise, and water pollution. For example, 

most actions include the operation of marine vessels, which contribute to vessel strikes and underwater 

noise. Many of the actions also contribute underwater noise from sources other than vessels, including 

use of explosives for oil rig removal, seismic surveys, construction activities, and military operations. 

Bycatch and entanglement, among the main threats to reptile populations in the Study Area, are chiefly 

associated with fishing and are discussed separately. While Table 4.2-1 and Table 4.2-2 discuss these 

stressors for individual actions, their aggregate impacts specific to reptiles are detailed in Section 

3.8.2.1.5 (General Threats) and further described below. 

4.4.8.3.2 Commercial Fishing and Harvest

Past and present commercial fishing activities have had a profound global effect on the recovery and 

conservation of marine turtle populations and, despite continued improvements in bycatch avoidance 

and the implementation of regulatory efforts, fisheries interactions continue to be the primary humanrelated source of mortality for most sea turtles (National Research Council of the National Academies, 

1990; Wallace et al., 2010). One comprehensive study estimated that worldwide, 447,000 turtles are 

killed each year from bycatch in commercial fisheries (Wallace et al., 2010). Among fisheries that 

incidentally capture sea turtles, certain types of trawl, gillnet, and longline fisheries generally pose the 

greatest threat. NMFS has instituted fishery observer and documentation programs to record bycatch 

events and implements regulations to reduce sea turtle bycatch in the Pacific and Atlantic Oceans and 

the Gulf of Mexico. In the Atlantic and Gulf of Mexico, NMFS requires gear modifications, changes to 

fishing practices, and time/area closures to reduce sea turtle bycatch in specific fisheries, especially the 

use of turtle excluder devices by the trawl fishing industry in the southeastern U.S. Atlantic and Gulf of 

Mexico. NMFS maintains a collaborative bycatch reduction engineering program that focuses on the 
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innovation of efficient and economically effective bycatch and interaction strategies in federally 

managed fisheries.

In the region of influence for sea turtles, three fishery groups comprised of 13 individual fisheries impact 

loggerhead, leatherback, green, and Kemp’s Ridley (National Marine Fisheries Service, 2016a). Fisheries 

that result in sea turtle bycatch in the Study Area include pelagic fisheries for swordfish, tuna, shark, and 

billfish; purse seine fisheries for tuna; commercial and recreational rod and reel fisheries; gillnet 

fisheries for shark; driftnet fisheries; bottom longline fisheries; and sea scallop fisheries (National 

Marine Fisheries Service, 2009a). NMFS has determined that Southeast shrimp trawl fisheries, Atlantic 

HMS pelagic longline, HMS directed shark, reef fish, and coastal migratory pelagic resources fisheries 

have been found likely to adversely affect threatened and endangered sea turtles (National Marine 

Fisheries Service, 2014b). 

However, the fisheries that have the most significant demographic effect on sea turtles are the shrimp 

trawl fisheries conducted off the southeast U.S. (from North Carolina to the Atlantic coast of Florida) 

and Gulf of Mexico (from the Gulf coast of Florida to Texas). Since 1994 all shrimp trawling participants 

are required to use turtle exclusion devices, which, when used, are estimated to reduce the number of 

sea turtles trawlers capture by as much as 94-97 percent (National Marine Fisheries Service, 2014b). 

However, from 2012 to 2013 use ranged from 58 to 83 percent on vessels boarded (National Marine 

Fisheries Service, 2014b). During this time, interactions between Southeastern shrimp fisheries and sea 

turtles were estimated to effect 663,636 individual sea turtles, including 527,842 interactions and 

43,622 mortalities. The majority of individuals affected are Kemp’s Ridley.

Globally, large-scale commercial exploitation also contributes to global decline in sea turtle populations. 

Currently, 42 countries and territories allow direct take of turtles and collectively take in excess of 

42,000 turtles per year, the majority of which (greater than 80 percent) are green turtles (Humber et al., 

2014). Illegal fishing for sea turtles and nest harvesting also continues to be a major cause of sea turtle 

mortality, both in countries that allow sea turtle take and in countries that outlaw the practice (Lam et 

al., 2011; Maison et al., 2010). For example, Humber et al. (2014) estimated that in Mexico 65,000 sea 

turtles were illegally harvested between 2000 and 2014. The authors, however, have seen legal and 

illegal direct take of sea turtles trending downward over the past three decades—citing a greater than 

40 percent decline in green sea turtle take since the 1980s, a greater than 60 percent decline in 

hawksbill and leatherback take, and a greater than 30 percent decline in loggerhead take (Humber et al., 

2014).

4.4.8.3.2.1 Maritime Traffic and Vessel Strikes

Maritime traffic has increased over the past 50 years, and vessel traffic is expected to continue to 

increase in the Study Area in response to continued economic globalization, widening of the Panama 

Canal, and increases in energy development and other offshore activities. Vessel strike has been 

identified as one of the important mortality factors in several nearshore turtle habitats worldwide. 

Precise data are lacking for sea turtle mortalities directly caused by ship strikes; however, live and dead 

turtles are often found with deep cuts and fractures indicative of collision with a boat hull or propeller

(Hazel et al., 2007; Lutcavage et al., 1997). For example, scientists in Hawaii reported that 2.5 percent of 

green turtles found dead on the beaches between 1982 and 2003 had been killed by boat strike

(Chaloupka et al., 2008), and in the Canary Islands, 23 percent of stranded sea turtles showed lesions 

from boat strikes or fishing gear (Oros et al., 2005). Denkinger et al. (2013) reports that boat strikes in 

the Galapagos Islands were most frequent at foraging sites close to a commercial and tourism port. 
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The Sea Turtle Stranding and Salvage Network includes federal, state and private partners who 

document sea turtle strandings along the U.S. Gulf of Mexico and Atlantic coasts from Maine to Texas 

and portions of the U.S. Caribbean (National Oceanic and Atmospheric Administration, 2017a). Network 

participants compile records of vessel interactions (propeller injury) from their respective areas and 

contribute those data to the centralized Sea Turtle Stranding and Salvage Network database on a weekly 

basis (National Oceanic and Atmospheric Administration, 2017a). For the Gulf of Mexico and Atlantic 

regions, the Sea Turtle Stranding and Salvage Network recorded 2,055 total nearshore and offshore 

strandings in 2016. (Louisiana had minimal participation in this program.)

Some vessel strikes could cause temporary impacts, such as diverting the turtle from its previous activity 

or causing minor injury. Major strikes could cause permanent injury or death from bleeding, infection, or 

inability to feed. Apart from the severity of the physical strike, the likelihood and rate of a turtle’s 

recovery from a strike may be influenced by its age, reproductive state, and general condition. 

Numerous living sea turtles bear scars that appear to have been caused by propeller cuts or collisions

with vessel hulls (Hazel et al., 2007; Lutcavage et al., 1997), suggesting that not all vessel strikes are 

lethal. While increased risks come with increased vessel traffic, risks of vessel strikes could be minimized 

by ongoing and future education and awareness, ship speed reduction measures, and maritime traffic 

planning and management (e.g. Atlantic Coast Port Access Study (U.S. Coast Guard, 2016)).

4.4.8.3.3 Coastal Land Development

The population along the U.S. coastline grew from 47 million in 1960 to 87 million in 2008, and human 

development now dominates the coastline almost continuously throughout its extent (Wilson & 

Fischetti, 2010). During this timeframe, the Atlantic coast grew by 15 million people and the Gulf of 

Mexico about 8 million. Although this represents 56 percent growth for the Atlantic region, the Gulf of 

Mexico, which prior to the 1960s was more rural, grew 150 percent during that timeframe. The limited 

space for development in coastal areas results in greater population density in these locations. In the 

U.S. (excluding Alaska), non-coastal counties average 98 persons per square mile while coastal counties 

average 300 persons per square mile. 

Female sea turtles migrate to their natal beaches to lay eggs, and pervasive coastal development often 

interferes with successful nesting at these locations. Shared use between turtles and human interests on 

increasingly populated and utilized beach areas has intensified the tendency for female turtles and their 

hatchlings to encounter various barriers and hazards accessing, nesting, and leaving these beaches. 

Beachfront construction of homes, hotels, restaurants, and roads; seawall construction, shoreline 

armoring, and beach erosion; ports and marinas; beach replenishment; nearshore dredging; and oil and 

gas activities can all prevent beach access and emigration; beach-going vehicles and watercraft cause 

injury and mortality; and abandoned debris and equipment are often insurmountable obstacles for both 

mother and offspring (SeeTurtles.org, 2017). Populated areas also often have excess nighttime lighting 

that confuses hatchlings’ instincts to orient toward the moon to arrive at the ocean, and in this journey 

they often fall into and can remain trapped within pits and scars left on the beach. Conservation 

awareness has increased on many popular U.S. beaches and tourist destinations, but nesting success 

remains imperiled in many others. Along the Atlantic coast, development can also lead to secondary 

impacts, such as barrier island migration induced by altering sediment loads into coastal environments. 

For example, landward barrier island migration is occurring at about 1–6 meters per year, which is 

leading to back barrier area reduction and large-scale salt marsh loss (0.45 km2 per year) (Deaton et al., 

2017). This process is responsible for 51 percent of the marsh loss in the Atlantic coastal region.
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Human development along coastal zones is also a major threat to crocodilian species and terrapin as 

development diminishes available habitat and restricts the species’ breeding range. In addition to direct 

habitat loss, alteration of habitat is a concern; typically, residential and urban development restricts 

freshwater flow into swamps and estuaries, which may in particular limit crocodilian growth, survival, 

and abundance (Mazzotti et al., 2007).

4.4.8.3.4 Ocean Pollution

As discussed in Table 4.2-1 and Table 4.2-2, multiple pollutants from multiple sources are present in, and 

continue to be released into, the oceans. Section 3.8.2.1.5.1 (Water Quality) provides an overview of 

these potential impacts on sea turtles, which include the ingestion of and entanglement in marine debris 

as well as toxicity from bisphenol-A, phthalates, and heavy metals. Sea turtles often mistake debris for 

prey; one study found 37 percent of dead leatherback turtles had ingested various types of plastic 

(Mrosovsky et al., 2009). Other marine debris, including derelict fishing gear and cargo nets, can 

entangle and drown turtles in all life stages.

A total of 1,146 sea turtle mortalities were recorded during the 2010 Deepwater Horizon Oil Spill, most 

of which were Kemp’s Ridley (National Marine Fisheries Service, 2011b, 2014a). The available data on 

sea turtle strandings and response collections during the time of the spill are expected to represent a 

fraction (currently unknown) of the actual losses to the species, as most individuals likely were not 

recovered. Indirect effects from the spill include loss of seagrass foraging habitat and other food species. 

Long-term effects of oil spills can persist for decades (National Marine Fisheries Service, 2011b, 2014a; 

Ortmann et al., 2012).

4.4.8.3.5 Ocean Noise

Ocean noise as a general stressor in modern oceans is described in Table 4.2-2. Anthropogenic noise is 

generated from a variety of sources throughout the region of influence, including commercial shipping, 

oil and gas exploration and production activities (including air guns, drilling, and explosive 

decommissioning), commercial and recreational fishing (including vessel noise, fish-finding sonar, 

fathometers, and acoustic deterrent and harassment devices), shoreline construction projects (including 

pile driving), recreational boating and whale-watching activities, offshore power generation (including 

offshore windfarms), and research (including sound from air guns, sonar, and telemetry). The military 

activities addressed in Table 4.2-1 include various training and testing activities that also contribute 

vessel noise, underwater and surface explosions, and sonar; however, due to the low risk of encounter 

and the implementation of required mitigation measures, sonar operations are not expected to result in 

mortality to any sea turtles and only minimal injury or behavioral changes are anticipated. Although 

various other military training and testing activities involve surface or underwater detonations or 

gunnery exercises, these are generally mitigated through monitored exclusion zones, and are infrequent 

and isolated events. Further, as described in Section 3.0.3.3.1.4 (Vessel Noise), it is estimated that the 

overall contribution of Navy vessel noise is less than 1 percent of the overall total vessel broadband 

noise in the entire AFTT study area.

In general, the potential concerns associated with ocean noise and sea turtles are not as well defined as 

those for marine mammals. While it is well known that many species of marine mammals use sound as a 

primary sense for navigating, finding prey, and communicating with other individuals, little is known 

about how sea turtles use sound in their environment. Based on knowledge of their sensory biology

(Bartol & Musick, 2003; Bartol & Ketten, 2006; Ketten & Moein-Bartol, 2006; Levenson et al., 2004), sea 

turtles may be able to detect objects within the water column (e.g., vessels, prey, predators) via some 
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combination of auditory and visual cues. However, research examining the ability of sea turtles to avoid 

collisions with vessels shows they may rely more on their vision than auditory cues (Hazel et al., 2007). 

Similarly, while sea turtles may rely on acoustic cues from breaking waves to identify nesting beaches, 

they also appear to rely on other nonacoustic cues for navigation, such as magnetic fields (Lohmann & 

Lohmann, 1992, 1996) and light (Avens, 2003). Additionally, sea turtles are not known to produce 

sounds underwater for communication. As a result, sound may play a limited role in a sea turtle’s 

environment.

Nonetheless, as discussed in Section 3.8.3.1 (Acoustic Stressors), sea turtles could experience a range of 

impacts from ocean noise, depending on the sound source. The impacts could include permanent or 

temporary hearing loss, changes in behavior, physiological stress, and auditory masking. In addition, 

potential impacts from use of explosives could range from physical discomfort to nonlethal and lethal 

injuries. 

4.4.8.3.6 Offshore Energy Development

Offshore energy development, including oil and natural gas extraction in coastal and deep waters on the 

continental shelf and renewable energy projects, can degrade sea turtle habitats during preconstruction, construction, and operation phases. Prior to any drilling or driving operations, vessel traffic 

and seismic disturbances through exploration activities can degrade sea turtle coastal and open ocean 

foraging habitats. Oil and gas exploration and development in the Gulf of Mexico are a particular threat 

to Kemp’s Ridley sea turtles. Sea turtles are also frequently observed in areas identified for renewable 

energy development along the mid-Atlantic coast, although the potential impacts of establishing 

windfarms or hydrokinetic energy turbines in turtle habitats are relatively unknown (Williams et al., 

2015). 

4.4.8.4 Impacts of the Proposed Action That May Contribute to Cumulative Impacts

Although susceptible to vessel noise, aircraft noise, and explosives, most activities associated with the 

Proposed Action would not occur in terrapin or crocodilian habitat and the probability of impacts on

these species is anticipated to be extremely low. 

The cumulative impacts analysis is generally focused on green, hawksbill, Kemp’s Ridley, leatherback, 

and loggerhead turtles, all of which are ESA-listed species. The analysis presented in Section 3.8

(Reptiles) concludes that some stressors associated with the Proposed Action could impact individuals of 

certain sea turtle species, but impacts are not expected to decrease the overall fitness of any sea turtle 

population. From a cumulative perspective, potential impacts on ESA-listed species are of particular 

concern, and mitigation measures designed to avoid potential impacts are discussed in Chapter 5 

(Mitigation). 

Impacts from the Proposed Action that may contribute to cumulative impacts on sea turtles can be 

generally categorized as behavioral responses, TTS, PTS, injury (modeled as slight lung injury), and 

mortality. As summarized below, these impacts would be associated with certain acoustic and physical 

strike stressors:

 The use of sonar and transducers may result in behavioral responses, TTS, and PTS in sea turtles 

(Tables 3.8-6 through 3.8-8) including ESA-listed sea turtles (Table 3.8-1).

 Explosives may result in behavioral responses, TTS, PTS, injury, and mortality in sea turtles 

(Tables 3.8-7 through 3.8-10), including ESA-listed sea turtles (Table 3.5-1).
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 Vessel strikes may cause injury or mortality in sea turtles, including ESA-listed sea turtles 

(Section 3.5.3.3.1, Impacts from Vessels).

The remaining acoustic stressors (noise from air guns, weapons firing/launch/impact, aircraft overflight, 

and vessels), energy stressors (electromagnetic and high energy lasers), physical disturbance and strike 

stressors (in-water devices, military expended materials, and seafloor devices), entanglement stressors 

(cables, wires, and decelerators/parachutes), ingestion stressors (munitions and military expended 

materials other than munitions), and secondary stressors are not expected to result in TTS, PTS, injury, 

or mortality of sea turtles under the Proposed Action, including ESA-listed sea turtles. The Proposed 

Action would not introduce significant light sources that would disorient nesting turtles or their 

hatchlings. Because Navy training and testing activities analyzed in this EIS/OEIS do not co-occur with 

nesting activities, it is unlikely that stressors presented to sea turtles will contribute to other 

anthropogenic threats not caused by Navy activities.

Although sea turtles could be exposed to sound and energy from explosive detonations throughout the 

Study Area, the estimated impacts on individual sea turtles are unlikely to affect populations. Injured sea 

turtles could suffer reduced fitness and long-term survival. Sea turtles that experience TTS or PTS may 

have reduced ability to detect relevant sounds such as predators or prey, although some experiencing 

TTS would recover quickly, possibly in a matter of minutes. It is uncertain whether some permanent 

hearing loss over a part of a sea turtle’s hearing range would have long-term consequences for that 

individual because the sea turtle hearing range is already limited (Section 3.8.3.1, Acoustic Stressors). 

Any significant behavioral reactions to acoustic stimuli could lead to a sea turtle expending energy and 

missing opportunities to secure resources. However, most individuals are not likely to experience longterm consequences from behavioral reactions because exposures would be intermittent and spatially 

distributed, allowing exposed individuals to recover. Since long-term consequences for most individuals 

are unlikely, long-term consequences for populations are not expected.

The Proposed Action is not anticipated to have any effect on sea turtle nesting beaches or crocodilian or 

terrapin habitat in the region of influence. The training and testing activities associated with the 

Proposed Action would not contribute to factors that impact nesting habitats for these species.

In summary and as determined in Section 3.8.4 (Summary of Potential Impacts on Reptiles), it is not 

anticipated that the Proposed Action would result in significant impacts to reptiles. Due to the wide 

dispersion of stressors and dynamic movement of many training and testing activities, it is unlikely that a 

sea turtle would remain in the potential impact range of multiple sources or sequential exercises. 

Additionally, the majority of the proposed activities are unit level training and small testing activities, 

which occur over a small spatial scale (one to a few square miles) and with few participants (usually one 

or two) or short duration (the order of a few hours or less). Likewise, training and testing activities are 

generally separated in space and time in such a way that it would be unlikely that any individual sea 

turtle would be exposed to stressors from multiple activities within a short timeframe. Furthermore, 

research and monitoring efforts have included before, during, and after-event observations and surveys;

data collection through conducting long-term studies in areas of Navy activity; occurrence surveys over 

large geographic areas; biopsy of animals occurring in areas of Navy activity; and tagging studies where 

animals are exposed to Navy stressors. To date, the findings from the research and monitoring and the 

regulatory conclusions from previous analyses by NMFS (National Marine Fisheries Service, 2015a; 

National Oceanic and Atmospheric Administration, 2013) are that the majority of impacts from Navy 

training and testing activities are not expected to have deleterious impacts on the fitness of any 

individuals or long-term consequences to populations of sea turtles.
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4.4.8.5 Cumulative Impacts on Reptiles

The fact that all five species of sea turtles occurring in the Study Area are ESA-listed provides a clear 

indication that the current aggregate impacts of past human activities are significant for sea turtles. 

Bycatch, vessel strikes, coastal land development, and ocean pollution are the leading causes of 

mortality and population decline for sea turtles, and, although mitigated/avoided to the greatest extent 

practicable, the Proposed Action could also result in stress, injury, and mortality to individuals of some 

sea turtle species from underwater explosions and vessel strikes. Implementation of observation and 

delay measures discussed in Chapter 5.0 (Mitigation) would help avoid, but not absolutely eliminate, the 

risk for potential impacts, and any incidence of injury and mortality that might occur under the Proposed 

Action could be additive to injury and mortality associated with other actions in the region of influence. 

Due to standard operating procedures and mitigation measures, most impacts associated with the 

Proposed Action are not anticipated to interact with or increase similar stressors experienced 

throughout the region of influence. According to scientific studies, reptiles may rely primarily on senses 

other than hearing for interacting with their environment and appear to quickly recover from noise 

stressors (Section 3.8.3.1, Acoustic Stressors); thus, the acoustic stressors produced by Navy activities 

are anticipated to have minimal cumulative impact on sea turtles. The Proposed Action will not affect 

turtle nesting or crocodilian habitat, and contaminants and debris discharged into the marine 

environment are expected to be negligible and not persistent (Section 4.4.1.2, Sediment and Water 

Quality). Affects from the Proposed Action to sea turtle food sources are avoided or insignificant 

(Section 4.4.1.4, Invertebrates and Section 4.4.1.3, Vegetation). Likewise, Navy actions generally would

not overlap in space and time with other stressors as they occur as dispersed, infrequent, and isolated 

events that do not last for extended periods of time. 

The potential exists for the impacts of ocean pollution (disease, malnourishment), injury, nesting habitat 

loss, starvation, and the composite increased underwater noise environment to contribute multiple 

stressors to an individual, and it is possible that the response of a previously stressed animal to impacts 

associated with the Proposed Action could be more severe than the response of an unstressed animal, 

or that impacts from the Proposed Action could make an individual more susceptible to other stressors. 

For example, if a Navy vessel were to strike an otherwise healthy sea turtle, exposure to multiple other 

stressors in the area may hinder the individual’s recovery from any injury sustained in the accident. 

Likewise, a sea turtle in the vicinity of an underwater explosion or sonar activity may become stressed or 

disoriented, and the time to recover may be increased if that individual is likewise experiencing disease, 

malnutrition, or other strike injury that may increase its vulnerability to predation or decrease its ability 

to forage.

In summary, the aggregate impacts of past, present, and other reasonably foreseeable future actions 

continue to have significant impacts on all reptile species in the Study Area. The Proposed Action could 

contribute incremental stressors to individuals, which would further compound effects on a given 

individual already experiencing stress. However, with the implementation of standard operating 

procedures reducing the likelihood of overlap in time and space with other stressors and the 

implementation of mitigation measures reducing the likelihood of impacts, the incremental stressors 

anticipated from the Proposed Action are not anticipated to be significant. Additionally, as with marine 

mammals, the NMFS regulatory process includes population assessments and 5-year reviews for all ESAlisted species, which provides a backstop that informs decisions on take authorizations and Biological 

Opinions. Biological Opinions for federal and non-federal actions are grounded in status reviews and 

conditioned to avoid jeopardy and to allow continued progress toward recovery. This processes helps to 
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ensure that, through compliance with these regulatory requirements, the Navy’s Proposed Action would

not have a measurable effect on the resource.

4.4.9 BIRDS AND BATS

Although not uniformly distributed, the region of influence for birds includes shorelines, surface water, 

water column and shallow bottom habitats, and airspace throughout the Study Area. Bats are also 

present in marine environments, although they do not utilize water column and shallow bottom habitat. 

The majority of species encountered in the Study Area are waterbirds, including seabirds, wading birds, 

shorebirds, and waterfowl that use Study Area habitat for breeding, foraging, roosting, and migration. 

The remainder of species that may be regularly encountered in the Study Area are landbirds that are 

coastal resident species that live on land but forage in the adjacent coastal and inshore waters or 

neotropical migrant species (primarily songbirds) that occur briefly during transit between breeding 

areas in eastern North America and wintering areas in Central and South America and the Caribbean. 

Many bat species occur in coastal (nearshore) waters, offshore waters (continental shelf), or open ocean 

areas while migrating or foraging. Bats almost exclusively use echolocation to navigate and feed, and 

they will use islands, ships, and other offshore structures as opportunistic or deliberate stopover sites 

for resting or roosting. 

All projects in the Study Area that affect ESA-listed species, species protected under the Migratory Bird 

Treaty Act, and U.S. Fish and Wildlife Service Birds of Conservation Concern are subject to regulatory 

processes and permitting that gives agencies a landscape management perspective of population trends 

and conservation measures. ESA-listed species are described in Table 3.9-1; there are four species of 

birds and two species of bats listed as endangered or threatened and one bird species with designated 

critical habitat under the ESA that occur in the Study Area. Despite numerous protective laws and 

regulations, seabirds are some of the most threatened marine animals in the world, with 29 percent of 

species at risk of extinction and approximately half of the 346 species of seabirds that depend on ocean 

habitats in decline (Section 3.9.2.1.5, General Threats). Bat populations are also in precipitous decline, 

impacted chiefly by disease (Section 3.9.2.1.5.3, Disease and Parasites).

Birds and bats are susceptible to multiple stressors, and the susceptibility of many species could be 

enhanced by additive or synergistic effects of multiple stressors. Section 3.9.2.1.5 (General Threats) 

includes an extensive discussion of the existing stressors to bird and bat populations in the Study Area, 

and all activities listed in Table 4.2-1 and stressors described in Table 4.2-2 contribute one or more of 

these stressors. Other activities in the Study Area that could have direct impacts on birds and bats 

include wind energy development (strike mortality and forage displacement); noise, light, and water 

pollution (direct impacts from major spills, indirect impacts from habitat loss and degradation, and 

marine debris); commercial fishing (loss of food source, strike, and entanglement); climate change; 

coastal land development (disturbance, collisions, and loss of breeding, nesting, or foraging habitat); and

operation of ports and terminals or military training areas (disturbance). Commercial fisheries are 

considered the most serious threat to the world’s seabirds. Most of the birds in the Study Area are 

relatively long-lived and wide-ranging seabirds, making it likely that individuals would be exposed to 

multiple activities and stressors over the course of their lifespans. 

The analysis in Section 3.9 (Birds and Bats) indicates that birds and bats (to a lesser extent) could 

potentially be impacted by in air and underwater acoustic stressors (sonar and other transducers, pile 

driving, air guns, weapons firing, aircraft and vessel noise), explosives (shock wave, sound, fragments), 

energy stressors (electromagnetic devices, lasers), physical disturbance and strikes (aircraft, aerial 
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targets, vessels and in-water devices, military expended materials, seafloor devices, pile driving), 

entanglement (fiber optic cables, guidance wires, vessel entanglement systems, and 

decelerators/parachutes), ingestion (military expended materials), and secondary stressors (explosives 

and explosion byproducts, unexploded munition, metals, chemicals, other materials, physical 

disturbance). Some stressors, including explosions, physical strikes, and ingestion of plastic military 

expended materials, could result in mortality. In general, however, the potential for training and testing 

activities to result in the injury or mortality of birds or bats is considered low to discountable, depending 

on the specific training or testing activity being considered. The vast majority of impacts are expected to 

be nonlethal: the most likely responses to training and testing activities are short-term behavioral or 

physiological, such as alert response, startle response, cessation of feeding, fleeing the immediate area, 

and a temporary increase in heart rate. Recovery from the impacts of most stressor exposures that elicit 

such short-term behavioral or physiological responses would occur quickly. 

Impacts that elicit behavioral or physiological impacts can combine with other stressors experienced 

elsewhere and result in decreased fitness of the individual as it moves throughout the Study Area. 

However, most of the proposed activities would be widely dispersed in offshore areas where bats are 

infrequent, bird distribution is patchy, and concentrations of individuals are often low; therefore, the 

potential for interactions between bats, birds and training and testing activities is low. Likewise, for most 

stressors associated with the Proposed Action, impacts would be short term and localized, and 

physiological recovery would occur quickly for any individuals experiencing a stress response. It is 

unlikely that training and testing activities would influence nesting because most activities take place in 

water and away from nesting habitats on land.

Although other past, present, and reasonably foreseeable actions individually and collectively cause 

widespread disturbance and mortality of bird and bat populations across the ocean landscape, the 

Proposed Action is not expected to substantially contribute to their diminishing abundance, induce 

widespread behavioral or physiological stress, or interfere with recovery from other stressors. It is 

anticipated that the incremental contribution of the Proposed Action, when added to the impacts of all 

other past, present and reasonably foreseeable future actions, would not result in measurable 

additional impacts on birds and bats in the Study Area or beyond. 

4.4.10 CULTURAL RESOURCES

As discussed in Section 3.10 (Cultural Resources), stressors, including explosive and physical disturbance 

and strike stressors associated with the Proposed Action would not affect submerged prehistoric sites 

and submerged historic resources in accordance with Section 106 of the National Historic Preservation 

Act because mitigation measures have been implemented to protect and avoid these resources (Chapter 

5, Mitigation). Furthermore, consultation with the appropriate State Historic Preservation Office will 

continue, as needed, for cultural resources located within state territorial waters (within 3 NM of the 

shoreline, except Texas, Puerto Rico, and Florida [Gulf Coast only], which have a 9 NM limit). The 

Proposed Action is not expected to result in impacts on cultural resources in the Study Area and likewise 

would not contribute incrementally to cumulative impacts on cultural resources. Therefore, further 

analysis of cumulative impacts on cultural resources is not warranted.

4.4.11 SOCIOECONOMICS

The analysis in Section 3.11 (Socioeconomics) indicates that the Proposed Action is not expected to 

result in long-term impacts to socioeconomic resources in the Study Area, including energy production 

and distribution, mineral extraction, commercial transportation and shipping, commercial and 
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recreational fishing, aquaculture, and tourism. Temporary and short duration (hours) impacts may occur

from limits on accessibility to marine areas used by the public (e.g., for fishing and tourism); however, 

most limitations on accessibility are temporary and would be lifted upon completion of training and 

testing activities. The public may intermittently hear airborne noise from transiting ships or aircraft 

overflights if they are in the general vicinity of a training or testing activity. These occurrences would be 

of short duration and infrequent, and other than transiting vessels and aircraft, most Navy training and 

testing that generates airborne noise would occur farther from shore than most recreational and 

tourism activities. Similarly, impacts on socioeconomic resources from physical disturbances and strikes 

are unlikely given that most training and testing activities that pose a risk of a physical disturbance or 

strike (e.g., activities using ordnance or military expended materials) occur farther from shore than most 

fishing or tourism activities. In locations where Navy training or testing occurs in nearshore areas (e.g., 

pierside), the Navy coordinates with civilian organizations to assure safe and unimpeded access and use 

of those areas. The Navy’s standard operating procedures also require that an area is clear of nonparticipating vessels and aircraft before an activity using ordnance or expended materials occurs. 

Secondary or indirect cumulative impacts on socioeconomic resources are dependent on the availability 

of other marine resources (e.g., fish species targeted by recreational and commercial fishers). 

Population-level impacts on fishes, marine mammals, and invertebrates, which are the primary 

resources indirectly affecting socioeconomics in the Study Area, are not anticipated. No cumulative 

impacts on commercial transportation and shipping are anticipated because commercial vessels and 

aircraft are primarily transiting through the Study Area along well established navigable routes or air 

traffic corridors that are avoided by Navy vessels and aircraft conducting training and testing activities.

Temporary limitations on accessibility to marine areas and the infrequent exposure to airborne noise 

would not result in a direct loss of income, revenue, employment, resource availability, or quality of 

experience. Similarly, physical disturbance and strike stressors would have negligible impacts on energy 

production and distribution, mineral extraction, commercial transportation and shipping, commercial 

and recreational fishing, aquaculture, and tourism in the Study Area and would not result in direct loss 

of income, revenue, employment, resource availability, or quality of experience. Short-term impacts, 

should they occur, would not contribute incrementally to cumulative impacts on socioeconomic 

resources in the study area. Therefore, further analysis of cumulative impacts on socioeconomic 

resources is not warranted.

4.4.12 PUBLIC HEALTH AND SAFETY

All Proposed Actions would be accomplished by technically qualified personnel and would be conducted 

in accordance with applicable Navy, state, and federal safety standards and requirements. The analysis 

presented in Section 3.12 (Public Health and Safety) indicates that the Proposed Action is not expected 

to result in impacts on public health and safety and likewise would not contribute incrementally to or 

combine with other impacts on health and safety within the Study Area. Therefore, further analysis of 

cumulative impacts on public health and safety is not warranted.

4.5 SUMMARY OF CUMULATIVE IMPACTS

The Action Alternatives would contribute incremental effects on the ocean ecosystem, which is already 

experiencing and absorbing a multitude of stressors to a variety of receptors. In general, it is not 

anticipated that the implementation of the Proposed Action would have meaningful contribution to the 

ongoing stress or cause significant collapse of any particular marine resource, but it would further cause 

minute impacts on resources that are already experiencing various degrees of interference and 
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degradation. It is intended that the mitigation measures described in Chapter 5 (Mitigation) will further 

reduce the potential impacts of the Proposed Action in such a way that they are avoided to the 

maximum extent practicable and to ensure that impacts do not become cumulatively significant to any 

marine resource.

Marine mammals and sea turtles are the primary resources of concern for cumulative impacts analysis, 

however, the incremental contributions of the Proposed Action are not anticipated to meaningfully 

contribute to the decline of these populations or interfere with the recovery efforts thereof due to the 

implementation of standard operating procedures that reduce the likelihood of overlap in time and 

space and mitigation measures as described in Chapter 5 (Mitigation) that reduce the likelihood of 

impacts to both resources.

The aggregate impacts of past, present, and other reasonably foreseeable future actions (Table 4.2-1

and Table 4.2-2) have resulted in significant impacts on some marine mammal and all sea turtle species 

in the Study Area; however, the decline of these species is chiefly attributable to other stressors in the 

environment, including the synergistic effect of bycatch, entanglement, vessel traffic, ocean pollution, 

and coastal zone development. The analysis presented in this Chapter 4 (Cumulative Impacts) and 

Chapter 3 (Affected Environment and Environmental Consequences) indicate that the incremental 

contribution of the Proposed Action to cumulative impacts on air quality, sediments and water quality, 

vegetation, invertebrates, marine habitats, fishes, birds and bats, cultural and socioeconomic resources, 

and public health and safety would not significantly contribute to cumulative stress on those resources. 
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4.0 References

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Avens, L. (2003). Use of multiple orientation cues by juvenile loggerhead sea turtles Caretta caretta. The 

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http://today.tamu.edu/2014/07/15/gulf-dead-zone-this-year-is-smaller/.

The Canal Connection. (2017). As the Expanded Canal’s Global Impact Grows, U.S. East Coast Ports Begin 

to Benefit. Retrieved from http://micanaldepanama.com/expansion.

The Times-Picayune. (2015). Shell Bringing World's Deepest Floating Oil Production Vessel to Gulf of 

Mexico. Retrieved from 

http://www.nola.com/business/index.ssf/2015/09/shell_turritella_gulf_of_mexic.html.

Tollefson, J. (2017). Air-gun blasts kill plankton. Nature, 546, 586–587. 

U.S. Army Corps of Engineers. (2012). Department of the Army Environmental Assessment and 

Statement of Finding for the modification of the Wallops Island danger zone published 33 CFR 

section 334.130, "Atlantic Ocean off Wallops Island and Chincoteague Inlet, VA; danger zone".

U.S. Coast Guard. (2013). Final Programmatic Environmental Assessment for the Nationwide Use of High 

Frequency and Ultra High Frequency Active SONAR Technology. Washington, DC: U.S. Coast 

Guard.

U.S. Coast Guard. (2016). Atlantic Coast Port Access Route Study Final Report. Washington, DC: Atlantic 

Coast Port Access Route Study Workgroup.

U.S. Department of Agriculture. (2014). Census of Aquaculture (2013). (AC-12-SS-2). Retrieved from 

http://www.agcensus.usda.gov/Publications/2012/Online_Resources/Aquaculture/.

U.S. Department of Energy. (2015a). U.S. Department of Energy Wind and Water Power Technologies 

Office Funding in the United States: Marine and Hydrokinetic Energy Products. Washington, DC: 
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U.S. Department of Energy. Retrieved from 

http://energy.gov/sites/prod/files/2015/04/f22/MHK-Project-Report-4-14-15.pdf.

U.S. Department of Energy. (2015b). Marine and Hydrokinetic Energy Research and Development. 

Retrieved from http://energy.gov/eere/water/marine-and-hydrokinetic-energy-researchdevelopment.

U.S. Department of the Navy. (2000). Compliance with Environmental Requirements in the Conduct of 

Naval Exercises or Training at Sea. Washington, DC: The Under Secretary of the Navy.

U.S. Department of the Navy. (2009a). VACAPES Range Complex Final Environmental Impact Statement/ 

Overseas Environmental Impact Statement. Washington, DC: United States Fleet Forces 

Command.

U.S. Department of the Navy. (2009b). Final Overseas Environmental Impact Statement/Environmental 

Impact Statement for the Undersea Warfare Training Range. Norfolk, VA: U.S. Department of 

Defense, U.S. Department of the Navy.

U.S. Department of the Navy. (2009c). Record of Decision for the Undersea Warfare Training Range. 

Washington, DC: U.S. Department of Defense.

U.S. Department of the Navy. (2013a). Finding of No Significant Impact and Environmental Assessment 

for the Homeporting of the Littoral Combat Ship on the East Coast of the United States. Norfolk, 

VA: U.S. Department of Defense, U.S. Department of the Navy.

U.S. Department of the Navy. (2013b). Atlantic Fleet Training and Testing Final Environmental Impact 

Statement/Overseas Environmental Impact Statement. Norfolk, VA: Naval Facilities Engineering 

Command Atlantic.

U.S. Department of the Navy. (2014). Request for Regulation and Letter of Authorization for the 

Incidental Taking of Marine Mammals Resulting from U.S. Navy Joint Logistics Over-the-Shore 

Training in Virginia and North Carolina. Norfolk, VA: Commander, United States Fleet Forces 

Command.

U.S. Department of the Navy. (2015). Finding of No Significant Impact and Draft Environmental 

Assessment for Joint Logistics Over-the-Shore Training at Joint Expeditionary Base Little CreekFort Story, Virginia Beach, Virgnia and Marine Corps Base Camp Lejeune, Jacksonville, North 

Carolina. Norfolk, VA: U.S. Department of Defense, U.S. Department of the Navy.

U.S. Department of the Navy. (2016). Draft Supplemental Environmental Impact 

Statement/Supplemental Overseas Environmental Impact Statement for Surveillance Towed 

Array Sensor System Low Frequency Active Sonar. Arlington, VA: U.S. Department of the Navy.

U.S. Department of the Navy. (2017a). Draft Environmental Assessment for Demolition/Replacement of 

Pier 32/Demolition of Pier 10 (P-898) at United States Naval Submarine Base New London 

Groton, Connecticut. Norfolk, VA: Navy Region Mid-Atlantic.

U.S. Department of the Navy. (2017b). Marine Mammal Strandings Associated with U.S. Navy Sonar 

Activities. San Diego, CA: U.S. Navy Marine Mammal Program and SPAWAR Naval Facilities 

Engineering Command.

U.S. Environmental Protection Agency. (2016). 2014 National Emissions Inventory. Retrieved from 

https://www.epa.gov/air-emissions-inventories/2014-national-emissions-inventory-nei-data.

U.S. Maritime Administration. (2015). U.S. Waterborne Foreign Container Trade by U.S. Customs Ports 

(2000–2015). Washington, DC: U.S. Department of Transportation.
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Van der Hoop, J. M., M. J. Moore, S. G. Barco, T. V. Cole, P. Y. Daoust, A. G. Henry, D. F. McAlpine, W. A. 

McLellan, T. Wimmer, and A. R. Solow. (2013). Assessment of management to mitigate 

anthropogenic effects on large whales. Conservation Biology: The Journal of the Society for 

Conservation Biology, 27(1), 121–133. 

van Hooidonk, R., J. A. Maynard, D. Manzello, and S. Planes. (2014). Opposite latitudinal gradients in 

projected ocean acidification and bleaching impacts on coral reefs. Global Change Biology, 

20(1), 103–112.

Wallace, B. P., R. L. Lewison, S. L. McDonald, R. K. McDonald, C. Y. Kot, S. Kelez, R. K. Bjorkland, E. M. 

Finkbeiner, S. Helmbrecht, and L. B. Crowder. (2010). Global patterns of marine turtle bycatch. 

Conservation Letters, 3(3), 131–142. 

Waycott, M., C. M. Duarte, T. J. B. Carruthers, R. J. Orth, W. C. Dennison, S. Olyarnik, A. Calladine, J. W. 

Fourqurean, K. L. Heck, Jr., A. R. Hughes, G. A. Kendrick, W. J. Kenworthy, F. T. Short, and S. L. 

Williams. (2009). Accelerating loss of seagrasses across the globe threatens coastal ecosystems. 

Proceedings of the National Academy of Sciences, 106(30), 12377–12381. 

Weilgart, L. (2013). A Review of the Impacts of Seismic Airgun Surveys on Marine Life. CBD Expert 

Workshop on Underwater Noise and its Impacts on Marine and Coastal Biodiversity, February 

25–27, 2014, 1–10. 

Williams, K. A., I. J. Stenhouse, E. E. Connelly, and S. M. Johnson. (2015). Mid-Atlantic Wildlife Studies: 

Distribution and Abundance of Wildlife along the Eastern Seaboard 2012–2014 (Science 

Communications Series BRI 2015-19). Portland, ME: Biodiversity Research Institute.

Wilson, S. G., and T. R. Fischetti. (2010). Coastline Population Trends in the United States: 1960 to 2008. 

Washington, DC: U.S. Department of Commerce, U.S. Census Bureau.
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Table of Contents

Final

Environmental Impact Statement/Overseas Environmental Impact Statement 

Atlantic Fleet Training and Testing Activities

TABLE OF CONTENTS

5 MITIGATION __________________________________________________________________5-1

5.1 Introduction ..............................................................................................................5-1

5.1.1 Benefits of Mitigation...........................................................................................5-1

5.1.2 Compliance Initiatives..........................................................................................5-2

5.1.2.1 Protective Measures Assessment Protocol ...........................................5-2

5.1.2.2 Monitoring, Research, and Reporting Initiatives...................................5-3

5.2 Mitigation Development Process................................................................................5-8

5.2.1 Procedural Mitigation Development....................................................................5-8

5.2.1.1 Lookouts ................................................................................................5-9

5.2.1.2 Mitigation Zones..................................................................................5-10

5.2.1.3 Procedural Mitigation Implementation...............................................5-11

5.2.2 Mitigation Area Development............................................................................5-12

5.2.3 Practicality of Implementation...........................................................................5-13

5.2.3.1 Assessment Criteria .............................................................................5-13

5.2.3.2 Factors Affecting Practicality ...............................................................5-16

5.3 Procedural Mitigation to be Implemented................................................................5-18

5.3.1 Environmental Awareness and Education .........................................................5-18

5.3.2 Acoustic Stressors...............................................................................................5-19

5.3.2.1 Active Sonar.........................................................................................5-20

5.3.2.2 Air Guns ...............................................................................................5-24

5.3.2.3 Pile Driving...........................................................................................5-25

5.3.2.4 Weapons Firing Noise..........................................................................5-27

5.3.2.5 Aircraft Overflight Noise......................................................................5-29

5.3.3 Explosive Stressors.............................................................................................5-30

5.3.3.1 Explosive Sonobuoys............................................................................5-30

5.3.3.2 Explosive Torpedoes............................................................................5-33

5.3.3.3 Explosive Medium-Caliber and Large-Caliber Projectiles....................5-35

5.3.3.4 Explosive Missiles and Rockets............................................................5-39

5.3.3.5 Explosive Bombs..................................................................................5-42

5.3.3.6 Sinking Exercises..................................................................................5-45

5.3.3.7 Explosive Mine Countermeasure and Neutralization Activities..........5-48

5.3.3.8 Explosive Mine Neutralization Activities Involving Navy Divers..........5-50

5.3.3.9 Maritime Security Operations – Anti-Swimmer Grenades..................5-54

5.3.3.10 Line Charge Testing..............................................................................5-56

5.3.3.11 Ship Shock Trials ..................................................................................5-58

5.3.4 Physical Disturbance and Strike Stressors..........................................................5-61

5.3.4.1 Vessel Movement................................................................................5-61

5.3.4.2 Towed In-Water Devices......................................................................5-65
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5.3.4.3 Small-, Medium-, and Large-Caliber Non-Explosive Practice 

Munitions.............................................................................................5-66

5.3.4.4 Non-Explosive Missiles and Rockets....................................................5-67

5.3.4.5 Non-Explosive Bombs and Mine Shapes..............................................5-68

5.4 Mitigation Areas to be Implemented........................................................................5-69

5.4.1 Mitigation Areas for Seafloor Resources............................................................5-69

5.4.1.1 Resource Description...........................................................................5-69

5.4.1.2 Mitigation Area Assessment................................................................5-70

5.4.2 Mitigation Areas off the Northeastern United States........................................5-75

5.4.2.1 Resource Description...........................................................................5-77

5.4.2.2 Mitigation Area Assessment................................................................5-83

5.4.3 Mitigation Areas off the Mid-Atlantic and Southeastern United States............5-87

5.4.3.1 Resource Description...........................................................................5-90

5.4.3.2 Mitigation Area Assessment................................................................5-94

5.4.4 Mitigation Areas in the Gulf of Mexico ............................................................5-100

5.4.4.1 Resource Description.........................................................................5-100

5.4.4.2 Mitigation Area Assessment..............................................................5-104

5.5 Measures Considered but Eliminated .....................................................................5-108

5.5.1 Active Sonar......................................................................................................5-109

5.5.2 Explosives.........................................................................................................5-111

5.5.3 Active and Passive Acoustic Monitoring Devices.............................................5-112

5.5.4 Thermal Detection Systems..............................................................................5-113

5.5.5 Third-Party Observers ......................................................................................5-115

5.5.6 Foreign Navy Mitigation...................................................................................5-116

5.5.7 Reporting Requirements..................................................................................5-117

5.5.8 Permission Schemes.........................................................................................5-118

5.6 Mitigation Summary ..............................................................................................5-118

List of Figures 

Figure 5.4-1: Seafloor Resource Mitigation Areas off the Northeastern United States..........................5-72

Figure 5.4-2: Seafloor Resource Mitigation Areas off the Mid-Atlantic and Southeastern 

United States ......................................................................................................................5-73

Figure 5.4-3: Seafloor Resource Mitigation Areas in the Gulf of Mexico ................................................5-74

Figure 5.4-4: Mitigation Areas and Habitats Considered off the Northeastern United States................5-76

Figure 5.4-5: Mitigation Areas and Habitats Considered off the Mid-Atlantic and 

Southeastern United States................................................................................................5-89

Figure 5.4-6: Mitigation Areas and Habitats Considered in the Gulf of Mexico....................................5-101

Figure 5.6-1: Summary of Mitigation Areas in the Study Area ..............................................................5-122
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List of Tables

Table 5.3-1: Environmental Awareness and Education ...........................................................................5-19

Table 5.3-2: Procedural Mitigation for Active Sonar ...............................................................................5-20

Table 5.3-3: Procedural Mitigation for Air Guns......................................................................................5-24

Table 5.3-4: Procedural Mitigation for Pile Driving .................................................................................5-26

Table 5.3-5: Procedural Mitigation for Weapons Firing Noise ................................................................5-28

Table 5.3-6: Procedural Mitigation for Aircraft Overflight Noise ............................................................5-30

Table 5.3-7: Procedural Mitigation for Explosive Sonobuoys..................................................................5-31

Table 5.3-8: Procedural Mitigation for Explosive Torpedoes ..................................................................5-34

Table 5.3-9: Procedural Mitigation for Explosive Medium-Caliber and Large-Caliber 

Projectiles ...........................................................................................................................5-36

Table 5.3-10: Procedural Mitigation for Explosive Missiles and Rockets................................................5-40

Table 5.3-11: Procedural Mitigation for Explosive Bombs.......................................................................5-43

Table 5.3-12: Procedural Mitigation for Sinking Exercises ......................................................................5-46

Table 5.3-13: Procedural Mitigation for Explosive Mine Countermeasure and Neutralization 

Activities..............................................................................................................................5-49

Table 5.3-14: Procedural Mitigation for Explosive Mine Neutralization Activities Involving 

Navy Divers.........................................................................................................................5-51

Table 5.3-15: Procedural Mitigation for Maritime Security Operations – Anti-Swimmer 

Grenades.............................................................................................................................5-55

Table 5.3-16: Procedural Mitigation for Line Charge Testing ..................................................................5-57

Table 5.3-17: Procedural Mitigation for Ship Shock Trials.......................................................................5-59

Table 5.3-18: Procedural Mitigation for Vessel Movement.....................................................................5-62

Table 5.3-19: Procedural Mitigation for Towed In-Water Devices..........................................................5-65

Table 5.3-20: Procedural Mitigation for Small-, Medium-, and Large-Caliber Non-Explosive 

Practice Munitions..............................................................................................................5-66

Table 5.3-21: Procedural Mitigation for Non-Explosive Missiles and Rockets........................................5-67

Table 5.3-22: Procedural Mitigation for Non-Explosive Bombs and Mine Shapes..................................5-68

Table 5.4-1: Mitigation Areas for Seafloor Resources.............................................................................5-70

Table 5.4-2: Mitigation Areas off the Northeastern United States .........................................................5-75

Table 5.4-3: Mitigation Areas off the Mid-Atlantic and Southeastern United States .............................5-88

Table 5.4-4: Mitigation Areas in the Gulf of Mexico..............................................................................5-100

Table 5.6-1: Summary of Procedural Mitigation....................................................................................5-119

Table 5.6-2: Summary of Mitigation Areas............................................................................................5-120
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5 MITIGATION

5.1 INTRODUCTION

This chapter describes the mitigation measures that the United States (U.S.) Department of the Navy 

(Navy) will implement to avoid or reduce potential impacts from the Atlantic Fleet Training and Testing 

(AFTT) Final Environmental Impact Statement (EIS)/Overseas Environmental Impact Statement (OEIS) 

Proposed Action. The Navy has been mitigating impacts from military readiness activities throughout 

areas where it trains and tests for more than two decades. Past environmental documents applicable to 

the Study Area are discussed in Section 1.2 (The Navy’s Environmental Compliance at At-Sea Policy). 

The Navy will also implement standard operating procedures specific to training and testing activities 

conducted under the Proposed Action. In many cases, standard operating procedures provide a benefit 

to environmental and cultural resources, some of which have high socioeconomic value in the Study 

Area. Standard operating procedures differ from mitigation measures because standard operating 

procedures are designed to provide for safety and mission success, whereas mitigation measures are

designed specifically to avoid or reduce potential environmental impacts. An example of a standard 

operating procedure is that ships operated by or for the Navy have personnel assigned to stand watch at 

all times when underway. Watch personnel monitor their assigned sectors for any indication of danger 

to the ship and the personnel on board, such as a floating or partially submerged object or piece of 

debris, periscope, surfaced submarine, wisp of smoke, flash of light, or surface disturbance. As a 

standard collision avoidance procedure, watch personnel also monitor for marine mammals that have 

the potential to be in the direct path of the ship. The standard operating procedures to avoid collision 

hazards are designed for safety of the ship and personnel on board. This is different from mitigation 

measures for vessel movement, which require vessels to maneuver to avoid marine mammals by 

specified distances to avoid or reduce the potential for physical disturbance and strike of marine 

mammals, as described in Section 5.3.4.1 (Vessel Movement). In this example, the benefit of the 

mitigation measure for vessel movement is additive to the benefit of the standard operating procedure 

for vessel safety. A full discussion of standard operating procedures is provided in Section 2.3.3 

(Standard Operating Procedures).

In addition to the mitigation measures and standard operating procedures specific to the Proposed 

Action, the Navy has existing routine operating instructions (e.g., training manuals) and local installation 

instructions (e.g., Integrated Natural Resource Management Plans) that were developed to meet other 

safety and environmental compliance requirements or initiatives. For example, the Naval Air Training 

and Operating Procedures Standardization (NATOPS) General Flight and Operating Instructions Manual 

(CNAF M-3710.7) contains naval air training procedures pertaining to safe operations of aircraft, which 

includes requirements to minimize the disturbance of wildlife. Aviation units are required to avoid noisesensitive areas, such as breeding farms, resorts, beaches, national parks, national monuments, and 

national recreational areas. They are also required to avoid disturbing wild fowl in their natural habitats 

and to avoid firing directly at large fish, whales, or other wildlife. These requirements are in addition to 

any measures identified for the Proposed Action. The Navy will continue complying with applicable 

operating instructions and local installation instructions within the Study Area, as appropriate.

5.1.1 BENEFITS OF MITIGATION

The Chapter 3 (Affected Environment and Environmental Consequences) environmental analyses 

indicate that certain acoustic, explosive, and physical disturbance and strike stressors have the potential 
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to impact certain biological or cultural resources. The Navy developed mitigation measures for those 

stressors and will implement the mitigation for either action alternative. The Navy considered the 

benefits of mitigation in the environmental analyses for both Alternative 1 and Alternative 2 of the 

Proposed Action in this Final EIS/OEIS. In addition to analyzing mitigation measures pursuant to the 

National Environmental Policy Act (NEPA), the Navy designed its mitigation measures to achieve one or 

more benefits, such as the following:

 Effect the least practicable adverse impact on marine mammal species or stocks and their 

habitat, and have a negligible impact on marine mammal species and stocks (as required under 

the Marine Mammal Protection Act [MMPA]);

 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 [ESA]);

 Avoid or minimize adverse effects on essential fish habitat (as required under the MagnusonStevens Fishery Conservation and Management Act); and 

 Avoid adversely impacting historic shipwrecks (as required under the Abandoned Shipwreck Act 

and National Historic Preservation Act).

The Navy coordinated its mitigation with the appropriate regulatory agencies, including the National 

Marine Fisheries Service (NMFS) and U.S. Fish and Wildlife Service (USFWS), through the consultation 

and permitting processes. The Navy and NMFS Records of Decision, MMPA Regulations and Letters of 

Authorization, and ESA Biological Opinion will document the mitigation measures that the Navy will 

implement under the Proposed Action. Should the Navy require a change in how it implements 

mitigation based on national security concerns, evolving readiness requirements, or other factors (e.g., 

significant changes in the best available science), the Navy will engage the appropriate agencies and 

reevaluate its mitigation through adaptive management or the appropriate consultations. The Navy’s 

adaptive management approach is discussed in Section 5.1.2.2.1.1 (Adaptive Management). This 

approach was coordinated with NMFS during the consultation and permitting processes and will be 

included in the MMPA Regulations and Letters of Authorization.

5.1.2 COMPLIANCE INITIATIVES

To disseminate its mitigation requirements to the appropriate personnel and meet other compliance 

requirements for the MMPA and ESA, the Navy will continue using the Protective Measures Assessment 

Protocol and its ongoing monitoring and reporting initiatives, as described in the sections below.

5.1.2.1 Protective Measures Assessment Protocol

To disseminate requirements to the personnel who are required to implement mitigation during training 

and testing activities, the Navy will continue inputting its mitigation measures into the Protective 

Measures Assessment Protocol and appropriate governing instructions. The Protective Measures 

Assessment Protocol is a software tool that serves as the Navy’s comprehensive data source for at-sea 

mitigation. The software tool provides personnel with notification of the required mitigation measures 

and a visual display of the planned training or testing activity location overlaid with relevant 

environmental data (e.g., mapped locations of shallow-water coral reefs). Navy policy requires 

applicable personnel to access the Protective Measures Assessment Protocol during the event planning 

process. This helps ensure that personnel receive mitigation instructions prior to the start of training 

and testing activities and that mitigation is implemented appropriately.
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5.1.2.2 Monitoring, Research, and Reporting Initiatives

Many of the Navy’s monitoring programs, research programs, and reporting initiatives have been 

ongoing for more than a decade and will continue as a compliance requirement for the MMPA, ESA, or 

both. The Navy is adding an ESA-listed coral and military expended material effects reporting initiative 

under Phase III as a new compliance requirement for the ESA, as described in Section 5.1.2.2.3 (Incident 

Reports). The Navy and NMFS will use the information contained within monitoring, research, activity, 

and incident reports when evaluating the effectiveness and practicality of mitigation and determining if 

adaptive adjustments to mitigation may be appropriate. These reports also facilitate better 

understandings of the biological resources that inhabit the Study Area and the potential impacts of the 

Proposed Action on those resources.

5.1.2.2.1 Marine Species Research and Monitoring Programs

Through its marine species research and monitoring programs, the Navy is one of the nation’s largest 

sponsors of scientific research on and monitoring of marine species. Detailed information on these 

programs is provided in Section 3.0.1.1 (Marine Species Monitoring and Research Programs). Navy 

research programs focus on investments in basic and applied research that increase fundamental 

knowledge and advance naval technological capabilities. Navy monitoring programs focus on the 

potential impacts of training and testing activities on biological resources. Monitoring reports are 

available to the public on the U.S. Navy Marine Species Monitoring webpage. The Navy will post future 

reports online as they become available. Specific details regarding the content of the reports were

coordinated with the appropriate agencies through the consultation and permitting processes. 

Additional information about the U.S. Navy Marine Species Monitoring Program, including its adaptive 

management and strategic planning components, is provided in the sections below.

5.1.2.2.1.1 Adaptive Management

Adaptive management is an iterative process of decision-making that accounts for changes in the 

environment and scientific understanding over time through a system of monitoring and feedback. 

Within the natural resource management community, adaptive management involves ongoing, realtime learning and knowledge creation, both in a substantive sense and in terms of the adaptive process 

itself (Williams et al., 2009). Adaptive management focuses on learning and adapting, through 

partnerships of natural resource managers, scientists, and other stakeholders. Adaptive management 

helps managers maintain flexibility in their decisions and provides them the latitude to change direction 

to improve understanding of ecological systems and achieve management objectives. Working to 

improve progress toward desired outcomes is another function of adaptive management.

The Navy’s adaptive management review process and reporting requirements serve as the basis for 

evaluating performance and compliance. The process involves technical review meetings and ongoing 

discussions between the Navy, NMFS, the Marine Mammal Commission, and other experts in the 

scientific community. An example of a revision to the compliance monitoring structure as a result of 

adaptive management is the development of the Strategic Planning Process, which is a planning tool for 

the selection and management of monitoring investments (U.S. Department of the Navy, 2013). 

Through adaptive management, the Strategic Planning Process has been incorporated into the 

Integrated Comprehensive Monitoring Program, which is described below.

5.1.2.2.1.2 Integrated Comprehensive Monitoring Program

The Navy developed an Integrated Comprehensive Monitoring Program to serve as the overarching 

framework for coordinating its marine species monitoring efforts and as a planning tool to focus its 
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monitoring priorities pursuant to ESA and MMPA requirements (U.S. Department of the Navy, 2010). 

The purpose of the Integrated Comprehensive Monitoring Program is to coordinate monitoring efforts 

across regions and to allocate the most appropriate level and type of monitoring effort for each range

complex based on a set of standardized objectives, regional expertise, and resource availability. The 

Integrated Comprehensive Monitoring Program does not identify specific field work or individual 

projects. It is designed to provide a flexible, scalable, and adaptable framework using adaptive 

management and the Strategic Planning Process to periodically assess progress and reevaluate 

objectives.

The Integrated Comprehensive Monitoring Program is evaluated through the adaptive management 

review process to: (1) assess progress, (2) provide a matrix of goals and objectives, and (3) make 

recommendations for refinement and analysis of monitoring and mitigation techniques. This process 

includes conducting an annual adaptive management review meeting where the Navy and NMFS jointly 

consider the prior year’s goals, monitoring results, and related scientific advances to determine if 

monitoring plan modifications are warranted to address program goals more effectively. Modifications 

to the Integrated Comprehensive Monitoring Program that result from annual adaptive management 

review discussions are incorporated by an addendum or revision to the Integrated Comprehensive 

Monitoring Program as needed. The Integrated Comprehensive Monitoring Program will be routinely 

updated as the program evolves and progresses. 

The Strategic Planning Process serves to guide the investment of resources to most efficiently address 

Integrated Comprehensive Monitoring Program objectives and intermediate scientific objectives. Navyfunded monitoring projects relating to the impact of Navy training and testing activities on protected 

marine species are designed to accomplish one or more of the following top-level goals, as described in 

the Integrated Comprehensive Monitoring Program charter: 

 Increase the understanding of the likely occurrence of marine mammals and ESA-listed marine 

species in the vicinity of the action (e.g., presence, abundance, distribution, density).

 Increase the understanding of the nature, scope, or context of the likely exposure of marine 

mammals and ESA-listed marine species to any of the potential stressors associated with the 

action (e.g., acoustics, explosives, physical disturbance and strike of military expended 

materials) through a better understanding of one or more of the following: (1) the nature of the 

action and its surrounding environment (e.g., sound-source characterization, propagation, 

ambient noise levels), (2) the affected species (e.g., life history, dive patterns), (3) the likely cooccurrence of marine mammals and ESA-listed marine species with the action (in whole or part), 

and (4) the likely biological or behavioral context of exposure to the stressor for the marine 

mammal and ESA-listed marine species (e.g., age class of exposed animals or known pupping, 

calving, or feeding areas).

 Increase the understanding of how individual marine mammals or ESA-listed marine species 

respond behaviorally or physiologically to the specific stressors associated with the action and in 

what context (e.g., at what distance or received level).

 Increase the understanding of how anticipated individual responses to individual stressors or 

anticipated combinations of stressors may impact either: (1) the long-term fitness and survival 

of an individual, or (2) the population, species, or stock (e.g., through impacts on annual rates of 

recruitment or survival).

 Increase the understanding of the effectiveness of mitigation and monitoring.
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 Improve the understanding and record of the manner in which the Navy complies with its 

Incidental Take Authorizations and Incidental Take Statements.

 Increase the probability of detecting marine mammals through improved technology or 

methods within the mitigation zones (to improve mitigation effectiveness) and generally (to 

better achieve monitoring goals).

The Navy established a Scientific Advisory Group in 2011 with the initial task of evaluating current Navy 

monitoring approaches under the Integrated Comprehensive Monitoring Plan and existing MMPA 

Regulations and Letters of Authorization. The Scientific Advisory Group was also tasked with developing 

objective scientific recommendations that would form the basis for the Strategic Plan. While 

recommendations were fairly broad and not specifically prescriptive, the Scientific Advisory Group did 

provide specific programmatic recommendations that serve as guiding principles for the continued 

evolution of the Integrated Comprehensive Monitoring Program. Key recommendations included:

 Working within a conceptual framework of knowledge, from basic information on the 

occurrence of species within each range complex, to more specific matters of exposure, 

response, and consequences. 

 Facilitating collaboration among researchers in each region, with the intent to develop a 

coherent and synergistic regional monitoring and research effort.

 Striving to move away from effort-based compliance metrics (e.g., completing a pre-determined 

amount of survey hours or days), with the intent to design and conduct monitoring projects 

according to scientific objectives rather than effort expended.

 Approaching the monitoring program holistically and selecting projects that offer the best 

opportunity to advance understanding of the issues, as opposed to establishing range-specific 

requirements.

5.1.2.2.1.3 Strategic Planning Process

The U.S. Navy Marine Species Monitoring Program has evolved and improved as a result of adaptive 

management review and the Strategic Planning Process through changes that include:

 Recognizing the limitations of effort-based compliance metrics; 

 Developing a strategic approach to monitoring based on recommendations from the Scientific 

Advisory Group;

 Shifting focus to projects based on scientific objectives that facilitate generation of statistically 

meaningful results upon which natural resources management decisions may be based;

 Focusing on priority species or areas of interest as well as best opportunities to address specific 

monitoring objectives to maximize return on investment; and

 Increasing transparency of the program and management standards, improving collaboration 

among participating researchers, and improving accessibility to monitoring data and results.

As a result of the changes outlined above due to the implementation of the Strategic Planning Process, 

the U.S. Navy Marine Species Monitoring Program has undergone a transition. Intermediate scientific 

objectives now serve as the basis for developing and executing new monitoring projects across Navy 

training and testing areas in the Atlantic and Pacific Oceans. Implementation of the Strategic Planning 

Process involves coordination among fleets, system commands, Chief of Naval Operations Energy and 

Environmental Readiness Division, NMFS, and the Marine Mammal Commission with five primary steps:
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 Identify overarching intermediate scientific objectives. Through the adaptive management 

process, the Navy coordinates with NMFS and the Marine Mammal Commission to review and 

revise the list of intermediate scientific objectives that guide development of individual 

monitoring projects. Examples include addressing information gaps in species occurrence and 

density, evaluating behavioral responses of marine mammals to Navy training and testing 

activities, and developing tools and techniques for passive acoustic monitoring.

 Develop individual monitoring project concepts. This step generally takes the form of soliciting 

input from the scientific community in terms of potential monitoring projects that address one 

or more of the intermediate scientific objectives. This can be accomplished through a variety of 

forums, including professional societies, regional scientific advisory groups, and contractor 

support.

 Evaluate, prioritize, and select monitoring projects. Navy technical experts and program 

managers review and evaluate monitoring project concepts and develop a prioritized ranking. 

The goal of this step is to establish a suite of monitoring projects that address a cross-section of 

intermediate scientific objectives spread over a variety of range complexes. 

 Execute and manage selected monitoring projects. Individual projects are initiated through 

appropriate funding mechanisms and include clearly defined objectives and deliverables, such as

data, reports, or publications.

 Report and evaluate progress and results. Progress on individual monitoring projects is updated 

through the U.S. Navy Marine Species Monitoring Program website as well as annual monitoring 

reports submitted to NMFS. Both internal review and discussions with NMFS through the 

adaptive management process are used to evaluate progress toward addressing the primary 

objectives of the Integrated Comprehensive Monitoring Program and serve to periodically 

recalibrate the focus of the monitoring program.

These steps serve three primary purposes: (1) to facilitate the Navy in developing specific projects 

addressing one or more intermediate scientific objectives, (2) to establish a more structured and 

collaborative framework for developing, evaluating, and selecting monitoring projects across areas 

where the Navy conducts training and testing activities, and (3) to maximize the opportunity for input 

and involvement across the research community, academia, and industry. This process is designed to 

integrate various elements, including:

 Integrated Comprehensive Monitoring Program top-level goals,

 Scientific Advisory Group recommendations,

 Integration of regional scientific expert input,

 Ongoing adaptive management review dialog between NMFS and the Navy,

 Lessons learned from past and future monitoring of Navy training and testing, and

 Leveraging of research and lessons learned from other Navy-funded science programs.

The Strategic Planning Process will continue to shape the future of the U.S. Navy Marine Species 

Monitoring Program and serve as the primary decision-making tool for guiding investments. Information 

on monitoring projects currently underway in the Atlantic and Pacific oceans, as well as results, reports, 

and publications, can be accessed through the U.S. Navy Marine Species Monitoring Program website.

5.1.2.2.2 Training and Testing Activity Reports

The Navy developed a classified data repository known as the Sonar Positional Reporting System to 

maintain an internal record of underwater sound sources (e.g., active sonar) used during training and 
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testing. The Sonar Positional Reporting System facilitates reporting pursuant to the Navy’s MMPA 

Regulations and Letters of Authorization. Using data from the Sonar Positional Reporting System and 

other relevant sources, the Navy will continue to provide the NMFS Office of Protected Resources with 

classified or unclassified (depending on the data) annual reports on the training and testing activities 

that use underwater sound sources. In its annual training and testing activity reports, the Navy will 

describe the level of training and testing conducted during the reporting period. For example, the Navy 

will report the location and total hours and counts of active sonar hours and in-water explosives used, 

and an assessment if activities conducted in the Study Area exceeded levels of training and testing 

analyzed in the MMPA authorization and ESA Biological Opinion. For major training exercises, the 

reports will also include information on each individual marine mammal sighting related to mitigation 

implementation. Unclassified annual training and testing activity reports that have been submitted to 

NMFS can be found on the NMFS Office of Protected Resources and U.S. Navy Marine Species 

Monitoring Program webpages.

5.1.2.2.3 Incident Reports

The Navy’s mitigation measures and many of its standard operating procedures are designed to prevent 

incidents involving biological and cultural resources, such as aircraft strikes, vessel strikes, and impacts 

on submerged historic properties and seafloor resources. The Navy has been collecting data on such 

incidents (if they have occurred) for more than a decade and will continue doing so under the Proposed 

Action. To provide information on incidents involving biological or cultural resources, the Navy will 

submit reports to the appropriate management authorities, as described below:

 Birds and Bats: As described in Section 2.3.3.3 (Aircraft Safety), animal strikes present an 

aviation safety risk for aircrews and aircraft. The Navy will report all bird and bat strikes per 

standard operating procedures.

 Marine Mammals, Sea Turtles, and ESA-Listed Species: The Navy will notify the appropriate 

regulatory agency, which may include NMFS or the USFWS, immediately or as soon as 

operational security considerations allow if it observes the following that is (or may be) 

attributable to Navy activities: (1) a vessel strike of a marine mammal or sea turtle during 

training or testing, (2) a stranded, injured, or dead marine mammal or sea turtle during training 

or testing, or (3) an injured or dead marine mammal, sea turtle or ESA-listed species during postexplosive event monitoring. The Navy will provide relevant information pertaining to the 

incident (e.g., vessel speed). Additional details on these incident reporting requirements will be 

included in the Notification and Reporting Plan. For manatee incidents, the agency contacts may 

include the Florida Fish and Wildlife Conservation Commission, Law Enforcement Division; the 

USFWS Jacksonville Ecological Field Office; the USFWS Raleigh Field Office; and the North 

Carolina Wildlife Resources Commission. If harassment, injury, or death of a manatee is 

observed, the Navy will immediately halt the training or testing activity. The Navy will continue 

to provide the appropriate personnel with training on marine species incidents and their 

associated reporting requirements to aid the data collection and reporting processes (see 

Section 5.3.1, Environmental Awareness and Education). Information on marine mammal 

strandings is included in the Marine Mammal Strandings Associated with U.S. Navy Sonar 

Activities technical report (U.S. Department of the Navy, 2017a).

 ESA-Listed Coral: The Navy will evaluate the extent to which military expended materials may 

have impacted ESA-listed corals and designated coral critical habitat in or near the Key West 

Range Complex through two initiatives: (1) evaluating existing data to determine whether there 

is past evidence of impacts, and (2) working with entities already conducting underwater 
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surveys to incorporate searches for potential military expended materials in future scheduled 

surveys to determine if there are any observed impacts from those materials. Details of the 

reporting process and requirements will be included in the Navy’s coordination and evaluation 

plan, which will be developed in cooperation with the NMFS ESA Interagency Cooperation 

Division and relevant entities (e.g., National Marine Sanctuaries Program, NOAA Marine Debris 

program, relevant coral researchers). 

 Cultural Resources: In the event the Navy impacts a submerged historic property (e.g., 

archaeological resource), it will commence consultation with the appropriate State Historic 

Preservation Officer or Tribal Historic Preservation Officer in accordance with 36 Code of Federal 

Regulations section 800.13(b)(3).

5.2 MITIGATION DEVELOPMENT PROCESS

The Navy, in coordination with the appropriate regulatory agencies, developed its initial suite of 

mitigation measures for Phase I of environmental planning (2009–2014) and subsequently revised those 

mitigation measures for Phase II (2013–2018). For this Final EIS/OEIS (which represents Phase III of 

environmental planning), the Navy worked collaboratively with the appropriate regulatory agencies to 

develop and finalize its mitigation through the consultation and permitting processes. The mitigation 

development process involved reanalyzing existing Phase II measures and analyzing new mitigation 

recommendations received from Navy and NMFS scientists, other governmental agencies, the public, 

and non-governmental organizations during the NEPA, consultation, and permitting processes. The Navy 

conducted a detailed review and assessment of each potential mitigation measure individually and then 

all potential mitigation measures collectively to determine if, as a whole, mitigation will effectively avoid 

or reduce potential impacts from the Proposed Action and will be practical to implement. The Navy 

operational community (i.e., leadership from the aviation, surface, subsurface, and special warfare 

communities; leadership from the research and acquisition community; and training and testing 

experts), environmental planners, and scientific experts provided input on the effectiveness and 

practicality of mitigation implementation. A four-star Admiral, the Fleet Commander of all Navy forces in 

the Study Area, and Navy Senior Leadership reviewed and approved the suite of mitigation measures 

included in this Final EIS/OEIS and determined it is the highest level of mitigation practical for the Navy 

to implement under the Proposed Action.

Mitigation measures that the Navy will implement under the Proposed Action are organized into two 

categories: procedural mitigation measures and mitigation areas. The sections below provide definitions 

of mitigation terminology, background information pertinent to the mitigation development process, 

and information about the mitigation effectiveness and practicality criteria. Additional activity or 

stressor-specific details, such as the level of effect to which a procedural mitigation measure is expected

to mitigate and if a measure has been modified from Phase II is provided throughout Section 5.3

(Procedural Mitigation to be Implemented) and Section 5.4 (Mitigation Areas to be Implemented). 

Section 5.5 (Measures Considered but Eliminated) contains information on measures that did not meet 

the appropriate balance between being effective and practical to implement, and therefore will not be 

implemented under the Proposed Action.

5.2.1 PROCEDURAL MITIGATION DEVELOPMENT

Procedural mitigation is mitigation that the Navy will implement whenever and wherever training or 

testing activities involving applicable acoustic, explosive, and physical disturbance and strike stressors

take place within the Study Area. Procedural mitigation generally involves: (1) the use of one or more 
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trained Lookouts to observe for specific biological resources within a mitigation zone, (2) requirements 

for Lookouts to immediately communicate sightings of specific biological resources to the appropriate 

watch station for information dissemination, and (3) requirements for the watch station to implement 

mitigation until a pre-activity commencement or during-activity recommencement condition has been 

met. 

Procedural mitigation primarily involves Lookouts observing for marine mammals and sea turtles. For 

some activities, Lookouts may also be required to observe for additional biological resources, such as 

marine birds, fish, jellyfish aggregations, or floating vegetation. In this chapter, the term “floating 

vegetation” refers specifically to floating concentrations of detached kelp paddies and Sargassum. Some 

biological resources, such as floating vegetation, can be indicators of potential marine mammal or sea 

turtle presence because marine mammals or sea turtles have been known to seek shelter in, feed on, or 

feed among them. For example, young sea turtles have been known to hide from predators and eat the 

algae associated with floating concentrations of Sargassum. The Navy observes for these additional 

biological resources prior to the initial start or during the conduct of certain activities to protect ESAlisted species or to offer an additional layer of protection for marine mammals and sea turtles.

To consider the benefits of procedural mitigation to marine mammals and sea turtles within the MMPA 

and ESA impact estimates, the Navy conservatively factored mitigation effectiveness into its quantitative 

analysis process, as described in the 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, 2018a). The Navy’s quantitative analysis assumes that Lookouts will not be 100 

percent effective at detecting all individual marine mammals and sea turtles within the mitigation zones

for each activity. This is due to the inherent limitations of observing marine species and because the 

likelihood of sighting individual animals is largely dependent on observation conditions (e.g., time of 

day, sea state, mitigation zone size, observation platform) and animal behavior (e.g., the amount of time 

an animal spends at the surface of the water). This is particularly true for sea turtles, small marine 

mammals, and marine mammals that display cryptic behaviors (e.g., surfacing to breathe with only a 

small portion of their body visible from the surface). Throughout Section 5.3 (Procedural Mitigation to 

be Implemented), discussions about the likelihood that a Lookout would observe a marine mammal or 

sea turtle pertain specifically to animals that are available to be observed (i.e., on, above, or just below

the water’s surface). The benefits of procedural mitigation measures for species that were not included 

in the quantitative analysis process (e.g., birds, fish) are discussed qualitatively.

Data inputs for assessing and developing procedural mitigation included operational data as described in 

Section 5.2.3 (Practicality of Implementation), the best available science discussed in Chapter 3 

(Affected Environment and Environmental Consequences), published literature, data on marine 

mammal and sea turtle impact ranges obtained through acoustic modeling, marine species monitoring 

and density data, and the most recent guidance from NMFS and the USFWS. Background information on 

the data that were used to develop the ranges to effect for marine mammals and sea turtles (such as 

hearing threshold metrics) is provided in Chapter 3.7 (Marine Mammals) and Chapter 3.8 (Reptiles).

5.2.1.1 Lookouts

Lookouts perform similar duties as standard watch personnel (e.g., personnel on the bridge watch team 

and personnel stationed for man-overboard precautions, as described in Section 2.3.3, Standard 

Operating Procedures), but are designated the responsibility of helping meet the Navy’s mitigation 

requirements by visually observing mitigation zones. The number of Lookouts designated for each 
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training or testing activity is dependent upon the number of personnel involved in the activity (i.e., 

manning restrictions) and the number and type of assets available (i.e., equipment and space 

restrictions). 

Depending on the activity, a Lookout may be positioned on a ship (i.e., surface ships and surfaced 

submarines), on a small boat (e.g., rigid-hull inflatable boat), in an aircraft, on a pier, or on the shore. 

Certain platforms, such as aircraft and small boats, have manning or space restrictions; therefore, the 

Lookout on these platforms is typically an existing member of the aircraft or boat crew who is 

responsible for other essential tasks (e.g., a pilot who is also responsible for navigation). Some platforms 

(e.g., the Littoral Combat Ship) are minimally manned and are therefore either physically unable to 

accommodate more than one Lookout or divert personnel from mission-essential tasks, including safe 

and secure operation of propulsion, weapons, and damage control systems that ensure the safety of the 

ship and the personnel on board. The number of Lookouts specified for each activity in Section 5.3

(Procedural Mitigation to be Implemented) represents the maximum number of Lookouts that can be 

designated for those activities without requiring additional personnel or reassigning duties. The Navy is 

unable to position Lookouts on unmanned surface vehicles, unmanned aerial systems, unmanned 

underwater vehicles, and submerged submarines, or have Lookouts observe during activities that use 

systems deployed from or towed by unmanned platforms.

When Lookouts are positioned in a fixed-wing aircraft or rotary-wing aircraft (i.e., helicopter), mission 

requirements determine the flight parameters (altitude, flight path, and speed) for that aircraft. For 

example, most fixed-wing aircraft sorties occur above 3,000 feet (ft.), while most rotary-wing sorties 

associated with mine countermeasure activities occur at altitudes as low as 75–100 ft. Similarly, when 

Lookouts are positioned on a vessel, mission requirements determine the operational parameters 

(course and speed) for that vessel. 

The Navy’s passive acoustic devices (e.g., remote acoustic sensors, expendable sonobuoys, passive 

acoustic sensors on submarines) can complement visual observations for marine mammals when 

passive acoustic assets are already participating in an activity. The passive acoustic devices can detect 

vocalizing marine mammals within the frequency bands already being monitored by Navy personnel. 

Marine mammal detections from passive acoustic devices can alert Lookouts to possible marine 

mammal presence in the vicinity. Lookouts can use the information from passive acoustic detections to 

assist their visual observations of the mitigation zone. Based on the number and type of passive acoustic 

devices that are typically used, passive acoustic detections do not provide range or bearing to a 

detected animal in order to determine its location or confirm its presence in a mitigation zone. 

Therefore, it is not practical for the Navy to implement mitigation in response to passive acoustic 

detections alone (i.e., without a visual sighting of an animal within the mitigation zone). Additional 

information about passive acoustic devices is provided in Section 5.5.3 (Active and Passive Acoustic

Monitoring Devices).

5.2.1.2 Mitigation Zones

Mitigation zones are areas at the surface of the water within which applicable training or testing 

activities will be ceased, powered down, or modified to protect specific biological resources from an 

auditory injury (permanent threshold shift [PTS]), non-auditory injury (from impulsive sources), or direct 

strike (e.g., vessel strike) to the maximum extent practicable. Mitigation zones are measured as the 

radius from a stressor. Implementation of procedural mitigation is most effective when mitigation zones

are appropriately sized to be realistically observed during typical training and testing activity conditions.
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The Navy customized its mitigation zone sizes and mitigation requirements for each applicable training 

and testing activity category or stressor. The Navy developed each mitigation zone to be the largest area

Lookouts can reasonably be expected to observe during typical activity conditions (i.e., the most 

environmentally protective) and the Navy can commit to implementing mitigation without impacting 

safety, sustainability, and the ability to meet mission requirements. The Navy designed the mitigation 

zones for most acoustic and explosive stressors according to its source bins. As described in Section 

3.0.3.3.1.1 (Sonar and Other Transducers), sonars and other transducers are grouped into classes that 

share an attribute, such as frequency range or purpose of use. Classes are further sorted by bins based 

on the frequency or bandwidth, source level, and when warranted, the application in which the source 

would be used. As described in Section 3.0.3.3.2.1 (Explosions in Water), explosives detonated in water 

are binned by net explosive weight. Mitigation does not pertain to stressors that do not have the 

potential to impact biological resources (e.g., de minimis acoustic and explosive sources that do not 

have the potential to impact marine mammals). 

Discussions throughout Section 5.3 (Procedural Mitigation to be Implemented) about the level of effect 

that will likely be mitigated are based on a comparison of the mitigation zone size to the predicted 

impact ranges for the applicable source bins with the longest average ranges to PTS. These conservative 

discussions represent the worst-case scenario for each activity category or stressor. The mitigation 

zones will oftentimes cover all or a larger portion of the predicted average ranges to PTS for other 

comparatively smaller sources with shorter impact ranges (e.g., sonar sources used at a lower source 

level, explosives in a smaller bin). The discussions are primarily focused on how the mitigation zone sizes 

compare to the ranges to PTS; however, depending on the activity category or stressor, the mitigation 

zones are oftentimes large enough to also mitigate within a portion of the ranges to temporary 

threshold shift (TTS). TTS is a threshold shift that is recoverable. Background information on PTS, TTS, 

and marine mammal and sea turtle hearing groups is presented in the U.S. Department of the Navy 

(2017d) technical report titled Criteria and Thresholds for U.S. Navy Acoustic and Explosive Effects 

Analysis (Phase III).

5.2.1.3 Procedural Mitigation Implementation

The Navy takes several courses of action in response to a sighting of an applicable biological resource in 

a mitigation zone. First, a Lookout will communicate the sighting to the appropriate watch station. Next, 

the watch station will implement the prescribed mitigation, such as delaying the initial start of an 

activity, powering down sonar, ceasing an explosive detonation, or maneuvering a vessel. If floating 

vegetation is observed in the mitigation zone prior to the initial start of an activity, the activity will either 

be relocated to an area where floating vegetation is not observed in concentrations, or the initial start of 

the activity will be delayed until the mitigation zone is clear of floating vegetation concentrations. There 

are no requirements to cease activities if vegetation floats into the mitigation zone after activities 

commence. For sightings of marine mammals, sea turtles, and other specified biological resources 

within a mitigation zone prior to the initial start of or during applicable activities, the Navy will continue 

mitigating until one of the five conditions listed below has been met. The conditions are designed to 

allow a sighted animal to leave the mitigation zone before the initial start of an activity or before an 

activity resumes.

 The animal is observed exiting the mitigation zone;

 The animal is thought to have exited the mitigation zone based on a determination of its course, 

speed, and movement relative to the stressor source;

 The mitigation zone has been clear from any additional sightings for a specific wait period;
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 For mobile activities, the stressor source has transited or has been relocated a distance equal to 

double the mitigation zone size beyond the location of the last sighting; or

 For activities using hull-mounted sonar, the ship concludes that dolphins are deliberately closing 

in on the ship to ride the ship’s bow wave and are therefore out of the main transmission axis of 

the sonar (and there are no other marine mammal sightings within the mitigation zone).

To supplement the implementation of procedural mitigation, the Navy has agreed to undertake 

reporting initiatives for certain activities or resources based on previous consultations with NMFS and 

the USFWS, as summarized in Section 5.1.2.2 (Monitoring, Research, and Reporting Initiatives) and 

detailed where applicable in Section 5.3 (Procedural Mitigation to be Implemented). For some activities, 

the Navy also agreed during previous consultations with NMFS or the USFWS to adapt some of its 

procedural mitigation for particular resources at certain locations and plans to continue those mitigation

measures for Phase III. For example, the Navy will continue implementing seasonal mitigation measures 

for line charge testing activities for ESA-listed Gulf Sturgeon, as discussed in Section 5.3.3.10 (Line 

Charge Testing).

5.2.2 MITIGATION AREA DEVELOPMENT

Mitigation areas are geographic locations within the Study Area where the Navy will implement 

mitigation measures to: (1) avoid or reduce potential impacts on biological or cultural resources that are 

not observable by Lookouts from the water’s surface (i.e., resources for which procedural mitigation 

cannot be implemented), (2) in combination with procedural mitigation, effect the least practicable 

adverse impact on marine mammal species or stocks and their habitat, or (3) in combination with 

procedural mitigation, 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.

The Navy completed an extensive assessment of the Study Area to develop the mitigation areas

included in this Final EIS/OEIS. The Navy reanalyzed existing Phase II mitigation areas; assessed 

additional habitat areas suggested by the public, NMFS, other governmental agencies, and nongovernmental organizations; and considered other habitats identified internally by the Navy. Data inputs 

for mitigation area assessment and development included the operational information described in 

Section 5.2.3 (Practicality of Implementation), 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 considered a mitigation 

area to be effective if it met the following criteria:

 The mitigation area is a key area of biological or ecological importance or contains cultural 

resources: The best available science suggests that the mitigation area contains submerged 

cultural resources (e.g., shipwrecks) or is particularly important to one or more species or 

resources for a biologically important life process (i.e., foraging, migration, reproduction) or 

ecological function (e.g., shallow-water coral reefs that provide critical ecosystem functions);

and

 The mitigation will result in an avoidance or reduction of impacts: Implementing the mitigation 

will likely avoid or reduce potential impacts on: (1) species, stocks, or populations of marine 

mammals based on data regarding their seasonality, density, and behavior; or (2) other 

biological or cultural resources based on their distribution and physical properties. Furthermore, 

implementing the mitigation will not shift or transfer adverse effects from one species to 

another (e.g., to a more vulnerable or sensitive species).
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Potential impacts on environmental and cultural resources cannot occur unless there is an overlap 

between a resource and a stressor. During the mitigation assessment and development process, the 

Navy did not develop mitigation areas in locations where stressors are not used because doing so would 

not meet the basic definition of effective mitigation (i.e., the mitigation areas would not effectively 

avoid or reduce potential impacts). For example, some explosive activities cannot realistically be 

conducted in certain areas based on operational requirements relating to water depth; therefore, 

mitigation to avoid conducting explosives in these locations is not warranted.

The benefits of mitigation areas are discussed qualitatively and have not been factored into the 

quantitative analysis process or reductions in take for MMPA and ESA impact estimates. Marine 

mammal mitigation areas are designed to help avoid or reduce potential impacts during biologically 

important life processes within particularly important habitat areas. Therefore, the mitigation benefit is 

discussed in terms of the context of impact avoidance or reduction. A discussion of the mitigation areas 

developed for this Final EIS/OEIS is presented in Section 5.4 (Mitigation Areas to be Implemented).

5.2.3 PRACTICALITY OF IMPLEMENTATION

Mitigation measures are expected to have some degree of impact on the training and testing activities 

that implement them (e.g., modifying where and when activities occur, ceasing an activity in response to 

a sighting). The Navy is willing to accept a certain level of impact on its military readiness activities 

because of the substantial benefit that mitigation measures provide for avoiding or reducing impacts on 

environmental and cultural resources. The Navy’s focus during mitigation assessment and development 

was that mitigation measures must meet the appropriate balance between being effective and practical

to implement. To evaluate practicality, the Navy operational community conducted an extensive and 

comprehensive assessment to determine how and to what degree potential mitigation measures would 

be compatible with planning, scheduling, and conducting training and testing activities under the 

Proposed Action in order to meet the Navy’s Title 10 requirements.

5.2.3.1 Assessment Criteria

The purpose and need of the Proposed Action is to ensure that the Navy meets its mission to maintain, 

train, and equip combat-ready naval forces capable of winning wars, deterring aggression, and 

maintaining freedom of the seas. The Navy is statutorily mandated to protect U.S. national security by 

being ready, at all times, to effectively prosecute war and defend the nation by conducting operations at

sea, as outlined in Title 10 section 5062 of the United States Code. The Navy’s mission is achieved in part 

by conducting training and testing within the Study Area in accordance with established Navy military 

readiness requirements. Training requirements have been developed through many years of iteration 

and adaptation and are designed to ensure that Sailors achieve the levels of readiness needed to 

properly respond to the multitude of contingencies they may face during military missions and combat 

operations. Activities are planned and scheduled in accordance with the Optimized Fleet Response Plan, 

which details instructions on manning distribution, range scheduling, operational requirements, 

maintenance and modernization plans, quality of work and life for personnel, achieving training 

capabilities, and meeting strategic readiness objectives. There are certain geographic areas, such as the 

coastal zone, where the Navy does not typically plan certain training or testing activities due to 

operational parameters (e.g., water depth) and planning considerations (e.g., ensuring public safety), as 

discussed in Section 2.3.3 (Standard Operating Procedures) and Appendix A (Navy Activity Descriptions).

To achieve the highest skill proficiency and most accurate testing results possible, the Navy conducts 

activities in a variety of realistic tactical oceanographic and environmental conditions. Such conditions 
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include variations in bathymetry, topography, surface fronts, and sea surface temperatures. Training 

activities must be as realistic as possible to provide the experiences vital to success and survival during 

military missions and combat operations. Degraded training would result in units being unqualified to 

conduct their range of military operations required by operational Commanders. The inability of such 

Commanders to meet security objectives would result in not only the increased risk to life, but also the 

degradation of national security. Testing activities must be as realistic as possible for the Navy to 

conduct accurate acoustic research to validate acoustic models; conduct accurate engineering tests of 

acoustic sources, signal processing algorithms, and acoustic interactions; and to effectively test systems 

and platforms (and components of these systems and platforms) to validate whether they perform as 

expected and determine whether they are operationally effective, suitable, survivable, and safe for their 

intended use by the fleet. Testing must be completed before full-scale production or delivery to the fleet 

to ensure functionality and accuracy in military mission and combat conditions.

As described in Chapter 2 (Description of Proposed Action and Alternatives), the Navy requires access to 

sea space and airspace throughout the Study Area within range complexes, pierside locations, nearshore 

areas, and large-scale open ocean areas of the high seas. Each area plays a critical role in the Navy’s 

ability to plan, schedule, and effectively execute military readiness activities. The locations where 

training and testing occur must be situated in a way that allows the Navy to complete its activities 

without physical or logistical obstructions. The Navy requires extensive sea space so that individual 

training and testing activities can occur at sufficient distances so they do not interfere with one another.

Some training and testing activities require continuous access to large and unobstructed areas, 

consisting potentially of tens or thousands of square miles. This provides personnel the ability to 

develop competence and confidence in their capabilities across multiple types of weapons and sensors, 

and the ability to train to communicate and operate in a coordinated fashion as required during military 

missions and combat operations. For example, major training exercises using integrated warfare 

components may require large areas of the littorals, open ocean, and nearshore areas for realistic and 

safe anti-submarine warfare training. The Navy also requires large areas of sea space because it trains in 

a manner to avoid observation by potential adversaries. Modern sensing technologies make training on 

a large scale without observation more difficult. A foreign military’s continual observation of U.S. Navy 

training in predictable geographic areas and timeframes would enable foreign nations to gather 

intelligence and subsequently develop techniques, tactics, and procedures to potentially and effectively 

counter U.S. naval operations. Other activities may be conducted on a smaller and more localized scale, 

with training or testing at discrete locations that are critical to certain aspects of military readiness.

The locations for training and testing activities are selected to maximize efficiency while supporting 

specific mission and safety requirements, deconflict sea space and airspace, and minimize the time 

personnel must spend away from home. Training and testing locations are typically selected based on 

their proximity to homeports, home bases, associated training ranges, testing facilities, air squadrons, 

and existing infrastructure (e.g., instrumented underwater ranges) to reduce travel time and associated 

costs. Activities involving the use of rotary-wing aircraft typically occur in proximity to shore or refueling 

stations due to fuel restrictions and safety requirements. Testing ranges are typically located near 

systems command support facilities, which provide critical infrastructure support and technical 

expertise necessary to conduct testing. Logistical support of range testing can only efficiently and 

effectively occur when the support is co-located with the testing activities. These same principles also 

apply to pierside and at-sea testing that must occur in proximity to naval shipyards and Navy contractor 

shipyards. Testing event site locations and associated field activities were originally established to 

support specific Navy mission testing needs using a selection process that included testing 
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requirements, cost of living, availability of personnel, and low level of crowding from industry and 

development.

During its assessment to determine how and to what degree the implementation of mitigation would be 

compatible with meeting the purpose and need of the Proposed Action, the Navy considered mitigation 

measures to be practical to implement if they met all criteria discussed below:

 Implementing the mitigation is safe: Mitigation measures must not increase safety risks to Navy 

personnel and equipment, or to the public. When assessing whether implementing a mitigation 

measure would be safe, the Navy factored in the potential for increased pilot fatigue;

accelerated fatigue-life of aircraft; typical fuel restrictions of participating aircraft; locations of 

refueling stations; proximity to aircraft emergency landing fields, critical medical facilities, and 

search and rescue capabilities; space restrictions of the observation platforms; the ability to deconflict platforms and activities to ensure that training and testing activities do not impact each 

other; and the ability to avoid interaction with non-Navy sea space and airspace uses, such as 

established commercial air traffic routes, commercial vessel shipping lanes, and areas used for 

energy exploration or alternative energy development. Other safety considerations included

identifying if mitigation measures would reasonably allow Lookouts to safely and effectively 

maintain situational awareness while observing the mitigation zones during typical activity 

conditions, or if the mitigation would increase the safety risk for personnel. For example, the 

safety risk would increase if Lookouts were required to direct their attention away from 

essential mission requirements.

 Implementing the mitigation is sustainable: One of the primary factors that the Navy 

incorporates into the planning and scheduling of its training and testing activities is the amount 

and type of available resources, such as funding, personnel, and equipment. Mitigation 

measures must be sustainable over the life of the Proposed Action, meaning that they will not 

require the use of resources in excess of what is available. When assessing whether 

implementing a mitigation measure would be sustainable, the Navy considered if the measure

would require excessive time on station or time away from homeport for Navy personnel, 

require the use of additional personnel (i.e., manpower) or equipment (e.g., adding a small boat

to serve as an additional observation platform), or result in additional operational costs (e.g., 

increased fuel consumption, equipment maintenance, or acquisition of new equipment).

 Implementing the mitigation allows the Navy to continue meeting its mission requirements:

The Navy considered if each individual measure and the iterative and cumulative impact of all 

potential measures would be within the Navy’s legal authority to implement. The Navy also 

considered if mitigation would modify training or testing activities in a way that would prevent

individual activities from meeting their mission objectives and if mitigation would prevent the 

Navy from meeting its national security requirements or statutorily-mandated Title 10 

requirements, such as by:

o Impacting training and testing realism or preventing ready access to ranges, operating 

areas, facilities, or range support structures (which would reduce realism and present 

sea space and airspace conflicts). 

o Impacting the ability for Sailors to train and become proficient in using sensors and 

weapon systems as would be required in areas analogous to where the military operates

or causing an erosion of capabilities or reduction in perishable skills (which would result 

in a significant risk to personnel or equipment safety during military missions and 

combat operations).
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o Impacting the ability for units to meet their individual training and certification 

requirements (which would impact the ability to deploy with the required level of 

readiness necessary to accomplish any tasking by Combatant Commanders).

o Impacting the ability to certify forces to deploy to meet national security tasking (which 

would limit the flexibility of Combatant Commanders and warfighters to project power, 

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

capabilities in support of national security interests).

o Impacting the ability of researchers, program managers, and weapons system 

acquisition programs to conduct accurate acoustic research to meet research objectives, 

effectively test systems and platforms (and components of these systems and 

platforms) before full-scale production or delivery to the fleet, or complete shipboard 

maintenance, repairs, or pierside testing prior to at-sea operations (which would not 

allow the Navy to ensure safety, functionality, and accuracy in military mission and 

combat conditions per required acquisition milestones or on an as-needed basis to meet 

operational requirements).

o Requiring the Navy to provide advance notification of specific times and locations of 

Navy platforms, such as platforms using active sonar (which would present national 

security concerns).

o Reducing the Navy’s ability to be ready, maintain deployment schedules, or respond to 

national emergencies or emerging national security challenges (which would present 

national security concerns).

5.2.3.2 Factors Affecting Practicality

Two of the factors that influenced whether procedural mitigation measures met the practicality criteria 

were the number of times mitigation measures would likely be implemented and the duration over 

which the activity would likely be ceased. The number of times mitigation would likely be implemented 

is largely dependent on the size of the mitigation zone. As a mitigation zone size increases, the area of 

observation increases by an order of magnitude. This is because mitigation zones are measured as the 

radius (r) from a stressor but apply to circular area (A) around that stressor (A = π * r2, where π is a 

constant that is approximately equal to 3.14). For example, a 100-yard (yd.) mitigation zone is 

equivalent to an area of 31,416 square yd. A 200-yd. mitigation zone is equivalent to an area of 125,664 

square yd. Therefore, increasing a mitigation zone from 100 yd. to 200 yd. (i.e., doubling the mitigation 

zone radius) would quadruple the mitigation zone area (the area over which mitigation must be 

implemented). Similarly, increasing a mitigation zone from 1,000 yd. to 4,000 yd. (i.e., quadrupling the 

mitigation zone radius) would increase the mitigation zone area by a factor of 16. Increasing the area 

over which mitigation must be implemented consequently increases the number of times mitigation 

would likely be implemented during that activity.

The duration over which mitigation is implemented can differ considerably depending on the mitigation 

zone size, number of animal sightings, behavioral state of animals sighted (e.g., travelling at a fast pace 

on course to exit the mitigation zone, milling slowly in the center of the mitigation zone), and which preactivity commencement or during-activity recommencement condition is met before the activity can 

commence or resume after each sighting. The duration of mitigation implementation typically equates 

to the amount of time the training or testing activity will be extended. The impact that extending the 

length of an activity has on safety, sustainability, and the Navy’s ability to accomplish the activity’s 
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intended objectives varies by activity. This is one reason why the Navy tailors its mitigation zone sizes

and mitigation requirements by activity category or stressor and the platforms involved.

As described in Section 5.2.1 (Procedural Mitigation Development), the Navy will mitigate for each 

applicable sighting and will continue mitigating until one of five conditions has been met. In some 

instances, such as if an animal dives underwater after a sighting, it may not be possible for a Lookout to 

visually verify if the animal has exited the mitigation zone. The Navy cannot delay or cease activities 

indefinitely for the purpose of mitigation due to impacts on safety, sustainability, and the Navy’s ability 

to continue meeting its mission requirements. To account for this, one of the pre-activity 

commencement and during-activity recommencement conditions is an established post-sighting wait 

period of 30 minutes (min.) or 10 min., based on the platforms involved. Wait periods are designed to 

allow animals the maximum amount of time practical to resurface (i.e., become available to be observed 

by a Lookout) before activities resume. When developing the length of its wait periods, the Navy 

factored in the assumption that mitigation may need to be implemented more than once. For example, 

an activity may need to be delayed or ceased for more than one 30-min. or 10-min. period. Information 

on diving behaviors of marine mammals and sea turtles is presented in the U.S. Department of the Navy 

(2017c) technical report titled Dive Distribution and Group Size Parameters for Marine Species Occurring 

in the U.S. Navy’s Atlantic and Hawaii-Southern California Training and Testing Study Areas.

The Navy assigns a 30-min. wait period to activities conducted from vessels and activities that involve 

aircraft that are not typically fuel constrained (e.g., maritime patrol aircraft). A 30-min. period covers the 

average dive times of most marine mammals and a portion of the dive times of sea turtles and deepdiving marine mammals (i.e., sperm whales, dwarf and pygmy sperm whales [Kogia whales], and beaked 

whales). The Navy determined that a 30-min. wait period is the maximum wait time that is practical to 

implement during activities involving vessels and aircraft that are not typically fuel constrained to allow 

the activities to continue meeting their intended objectives. For example, the typical duration of 

Maritime Security Operations – Anti-Swimmer Grenades (which involve the use of small boats) is 1 hour. 

These activities are scheduled to occur at specific locations within specific timeframes based on range 

scheduling and for sea space deconfliction. Implementing one wait period would result in the activity 

being extended by half of the typical activity duration. The Navy determined that, given the benefit of 

this mitigation, a 30-min. wait period would be practical to implement for this activity; however, 

implementing a longer wait period (such as extending the wait period to 45 min. or 60 min. to cover the 

average dive times of sea turtles and additional marine mammal species) would be impractical. 

Increasing the wait period, and consequently the amount of time the activity would need to be delayed 

or extended in order to accomplish its intended objective, would impact activity realism or cause sea 

space conflicts in a way that could impact the Navy’s ability to continue meeting its mission

requirements. For example, delaying an activity for multiple wait periods could result in personnel not 

being able to detonate an explosive before the participating platforms are required to depart the range 

due to range scheduling; therefore, the activity would not accomplish its intended objectives.

The Navy assigns a 10-min. wait period to activities involving aircraft that are typically fuel constrained 

(e.g., rotary-wing aircraft, fighter aircraft). A 10-min. period covers a portion, but not the average, dive 

times of marine mammals and sea turtles. The Navy determined that a 10-min. wait period is the 

maximum wait time that is practical to implement during activities involving aircraft that are typically 

fuel constrained. Increasing the wait period, and consequently the amount of time the training or 

testing activity would need to be extended in order to accomplish its intended objective, would require 

aircraft to depart the activity area to refuel in order to safely complete the event. If the wait period was 
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implemented multiple times, the aircraft would be required to depart the activity area to refuel multiple 

times. Refueling events would vary in duration, depending on the activity location and proximity to the 

nearest refueling station. Multiple refueling events would generally be expected to extend the length of 

the activity by two to five times or more. This would impact activity realism, could cause air space or sea 

space conflicts in a way that could impact the Navy’s ability to continue meeting its mission 

requirements, would decrease the ability for Lookouts to safely and effectively maintain situational 

awareness of the activity area, and would increase safety risks due to increased pilot fatigue and 

accelerated fatigue-life of aircraft. For example, delaying a Kilo Dip activity for multiple wait periods 

could result in personnel not being able to conduct a functional check of the dipping sonar system

before the rotary-wing aircraft is required to depart the range due to range scheduling; therefore, the 

activity would not accomplish its intended objectives.

Factors that influenced whether a mitigation area measure met the practicality criteria included the 

historical use and projected future use of geographic locations for training and testing activities under 

the Proposed Action, and the relative importance of each location. The frequency that an area is used 

for training or testing does not necessarily equate to that area’s level of importance for meeting an 

individual activity objective, or collectively, the Navy’s mission requirements. While frequently used 

areas can be essential to one or more types of military readiness activities, some infrequently used areas

are critical for a particular training exercise, testing mission, or research project.

5.3 PROCEDURAL MITIGATION TO BE IMPLEMENTED

The first procedural mitigation measure (Section 5.3.1, Environmental Awareness and Education) is 

designed to aid Lookouts and other personnel with observation, environmental compliance, and 

reporting responsibilities. The remaining procedural mitigation measures are organized by stressor type 

and training or testing activity category.

5.3.1 ENVIRONMENTAL AWARENESS AND EDUCATION

The Navy will continue to implement procedural mitigation to provide environmental awareness and 

education to the appropriate personnel to aid visual observation, environmental compliance, and 

reporting responsibilities, as outlined in Table 5.3-1.

The Navy requires Lookouts and other personnel to complete their assigned environmental compliance 

responsibilities (e.g., mitigation, reporting requirements) before, during, and after training and testing 

activities. Marine Species Awareness Training was first developed in 2007 and has since undergone 

numerous updates to ensure that the content remains current. The most recent product was approved 

by NMFS and released by the Navy in 2014. In 2014, the Navy developed a series of educational training 

modules, known as the Afloat Environmental Compliance Training program, to ensure Navywide 

compliance with environmental requirements. The Afloat Environmental Compliance Training program, 

including the updated Marine Species Awareness Training, helps Navy personnel from the most junior 

Sailors to Commanding Officers gain a better understanding of their personal environmental compliance 

roles and responsibilities. Additional information on the Protective Measures Assessment Protocol is 

provided in Section 5.1.2.1 (Protective Measures Assessment Protocol), and additional information on 

training and testing activity and incident reports is provided in Section 5.1.2.2 (Monitoring, Research,

and Reporting Initiatives).

From an operational perspective, the interactive web-based format of the U.S. Navy Afloat 

Environmental Compliance Training Series is ideal for providing engaging and educational content that is 
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cost effective and convenient to access by personnel who oftentimes face rotating job assignments. The 

U.S. Navy Afloat Environmental Compliance Training Series has resulted in an improvement in the 

quality and accuracy of training and testing activity reports, incident reports, and Sonar Positional 

Reporting System reports submitted by Navy operators. Improved reporting quality indicates that the 

U.S. Navy Afloat Environmental Compliance Training Series is helping to facilitate Navywide 

environmental compliance as intended.

Table 5.3-1: Environmental Awareness and Education

Procedural Mitigation Description

Stressor or Activity

 All training and testing activities, as applicable

Resource Protection Focus

 Marine mammals

 Sea turtles

Mitigation Requirements

 Appropriate personnel (including civilian personnel) involved in mitigation and training or testing activity reporting under the 

Proposed Action will complete one or more modules of the U.S. Navy Afloat Environmental Compliance Training Series, as 

identified in their career path training plan. Modules include:

 Introduction to the U.S. Navy Afloat Environmental Compliance Training Series. The introductory module provides 

information on environmental laws (e.g., ESA, MMPA) and the corresponding responsibilities that are relevant to Navy 

training and testing activities. The material explains why environmental compliance is important in supporting the Navy’s 

commitment to environmental stewardship.

 Marine Species Awareness Training. All bridge watch personnel, Commanding Officers, Executive Officers, maritime patrol 

aircraft aircrews, anti‐submarine warfare and mine warfare rotary-wing aircrews, Lookouts, and equivalent civilian personnel 

must successfully complete the Marine Species Awareness Training prior to standing watch or serving as a Lookout. The 

Marine Species Awareness Training provides information on sighting cues, visual observation tools and techniques, and 

sighting notification procedures. Navy biologists developed Marine Species Awareness Training to improve the effectiveness 

of visual observations for biological resources, focusing on marine mammals and sea turtles, and including floating 

vegetation, jellyfish aggregations, and flocks of seabirds.

 U.S. Navy Protective Measures Assessment Protocol. This module provides the necessary instruction for accessing mitigation 

requirements during the event planning phase using the Protective Measures Assessment Protocol software tool.

 U.S. Navy Sonar Positional Reporting System and Marine Mammal Incident Reporting. This module provides instruction on 

the procedures and activity reporting requirements for the Sonar Positional Reporting System and marine mammal incident 

reporting.

Lookouts and members of the operational community have demonstrated enhanced knowledge and 

understanding of the Navy’s environmental compliance responsibilities since the development of the 

U.S. Navy Afloat Environmental Compliance Training Series. From January 2007 through August 2018, 

the Navy reported four whale strikes during Navy activities in the Study Area (an average of 0.34 per

year), with the last strike occurring in 2012. For the 10-year period (1997–2006) prior to the 

implementation of the original Marine Species Awareness Training in 2007, the Navy reported 15 whale 

strikes during Navy activities in the Study Area (an average of 1.5 per year). This is more than three 

times the amount reported for January 2007 through August 2018. It is likely that the implementation of 

the Marine Species Awareness Training starting in 2007, and the additional U.S. Navy Afloat 

Environmental Compliance Training Series modules starting in 2014, has contributed to this reduction in 

marine mammal strikes. This indicates that the environmental awareness and education program is 

helping to improve the effectiveness of mitigation implementation. A more detailed analysis of marine 

mammal vessel strikes is presented in Section 3.7.3.4.1 (Impacts from Vessels and In-Water Devices).

5.3.2 ACOUSTIC STRESSORS

The Navy will implement procedural mitigation to avoid or reduce potential impacts on biological 

resources from the acoustic stressors or activities discussed in the sections below.
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5.3.2.1 Active Sonar

The Navy will continue to implement procedural mitigation to avoid or reduce potential impacts on

marine mammals and sea turtles from active sonar, as outlined in Table 5.3-2. In addition to procedural 

mitigation, the Navy will implement mitigation for the use of active sonar within mitigation areas (see 

Section 5.4.2, Mitigation Areas off the Northeastern United States; Section 5.4.3, Mitigation Areas off 

the Mid-Atlantic and Southeastern United States; and Section 5.4.4, Mitigation Areas in the Gulf of 

Mexico).

Table 5.3-2: Procedural Mitigation for Active Sonar

Procedural Mitigation Description

Stressor or Activity

 Low-frequency active sonar, mid-frequency active sonar, high-frequency active sonar

 For vessel-based activities, mitigation applies only to sources that are positively controlled and deployed from manned surface 

vessels (e.g., sonar sources towed from manned surface platforms).

 For aircraft-based activities, mitigation applies only to sources that are positively controlled and deployed from manned aircraft 

that do not operate at high altitudes (e.g., rotary-wing aircraft). Mitigation does not apply to active sonar sources deployed 

from unmanned aircraft or aircraft operating at high altitudes (e.g., maritime patrol aircraft).

Resource Protection Focus

 Marine mammals

 Sea turtles (only for sources <2 kilohertz [kHz])

Number of Lookouts and Observation Platform

 Hull-mounted sources: 

 1 Lookout: Platforms with space or manning restrictions while underway (at the forward part of a small boat or ship) and 

platforms using active sonar while moored or at anchor (including pierside)

 2 Lookouts: Platforms without space or manning restrictions while underway (at the forward part of the ship)

 4 Lookouts: Pierside sonar testing activities at Port Canaveral, Florida and Kings Bay, Georgia

 Sources that are not hull-mounted:

 1 Lookout on the ship or aircraft conducting the activity

Mitigation Requirements

 Mitigation zones:

 1,000 yd. power down, 500 yd. power down, and 200 yd. shut down for low-frequency active sonar ≥200 decibels (dB) and hullmounted mid-frequency active sonar

 200 yd. shut down for low-frequency active sonar <200 dB, mid-frequency active sonar sources that are not hull-mounted, and 

high-frequency active sonar

 Prior to the initial start of the activity (e.g., when maneuvering on station):

 Observe the mitigation zone for floating vegetation; if observed, relocate or delay the start until the mitigation zone is clear.

 Observe the mitigation zone for marine mammals and sea turtles; if observed, relocate or delay the start of active sonar

transmission.

 During the activity: 

 Low-frequency active sonar ≥200 decibels (dB) and hull-mounted mid-frequency active sonar: Observe the mitigation zone for 

marine mammals and sea turtles (for sources <2 kHz); power down active sonar transmission by 6 dB if observed within 1,000 

yd. of the sonar source; power down an additional 4 dB (10 dB total) within 500 yd.; cease transmission within 200 yd.

 Low-frequency active sonar <200 dB, mid-frequency active sonar sources that are not hull-mounted, and high-frequency active 

sonar: Observe the mitigation zone for marine mammals and sea turtles (for sources <2 kHz); cease active sonar transmission if

observed within 200 yd. of the sonar source.

 Commencement/recommencement conditions after a marine mammal or sea turtle sighting before or during the activity:

 The Navy will allow a sighted marine mammal or sea turtle to leave the mitigation zone prior to the initial start of the activity 

(by delaying the start) or during the activity (by not recommencing or powering up active sonar transmission) until one of the 

following conditions has been met: (1) the animal is observed exiting the mitigation zone; (2) the animal is thought to have 

exited the mitigation zone based on a determination of its course, speed, and movement relative to the sonar source; (3) the 

mitigation zone has been clear from any additional sightings for 10 min. for aircraft-deployed sonar sources or 30 min. for 

vessel-deployed sonar sources; (4) for mobile activities, the active sonar source has transited a distance equal to double that of 

the mitigation zone size beyond the location of the last sighting; or (5) for activities using hull-mounted sonar, the ship 

concludes that dolphins are deliberately closing in on the ship to ride the ship’s bow wave, and are therefore out of the main 

transmission axis of the sonar (and there are no other marine mammal sightings within the mitigation zone).
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Table 5.3-2: Procedural Mitigation for Active Sonar (continued)

Procedural Mitigation Description

 Additional requirements:

 At Port Canaveral, Florida and Kings Bay, Georgia the Navy will equip Lookouts with polarized sunglasses and conduct active 

sonar activities during daylight hours to ensure adequate sightability of manatees and sea turtles. The Navy will notify the Port 

Authority prior to commencing pierside sonar testing at these locations. The Navy will observe the mitigation zone for marine 

mammals and sea turtles for 30 min. after completion of pierside sonar testing at these locations.

 The Navy will reduce mid-frequency active sonar transmissions at Kings Bay, Georgia by at least 36 dB from full power. The 

Navy will communicate sightings of manatees and sea turtles (e.g., time, location, count, animal size, description of research 

tags if present, direction of travel) made during or after pierside sonar testing at Kings Bay, Georgia to the Georgia Department 

of Natural Resources sightings hotline, Base Natural Resources Manager, and Port Operations. Port Operations will disseminate

sightings information to other vessels operating in the vicinity and will keep logs of all manatee sightings.

In Phase II, the Navy’s active sonar mitigation zones were based on associated average ranges to PTS. 

When developing Phase III mitigation, the Navy analyzed the potential for increasing the sizes of these

mitigation zones. The Navy determined that the current mitigation zones for active sonar are the largest 

areas within which it is practical to implement mitigation; therefore, it will continue implementing these 

same mitigation zones for Phase III. The Navy is clarifying that the mitigation zone for low-frequency 

active sonar sources at or above 200 dB will be the same as the mitigation implemented for hullmounted mid-frequency active sonar; whereas low-frequency active sonar sources below 200 dB will 

implement the same mitigation zone as high-frequency active sonar and mid-frequency active sonar 

sources that are not hull-mounted. The Navy is also clarifying that it will require observation of the 

mitigation zone prior to the initial start of the activity to ensure the area is clear of applicable biological 

resources. The Navy has always verified that the mitigation zone is visually clear prior to conducting 

active sonar activities and is more clearly capturing this current practice in the mitigation measures for 

Phase III. The Navy will follow the incident reporting procedures outlined in Section 5.1.2.2.3 (Incident 

Reports) if an incident is detected at any time during the event.

The mitigation zone sizes and proximity to the observation platforms will result in a high likelihood that 

Lookouts will be able to detect marine mammals and sea turtles throughout the mitigation zones.

Observing for indicators of marine mammal and sea turtle presence will further help avoid or reduce 

potential impacts on these resources within the mitigation zones. The mitigation specific to Port 

Canaveral, Florida and Kings Bay, Georgia will provide additional protection for sea turtles and manatees 

during pierside testing at these locations. The mitigation to conduct pierside sonar activities during 

daylight hours will help increase the likelihood that Lookouts will detect manatees and sea turtles. The 

Navy is able to implement a 36-dB reduction from full power for mid-frequency active sonar 

transmissions at Kings Bay; however, this same mitigation is not practical to implement elsewhere due 

to the type of submarines and sonar systems used during testing activities at other pierside locations 

(e.g., Port Canaveral).

Section 3.7.3.1.2 (Impacts from Sonar and Other Transducers) provides a full analysis of the potential 

impacts of sonar on marine mammals and includes the predicted impact ranges for various source bins. 

For low-frequency active sonar at 200 dB or more and hull-mounted mid-frequency active sonar, bin 

MF1 has the longest predicted ranges to PTS. For the highest source level in bin MF1, the 1,000-yd. and 

500-yd. power down mitigation zones extend beyond the average ranges to PTS for marine mammals. 

The 200-yd. shut down mitigation zone extends beyond the average ranges to PTS for all marine 

mammal hearing groups except high-frequency cetaceans (the mitigation zone extends into a portion of 

the average range to PTS for this hearing group). The ranges to PTS for the 200-yd. shut down mitigation 

zone were calculated based on full power transmissions and do not consider that the impact ranges 
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would be reduced if the 1,000-yd. and 500-yd. power down mitigation measures are implemented in 

response to a marine mammal sighting in those mitigation zones. If an animal is first sighted in the 

1,000-yd. or 500-yd. power down mitigation zone, the source level reduction would shorten the ranges 

to PTS, and the 200-yd. shut down mitigation would then extend beyond the average ranges to PTS for 

all hearing groups. For low-frequency active sonar below 200 dB, mid-frequency active sonar sources 

that are not hull-mounted, and high-frequency active sonar, bin HF4 has the longest predicted ranges to 

PTS. For the highest source level in bin HF4, the 200-yd. shut down mitigation zone extends beyond the 

average ranges to PTS for marine mammals. The mitigation zones for active sonar will help avoid or 

reduce the potential for exposure to PTS for marine mammals.

The active sonar mitigation zones also extend into a portion of the average ranges to TTS for marine 

mammals; therefore, mitigation will help avoid or reduce the potential for some exposure to higher 

levels of TTS. Active sonar sources that fall within lower source bins or are used at lower source levels 

have shorter impact ranges than those discussed above; therefore, the mitigation zones will extend 

further beyond or into the average ranges to PTS and TTS for these sources. The analysis in Section 

3.7.3.1.2 (Impacts from Sonar and Other Transducers) indicates that pygmy and dwarf sperm whales 

(Kogia whales) are the only deep-diving marine mammal species that could potentially experience PTS 

impacts from active sonar in the Study Area. The 30-min. wait period for vessel-deployed sources will

cover the average dive times of marine mammal species that could experience PTS from sonar in the 

mitigation zone, except for Kogia whales. The 10-min. wait period for aircraft-deployed sources will

cover a portion, but not the average, dive times of marine mammals.

Section 3.8.3.1.2 (Impacts from Sonar and Other Transducers) provides a full analysis of the potential 

impacts of sonar on sea turtles. Due to sea turtle hearing capabilities, the mitigation only applies to sea 

turtles during the use of sources below 2 kHz. The range to auditory effects for most active sonar 

sources in sea turtle hearing range (e.g., LF5) is zero meters. Impact ranges are longer (i.e., up to tens of 

meters) for active sonars with higher source levels. The mitigation zones for active sonar extend beyond 

the ranges to PTS and TTS for sea turtles; therefore, mitigation will help avoid or reduce the potential for 

exposure to these effects for sea turtles.

As described previously, the Phase III mitigation zones are based on the largest areas within which it is 

practical for the Navy to implement mitigation during training and testing. Training and testing with 

active sonar is essential to national security. Active sonar is the only reliable technology for detecting 

and tracking potential enemy diesel-electric submarines that could be operating covertly in coastal 

waters of the United States or its allies. For example, small diesel-electric submarines operate quietly 

and may hide in shallow coastal and littoral waters. The ability to effectively operate active sonar is a 

highly perishable skill that must be repeatedly practiced during realistic training. Naval forces must train 

in the same mode and manner in which they conduct military missions and combat operations. Antisubmarine warfare training typically involves the periodic use of active sonar to develop the “tactical 

picture,” or an understanding of the battle space (e.g., area searched or unsearched, identifying false 

contacts, and understanding the water conditions). This can take from several hours to multiple days 

and typically occurs over vast areas with varying physical and oceanographic conditions (e.g., 

bathymetry, topography, surface fronts, and variations in sea surface temperature). Sonar operators 

train to avoid or reduce interference and sound-reducing clutter from varying ocean floor topographies 

and environmental conditions, practice coordinating their efforts with other sonar operators in a strike 

group, develop skill proficiency in detecting and tracking submarines and other threats, and practice the 
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focused endurance vital to effectively working as a team in shifts around the clock until the conclusion 

of the event.

Increasing the mitigation zone sizes would result in a larger area over which active sonar would need to 

be powered down or shut down in response to a sighting, and therefore would likely increase the 

number of times that these mitigation measures would be implemented. This would extend the length 

of the activity, significantly diminish event realism, and prevent activities from meeting their intended 

objectives. It would also create fundamental differences between how active sonar would be used in 

training and how active sonar should be used during military missions and combat operations. For 

example, additional active sonar power downs or shut downs would prevent sonar operators from

developing and maintaining awareness of the tactical picture during training events. Without realistic 

training in conditions analogous to military missions and combat operations, sonar operators cannot

become proficient in effectively operating active sonar. Sonar operators, vessel crews, and aircrews 

would be expected to operate active sonar during military missions and combat operations in a manner 

inconsistent with how they were trained. 

During integrated training, multiple vessels and aircraft may participate in an exercise using different 

warfare components simultaneously. Degrading the value of one training element results in a 

degradation of the training value of the other training elements. Degrading the value of training would 

cause a reduction in perishable skills and diminished operational capability, which would significantly 

impact military readiness. Each of these factors would ultimately impact the ability for units to meet 

their individual training and certification requirements and the Navy’s ability to certify forces to safely 

deploy to meet national security tasking. Diminishing proficiency or eroding active sonar capabilities 

would present a significant risk to personnel safety during military missions and combat operations and 

would impact the ability to deploy with the required level of readiness necessary to accomplish any 

tasking by Combatant Commanders.

Increasing the number of times that the Navy must power down or shut down active sonar 

transmissions during testing activities would result in similar consequences to activity realism. For 

example, at-sea sonar testing activities are required in order to calibrate or document the functionality 

of sonar and torpedo systems while a ship or submarine is in an open ocean environment. Additional 

powering down or shutting down active sonar transmissions would prevent this activity from meeting its 

intended objective, such as verifying if the ship meets design acoustic specifications. These types of 

impacts would impede the ability of researchers, program managers, and weapons system acquisition 

programs to meet research objectives and testing requirements per required acquisition milestones or 

on an as-needed basis to meet operational requirements, and would impede shipboard maintenance, 

repairs, or pierside testing prior to at-sea operations.

For activities that involve aircraft (e.g., activities involving rotary-wing aircraft that use dipping sonar or 

sonobuoys to locate submarines or submarine targets), extending the length of the activity would

require aircraft to depart the area to refuel. If multiple refueling events were required, the length of the 

activity would be extended by two to five times or more, which would decrease the ability for Lookouts 

to safely and effectively maintain situational awareness of the activity area and increase safety risks due 

to increased pilot fatigue and accelerated fatigue-life of aircraft. Extending the length of the activity 

would also result in additional operational costs due to increased fuel consumption. Increasing the 

mitigation zone sizes would not result in a substantial reduction of injurious impacts because, as 

described above, the mitigation zones extend beyond the average ranges to PTS for sea turtles and 

marine mammals.
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In summary, the operational community determined that implementing procedural mitigation for active 

sonar beyond what is detailed in Table 5.3-2 would be incompatible with the practicality assessment 

criteria for safety, sustainability, and mission requirements.

5.3.2.2 Air Guns

The Navy developed new procedural mitigation for Phase III to avoid or reduce potential impacts on 

marine mammals and sea turtles from air guns, as outlined in Table 5.3-3. The Navy developed the new 

mitigation zone based on the largest area within which it is practical to implement mitigation for air gun 

activities. The Navy will implement procedural mitigation measures for this activity that are consistent 

with procedural mitigation for other acoustic stressors. For example, the Navy will require observations 

of the mitigation zone prior to the initial start of the activity to ensure the area is clear of applicable 

biological resources. The Navy will follow the incident reporting procedures outlined in Section 5.1.2.2.3

(Incident Reports) if an incident is detected at any time during the event. The small mitigation zone size 

and proximity to the observation platform will result in a high likelihood that Lookouts will be able to 

detect marine mammals and sea turtles throughout the mitigation zone. Observing for indicators of 

marine mammal and sea turtle presence will further help avoid or reduce potential impacts on these 

resources within the mitigation zone.

Table 5.3-3: Procedural Mitigation for Air Guns

Procedural Mitigation Description

Stressor or Activity

 Air guns

Resource Protection Focus

 Marine mammals

 Sea turtles 

Number of Lookouts and Observation Platform

 1 Lookout positioned on a ship or pierside

Mitigation Requirements

 Mitigation zone:

 150 yd. around the air gun

 Prior to the initial start of the activity (e.g., when maneuvering on station):

 Observe the mitigation zone for floating vegetation; if observed, relocate or delay the start until the mitigation zone is clear. 

 Observe the mitigation zone for marine mammals and sea turtles; if observed, relocate or delay the start of air gun use. 

 During the activity:

 Observe the mitigation zone for marine mammals and sea turtles; if observed, cease air gun use.

 Commencement/recommencement conditions after a marine mammal or sea turtle sighting before or during the activity:

 The Navy will allow a sighted marine mammal or sea turtle to leave the mitigation zone prior to the initial start of the activity 

(by delaying the start) or during the activity (by not recommencing air gun use) until one of the following conditions has been 

met: (1) the animal is observed exiting the mitigation zone; (2) the animal is thought to have exited the mitigation zone based 

on a determination of its course, speed, and movement relative to the air gun; (3) the mitigation zone has been clear from 

any additional sightings for 30 min.; or (4) for mobile activities, the air gun has transited a distance equal to double that of the 

mitigation zone size beyond the location of the last sighting.

Section 3.7.3.1.3 (Impacts from Air Guns) and Section 3.8.3.1.3 (Impacts from Air Guns) provide a full 

analysis of the potential impacts of air guns on marine mammals and sea turtles, respectively, including 

the air gun impact ranges for the maximum number of pulses expected for air gun activities in the Study 

Area, which is 100 pulses. For 100 pulses, the mitigation zone extends beyond the average ranges to PTS 

for sea turtles and all marine mammal hearing groups. Therefore, mitigation will help avoid or reduce 

the potential for exposure to PTS. 
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The air gun mitigation zone also extends beyond the average ranges to TTS for sea turtles, highfrequency cetaceans, mid-frequency cetaceans, and phocids; and into a portion of the average ranges to 

TTS for low-frequency cetaceans. Therefore, depending on the hearing group, mitigation will help avoid 

or reduce the potential for exposure to all or a portion of TTS. Air gun activities using 10 pulses or 1 

pulse have shorter impact ranges those using 100 pulses. The mitigation zone extends beyond the 

average ranges to PTS and TTS for sea turtles and marine mammals for 10 pulses and 1 pulse. The 30-

min. wait period will cover the average dive times of the marine mammal species that could be present

in the mitigation zone. 

When developing the new mitigation, the Navy analyzed a range of potential mitigation zone sizes. A 

larger mitigation zone would result in a larger area over which air gun activities would need to be ceased 

in response to a sighting, and therefore would likely increase the number of times air guns would be 

ceased. However, establishing a larger mitigation zone would not result in a substantial reduction of 

injurious impacts because the mitigation zone extends beyond the average ranges to PTS for sea turtles 

and marine mammals. 

Due to the nature of how air gun testing is conducted (e.g., generated impulses with short durations), 

increasing the size of the mitigation zone would extend the length of the activity and significantly 

diminish realism in a way that would prevent the activity from meeting its intended objectives. For 

example, during semi-stationary equipment testing, the Navy determines the functionality of air gun 

equipment and test sensors and system performance. These tests must be conducted in the same 

manner and under the same conditions in which they will be conducted during military readiness 

training exercises, military missions, and combat operations. Extending the length of the activity would 

decrease realism, increase time at sea for vessels, and increase fuel usage, particularly when air guns are 

deployed from small boats or small research vessels. Therefore, additional mitigation would prevent the 

Navy from validating whether air guns perform as expected; determining whether they are operationally 

effective, suitable, survivable, and safe for their intended uses by the fleet; from meeting research 

program objectives; and from meeting testing requirements per required acquisition milestones or on 

an as-needed basis to meet operational requirements.

In summary, the operational community determined that implementing procedural mitigation beyond 

what is detailed in Table 5.3-3 would be incompatible with the practicality assessment criteria for safety, 

sustainability, and mission requirements.

5.3.2.3 Pile Driving

The Navy is incorporating mitigation from the 2015 Environmental Assessment for Joint Logistics Overthe-Shore Training at Joint Expeditionary Base Little Creek-Fort Story, Virginia Beach, Virginia and 

Marine Corps Base Camp Lejeune, Jacksonville, North Carolina to avoid or reduce potential impacts on

marine mammals and sea turtles from pile driving, as outlined in Table 5.3-4. In the 2015 Environmental 

Assessment for Joint Logistics Over-the-Shore Training at Joint Expeditionary Base Little Creek-Fort 

Story, Virginia Beach, Virginia and Marine Corps Base Camp Lejeune, Jacksonville, North Carolina, the 

pile driving mitigation zone was based on the associated average ranges to PTS. When developing Phase 

III mitigation, the Navy analyzed the potential for increasing the size of the mitigation zone. The Navy 

identified an opportunity to increase the mitigation zone size for pile driving by 40 yd. to enhance 

protections to the maximum extent practicable. This increase is reflected in Table 5.3-4. The mitigation 

zone for pile driving is now based on the largest area within which it is practical to implement 

mitigation.
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Table 5.3-4: Procedural Mitigation for Pile Driving

Procedural Mitigation Description

Stressor or Activity

 Pile driving and pile extraction sound during Elevated Causeway System training

Resource Protection Focus

 Marine mammals

 Sea turtles 

Number of Lookouts and Observation Platform

 1 Lookout positioned on the shore, the elevated causeway, or a small boat

Mitigation Requirements

 Mitigation zone:

 100 yd. around the pile

 Prior to the initial start of the activity (for 30 min.):

 Observe the mitigation zone for floating vegetation; if observed, delay the start until the mitigation zone is clear. 

 Observe the mitigation zone for marine mammals and sea turtles; if observed, delay the start of pile driving or vibratory pile 

extraction. 

 During the activity:

 Observe the mitigation zone for marine mammals and sea turtles; if observed, cease impact pile driving or vibratory pile 

extraction.

 In the Navy Cherry Point Range Complex, the Navy will maintain a log detailing any sightings or injuries to manatees during 

pile driving. If a manatee was sighted during the activity, upon completion of the activity, the Navy project manager or civilian 

equivalent will prepare a report that summarizes all information on manatees encountered and submit the report to the 

USFWS, Raleigh Field Office. The Navy will report any injury of a manatee to the USFWS, NMFS, and the North Carolina 

Wildlife Resources Commission.

 Commencement/recommencement conditions after a marine mammal or sea turtle sighting before or during the activity:

 The Navy will allow a sighted marine mammal or sea turtle to leave the mitigation zone prior to the initial start of the activity 

(by delaying the start) or during the activity (by not recommencing pile driving or pile extraction) until one of the following

conditions has been met: (1) the animal is observed exiting the mitigation zone; (2) the animal is thought to have exited the 

mitigation zone based on a determination of its course, speed, and movement relative to the pile driving location; or (3) the 

mitigation zone has been clear from any additional sightings for 30 min.

The Navy is clarifying that it will require observation of the mitigation zone prior to the initial start of the 

activity to ensure the area is clear of applicable biological resources. The Navy has always verified that 

the mitigation zone is visually clear prior to conducting pile driving activities and is more clearly 

capturing this current practice in the mitigation measures for Phase III. The Navy will follow the incident 

reporting procedures outlined in Section 5.1.2.2.3 (Incident Reports) if an incident is detected at any 

time during the event.

The small mitigation zone size and proximity to the observation platform will result in a high likelihood 

that Lookouts will be able to detect marine mammals and sea turtles throughout the mitigation zone. 

Observing for indicators of marine mammal and sea turtle presence will further help avoid or reduce 

potential impacts on these resources within the mitigation zone. The additional mitigation in the Navy 

Cherry Point Range Complex will help facilitate a better understanding of manatee presence and 

potential impacts from pile driving at this location.

Section 3.7.3.1.4 (Impacts from Pile Driving) and Section 3.8.3.1.4 (Impacts from Pile Driving) provide a 

full analysis of the potential impacts of pile driving on marine mammals and sea turtles, respectively,

and include the approximate impact ranges for impact pile driving and vibratory pile extraction. The 

ranges to effect from impact pile driving are longer than the ranges to effect for vibratory pile 

extraction. For impact pile driving, the 100 yd. mitigation zone extends beyond the average ranges to 

PTS for sea turtles and marine mammals. Therefore, mitigation will help avoid or reduce the potential 

for exposure to PTS. The mitigation zone also extends beyond the average range to TTS for impact pile 

driving for sea turtles and mid-frequency cetaceans, and into a portion of the average range to TTS for 
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low-frequency cetaceans, high-frequency cetaceans, and phocids. Therefore, depending on the hearing 

group, mitigation will help avoid or reduce the potential for exposure to all or a portion of TTS. Vibratory 

pile extraction has shorter predicted impact ranges than impact pile driving. The mitigation zone will 

extend further beyond the average ranges to PTS, and further beyond (or into, depending on hearing 

group) the average ranges to TTS during vibratory pile driving. The 30-min. wait period will cover the 

average dive times of the marine mammal species that could be present in the mitigation zone.

As described previously, the Phase III mitigation zone is based on the largest area within which it is 

practical for the Navy to implement mitigation for this activity. Increasing the mitigation zone would 

result in a larger area over which pile driving would need to be ceased in response to a sighting, and 

therefore would likely increase the number of times pile driving is ceased during Elevated Causeway 

System training. However, increasing the mitigation zone would not result in a substantial reduction of 

injurious impacts because the mitigation zone extends beyond the average ranges to PTS for sea turtles 

and marine mammals. The Navy also analyzed the potential for implementing additional types of

mitigation employed by commercial construction projects, such as the use of bubble curtains and other 

sound attenuation devices. The Navy determined that these mitigation techniques would be impractical

to use during Elevated Causeway System training due to impacts on event realism. The use of additional 

mitigation techniques would create fundamental differences between how pile driving would be 

conducted during training and how pile driving should be conducted during military missions and 

combat operations. This would present a significant risk to personnel safety during military missions and 

combat operations.

Elevated Causeway System training involves multiple steps, including driving support pilings into the

sand, securing causeway platforms onto the piles, assembling causeway platforms into a pier, and

removing the pier and piles. The activity provides essential training for each component individually and 

for the logistical coordination of all components as a whole. In order for the Navy to effectively conduct 

this training exercise, all components must be completed on time and as they would during military 

missions and combat operations. Increasing the number of times that the Navy must cease pile driving 

would result in schedule delays to the first component of Elevated Causeway System training (i.e., 

installation of support pilings), which would diminish realism, put the activity timeline at risk, and impact 

the Navy’s ability to become proficient in each component individually and the logistical coordination of 

the activity as a whole. These factors would prevent the activity from meeting its intended objective.

In summary, the operational community determined that implementing procedural mitigation beyond 

what is detailed in Table 5.3-4 would be incompatible with the practicality assessment criteria for safety 

and mission requirements. 

5.3.2.4 Weapons Firing Noise

The Navy will continue to implement procedural mitigation to avoid or reduce potential impacts on 

marine mammals and sea turtles from weapons firing noise, as outlined in Table 5.3-5. In Phase II, the 

weapons firing noise mitigation zone was based on the associated average ranges to PTS. When 

developing Phase III mitigation, the Navy analyzed the potential for increasing the size of the mitigation 

zone. The Navy determined that the current mitigation zone is the largest area within which it is 

practical to implement mitigation for this activity; therefore, it will continue implementing this same 

mitigation zone for Phase III.

The Navy is clarifying that it will require observation of the mitigation zone prior to the initial start of the 

activity to ensure the area is clear of applicable biological resources. The Navy has always verified that 
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the mitigation zone is visually clear prior to conducting weapons firing activities and is more clearly 

capturing this current practice in the mitigation measures for Phase III. The Navy will follow the incident 

reporting procedures outlined in Section 5.1.2.2.3 (Incident Reports) if an incident is detected at any 

time during the event.

Table 5.3-5: Procedural Mitigation for Weapons Firing Noise

Procedural Mitigation Description

Stressor or Activity

 Weapons firing noise associated with large-caliber gunnery activities

Resource Protection Focus

 Marine mammals

 Sea turtles 

Number of Lookouts and Observation Platform

 1 Lookout positioned on the ship conducting the firing

 Depending on the activity, the Lookout could be the same one described in Section 5.3.3.3 (Explosive Medium-Caliber and 

Large-Caliber Projectiles) or Section 5.3.4.3 (Small-, Medium-, and Large-Caliber Non-Explosive Practice Munitions).

Mitigation Requirements

 Mitigation zone:

 30° on either side of the firing line out to 70 yd. from the muzzle of the weapon being fired

 Prior to the initial start of the activity:

 Observe the mitigation zone for floating vegetation; if observed, relocate or delay the start until the mitigation zone is clear.

 Observe the mitigation zone for marine mammals and sea turtles; if observed, relocate or delay the start of weapons firing.

 During the activity:

 Observe the mitigation zone for marine mammals and sea turtles; if observed, cease weapons firing.

 Commencement/recommencement conditions after a marine mammal or sea turtle sighting before or during the activity:

 The Navy will allow a sighted marine mammal or sea turtle to leave the mitigation zone prior to the initial start of the activity 

(by delaying the start) or during the activity (by not recommencing weapons firing) until one of the following conditions has 

been met: (1) the animal is observed exiting the mitigation zone; (2) the animal is thought to have exited the mitigation zone 

based on a determination of its course, speed, and movement relative to the firing ship; (3) the mitigation zone has been 

clear from any additional sightings for 30 min.; or (4) for mobile activities, the firing ship has transited a distance equal to 

double that of the mitigation zone size beyond the location of the last sighting.

The small mitigation zone size and proximity to the observation platform will result in a high likelihood 

that Lookouts will be able to detect marine mammals and sea turtles throughout the mitigation zone. 

Observing for indicators of marine mammal and sea turtle presence will further help avoid or reduce 

potential impacts on these resources within the mitigation zone. 

Section 3.7.3.1.7 (Impacts from Weapons Noise) and Section 3.8.3.1.7 (Impacts from Weapons Noise) 

provide a full analysis of the potential impacts of weapons noise on marine mammals and sea turtles, 

respectively. As described in Section 3.0.3.3.1.6 (Weapons Firing, Launch, and Inert Impact), underwater 

sounds would be strongest just below the surface and directly under the firing point. Any sound that 

enters the water only does so within a narrow cone below the firing point or path of the projectile. The 

mitigation zone extends beyond the distance to which marine mammals and sea turtles would likely

experience PTS or TTS from weapons firing noise; therefore, mitigation will help avoid or reduce the 

potential for exposure to these impacts.

As described previously, the Phase III mitigation zone is based on the largest area within which it is 

practical for the Navy to implement mitigation for this activity. Increasing the mitigation zone would 

result in a larger area over which weapons firing would need to be ceased in response to a sighting, and 

therefore would likely increase the number of times weapons firing would be ceased. However, 

increasing the mitigation zone size would not result in a substantial reduction of injurious impacts
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because the mitigation zone extends beyond the average ranges to PTS for sea turtles and marine 

mammals.

Large-caliber gunnery training activities may involve a single ship firing or may be conducted as part of a 

larger exercise involving multiple ships. Surface ship crews learn to track targets (e.g., with radar), 

engage targets, practice defensive marksmanship, and coordinate their efforts within the context of 

larger activities. Increasing the number of times that the Navy must cease weapons firing during training 

would decrease realism and impact the ability for Navy Sailors to train and become proficient in using 

large-caliber guns as required during military missions and combat operations. For example, additional 

ceasing of the activity would reduce the crew’s ability to react to changes in the tactical situation or 

response to an incoming threat, which could result in a delay to the ship’s training schedule. When

training is undertaken in the context of a coordinated exercise involving multiple ships, degrading the 

value of one of the training element results in a degradation of the training value of the other training 

elements. These factors would ultimately impact the ability for units to meet their individual training 

and certification requirements, and the Navy’s ability to certify forces to deploy to meet national 

security tasking.

Increasing the number of times that the Navy must cease weapons firing during testing activities would 

result in similar consequences to activity realism, which would impede the ability of program managers 

and weapons system acquisition programs to meet testing requirements per required acquisition 

milestones or on an as-needed basis to meet operational requirements. This would impact the ability to 

effectively test large-caliber guns before full-scale production or delivery to the fleet to ensure 

functionality, safety, and accuracy in military mission and combat conditions.

In summary, the operational community determined that implementing procedural mitigation for 

weapons firing noise beyond what is detailed in Table 5.3-5 would be incompatible with the practicality

assessment criteria for safety and mission requirements.

5.3.2.5 Aircraft Overflight Noise

The Navy will continue to implement procedural mitigation to avoid or reduce potential impacts on 

nesting birds and cultural resources from aircraft overflights during applicable activities off Virginia and 

Florida, as outlined in Table 5.3-6. In Phase II, the aircraft overflight noise mitigation measures were

based on the Navy’s operational assessments. The Navy determined that the current mitigation 

measures are the largest areas within which it is practical to implement mitigation for aircraft overflight 

noise; therefore, it will continue implementing the same procedural mitigation measures for Phase III.

Section 3.9.3.1.6 (Impacts from Aircraft Overflight Noise) provides a full analysis of the potential impacts 

of aircraft noise on birds. One of the highest concentration areas for rotary-wing aircraft training is 

located adjacent to fleet concentration areas at Naval Station Norfolk in the lower Chesapeake Bay and 

off the coast of Virginia Beach, Virginia. This area is located nearby important nesting habitat for the 

ESA-listed piping plover and other birds that breed along Virginia’s barrier islands. The Navy’s mitigation 

for aircraft overflight noise off Virginia will help avoid potential disturbances to nesting birds within the 

Virginia Capes Range Complex and Fisherman Island National Wildlife Refuge during applicable activities.

The Key West Range Complex contains Fort Jefferson, which is listed on the National Register of Historic 

Places. Fragile mortar in Fort Jefferson’s brick masonry is susceptible to damage from sonic booms 

(Hanson et al., 1991; James et al., 2009). As described in Section 3.10.2.3 (Tortugas Military Operations 

Area), the Navy established the Tortugas Military Operations Area in 2009 to reduce potential impacts of 

sonic booms on Fort Jefferson. The Navy’s mitigation is designed to help preserve the structural integrity 
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of this cultural resource. The mitigation also helps the Navy avoid or reduce potential impacts from 

aircraft overflight noise on a nesting colony of roseate terns in the Dry Tortugas Islands.

Table 5.3-6: Procedural Mitigation for Aircraft Overflight Noise

Procedural Mitigation Description

Stressor or Activity

 Aircraft overflight noise

Resource Protection Focus

 Birds (ESA-listed piping plovers and other nesting birds in Virginia; roseate terns in Florida)

 Cultural resources (Fort Jefferson)

Number of Lookouts and Observation Platform

 Not applicable

Mitigation Requirements

 1 nautical mile (NM) from the beach within the Virginia Capes Range Complex during explosive mine neutralization activities 

involving Navy divers:

 Maneuver to maintain distance (except when transiting offshore from Norfolk Naval Station).

 3,000 ft. altitude and 1,000 yd. from Fisherman Island National Wildlife Refuge off the coast of Cape Charles, Virginia during 

explosive mine neutralization activities involving Navy divers:

 When transiting offshore from Norfolk Naval Station, maneuver to maintain altitude and distance.

 Within the Tortugas Military Operations Area (12 NM from shore within the Dry Tortugas Islands):

 Do not conduct air combat maneuver flights below 5,000 ft. or tactical maneuvers resulting in supersonic flights below 20,000 

ft.

 Conduct aircraft activities in the airspace adjacent to Fort Jefferson in a manner that will avoid or reduce sonic booms to the 

maximum extent practicable. This includes conducting training flights predisposed to supersonic conditions within designated 

airspace at least 30 NM from Fort Jefferson.

 The Navy will incorporate mitigation instructions into pre-flight planning guidance for applicable aircrews. 

Increasing mitigation would result in aircraft flying at a higher altitude, farther offshore, or in locations 

that could potentially interfere with established commercial air traffic routes. Extending distance 

offshore would increase transit distance and pilot fatigue and would accelerate the fatigue-life of 

aircraft. Interfering with commercial air traffic routes would increase safety risks to the commercial 

aircraft, Navy aircraft, and the personnel or civilians on board. In addition to these increased safety risks, 

the extending distances offshore would increase transit distances and result in additional operational 

costs due to increased fuel consumption.

In summary, the operational community determined that implementing procedural mitigation for 

aircraft overflight noise beyond what is detailed in Table 5.3-6 would be incompatible with the 

practicality assessment criteria for safety and sustainability.

5.3.3 EXPLOSIVE STRESSORS

The Navy will implement procedural mitigation to avoid or reduce potential impacts on biological 

resources from the explosive stressors or activities discussed in the sections below. Section 3.7.3.2

(Explosive Stressors) and Section 3.8.3.2 (Explosive Stressors) provide a full analysis of potential impacts 

of explosives on marine mammals and sea turtles, respectively, including predicted impact ranges.

5.3.3.1 Explosive Sonobuoys

The Navy will continue to implement procedural mitigation to avoid or reduce potential impacts on 

marine mammals and sea turtles from explosive sonobuoys, as outlined in Table 5.3-7. In addition to 

procedural mitigation, the Navy will implement mitigation for the use of Improved Extended Echo 

Ranging Sonobuoys within mitigation areas (see Section 5.4.2, Mitigation Areas off the Northeastern
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United States; Section 5.4.3, Mitigation Areas off the Mid-Atlantic and Southeastern United States; and 

Section 5.4.4, Mitigation Areas in the Gulf of Mexico).

Table 5.3-7: Procedural Mitigation for Explosive Sonobuoys

Procedural Mitigation Description

Stressor or Activity

 Explosive sonobuoys

Resource Protection Focus

 Marine mammals

 Sea turtles

Number of Lookouts and Observation Platform

 1 Lookout positioned in an aircraft or on small boat

 If additional platforms are participating in the activity, personnel positioned in those assets (e.g., safety observers, evaluators) 

will support observing the mitigation zone for applicable biological resources while performing their regular duties.

Mitigation Requirements

 Mitigation zone:

 600 yd. around an explosive sonobuoy

 Prior to the initial start of the activity (e.g., during deployment of a sonobuoy field, which typically lasts 20–30 min.):

 Observe the mitigation zone for floating vegetation; if observed, relocate or delay the start until the mitigation zone is clear.

 Conduct passive acoustic monitoring for marine mammals; use information from detections to assist visual observations.

 Visually observe the mitigation zone for marine mammals and sea turtles; if observed, relocate or delay the start of sonobuoy 

or source/receiver pair detonations. 

 During the activity:

 Observe the mitigation zone for marine mammals and sea turtles; if observed, cease sonobuoy or source/receiver pair 

detonations.

 Commencement/recommencement conditions after a marine mammal or sea turtle sighting before or during the activity:

 The Navy will allow a sighted marine mammal or sea turtle to leave the mitigation zone prior to the initial start of the activity 

(by delaying the start) or during the activity (by not recommencing detonations) until one of the following conditions has 

been met: (1) the animal is observed exiting the mitigation zone; (2) the animal is thought to have exited the mitigation zone 

based on a determination of its course, speed, and movement relative to the sonobuoy; or (3) the mitigation zone has been 

clear from any additional sightings for 10 min. when the activity involves aircraft that have fuel constraints, or 30 min. when 

the activity involves aircraft that are not typically fuel constrained.

 After completion of the activity (e.g., prior to maneuvering off station):

 When practical (e.g., when platforms are not constrained by fuel restrictions or mission-essential follow-on commitments), 

observe the vicinity of where detonations occurred; if any injured or dead marine mammals or ESA-listed species are 

observed, follow established incident reporting procedures.

 If additional platforms are supporting this activity (e.g., providing range clearance), these assets will assist in the visual 

observation of the area where detonations occurred.

In Phase II, explosive sonobuoys had two mitigation zone sizes based on net explosive weight and the 

associated average ranges to PTS. When developing Phase III mitigation, the Navy analyzed the potential 

for increasing the size of these mitigation zones. The Navy identified an opportunity to increase the 

mitigation zone size by 250 yd. for sonobuoys using up to 2.5-lb. net explosive weight so that explosive 

sonobuoys will implement a 600-yd. mitigation zone, regardless of net explosive weight, to enhance 

protections to the maximum extent practicable. This increase is reflected in Table 5.3-7. The mitigation 

zone for explosive sonobuoys is now based on the largest area within which it is practical to implement 

mitigation.

The Navy is clarifying that it will require observation of the mitigation zone prior to the initial start of the 

activity to ensure the area is clear of applicable biological resources. The Navy has always verified that 

the mitigation zone is visually clear prior to conducting explosive activities and is more clearly capturing 

this current practice in the mitigation measures for Phase III. The Navy developed a new mitigation 

measure requiring the Lookout to observe the mitigation zone after completion of the activity. The Navy 

currently conducts post-activity observations for some, but not all explosive activities. In developing 
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mitigation for Phase III, the Navy determined that it could expand this requirement to other explosive 

activities for enhanced consistency and to help determine if any resources were injured during explosive 

events, when practical. The Navy is adding a requirement that additional platforms already participating 

in the activity will support observing the mitigation zone before, during, and after the activity while 

performing their regular duties. There are typically multiple platforms in the vicinity of activities that use 

explosive sonobuoys (e.g., safety aircraft). When available, having additional personnel support 

observations of the mitigation zone will help increase the likelihood of detecting biological resources.

The Navy will follow the incident reporting procedures outlined in Section 5.1.2.2.3 (Incident Reports) if 

an incident is detected at any time during the event, including during the post-activity observations.

Some activities that use explosive sonobuoys involve detonations of a single sonobuoy or sonobuoy pair, 

while other activities involve deployment of a field of sonobuoys that may be dispersed over a large 

distance. Lookouts will have a better likelihood of detecting marine mammals and sea turtles when 

observing the mitigation zone around a single sonobuoy, sonobuoy pair, or a smaller sonobuoy field 

than when observing a sonobuoy field dispersed over a large distance. When observing large sonobuoy 

fields, Lookouts will be more likely to detect large visual cues (e.g., whale blows or large pods of 

dolphins) than individual marine mammals, cryptic marine mammal species, and sea turtles. Observing 

for indicators of marine mammal and sea turtle presence will further help avoid or reduce potential 

impacts on these resources within the mitigation zones.

Bin E4 (e.g., Improved Extended Echo Ranging Sonobuoys) has the longest predicted impact ranges for 

explosive sonobuoys used in the Study Area. For the largest explosive in bin E4, the mitigation zone 

extends beyond the ranges to 50 percent non-auditory injury and 50 percent mortality for sea turtles 

and marine mammals. The mitigation zone extends beyond the average ranges to PTS for sea turtles, 

mid-frequency cetaceans, and sirenians, and into a portion of the average ranges to PTS for highfrequency cetaceans, low-frequency cetaceans, and phocids. The mitigation zone also extends into a 

portion of the average ranges to TTS for sea turtles and marine mammals. Therefore, depending on the 

species, mitigation will help avoid or reduce all or a portion of the potential for exposure to mortality, 

non-auditory injury, PTS, and higher levels of TTS for the largest explosives in bin E4. Smaller explosives 

in bin E4 and explosives in smaller source bins (E1, E3) have shorter predicted impact ranges; therefore, 

the mitigation zone will extend further beyond or cover a greater portion of the impact ranges for these 

explosives.

As described previously, the Phase III mitigation zone is based on the largest area within which it is 

practical for the Navy to implement mitigation. It is not practical to increase the mitigation zone because 

observations within the margin of increase would be ineffective unless the Navy allocated additional 

platforms to observe for biological resources. This is particularly true when observations occur from a 

small boat or during observations of a large field of sonobuoys. The use of additional personnel and 

equipment (aircraft or small boats) would be unsustainable due to increased operational costs and an

exceedance of the available manpower and resources for this activity. Adding aircraft to observe the 

mitigation zone could result in airspace conflicts with the event participants. This would either require 

the aircraft conducting the activity to modify their flights plans (which would reduce activity realism) or 

force the observing aircraft to position itself a safe distance away from the activity area (which would 

decrease observation effectiveness). Adding vessels to observe the mitigation zone would increase 

safety risks due to the presence of observation vessels within the vicinity of explosive sonobuoys or an 

explosive sonobuoy field.
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Increasing the mitigation zone size would result in a larger area over which detonations would need to 

be ceased in response to a sighting, and therefore would likely increase the number of times 

detonations would be ceased and would extend the length of the activity. These impacts would 

significantly diminish event realism in a way that would prevent the activity from meeting its intended 

objectives. For example, during Sonobuoy Lot Acceptance Testing, additional ceasing of the activity 

would not allow the Navy to effectively verify the integrity and performance of a lot or group of 

sonobuoys before full-scale production or delivery to the fleet. Such testing is required to ensure 

functionality and accuracy in military mission and combat conditions. Extending the length of the activity 

would require aircraft to depart the area to refuel. If multiple refueling events were required, the 

activity length would extend by two to five times or more, which would decrease the ability for Lookouts 

to safely and effectively maintain situational awareness of the activity area and increase safety risks due 

to increased pilot fatigue and accelerated fatigue-life of aircraft. Extending the length of the activity

would also result in additional operational costs due to increased fuel consumption.

In summary, the operational community determined that implementing procedural mitigation for 

explosive sonobuoys beyond what is detailed in Table 5.3-7 would be incompatible with the practicality

assessment criteria for safety, sustainability, and mission requirements.

5.3.3.2 Explosive Torpedoes

The Navy will continue to implement procedural mitigation to avoid or reduce potential impacts on 

marine mammals and sea turtles from explosive torpedoes, as outlined in Table 5.3-8. In addition to 

procedural mitigation, the Navy will implement mitigation for explosive torpedoes within mitigation 

areas (see Section 5.4.2, Mitigation Areas off the Northeastern United States; Section 5.4.3, Mitigation 

Areas off the Mid-Atlantic and Southeastern United States; and Section 5.4.4, Mitigation Areas in the 

Gulf of Mexico).

In Phase II, the explosive torpedo mitigation zone was based on net explosive weight and the associated 

average ranges to PTS. When developing Phase III mitigation, the Navy analyzed the potential for 

increasing the size of this mitigation zone. The Navy determined that the current mitigation zone is the

largest area within which it is practical to implement mitigation for this activity; therefore, it will 

continue implementing this same mitigation zone for Phase III. The post-activity observations for 

explosive torpedoes are a continuation from Phase II and will help the Navy determine if any resources 

were injured during the activity. The Navy will follow the incident reporting procedures outlined in 

Section 5.1.2.2.3 (Incident Reports) if an incident is detected at any time during the event, including 

during the post-activity observations.

The Navy is clarifying that it will require observation of the mitigation zone prior to the initial start of the 

activity to ensure the area is clear of applicable biological resources. The Navy has always verified that 

the mitigation zone is visually clear prior to conducting explosive activities and is more clearly capturing 

this current practice in the mitigation measures for Phase III. The Navy is adding a requirement that 

additional platforms already participating in the activity will support observing the mitigation zone 

before, during, and after the activity while performing their regular duties. Typically, when aircraft are 

firing explosive torpedoes, there are additional observation aircraft, support vessels (e.g., range craft for 

torpedo retrieval), or other safety aircraft in the vicinity. When available, having additional personnel 

support observations of the mitigation zone will help increase the likelihood of detecting biological 

resources.
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Table 5.3-8: Procedural Mitigation for Explosive Torpedoes

Procedural Mitigation Description

Stressor or Activity

 Explosive torpedoes

Resource Protection Focus

 Marine mammals

 Sea turtles 

Number of Lookouts and Observation Platform

 1 Lookout positioned in an aircraft

 If additional platforms are participating in the activity, personnel positioned in those assets (e.g., safety observers, evaluators) 

will support observing the mitigation zone for applicable biological resources while performing their regular duties.

Mitigation Requirements

 Mitigation zone:

 2,100 yd. around the intended impact location

 Prior to the initial start of the activity (e.g., during deployment of the target):

 Observe the mitigation zone for floating vegetation; if observed, relocate or delay the start until the mitigation zone is clear.

 Conduct passive acoustic monitoring for marine mammals; use information from detections to assist visual observations.

 Visually observe the mitigation zone for marine mammals, sea turtles, and jellyfish aggregations; if observed, relocate or 

delay the start of firing. 

 During the activity:

 Observe the mitigation zone for marine mammals, sea turtles, and jellyfish aggregations; if observed, cease firing.

 Commencement/recommencement conditions after a marine mammal or sea turtle sighting before or during the activity:

 The Navy will allow a sighted marine mammal or sea turtle to leave the mitigation zone prior to the initial start of the activity 

(by delaying the start) or during the activity (by not recommencing firing) until one of the following conditions has been met: 

(1) the animal is observed exiting the mitigation zone; (2) the animal is thought to have exited the mitigation zone based on a 

determination of its course, speed, and movement relative to the intended impact location; or (3) the mitigation zone has 

been clear from any additional sightings for 10 min. when the activity involves aircraft that have fuel constraints, or 30 min. 

when the activity involves aircraft that are not typically fuel constrained.

 After completion of the activity (e.g., prior to maneuvering off station):

 When practical (e.g., when platforms are not constrained by fuel restrictions or mission-essential follow-on commitments), 

observe the vicinity of where detonations occurred; if any injured or dead marine mammals or ESA-listed species are 

observed, follow established incident reporting procedures.

 If additional platforms are supporting this activity (e.g., providing range clearance), these assets will assist in the visual 

observation of the area where detonations occurred.

Explosive torpedo activities involve detonations at a target located down range of the firing platform.

Due to the distance between the mitigation zone and the observation platform, Lookouts will have a 

better likelihood of detecting large visual cues (e.g., whale blows or large pods of dolphins) than 

individual marine mammals, cryptic marine mammal species, and sea turtles. As described in Chapter 

3.8 (Reptiles), some species of sea turtles forage on jellyfish, and some of the locations (such as off the 

northeastern United States) where explosive torpedo activities could occur support high densities of 

jellyfish throughout parts of the year. Observing for indicators of marine mammal and sea turtle 

presence (including jellyfish aggregations) will further help avoid or reduce potential impacts on these 

resources within the mitigation zone.

Bin E11 has the longest predicted impact ranges for explosive torpedoes used in the Study Area. For the 

largest explosive in bin E11, the mitigation zone extends beyond the ranges to 50 percent non-auditory 

injury and 50 percent mortality for sea turtles and marine mammals. The mitigation zone extends 

beyond the average ranges to PTS for sea turtles, mid-frequency cetaceans, and sirenians, and into a 

portion of the average ranges to PTS for high-frequency cetaceans, low-frequency cetaceans, and 

phocids. The mitigation zone also extends into a portion of the average ranges to TTS for sea turtles and 

marine mammals. Therefore, depending on the species, mitigation will help avoid or reduce all or a 

portion of the potential for exposure to mortality, non-auditory injury, PTS, and higher levels of TTS for 
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the largest explosives in bin E11. Explosive torpedoes in smaller source bins (e.g., E8) have shorter 

predicted impact ranges; therefore, the mitigation zone will extend further beyond or cover a greater 

portion of the impact ranges for these explosives.

As described previously, the Phase III mitigation zone is based on the largest area within which it is 

practical for the Navy to implement mitigation. It is not practical to increase this mitigation zone 

because observations within the margin of increase would be ineffective unless the Navy allocated 

additional platforms to observe for biological resources. The use of additional personnel and 

observation platforms would be unsustainable due to increased operational costs and an exceedance of 

the available manpower and resources for this activity. Adding aircraft to observe the mitigation zone 

could result in airspace conflicts with the event participants. This would either require the aircraft 

participating in the activity to modify their flights plans (which would reduce activity realism) or force 

the observing aircraft to position itself a safe distance away from the activity area (which would 

decrease observation effectiveness). Adding vessels to observe the mitigation zone would increase 

safety risks due to the presence of observation vessels within the vicinity of explosive torpedoes.

Increasing the mitigation zone size would result in a larger area over which detonations would need to 

be ceased in response to a sighting, and therefore would likely increase the number of times 

detonations would be ceased and would extend the length of the activity. These impacts would 

significantly diminish event realism in a way that would prevent the activity from meeting its intended 

objectives. For example, the Navy conducts Torpedo (Explosive) Testing events to test the functionality 

of torpedoes and torpedo launch systems. These events often involve aircrews locating, approaching,

and firing a torpedo on an artificial target. They require focused situational awareness of the activity 

area and continuous coordination between the participating platforms as required during military 

missions and combat operations. Extending the length of the activity would require aircraft to depart 

the area to refuel. If the firing aircraft departed the activity location to refuel, the aircrew would lose the 

ability to maintain situational awareness and effectively coordinate with other participating platforms. If 

multiple refueling events were required, the activity length would extend by two to five times or more, 

which would increase safety risks due to increased pilot fatigue and accelerated fatigue-life of aircraft. 

Therefore, an increase in mitigation would impede the Navy’s ability to meet testing requirements per 

required acquisition milestones or on an as-needed basis to meet operational requirements. Extending 

the length of the activity would also result in additional operational costs due to increased fuel 

consumption.

In summary, the operational community determined that implementing procedural mitigation for 

explosive torpedoes beyond what is detailed in Table 5.3-8 would be incompatible with the practicality

assessment criteria for safety, sustainability, and mission requirements.

5.3.3.3 Explosive Medium-Caliber and Large-Caliber Projectiles

The Navy will continue to implement procedural mitigation to avoid or reduce potential impacts on 

marine mammals and sea turtles from explosive gunnery activities, as outlined in Table 5.3-9. In addition 

to procedural mitigation, the Navy will implement mitigation for explosive gunnery activities within 

mitigation areas (see Section 5.4.1, Mitigation Areas for Seafloor Resources; Section 5.4.2, Mitigation 

Areas off the Northeastern United States; Section 5.4.3, Mitigation Areas off the Mid-Atlantic and 

Southeastern United States; and Section 5.4.4, Mitigation Areas in the Gulf of Mexico).
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Table 5.3-9: Procedural Mitigation for Explosive Medium-Caliber and Large-Caliber Projectiles

Procedural Mitigation Description

Stressor or Activity

 Gunnery activities using explosive medium-caliber and large-caliber projectiles

 Mitigation applies to activities using a surface target

Resource Protection Focus

 Marine mammals

 Sea turtles

Number of Lookouts and Observation Platform

 1 Lookout on the vessel or aircraft conducting the activity

 For activities using explosive large-caliber projectiles, depending on the activity, the Lookout could be the same as the one 

described in Section 5.3.2.4 (Weapons Firing Noise).

 If additional platforms are participating in the activity, personnel positioned in those assets (e.g., safety observers, evaluators) 

will support observing the mitigation zone for applicable biological resources while performing their regular duties.

Mitigation Requirements

 Mitigation zones:

 200 yd. around the intended impact location for air-to-surface activities using explosive medium-caliber projectiles

 600 yd. around the intended impact location for surface-to-surface activities using explosive medium-caliber projectiles

 1,000 yd. around the intended impact location for surface-to-surface activities using explosive large-caliber projectiles

 Prior to the initial start of the activity (e.g., when maneuvering on station):

 Observe the mitigation zone for floating vegetation; if observed, relocate or delay the start until the mitigation zone is clear.

 Observe the mitigation zone for marine mammals and sea turtles; if observed, relocate or delay the start of firing. 

 During the activity:

 Observe the mitigation zone for marine mammals and sea turtles; if observed, cease firing.

 Commencement/recommencement conditions after a marine mammal or sea turtle sighting before or during the activity:

 The Navy will allow a sighted marine mammal or sea turtle to leave the mitigation zone prior to the initial start of the activity 

(by delaying the start) or during the activity (by not recommencing firing) until one of the following conditions has been met: 

(1) the animal is observed exiting the mitigation zone; (2) the animal is thought to have exited the mitigation zone based on a 

determination of its course, speed, and movement relative to the intended impact location; (3) the mitigation zone has been 

clear from any additional sightings for 10 min. for aircraft-based firing or 30 min. for vessel-based firing; or (4) for activities 

using mobile targets, the intended impact location has transited a distance equal to double that of the mitigation zone size 

beyond the location of the last sighting.

 After completion of the activity (e.g., prior to maneuvering off station):

 When practical (e.g., when platforms are not constrained by fuel restrictions or mission-essential follow-on commitments),

observe the vicinity of where detonations occurred; if any injured or dead marine mammals or ESA-listed species are 

observed, follow established incident reporting procedures.

 If additional platforms are supporting this activity (e.g., providing range clearance), these assets will assist in the visual 

observation of the area where detonations occurred.

In Phase II, explosive gunnery activity mitigation zones were based on net explosive weight and the 

associate average ranges to PTS. When developing Phase III mitigation, the Navy analyzed the potential 

for increasing the size of these mitigation zones. The Navy identified an opportunity to increase the 

mitigation zone size by 400 yd. for surface-to-surface activities to enhance protections to the maximum 

extent practicable. This increase is reflected in Table 5.3-9. The mitigation zones for explosive mediumcaliber and large-caliber projectiles are now based on the largest areas within which it is practical to 

implement mitigation.

The Navy is clarifying that it will require observation of the mitigation zone prior to the initial start of the 

activity to ensure the area is clear of applicable biological resources. The Navy has always verified that 

the mitigation zone is visually clear prior to conducting explosive activities and is more clearly capturing 

this current practice in the mitigation measures for Phase III. The Navy developed a new mitigation 

measure requiring the Lookout to observe the mitigation zone after completion of the activity. The Navy 

currently conducts post-activity observations for some, but not all explosive activities. In developing 
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mitigation for Phase III, the Navy determined that it could expand this requirement to other explosive 

activities for enhanced consistency and to help determine if any resources were injured during explosive 

events, when practical. The Navy is adding a requirement that additional platforms already participating 

in the activity will support observing the mitigation zone before, during, and after the activity while 

performing their regular duties. Typically, when aircraft are firing explosive munitions there are 

additional observation aircraft, multiple aircraft firing munitions, or other safety aircraft in the vicinity. 

When available, having additional personnel support observations of the mitigation zone will help 

increase the likelihood of detecting biological resources. The Navy will follow the incident reporting 

procedures outlined in Section 5.1.2.2.3 (Incident Reports) if an incident is detected at any time during 

the event, including during the post-activity observations.

Large-caliber gunnery activities involve vessels firing projectiles at targets located up to 6 NM down 

range. Medium-caliber gunnery activities involve vessels or aircraft firing projectiles at targets located 

up to 4,000 yd. down range, although typically much closer. As described in Section 5.2.1 (Procedural

Mitigation Development), certain platforms, such as the small boats and aircraft used during explosive 

medium-caliber gunnery exercises, have manning or space restrictions; therefore, the Lookout for these 

activities is typically an existing member of the aircraft or boat crew who is responsible for other 

essential tasks (e.g., navigation). Due to their relatively lower vantage point, Lookouts on vessels (during 

medium-caliber or large-caliber gunnery exercises) will be more likely to detect large visual cues (e.g., 

whale blows or large pods of dolphins) than individual marine mammals, cryptic marine mammal 

species, and sea turtles when observing around targets located at the furthest firing distances. The Navy 

will implement larger mitigation zones for large-caliber gunnery activities than for medium-caliber 

gunnery activities due to the nature of how the activities are conducted. For example, large-caliber 

gunnery activities are conducted from surface combatants, so Lookouts can observe a larger mitigation 

zone because they typically have access to high-powered binoculars mounted on the ship deck. This will 

enable observation of the distant mitigation zone in combination with hand-held binoculars and nakedeye scanning. Lookouts in aircraft (during medium-caliber gunnery exercises), have a relatively higher 

vantage point for observing the mitigation zones but will still be more likely to detect individual marine 

mammals and sea turtles when observing mitigation zones located close to the firing platform than at 

the furthest firing distances. Observing for indicators of marine mammal and sea turtle presence will

further help avoid or reduce potential impacts on these resources within the mitigation zones.

The mitigation applies only to activities using surface targets. Most airborne targets are recoverable 

aerial drones that are not intended to be hit by ordnance. Given the speed of the projectiles and mobile 

target, and the long ranges that projectiles typically travel, it is not possible to definitively predict or to 

effectively observe where the projectile fragments will fall. For gunnery activities using explosive 

medium-caliber and large-caliber projectiles, the potential military expended material fall zone can only 

be predicted within thousands of yards, which can be up to 6 NM from the firing location. These areas 

are too large to be effectively observed for marine mammals and sea turtles with the number of 

personnel and platforms available for this activity. The potential risk to marine mammals and sea turtles 

during events using airborne targets is limited to the animal being directly struck by falling military 

expended materials. There is no potential for direct impact from the explosives because the detonations

occur in air. Based on the extremely low potential for projectile fragments to co-occur in space and time 

with a marine mammal or sea turtle at or near the surface of the water, the potential for a direct strike 

is negligible; therefore, mitigation for gunnery activities using airborne targets would not be effective at 

avoiding or reducing potential impacts. Additional information on military expended materials is 

provided in Appendix F (Military Expended Material and Direct Strike Impact Analysis).
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Bin E5 (e.g., 5-in. projectiles) has the longest predicted impact ranges for explosive projectiles that apply 

to the 1,000-yd. mitigation zone. Bin E2 (e.g., 40-millimeter [mm] projectiles) has the longest predicted 

impact ranges for explosive projectiles that apply to the 600-yd. and 200-yd. mitigation zones. The 

1,000-yd., 600-yd., and 200-yd. mitigation zones extend beyond the respective ranges to 50 percent 

non-auditory injury and 50 percent mortality for sea turtles and marine mammals. The mitigation zones 

extend beyond the respective average ranges to PTS for sea turtles and all marine mammal hearing 

groups except high-frequency cetaceans (the mitigation zones extend into a portion of the respective 

average ranges to PTS for this hearing group). The mitigation zones also extend into a portion of the 

average ranges to TTS for sea turtles and marine mammals. Therefore, depending on the species, 

mitigation will help avoid or reduce all or a portion of the potential for exposure to mortality, nonauditory injury, PTS, and higher levels of TTS for the largest explosives in bin E5 and bin E2. Explosives in 

smaller source bins (e.g., E1) have shorter predicted impact ranges; therefore, the mitigation zones will 

extend further beyond or cover a greater portion of the impact ranges for these explosives.

As described previously, the Phase III mitigation zones are based on the largest areas within which it is 

practical for the Navy to implement mitigation. It is not practical to increase these mitigation zones

because observations within the margin of increase would be unsafe and ineffective. One of the 

mission-essential safety protocols for explosive gunnery activities is a requirement for event participants

(including Lookouts) to maintain focus on the activity area to ensure safety of Navy personnel and 

equipment, and the public. For example, when air-to-surface medium-caliber gunnery exercises involve 

fighter aircraft descending on a target, or rotary-wing aircraft flying a racetrack pattern and descending 

on a target using a forward-tilted firing angle, maintaining attention on the activity area is paramount to 

aircraft safety. The typical activity areas for medium-caliber and large-caliber gunnery activities coincide 

with the applicable mitigation zones developed for Phase III; therefore, Lookouts can safely and 

effectively observe the mitigation zones for biological resources while simultaneously maintaining focus 

on the activity areas. However, if the mitigation zone sizes increased, Lookouts would need to redirect 

their attention to observe beyond the activity area. This would not meet the safety criteria since 

personnel would be required to direct attention away from mission requirements. Alternatively, the 

Navy would need to add personnel to serve as additional Lookouts on the existing observation platforms

or allocate additional platforms to the activity to observe for biological resources. These actions would 

not be safe or sustainable due to an exceedance of manpower, resource, and space restrictions for 

these activities. Similarly, positioning platforms closer to the intended impact location would increase 

safety risks related to proximity to the detonation location and path of the explosive projectile.

Increasing the mitigation zone sizes would result in larger areas over which detonations would need to 

be ceased in response to a sighting, and therefore would likely increase the number of times firing

would be ceased and would extend the length of the activity. These impacts would significantly diminish 

event realism in a way that would prevent activities from meeting their intended objectives. For 

example, the Navy must train its gun crews to coordinate with other participating platforms (e.g., small 

boats launching a target, other firing platforms), locate and engage surface targets (e.g., high speed 

maneuverable surface targets), and practice precise defensive marksmanship to disable threats. The 

Navy must test the functionality of its guns in advance of delivery to the fleet for operational use.

Depending on the type of target being used, additional stopping of the activity could result in the target 

needing to be recovered and relaunched, which would cause a significant loss of training or testing time. 

For activities that involve aircraft, extending the length of the activity would require aircraft to depart 

the area to refuel. If multiple refueling events were required, the length of the activity would be 
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extended by two to five times or more, which would decrease the ability for Lookouts to safely and 

effectively maintain situational awareness of the activity area and increase safety risks due to increased 

pilot fatigue and accelerated fatigue-life of aircraft. These types of impacts would reduce the number of 

opportunities that gun crews have to fire on the target and cause significant delays to the training or 

testing schedule. Therefore, an increase in mitigation would impede the ability for gun crews to train 

and become proficient in using their weapons as required during military missions and combat

operations, would prevent units from meeting their individual training and certification requirements

(which would prevent them from deploying with the required level of readiness necessary to accomplish 

their missions), and would impede the ability of program managers and weapons system acquisition 

programs to meet testing requirements per required acquisition milestones or on an as-needed basis to 

meet operational requirements. Extending the length of the activity would also result in additional 

operational costs due to increased fuel consumption.

In summary, the operational community determined that implementing procedural mitigation for 

explosive medium-caliber and large-caliber projectiles beyond what is detailed in Table 5.3-9 would be 

incompatible with the practicality assessment criteria for safety, sustainability, and mission

requirements.

5.3.3.4 Explosive Missiles and Rockets

The Navy will continue to implement procedural mitigation to avoid or reduce potential impacts on

marine mammals and sea turtles from explosive missiles and rockets, as outlined in Table 5.3-10. In 

addition to procedural mitigation, the Navy will implement mitigation for explosive missiles and rockets 

within mitigation areas (see Section 5.4.1, Mitigation Areas for Seafloor Resources; Section 5.4.2, 

Mitigation Areas off the Northeastern United States; Section 5.4.3, Mitigation Areas off the Mid-Atlantic 

and Southeastern United States, and Section 5.4.4, Mitigation Areas in the Gulf of Mexico).

In Phase II, explosive missile and rocket mitigation zones were based on net explosive weight and the 

associate average ranges to PTS. When developing Phase III mitigation, the Navy analyzed the potential 

for increasing the mitigation zone sizes. The Navy identified an opportunity to increase the mitigation 

zone by 1,100 yd. for missiles and rockets using 21–250 lb. net explosive weight to enhance protections 

to the maximum extent practicable. This increase is reflected in Table 5.3-10. The mitigation zones are

now based on the largest areas within which it is practical to implement mitigation.

The Navy is clarifying that it will require observation of the mitigation zone prior to the initial start of the 

activity to ensure the area is clear of applicable biological resources. The Navy has always verified that 

the mitigation zone is visually clear prior to conducting explosive activities and is more clearly capturing 

this current practice in the mitigation measures for Phase III. The Navy developed a new mitigation 

measure requiring the Lookout to observe the mitigation zone after completion of the activity. The Navy 

currently conducts post-activity observations for some, but not all explosive activities. In developing 

mitigation for Phase III, the Navy determined that it could expand this requirement to other explosive 

activities for enhanced consistency and to help determine if any resources were injured during explosive 

events, when practical. The Navy is adding a requirement that additional platforms already participating 

in the activity will support observing the mitigation zone before, during, and after the activity while 

performing their regular duties. Typically, when aircraft are firing explosive munitions there are 

additional observation aircraft, multiple aircraft firing munitions, or other safety aircraft in the vicinity. 

For example, during typical explosive missile exercises, two aircraft circle the activity location, one 

aircraft clears the intended impact location while the other fires, and vice versa. A third aircraft is 
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typically present for safety or proficiency inspections. When available, having additional personnel 

support observations of the mitigation zone will help increase the likelihood of detecting biological 

resources. The Navy will follow the incident reporting procedures outlined in Section 5.1.2.2.3 (Incident 

Reports) if an incident is detected at any time during the event, including during the post-activity 

observations.

Table 5.3-10: Procedural Mitigation for Explosive Missiles and Rockets

Procedural Mitigation Description

Stressor or Activity

 Aircraft-deployed explosive missiles and rockets

 Mitigation applies to activities using a surface target

Resource Protection Focus

 Marine mammals

 Sea turtles

Number of Lookouts and Observation Platform

 1 Lookout positioned in an aircraft

 If additional platforms are participating in the activity, personnel positioned in those assets (e.g., safety observers, evaluators) 

will support observing the mitigation zone for applicable biological resources while performing their regular duties.

Mitigation Requirements

 Mitigation zones:

 900 yd. around the intended impact location for missiles or rockets with 0.6–20 lb. net explosive weight

 2,000 yd. around the intended impact location for missiles with 21–500 lb. net explosive weight

 Prior to the initial start of the activity (e.g., during a fly-over of the mitigation zone):

 Observe the mitigation zone for floating vegetation; if observed, relocate or delay the start until the mitigation zone is clear.

 Observe the mitigation zone for marine mammals and sea turtles; if observed, relocate or delay the start of firing. 

 During the activity:

 Observe the mitigation zone for marine mammals and sea turtles; if observed, cease firing.

 Commencement/recommencement conditions after a marine mammal or sea turtle sighting before or during the activity:

 The Navy will allow a sighted marine mammal or sea turtle to leave the mitigation zone prior to the initial start of the activity 

(by delaying the start) or during the activity (by not recommencing firing) until one of the following conditions has been met: 

(1) the animal is observed exiting the mitigation zone; (2) the animal is thought to have exited the mitigation zone based on a 

determination of its course, speed, and movement relative to the intended impact location; or (3) the mitigation zone has 

been clear from any additional sightings for 10 min. when the activity involves aircraft that have fuel constraints, or 30 min. 

when the activity involves aircraft that are not typically fuel constrained.

 After completion of the activity (e.g., prior to maneuvering off station):

 When practical (e.g., when platforms are not constrained by fuel restrictions or mission-essential follow-on commitments),

observe the vicinity of where detonations occurred; if any injured or dead marine mammals or ESA-listed species are 

observed, follow established incident reporting procedures.

 If additional platforms are supporting this activity (e.g., providing range clearance), these assets will assist in the visual 

observation of the area where detonations occurred.

Missile and rocket exercises involve firing munitions at a target typically located up to 15 NM down 

range, and infrequently up to 75 NM down range. Due to the distance between the mitigation zone and 

the observation platform, Lookouts will have a better likelihood of detecting marine mammals and sea 

turtles during close-range observations and are less likely to detect these resources once positioned at 

the firing location, particularly individual marine mammals, cryptic marine mammal species, and sea 

turtles. There is a chance that animals could enter the mitigation zone after the aircraft conducts its 

close-range mitigation zone observations and before firing begins (once the aircraft has transited to its 

firing position). Observing for indicators of marine mammal and sea turtle presence will further help 

avoid or reduce potential impacts on these resources within the mitigation zones.

The Navy will implement larger mitigation zones for missiles using 21–500 lb. net explosive weight than 

for missiles and rockets using 0.6–20 lb. net explosive weight due to the nature of how these activities 
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are conducted. During activities using missiles in the larger net explosive weight category, the firing 

aircraft (e.g., maritime patrol aircraft) have the capability of mitigating a larger area due to their larger 

fuel capacity. During activities using missiles or rockets in the smaller net explosive weight category, the 

firing aircraft (e.g., rotary-wing aircraft) are typically constrained by their fuel capacity.

The mitigation applies to aircraft-deployed missiles and rockets because aircraft can fly over the 

intended impact area prior to commencing firing. Mitigation would be ineffective for vessel-deployed

missiles and rockets because of the inability for a Lookout to detect marine mammals or sea turtles from 

a vessel from the distant firing position. It would not be effective or practical to have a vessel conduct 

close-range observations of the mitigation zone prior to firing due to the length of time it would take to 

complete observations and transit back to the firing position, and the costs associated with increased 

fuel consumption. 

The mitigation applies to activities using surface targets. Most airborne targets are recoverable aerial 

drones that are not intended to be hit by ordnance. For example, telemetry-configured anti-air missiles 

used in training are designed to detonate or simulate a detonation near a target, but not as a result of a 

direct strike on a target. Given the speed of missiles and mobile targets, the high altitudes involved, and 

the long ranges that missiles typically travel, it is not possible to definitively predict or to effectively 

observe where the missile fragments will fall. The potential expended material fall zone can only be 

predicted within tens of miles for long range events, which can be 75 NM from the firing location; and 

thousands of yards for short range events, which can occur 15 NM from the firing location. These areas 

are too large to be effectively observed for marine mammals and sea turtles with the number of 

personnel and platforms available for this activity. The potential risk to marine mammals and sea turtles 

during events using airborne targets is limited to the animal being directly struck by falling military 

expended materials. There is no potential for direct impact from the explosives because the detonations

occur in air. Based on the extremely low potential for military expended materials to co-occur in space 

and time with a marine mammal or sea turtle at or near the surface of the water, the potential for a 

direct strike is negligible; therefore, mitigation would not be effective at avoiding or reducing impacts. 

Additional information on military expended materials is provided in Appendix F (Military Expended 

Material and Direct Strike Impact Analysis).

Bin E10 (e.g., Harpoon missiles) has the longest predicted impact ranges for explosive missiles that apply 

to the 2,000-yd. mitigation zone. Bin E6 (e.g., Hellfire missiles) has the longest predicted impact ranges

for explosive missiles and rockets that apply to the 900-yd. mitigation zone. The 2,000-yd. and 900-yd. 

mitigation zones extend beyond the respective ranges to 50 percent non-auditory injury and 50 percent 

mortality for sea turtles and marine mammals. The mitigation zones extend beyond the respective 

average ranges to PTS for sea turtles and all marine mammal hearing groups except high-frequency 

cetaceans (the mitigation zones extend into a portion of the respective average ranges to PTS for this 

hearing group). The mitigation zones also extend into a portion of the average ranges to TTS for sea 

turtles and marine mammals. Therefore, depending on the species, mitigation will help avoid or reduce 

all or a portion of the potential for exposure to mortality, non-auditory injury, PTS, and higher levels of 

TTS for the largest explosives in bin E10 and bin E6. Explosives in smaller source bins (e.g., missiles in bin 

E9, rockets in bin E3) have shorter predicted impact ranges; therefore, the mitigation zones will cover a 

greater portion of the impact ranges for these explosives.

As described previously, the Phase III mitigation zones are based on the largest areas within which it is 

practical for the Navy to implement mitigation. It is not practical to increase these mitigation zones

because observations within the margin of increase would be unsafe and ineffective unless the Navy 
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allocated additional platforms to the activity to observe for biological resources. The use of additional 

personnel and equipment (e.g., aircraft) would be unsustainable due to increased operational costs and 

an exceedance of the available manpower and resources for this activity. Adding aircraft to observe the 

mitigation zone could result in airspace conflicts with the event participants. This would either require 

the aircraft conducting the activity to modify their flights plans (which would reduce activity realism) or 

force the observing aircraft to position itself a safe distance away from the activity area (which would 

decrease observation effectiveness). Similarly, positioning platforms closer to the intended impact 

location (as would be required if mitigation applied to vessel-deployed missiles and rockets) would 

increase safety risks related to proximity to the detonation location and path of the explosive missile or 

rocket.

Increasing the mitigation zone sizes would result in larger areas over which firing would need to be 

ceased in response to a sighting, and therefore would likely increase the number of times detonations 

would be ceased and would extend the length of the activity. These impacts would significantly diminish 

event realism in a way that would prevent the activity from meeting its intended objectives. Explosive 

missile and rocket events require focused situational awareness of the activity area and continuous 

coordination between the participating platforms as required during military missions and combat 

operations. For activities using missiles in the larger net explosive weight category, the flyover distance 

between the mitigation zone and the firing location can extend upwards of 75 NM; therefore, even 

aircraft with larger fuel capacities would need to depart the activity area to refuel if the length of the 

activity was extended. If the firing aircraft departed the activity location to refuel, the aircrew would 

lose the ability to maintain situational awareness of the activity area and effectively coordinate with 

other participating platforms. If multiple refueling events were required, the activity length would 

extend by two to five times or more, which would increase safety risks due to increased pilot fatigue and 

accelerated fatigue-life of aircraft. These types of impacts would cause a significant loss of training or

testing time, reduce the number of opportunities that aircrews have to fire on the target, and cause a 

significant delay to the training or testing schedule. Therefore, an increase in mitigation would impede 

the ability for aircrews to train and become proficient in using their weapons as required during military 

missions and combat operations, would prevent units from meeting their individual training and 

certification requirements (which would prevent them from deploying with the required level of 

readiness necessary to accomplish their missions), and would impede the ability of program managers 

and weapons system acquisition programs to meet testing requirements per required acquisition 

milestones or on an as-needed basis to meet operational requirements. Extending the length of the 

activity would also result in additional operational costs due to increased fuel consumption.

In summary, the operational community determined that implementing procedural mitigation for 

explosive missiles and rockets beyond what is detailed in Table 5.3-10 would be incompatible with the 

practicality assessment criteria for safety, sustainability, and mission requirements.

5.3.3.5 Explosive Bombs

The Navy will continue to implement procedural mitigation to avoid or reduce potential impacts on 

marine mammals and sea turtles from explosive bombs, as outlined in Table 5.3-11. In addition to 

procedural mitigation, the Navy will implement mitigation for explosive bombs within mitigation areas 

(see Section 5.4.1, Mitigation Areas for Seafloor Resources; Section 5.4.2, Mitigation Areas off the 

Northeastern United States; Section 5.4.3, Mitigation Areas off the Mid-Atlantic and Southeastern 

United States; and Section 5.4.4, Mitigation Areas in the Gulf of Mexico).
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Table 5.3-11: Procedural Mitigation for Explosive Bombs

Procedural Mitigation Description

Stressor or Activity

 Explosive bombs

Resource Protection Focus

 Marine mammals

 Sea turtles 

Number of Lookouts and Observation Platform

 1 Lookout positioned in the aircraft conducting the activity

 If additional platforms are participating in the activity, personnel positioned in those assets (e.g., safety observers, evaluators) 

will support observing the mitigation zone for applicable biological resources while performing their regular duties.

Mitigation Requirements

 Mitigation zone:

 2,500 yd. around the intended target

 Prior to the initial start of the activity (e.g., when arriving on station):

 Observe the mitigation zone for floating vegetation; if observed, relocate or delay the start until the mitigation zone is clear.

 Observe the mitigation zone for marine mammals and sea turtles; if observed, relocate or delay the start of bomb 

deployment. 

 During the activity (e.g., during target approach):

 Observe the mitigation zone for marine mammals and sea turtles; if observed, cease bomb deployment.

 Commencement/recommencement conditions after a marine mammal or sea turtle sighting before or during the activity:

 The Navy will allow a sighted marine mammal or sea turtle to leave the mitigation zone prior to the initial start of the activity 

(by delaying the start) or during the activity (by not recommencing bomb deployment) until one of the following conditions 

has been met: (1) the animal is observed exiting the mitigation zone; (2) the animal is thought to have exited the mitigation

zone based on a determination of its course, speed, and movement relative to the intended target; (3) the mitigation zone 

has been clear from any additional sightings for 10 min.; or (4) for activities using mobile targets, the intended target has

transited a distance equal to double that of the mitigation zone size beyond the location of the last sighting.

 After completion of the activity (e.g., prior to maneuvering off station):

 When practical (e.g., when platforms are not constrained by fuel restrictions or mission-essential follow-on commitments),

observe the vicinity of where detonations occurred; if any injured or dead marine mammals or ESA-listed species are 

observed, follow established incident reporting procedures.

 If additional platforms are supporting this activity (e.g., providing range clearance), these assets will assist in the visual 

observation of the area where detonations occurred.

In Phase II, the explosive bombing mitigation zone was based on net explosive weight and the associated 

average ranges to PTS. When developing Phase III mitigation, the Navy analyzed the potential for 

increasing the size of this mitigation zone. The Navy determined that the current mitigation zone for 

explosive bombs is the largest area within which it is practical to implement mitigation for this activity; 

therefore, it will continue implementing this same mitigation zone for Phase III.

The Navy is clarifying that it will require observation of the mitigation zone prior to the initial start of the 

activity to ensure the area is clear of applicable biological resources. The Navy has always verified that 

the mitigation zone is visually clear prior to conducting explosive activities and is more clearly capturing 

this current practice in the mitigation measures for Phase III. The Navy developed a new mitigation 

measure requiring the Lookout to observe the mitigation zone after completion of this activity. The Navy 

currently conducts post-activity observations for some, but not all explosive activities. In developing 

mitigation for Phase III, the Navy determined that it could expand this requirement to other explosive 

activities for enhanced consistency and to help determine if any resources were injured during explosive 

events, when practical. The Navy is adding a requirement that additional platforms already participating 

in the activity will support observing the mitigation zone before, during, and after the activity while 

performing their regular duties. Typically, when aircraft are firing explosive munitions there are 

additional observation aircraft, multiple aircraft firing munitions, or other safety aircraft in the vicinity. 

When available, having additional personnel support observations of the mitigation zone will help 
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increase the likelihood of detecting biological resources. The Navy will follow the incident reporting 

procedures outlined in Section 5.1.2.2.3 (Incident Reports) if an incident is detected at any time during 

the event, including during the post-activity observations.

Bombing exercises involve an aircraft deploying munitions at a surface target located beneath the firing 

platform. During target approach, aircraft maintain a relatively steady altitude of approximately 1,500 ft.

Lookouts, by necessity for safety and mission success, primarily focus their attention on the water 

surface surrounding the intended detonation location (i.e., the mitigation zone). Being positioned in an 

aircraft gives the Lookout a good vantage point for observing marine mammals and sea turtles 

throughout the mitigation zone. Observing for indicators of marine mammal and sea turtle presence will 

further help avoid or reduce potential impacts on these resources within the mitigation zone.

Bin E12 (e.g., 2,000-lb. bombs) has the longest predicted impact ranges for explosive bombs used in the 

Study Area. The 2,500-yd. mitigation zone extends beyond the ranges to 50 percent non-auditory injury 

and 50 percent mortality for sea turtles and marine mammals. The mitigation zone extends beyond the 

average ranges to PTS for sea turtles and all marine mammal hearing groups except high-frequency 

cetaceans (the mitigation zones extend into a portion of the respective average ranges to PTS for this

hearing group). The mitigation zone also extends into a portion of the average ranges to TTS for sea 

turtles and marine mammals. Therefore, depending on the species, mitigation will help avoid or reduce 

all or a portion of the potential for exposure to mortality, non-auditory injury, PTS, and higher levels of 

TTS for the largest bombs in bin E12. Smaller bombs (e.g., 250-lb. bombs, 500-lb. bombs) have shorter 

predicted impact ranges; therefore, the mitigation zone will extend further beyond or cover a greater 

portion of the impact ranges for these explosives.

As described previously, the Phase III mitigation zone is based on the largest area within which it is 

practical for the Navy to implement mitigation. It is not practical to increase this mitigation zone 

because observations within the margin of increase would be unsafe and ineffective unless the Navy 

allocated additional platforms to the activity to observe for biological resources. The use of additional 

personnel and aircraft would be unsustainable due to increased operational costs and an exceedance of 

the available manpower and resources for this activity. Adding aircraft to observe the mitigation zone 

could result in airspace conflicts with the event participants. This would either require the aircraft 

participating in the activity to modify their flights plans (which would reduce activity realism) or force 

the observing aircraft to position itself a safe distance away from the activity area (which would 

decrease observation effectiveness). Adding vessels to observe the mitigation zone would increase 

safety risks due to the presence of observation vessels within the vicinity of the intended explosive 

bomb detonation location.

Increasing the mitigation zone would result in a larger area over which explosive bomb deployment 

would need to be ceased in response to a sighting, and therefore would likely increase the number of 

times explosive bombing activities would be ceased and would extend the length of the activity. These 

impacts would significantly diminish event realism in a way that would prevent the activity from meeting 

its intended objectives. For example, critical components of a Bombing Exercise Air-to-Surface training

activity are the assembly, loading, delivery, and assessment of an explosive bomb. The activity requires 

focused situational awareness of the activity area and continuous coordination between multiple 

training components. The training exercise starts with ground personnel, who must practice the building 

and loading of explosive munitions. Training includes the safe handling of explosive material, configuring 

munitions to precise specifications, and loading munitions onto aircraft. Aircrew must then identify a 

target and safely deliver fused munitions, discern if the bomb was assembled correctly, and determine
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bomb damage assessments based on how and where the explosive detonated. Extending the length of 

the activity would require aircraft to depart the area to refuel. If the firing aircraft departed the activity 

area to refuel, aircrew would lose the ability to maintain situational awareness of the activity area, 

effectively coordinate with other participating platforms, and complete all training components as 

required during military missions and combat operations. If multiple refueling events were required, the 

activity length would be extended by two to five times or more, which would cause a significant loss of 

training or testing time and would increase safety risks due to increased pilot fatigue and accelerated 

fatigue-life of aircraft. This which would reduce the number of opportunities that aircrews have to 

approach targets and deploy bombs and reduce the Navy’s ability to evaluate the bomb, the bomb carry 

and delivery system, and any associated systems that may have been newly developed or enhanced, 

which would cause a significant delay to the training or testing schedule. Therefore, an increase in 

mitigation would impede the ability for aircrews to train and become proficient in using their weapons, 

would prevent units from meeting their individual training and certification requirements (which would 

prevent them from deploying with the required level of readiness necessary to accomplish their 

missions), and would impede the ability of program managers and weapons system acquisition 

programs to meet testing requirements per required acquisition milestones or on an as-needed basis to 

meet operational requirements. Extending the length of the activity would also result in additional 

operational costs due to increased fuel consumption.

In summary, the operational community determined that implementing procedural mitigation for 

explosive bombs beyond what is detailed in Table 5.3-11 would be incompatible with the practicality

assessment criteria for safety, sustainability, and mission requirements.

5.3.3.6 Sinking Exercises

The Navy will continue to implement procedural mitigation to avoid or reduce potential impacts on 

marine mammals and sea turtles during sinking exercises, as outlined in Table 5.3-12. In Phase II, the 

mitigation zone was based on net explosive weight and the associated average ranges to PTS. When 

developing Phase III mitigation, the Navy analyzed the potential for increasing the size of the mitigation 

zone. The Navy determined that the current mitigation zone for sinking exercises is the largest area 

within which it is practical to implement mitigation; therefore, it will continue implementing this same 

mitigation zone for Phase III.

The Navy is clarifying that it will require observation of the mitigation zone prior to the initial start of the 

activity to ensure the area is clear of applicable biological resources. The Navy has always verified that 

the mitigation zone is visually clear prior to conducting explosive activities and is more clearly capturing 

this current practice in the mitigation measures for Phase III. The Navy is adding a requirement that 

additional platforms already participating in the activity will support observing the mitigation zone 

before, during, and after the activity while performing their regular duties. Sinking exercises typically 

involved multiple participating platforms. When available, having additional personnel support 

observations of the mitigation zone will help increase the likelihood of detecting biological resources.

The 2-hour post-activity observations for sinking exercises are a continuation from Phase II and will help 

the Navy determine if any resources were injured during the activity. Sinking exercises are scheduled to 

ensure they are conducted only in daylight hours. The Navy will be able to complete the full 2-hours of

post-activity observation during typical activity conditions and it is unlikely that observations will be 

shortened due to nightfall. The Navy will follow the incident reporting procedures outlined in Section 

5.1.2.2.3 (Incident Reports) if an incident is detected at any time during the event, including during the 

post-activity observations.
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Table 5.3-12: Procedural Mitigation for Sinking Exercises

Procedural Mitigation Description

Stressor or Activity

 Sinking exercises

Resource Protection Focus

 Marine mammals

 Sea turtles 

Number of Lookouts and Observation Platform

 2 Lookouts (one positioned in an aircraft and one on a vessel)

 If additional platforms are participating in the activity, personnel positioned in those assets (e.g., safety observers, evaluators) 

will support observing the mitigation zone for applicable biological resources while performing their regular duties.

Mitigation Requirements

 Mitigation zone:

 2.5 NM around the target ship hulk

 Prior to the initial start of the activity (90 min. prior to the first firing):

 Conduct aerial observations of the mitigation zone for floating vegetation; delay the start until the mitigation zone is clear. 

 Conduct aerial observations of the mitigation zone for marine mammals, sea turtles, and jellyfish aggregations; if observed, 

delay the start of firing.

 During the activity:

 Conduct passive acoustic monitoring for marine mammals; use information from detections to assist visual observations.

 Visually observe the mitigation zone for marine mammals and sea turtles from the vessel; if observed, cease firing.

 Immediately after any planned or unplanned breaks in weapons firing of longer than 2 hours, observe the mitigation zone for 

marine mammals and sea turtles from the aircraft and vessel; if observed, delay recommencement of firing.

 Commencement/recommencement conditions after a marine mammal or sea turtle sighting before or during the activity:

 The Navy will allow a sighted marine mammal or sea turtle to leave the mitigation zone prior to the initial start of the activity 

(by delaying the start) or during the activity (by not recommencing firing) until one of the following conditions has been met: 

(1) the animal is observed exiting the mitigation zone; (2) the animal is thought to have exited the mitigation zone based on a 

determination of its course, speed, and movement relative to the target ship hulk; or (3) the mitigation zone has been clear 

from any additional sightings for 30 min.

 After completion of the activity (for 2 hours after sinking the vessel or until sunset, whichever comes first):

 Observe the vicinity of where detonations occurred; if any injured or dead marine mammals or ESA-listed species are 

observed, follow established incident reporting procedures.

 If additional platforms are supporting this activity (e.g., providing range clearance), these assets will assist in the visual 

observation of the area where detonations occurred.

There is a chance that animals could enter the mitigation zone after the aircraft conducts its close-range 

mitigation zone observations and before firing begins (once the aircraft has transited to its distant firing 

position). The Lookout positioned on the vessel will have a higher likelihood of detecting individual 

marine mammals and sea turtles that are in the central portion of the mitigation zone near the target 

ship hulk. Near the perimeter of the mitigation zone, the Lookout will be more likely to detect large 

visual cues (e.g., whale blows or large pods of dolphins) than individual marine mammals, cryptic marine 

mammal species, and sea turtles. The Lookout positioned in the aircraft will be able to assist the vesselbased Lookout by observing the entire mitigation zone, including near the perimeter, because the 

aircraft will be able to transit a larger area more quickly (e.g., during range clearance), and will offer a 

better vantage point. As described in Chapter 3.8 (Reptiles), some species of sea turtles forage on 

jellyfish in the region where this activity occurs. Observing for indicators of marine mammal and sea 

turtle presence will further help avoid or reduce potential impacts on these resources within the 

mitigation zone. 

Bin E11 has the longest predicted impact ranges for the types of explosives used during sinking exercises

in the Study Area. For the largest explosive in bin E11, the mitigation zone extends beyond the ranges to 

50 percent non-auditory injury and 50 percent mortality for sea turtles and marine mammals. The 

mitigation zone extends beyond the average ranges to PTS for sea turtles and all marine mammal 
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hearing groups except high-frequency cetaceans (the mitigation zone extends into a portion of the 

average range to PTS for this hearing group). The mitigation zone also extends beyond or into a portion 

of the average ranges to TTS for sea turtles and marine mammals. Therefore, depending on the species, 

mitigation will help avoid or reduce all or a portion of the potential for exposure to mortality, nonauditory injury, PTS, and higher levels of TTS for the largest explosives in bin E11. Smaller explosives in 

bin E11 and explosives in smaller source bins (e.g., E5, E10) have shorter predicted impact ranges; 

therefore, the mitigation zone will extend further beyond or cover a greater portion of the impact 

ranges for these explosives.

As described previously, the Phase III mitigation zone is based on the largest area within which it is 

practical for the Navy to implement mitigation. It is not practical to increase this mitigation zone 

because observations within the margin of increase would be ineffective unless the Navy allocated 

additional platforms to the activity to observe for biological resources. The use of additional personnel, 

aircraft, or vessels would be unsustainable due to increased operational costs and an exceedance of 

available manpower and resources for this activity. Adding aircraft to observe the mitigation zone could 

result in airspace conflicts with the event participants. This would either require the aircraft 

participating in the activity to modify their flights plans (which would reduce activity realism) or force 

the observing aircraft to position itself a safe distance away from the activity area (which would 

decrease observation effectiveness). Adding additional platforms to observe the mitigation zone would 

increase safety risks due to the presence of additional vessels or aircraft within the vicinity of the 

intended impact location or in the path of explosive projectiles.

Increasing the mitigation zone size would result in a larger area over which firing would need to be 

ceased in response to a sighting, and therefore would likely increase the number of times that the 

sinking exercise would be ceased and would extend the length of the activity. These impacts would 

significantly diminish event realism in a way that would prevent the activity from meeting its intended 

objectives. Sinking exercises require focused situational awareness of the activity area and continuous

coordination of tactics between ship, submarine, and aircraft crews using multiple weapon systems to 

deliver explosive ordnance to deliberately sink a deactivated vessel. Extending the length of the activity 

would require aircraft to depart the area to refuel, which would disrupt the ability for platforms to 

maintain continuous coordination of tactics. If multiple refueling events were required, the length of the 

activity would be extended by two to five times or more, which would decrease the ability for Lookouts 

to safely and effectively maintain situational awareness of the activity area and increase safety risks due 

to increased pilot fatigue and accelerated fatigue-life of aircraft. These types of impacts would reduce 

the frequency at which participants would be able to fire on the deactivated vessel. Because the activity 

ends when the ship sinks, firing at a decreased frequency would ultimately extend the amount of time it 

takes for the deactivated vessel to sink. Sinking exercises only take place during daylight hours; 

therefore, the training exercise would likely be delayed into the next day or next several days, which 

would significantly impact the schedules of the multiple participants. An increase in mitigation would 

impede the ability for the participants to become proficient in using their weapons as required during 

military missions and combat operations and would prevent units from meeting their individual training 

and certification requirements (which would prevent them from deploying with the required level of 

readiness necessary to accomplish their missions). Extending the length of the activity would also result 

in additional operational costs due to increased fuel consumption.
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In summary, the operational community determined that implementing procedural mitigation for 

sinking exercises beyond what is detailed in Table 5.3-12 would be incompatible with the practicality

assessment criteria for safety, sustainability, and mission requirements.

5.3.3.7 Explosive Mine Countermeasure and Neutralization Activities

The Navy will continue to implement procedural mitigation to avoid or reduce potential impacts on 

marine mammals and sea turtles from explosive mine countermeasure and neutralization activities, as 

outlined in Table 5.3-13. The mitigation applies to explosive mine countermeasure and neutralization 

activities except those that involve the use of Navy divers, which are discussed in Section 5.3.3.8

(Explosive Mine Neutralization Activities Involving Navy Divers). In addition to procedural mitigation, the 

Navy will implement mitigation for explosive mine countermeasure and neutralization activities within 

mitigation areas (see Section 5.4.1, Mitigation Areas for Seafloor Resources; Section 5.4.2, Mitigation 

Areas off the Northeastern United States; and Section 5.4.3, Mitigation Areas off the Mid-Atlantic and 

Southeastern United States).

The types of charges used in these activities are positively controlled, which means the detonation is 

controlled by the personnel conducting the activity and is not authorized until the mitigation zone is 

clear at the time of detonation. In Phase II, explosive mine countermeasure and neutralization activity

mitigation zones were based on net explosive weight and the associated average ranges to PTS. When 

developing Phase III mitigation, the Navy analyzed the potential for increasing the size of the mitigation 

zones. The Navy identified an opportunity to increase the mitigation zone sizes for bins E5 through E10 

to enhance protections to the maximum extent practicable. This increase is reflected in Table 5.3-13. 

The mitigation zones for explosive mine countermeasure and neutralization activities are now based on 

the largest areas within which it is practical to implement mitigation. The post-activity observations are 

a continuation from Phase II and will help the Navy determine if any resources were injured during the 

activity. The Navy will follow the incident reporting procedures outlined in Section 5.1.2.2.3 (Incident 

Reports) if an incident is detected at any time during the event, including during the post-activity 

observations.

The Navy is clarifying that it will require observation of the mitigation zone prior to the initial start of 

the activity to ensure the area is clear of applicable biological resources. The Navy has always verified 

that the mitigation zone is visually clear prior to conducting explosive activities and is more clearly 

capturing this current practice in the mitigation measures for Phase III. The Navy is adding a 

requirement that additional platforms already participating in the activity will support observing the 

mitigation zone before, during, and after the activity while performing their regular duties. When 

available, having additional personnel support observations of the mitigation zone will help increase the 

likelihood of detecting biological resources.

For the 600-yd. mitigation zone, the small observation area and proximity to the observation platform 

will result in a high likelihood that the Lookout will be able to detect marine mammals and sea turtles

throughout the mitigation zone (regardless of the type of observation platform used). For the 2,100-yd. 

mitigation zone, the Lookout on a small boat will be more likely to detect large visual cues (e.g., whale 

blows or large pods of dolphins) or splashes of individual marine mammals than cryptic marine mammal 

species and sea turtles near the mitigation zone perimeter, while the Lookout positioned in an aircraft 

will help increase the chance that marine mammals and sea turtles will be detected throughout the 

mitigation zone. Observing for indicators of marine mammal and sea turtle presence will further help 

avoid or reduce potential impacts on these resources within the mitigation zones.
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Table 5.3-13: Procedural Mitigation for Explosive Mine Countermeasure and Neutralization 

Activities

Procedural Mitigation Description

Stressor or Activity

 Explosive mine countermeasure and neutralization activities

Resource Protection Focus

 Marine mammals

 Sea turtles 

Number of Lookouts and Observation Platform

 1 Lookout positioned on a vessel or in an aircraft when implementing the smaller mitigation zone

 2 Lookouts (one positioned in an aircraft and one on a small boat) when implementing the larger mitigation zone

 If additional platforms are participating in the activity, personnel positioned in those assets (e.g., safety observers, evaluators) 

will support observing the mitigation zone for applicable biological resources while performing their regular duties.

Mitigation Requirements

 Mitigation zones:

 600 yd. around the detonation site for activities using 0.1–5-lb. net explosive weight

 2,100 yd. around the detonation site for activities using 6–650 lb. net explosive weight (including high explosive target mines)

 Prior to the initial start of the activity (e.g., when maneuvering on station; typically, 10 min. when the activity involves aircraft 

that have fuel constraints, or 30 min. when the activity involves aircraft that are not typically fuel constrained):

 Observe the mitigation zone for floating vegetation; if observed, relocate or delay the start until the mitigation zone is clear.

 Observe the mitigation zone for marine mammals and sea turtles; if observed, relocate or delay the start of detonations.

 During the activity:

 Observe the mitigation zone for marine mammals and sea turtles; if observed, cease detonations.

 Commencement/recommencement conditions after a marine mammal or sea turtle sighting before or during the activity:

 The Navy will allow a sighted marine mammal or sea turtle to leave the mitigation zone prior to the initial start of the activity 

(by delaying the start) or during the activity (by not recommencing detonations) until one of the following conditions has 

been met: (1) the animal is observed exiting the mitigation zone; (2) the animal is thought to have exited the mitigation zone 

based on a determination of its course, speed, and movement relative to detonation site; or (3) the mitigation zone has been 

clear from any additional sightings for 10 min. when the activity involves aircraft that have fuel constraints, or 30 min. when 

the activity involves aircraft that are not typically fuel constrained.

 After completion of the activity (typically 10 min. when the activity involves aircraft that have fuel constraints, or 30 min. when 

the activity involves aircraft that are not typically fuel constrained):

 Observe the vicinity of where detonations occurred; if any injured or dead marine mammals or ESA-listed species are 

observed, follow established incident reporting procedures.

 If additional platforms are supporting this activity (e.g., providing range clearance), these assets will assist in the visual 

observation of the area where detonations occurred.

Bin E11 (e.g., 650-lb. high explosive target mines) has the longest predicted impact ranges for explosives 

that apply to the 2,100-yd. mitigation zone. Bin E4 (e.g., 5-lb. net explosive weight charges) has the 

longest predicted impact ranges for explosives that apply to the 600-yd. mitigation zone. The 2,100-yd. 

and 600-yd. mitigation zones extend beyond the respective ranges to 50 percent non-auditory injury 

and 50 percent mortality for sea turtles and marine mammals. The mitigation zones extend beyond the 

respective average ranges to PTS for sea turtles, mid-frequency cetaceans, and sirenians, and into a 

portion of the average ranges to PTS for high-frequency cetaceans, low-frequency cetaceans, and 

phocids. The mitigation zones also extend into a portion of the average ranges to TTS for sea turtles and 

marine mammals. Therefore, depending on the species, mitigation will help avoid or reduce all or a 

portion of the potential for exposure to mortality, non-auditory injury, PTS, and higher levels of TTS for 

the largest explosives in bin E11 and bin E4. Smaller explosives within bin E11 and bin E4 and explosives 

in smaller source bins (e.g., E2) have shorter predicted impact ranges; therefore, the mitigation zones 

will cover a greater portion of the impact ranges for these explosives.

As described previously, the Phase III mitigation zones are based on the largest areas within which it is 

practical for the Navy to implement mitigation. It is not practical to increase these mitigation zones 
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because observations within the margin of increase would be unsafe and ineffective unless the Navy 

allocated additional platforms to the activity to observe for biological resources. The use of additional 

personnel and equipment (e.g., small boats, aircraft) would be unsustainable due to increased 

operational costs and an exceedance of available manpower and resources for this activity. Adding 

aircraft to observe the mitigation zone could result in airspace conflicts with the event participants. This 

would either require the aircraft conducting the activity to modify their flights plans (which would 

reduce activity realism) or force the observing aircraft to position itself a safe distance away from the 

activity area (which would decrease observation effectiveness). Adding vessels to observe the mitigation 

zone would increase safety risks due to the presence observation vessels within the vicinity of 

detonations.

Increasing the mitigation zone sizes would result in larger areas over which firing would need to be 

ceased in response to a sighting, and therefore would likely increase the number of times detonations 

would be ceased and would extend the length of the activity. These impacts would significantly diminish 

realism in a way that would prevent the activity from meeting its intended objectives. For example, 

Mine Countermeasures – Mine Neutralization – Remotely Operated Vehicle training exercises require 

focused situational awareness of the activity area and continuous coordination of tactics between ship, 

small boat, and rotary-wing aircraft crews to locate and neutralize mines. During Airborne Mine 

Neutralization Systems Test events, personnel evaluate the system’s ability to detect and destroy mines 

from an airborne mine countermeasures-capable rotary-wing aircraft in advance of delivery to the fleet 

for operational use. Extending the length of these activities would require aircraft to depart the activity 

area to refuel. If multiple refueling events were required, the length of the activity would be extended 

by two to five times or more. This would decrease the ability for Lookouts to safely and effectively 

maintain situational awareness of the activity area and would increase safety risks due to increased pilot 

fatigue and accelerated fatigue-life of aircraft. 

These types of impacts would result in a significant loss of training or testing time (which would reduce 

the number of opportunities that platforms have to locate and neutralize mines and reduce the Navy’s 

ability to validate whether mine neutralization systems perform as expected) and cause a significant 

delay to the training or testing schedule. Therefore, an increase in mitigation would impede the ability 

for the Navy to train and become proficient in using mine neutralization systems as required during 

military missions and combat operations, would prevent units from meeting their individual training and 

certification requirements (which would prevent them from deploying with the required level of 

readiness necessary to accomplish their missions), and would impede the ability of program managers 

and weapons system acquisition programs to meet testing requirements per required acquisition 

milestones or on an as-needed basis to meet operational requirements. Extending the length of the 

activities would also result in additional operational costs due to increased fuel consumption.

In summary, the operational community determined that implementing procedural mitigation for 

explosive mine countermeasure and neutralization activities beyond what is detailed in Table 5.3-13

would be incompatible with the practicality assessment criteria for safety, sustainability, and mission

requirements.

5.3.3.8 Explosive Mine Neutralization Activities Involving Navy Divers

The Navy will continue to implement procedural mitigation to avoid or reduce potential impacts on 

marine mammals and sea turtles from explosive mine neutralization activities involving Navy divers, as

outlined in Table 5.3-14. Navy divers participating in these activities may be explosive ordnance disposal 
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personnel. In addition to procedural mitigation, the Navy will implement mitigation for these activities 

within mitigation areas (see Section 5.4.1, Mitigation Areas for Seafloor Resources; Section 5.4.2, 

Mitigation Areas off the Northeastern United States; and Section 5.4.3, Mitigation Areas off the MidAtlantic and Southeastern United States).

Table 5.3-14: Procedural Mitigation for Explosive Mine Neutralization Activities Involving 

Navy Divers 

Procedural Mitigation Description

Stressor or Activity

 Explosive mine neutralization activities involving Navy divers 

Resource Protection Focus

 Marine mammals

 Sea turtles 

Number of Lookouts and Observation Platform

 2 Lookouts (two small boats with one Lookout each, or one Lookout on a small boat and one in a rotary-wing aircraft) when 

implementing the smaller mitigation zone

 4 Lookouts (two small boats with two Lookouts each), and a pilot or member of an aircrew will serve as an additional Lookout if 

aircraft are used during the activity, when implementing the larger mitigation zone

 All divers placing the charges on mines will support the Lookouts while performing their regular duties and will report applicable 

sightings to their supporting small boat or Range Safety Officer.

 If additional platforms are participating in the activity, personnel positioned in those assets (e.g., safety observers, evaluators) 

will support observing the mitigation zone for applicable biological resources while performing their regular duties.

Mitigation Requirements

 Mitigation zones:

 500 yd. around the detonation site during activities under positive control using 0.1–20 lb. net explosive weight

 1,000 yd. around the detonation site during activities using time-delay fuses (0.1–20 lb. net explosive weight) and during 

activities under positive control using 21–60 lb. net explosive weight charges

 Prior to the initial start of the activity (e.g., when maneuvering on station for activities under positive control; 30 min. for 

activities using time-delay firing devices):

 Observe the mitigation zone for floating vegetation; if observed, relocate or delay the start until the mitigation zone is clear.

 Observe the mitigation zone for marine mammals and sea turtles; if observed, relocate or delay the start of detonations or 

fuse initiation.

 During the activity:

 Observe the mitigation zone for marine mammals and sea turtles; if observed, cease detonations or fuse initiation.

 To the maximum extent practicable depending on mission requirements, safety, and environmental conditions, boats will 

position themselves near the mid-point of the mitigation zone radius (but outside of the detonation plume and human safety 

zone), will position themselves on opposite sides of the detonation location (when two boats are used), and will travel in a 

circular pattern around the detonation location with one Lookout observing inward toward the detonation site and the other 

observing outward toward the perimeter of the mitigation zone.

 If used, aircraft will travel in a circular pattern around the detonation location to the maximum extent practicable.

 The Navy will not set time-delay firing devices (0.1–20 lb. net explosive weight) to exceed 10 min.

 Commencement/recommencement conditions after a marine mammal or sea turtle sighting before or during the activity:

 The Navy will allow a sighted marine mammal or sea turtle to leave the mitigation zone prior to the initial start of the activity 

(by delaying the start) or during the activity (by not recommencing detonations) until one of the following conditions has 

been met: (1) the animal is observed exiting the mitigation zone; (2) the animal is thought to have exited the mitigation zone 

based on a determination of its course, speed, and movement relative to the detonation site; or (3) the mitigation zone has 

been clear from any additional sightings for 10 min. during activities under positive control with aircraft that have fuel 

constraints, or 30 min. during activities under positive control with aircraft that are not typically fuel constrained and during 

activities using time-delay firing devices.

 After completion of an activity (for 30 min):

 Observe the vicinity of where detonations occurred; if any injured or dead marine mammals or ESA-listed species are 

observed, follow established incident reporting procedures.

 If additional platforms are supporting this activity (e.g., providing range clearance), these assets will assist in the visual 

observation of the area where detonations occurred.
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In Phase II, the mitigation zones for explosive mine neutralization activities involving Navy divers were

based on net explosive weight and the associated average ranges to PTS. When developing Phase III 

mitigation, the Navy analyzed the potential for increasing the size of the mitigation zones. The Navy 

identified an opportunity to increase the mitigation zone size for positive control charges in bin E4 or 

below and bin E7 to enhance protections to the maximum extent practicable and for consistency across 

activities. These increases are reflected in Table 5.3-14. The mitigation zones for explosive mine 

neutralization activities involving the use of Navy divers are now based on the largest areas within which 

it is practical to implement mitigation. The post-activity observations are a continuation from Phase II 

and will help the Navy determine if any resources were injured during the activity. The Navy will follow 

the incident reporting procedures outlined in Section 5.1.2.2.3 (Incident Reports) if an incident is 

detected at any time during the event, including during the post-activity observations.

The Navy is clarifying that it will require observation of the mitigation zone prior to the initial start of the 

activity to ensure the area is clear of applicable biological resources. The Navy has always verified that 

the mitigation zone is visually clear prior to conducting explosive activities and is more clearly capturing 

this current practice in the mitigation measures for Phase III. The Navy is adding a requirement that 

additional platforms already participating in the activity will support observing the mitigation zone 

before, during, and after the activity while performing their regular duties. When available, having 

additional personnel support observations of the mitigation zone will help increase the likelihood of 

detecting biological resources.

The charges used during explosive mine neutralization activities involving Navy divers are either 

positively controlled or initiated using a time-delay fuse. Positive control means the detonation is 

controlled by the personnel conducting the activity and is not authorized until the area is clear at the 

time of detonation. Time-delay means the detonation is fused with a specified time-delay by the 

personnel conducting the activity and is not authorized until the area is clear at the time the fuse is 

initiated but cannot be terminated once the fuse is initiated due to human safety concerns. For activities 

using a time-delay fuse, there is a remote chance that animals could swim into the mitigation zone after 

the fuse has been initiated. The Navy established a mitigation measure to set time-delay firing devices 

not to exceed 10-min. to limit the potential time that animals have to swim into the mitigation zone 

after fuse initiation. During activities under positive control, the Navy can cease detonations at any time 

in response to a sighting of a marine mammal or sea turtle. For this reason, all activities using a timedelay fuse will implement the 1,000-yd. mitigation zone, while activities that are under positive control 

will implement either the 500-yd. or 1,000-yd. mitigation zone, depending on the size of the charge.

Time-delay charges have a maximum charge size of 20-lb. net explosive weight.

For the 500-yd. mitigation zone, the small observation area and proximity to observation platforms will 

result in a high likelihood that Lookouts will be able to detect marine mammals and sea turtles

throughout the mitigation zone. For the 1,000-yd. mitigation zone, the use of two additional Lookouts 

increases the likelihood that Lookouts will be able to detect marine mammals and sea turtles across the 

larger observation area. Due to their low vantage point on the water, Lookouts in small boats will be 

more likely to detect large visual cues (e.g., whale blows or large pods of dolphins) or the splashes of 

individual marine mammals than cryptic marine mammal species and sea turtles near the perimeter of 

the 1,000-yd. mitigation zone. When rotary-wing aircraft are used, Lookouts positioned in an aircraft will

have a good vantage point for observing out to the perimeter of the 500-yd. and 1,000-yd. mitigation 

zones. Observing for indicators of marine mammal and sea turtle presence will further help avoid or 

reduce potential impacts on these resources within the mitigation zones.
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Bin E7 (e.g., 60-lb. net explosive weight charges) and bin E6 (e.g., 20-lb. net explosive weight) have the 

longest predicted impact ranges for positive control explosives and time-delay explosives that apply to 

the 1,000-yd. mitigation zone, respectively. Bin E6 (e.g., 20-lb. net explosive weight) has the longest 

predicted impact ranges for the positive control explosives that apply to the 500-yd. mitigation zone. 

The 1,000-yd. and 500-yd. mitigation zones extend beyond the respective ranges to 50 percent nonauditory injury and 50 percent mortality for sea turtles and marine mammals. For time-delay charges, 

the 1,000-yd. mitigation zone extends beyond the average ranges to PTS for sea turtles and marine 

mammals that could potentially occur in the locations where this activity takes place (high-frequency 

cetaceans and phocids are unlikely to occur in the areas where these activities take place). For positive 

control charges, the 1,000-yd. and 500-yd. mitigation zones extend beyond the average ranges to PTS 

for sea turtles and marine mammals that could potentially occur in the locations where this activity 

takes place except low-frequency cetaceans (the mitigation zones extend into a portion of the average 

ranges to PTS for this hearing group). The mitigation zones also extend into a portion of the average 

ranges to TTS for sea turtles and marine mammals. Therefore, depending on the species, mitigation will 

help avoid or reduce all or a portion of the potential for exposure to mortality, non-auditory injury, PTS, 

and higher levels of TTS for the largest explosives in bin E7 and bin E6. Smaller explosives within bin E7

and bin E6 and explosives in smaller source bins (e.g., E5) have shorter predicted impact ranges; 

therefore, the mitigation zones will cover a greater portion of the impact ranges for these explosives.

As described previously, the Phase III mitigation zones are based on the largest areas within which it is 

practical for the Navy to implement mitigation. It is not practical to increase these mitigation zones 

because observations within the margin of increase would be unsafe and ineffective unless the Navy 

allocated additional platforms to the activity to observe for biological resources. Because mine 

neutralization activities involve training Navy divers in the safe handling of explosive charges, one of the 

mission-essential safety protocols required of all event participants, including Lookouts, is to maintain 

focus on the activity area to ensure safety of personnel and equipment. The typical mine neutralization 

activity areas coincide with the mitigation zone sizes developed for Phase III; therefore, Lookouts can

safely and effectively observe the mitigation zones for biological resources while simultaneously 

maintaining focus on the activity areas. However, if the mitigation zone sizes increased, Lookouts would 

need to redirect their attention beyond the activity areas. This would not meet the safety criteria since 

personnel would be required to direct their attention away from mission requirements. Alternatively, 

the Navy would need to add personnel to serve as additional Lookouts on the existing observation 

platforms or allocate additional platforms to the activity to observe for biological resources. These 

actions would not be safe or sustainable due to an exceedance of manpower, resource, and space

restrictions for these activities.

Increasing the mitigation zone sizes would result in larger areas over which detonations would need to 

be ceased in response to a sighting, and therefore would likely increase the number of times 

detonations would be ceased. This would extend the length of the activities and cause significant safety 

risks for Navy divers and loss of training time. Ceasing an activity (e.g., fuse initiation) with divers in the 

water would have safety implications for diver air consumption and bottom time. It would also impede 

the ability for Navy divers to complete the training exercise with the focused endurance as required 

during military missions and combat operations. These impacts would significantly diminish event 

realism in a way that would prevent activities from meeting their intended objectives. For example, the 

number of opportunities that divers would have to locate and neutralize mines would be reduced. 

Divers would then not be able to gain skill proficiency in precise identification and evaluation of a threat 

mine, safe handling of explosive material during charge placement, and effective charge detonation or 
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fuse initiation. Mine neutralization activities involving the use of Navy divers only take place during 

daylight hours for safety reasons; therefore, extending the length of the activity could delay the activity 

into the next day or next several days, which would significantly impact training schedules for all 

participating platforms. Therefore, an increase in mitigation would impede the ability for Navy divers to 

train and become proficient in mine neutralization and would prevent units from meeting their 

individual training and certification requirements (which would prevent them from deploying with the 

required level of readiness necessary to accomplish their missions).

For activities that involve aircraft, extending the length of the activity would require aircraft to depart 

the area to refuel. If multiple refueling events were required, the length of the activity would be 

extended by two to five times or more, which would decrease the ability for Lookouts to safely and 

effectively maintain situational awareness of the activity area and increase safety risks due to increased 

pilot fatigue and accelerated fatigue-life of aircraft. Extending the length of the activity would also result 

in additional operational costs due to increased fuel consumption.

In summary, the operational community determined that implementing procedural mitigation for 

explosive mine neutralization activities involving Navy divers beyond what is detailed in Table 5.3-14

would be incompatible with the practicality assessment criteria for safety, sustainability, and mission

requirements.

5.3.3.9 Maritime Security Operations – Anti-Swimmer Grenades

The Navy will continue to implement procedural mitigation to avoid or reduce potential impacts on

marine mammals and sea turtles from anti-swimmer grenades during Maritime Security Operations, as 

outlined in Table 5.3-15. In addition to procedural mitigation, the Navy will implement mitigation for inwater detonations within mitigation areas (see Section 5.4.2, Mitigation Areas off the Northeastern

United States; Section 5.4.3, Mitigation Areas off the Mid-Atlantic and Southeastern United States; and 

Section 5.4.4, Mitigation Areas in the Gulf of Mexico).

In Phase II, the Maritime Security Operations – Anti-Swimmer Grenade mitigation zone was based on 

net explosive weight and the associated average ranges to PTS. When developing Phase III mitigation, 

the Navy analyzed the potential for increasing the size of the mitigation zone. The Navy determined that 

the current mitigation zone is the largest area within which it is practical to implement mitigation for 

this activity; therefore, it will continue implementing this same mitigation zone for Phase III.

The Navy is clarifying that it will require observation of the mitigation zone prior to the initial start of the 

activity to ensure the area is clear of applicable biological resources. The Navy has always verified that 

the mitigation zone is visually clear prior to conducting explosive activities and is more clearly capturing 

this current practice in the mitigation measures for Phase III. The Navy developed a new mitigation 

measure requiring the Lookout to observe the mitigation zone after completion of the activity. The Navy 

currently conducts post-activity observations for some, but not all explosive activities. In developing 

mitigation for Phase III, the Navy determined that it could expand this requirement to other explosive 

activities for enhanced consistency and to help determine if any resources were injured during explosive 

events, when practical. The Navy is adding a requirement that additional platforms already participating 

in the activity will support observing the mitigation zone before, during, and after the activity while 

performing their regular duties. When available, having additional personnel support observations of 

the mitigation zone will help increase the likelihood of detecting biological resources. The Navy will 

follow the incident reporting procedures outlined in Section 5.1.2.2.3 (Incident Reports) if an incident is 

detected at any time during the event, including during the post-activity observations.
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Table 5.3-15: Procedural Mitigation for Maritime Security Operations – Anti-Swimmer 

Grenades

Procedural Mitigation Description

Stressor or Activity

 Maritime Security Operations – Anti-Swimmer Grenades

Resource Protection Focus

 Marine mammals

 Sea turtles 

Number of Lookouts and Observation Platform

 1 Lookout positioned on the small boat conducting the activity

 If additional platforms are participating in the activity, personnel positioned in those assets (e.g., safety observers, evaluators) 

will support observing the mitigation zone for applicable biological resources while performing their regular duties.

Mitigation Requirements

 Mitigation zone:

 200 yd. around the intended detonation location

 Prior to the initial start of the activity (e.g., when maneuvering on station):

 Observe the mitigation zone for floating vegetation; if observed, relocate or delay the start until the mitigation zone is clear.

 Observe the mitigation zone for marine mammals and sea turtles; if observed, relocate or delay the start of detonations.

 During the activity:

 Observe the mitigation zone for marine mammals and sea turtles; if observed, cease detonations.

 Commencement/recommencement conditions after a marine mammal or sea turtle sighting before or during the activity:

 The Navy will allow a sighted marine mammal or sea turtle to leave the mitigation zone prior to the initial start of the activity 

(by delaying the start) or during the activity (by not recommencing detonations) until one of the following conditions has 

been met: (1) the animal is observed exiting the mitigation zone; (2) the animal is thought to have exited the mitigation zone 

based on a determination of its course, speed, and movement relative to the intended detonation location; (3) the mitigation 

zone has been clear from any additional sightings for 30 min.; or (4) the intended detonation location has transited a distance 

equal to double that of the mitigation zone size beyond the location of the last sighting.

 After completion of the activity (e.g., prior to maneuvering off station):

 When practical (e.g., when platforms are not constrained by fuel restrictions or mission-essential follow-on commitments),

observe the vicinity of where detonations occurred; if any injured or dead marine mammals or ESA-listed species are 

observed, follow established incident reporting procedures.

 If additional platforms are supporting this activity (e.g., providing range clearance), these assets will assist in the visual 

observation of the area where detonations occurred.

The small mitigation zone size and proximity to the observation platform result in a high likelihood that 

Lookouts will be able to detect marine mammals and sea turtles throughout the mitigation zone. 

Observing for indicators of marine mammal and sea turtle presence will further help avoid or reduce

potential impacts on these resources within the mitigation zone.

Explosives used during Maritime Security Operations – Anti-Swimmer Grenades exercises are in bin E2 

(e.g., 0.5-lb. net explosive weight). The mitigation zone extends beyond the ranges to 50 percent nonauditory injury and 50 percent mortality for sea turtles and marine mammals. The mitigation zone 

extends beyond the respective average ranges to PTS for sea turtles all marine mammal hearing groups 

that could potentially occur in the locations where this activity takes place (high-frequency cetaceans 

are unlikely to occur in the areas where this activity takes place). The mitigation zone also extends into a 

portion of the average ranges to TTS for sea turtles and marine mammals. Therefore, mitigation will help 

avoid or reduce all or a portion of the potential for exposure to mortality, non-auditory injury, PTS, and 

higher levels of TTS for the largest explosives in bin E2.

As described previously, the Phase III mitigation zone is based on the largest area within which it is 

practical for the Navy to implement mitigation. It is not practical to increase the mitigation zone because 

observations within the margin of increase would be unsafe and ineffective. Because this activity 

involves training crews in the safe handling of explosive hand grenades, one of the mission-essential 
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safety protocols required of all event participants, including the Lookout, is to maintain focus on the 

activity area to ensure safety of personnel and equipment. The typical activity area coincides with the 

mitigation zone that will be implemented for Phase III; therefore, Lookouts can safely and effectively 

observe the mitigation zone for biological resources while simultaneously maintaining focus on the 

activity area. However, if the mitigation zone size increased, the Lookout would need to redirect 

attention to observe beyond the activity area. This would not meet the safety criteria since personnel 

would be required to direct their attention away from mission requirements. Alternatively, the Navy 

would need to either add personnel to serve as additional Lookouts on the existing observation platform 

or allocate additional platforms to the activity to observe for biological resources. These actions would 

not be safe or sustainable due an exceedance of manpower, resource, and space restrictions for this

activity.

In summary, the operational community determined that implementing procedural mitigation for 

Maritime Security Operations – Anti-Swimmer Grenades beyond what is detailed in Table 5.3-15 would 

be incompatible with the practicality assessment criteria for safety and sustainability.

5.3.3.10 Line Charge Testing

The Navy will continue to implement procedural mitigation to avoid or reduce potential impacts on

marine mammals, sea turtles, and fish (ESA-listed Gulf sturgeon) from line charge testing, as outlined in 

Table 5.3-16. In Phase II, the line charge testing mitigation zone was based on net explosive weight and 

the associated average ranges to PTS. When developing Phase III mitigation, the Navy analyzed the 

potential for increasing the size of the mitigation zone. The Navy determined that the current mitigation 

zone is the largest area within which it is practical to implement mitigation for this activity; therefore, it 

will continue implementing this same mitigation zone for Phase III.

The Navy is clarifying that it will require observation of the mitigation zone prior to the initial start of the 

activity to ensure the area is clear of applicable biological resources. The Navy has always verified that 

the mitigation zone is visually clear prior to conducting explosive activities and is more clearly capturing 

this current practice in the mitigation measures for Phase III. The Navy developed a new mitigation 

measure requiring the Lookout to observe the mitigation zone after completion of the activity. The Navy 

currently conducts post-activity observations for some, but not all explosive activities. In developing 

mitigation for Phase III, the Navy determined that it could expand this requirement to other explosive 

activities for enhanced consistency and to help determine if any resources were injured during explosive 

events, when practical. The Navy is adding a requirement that additional platforms already participating 

in the activity will support observing the mitigation zone before, during, and after the activity while 

performing their regular duties. When available, having additional personnel support observations of 

the mitigation zone will help increase the likelihood of detecting biological resources. The Navy will 

follow the incident reporting procedures outlined in Section 5.1.2.2.3 (Incident Reports) if an incident is 

detected at any time during the event, including during the post-activity observations.

Naval Surface Warfare Center, Panama City Division Testing Range is currently the Navy’s only location 

capable of supporting this type of activity. Mitigation to not conduct line charge testing at night from 

March through September will help avoid or reduce potential impacts on green, Kemp’s ridley, 

loggerhead, and leatherback sea turtles during the time of day when they would be most likely to transit 

to and from their nesting beaches during nesting season. Mitigation to not conduct line charge testing 

activities from October through March (except within a designated location on Santa Rosa Island) will 

help avoid or reduce potential impacts on ESA-listed Gulf sturgeon during their seasonal migration from 
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the Gulf of Mexico winter and feeding grounds to the spring and summer natal (hatching) rivers (the 

Yellow, Choctawhatchee, and Apalachicola Rivers).

Table 5.3-16: Procedural Mitigation for Line Charge Testing

Procedural Mitigation Description

Stressor or Activity

 Line charge testing

Resource Protection Focus

 Marine mammals

 Sea turtles

 Fish (Gulf sturgeon)

Number of Lookouts and Observation Platform

 1 Lookout positioned on a vessel

 If additional platforms are participating in the activity, personnel positioned in those assets (e.g., safety observers, evaluators) 

will support observing the mitigation zone for applicable biological resources while performing their regular duties.

Mitigation Requirements

 Mitigation zone:

 900 yd. around the intended detonation location

 Prior to the initial start of the activity (e.g., when maneuvering on station):

 Observe the mitigation zone for floating vegetation; if observed, delay the start until the mitigation zone is clear.

 Observe the mitigation zone for marine mammals and sea turtles; if observed, delay the start of detonations.

 During the activity:

 Observe the mitigation zone for marine mammals and sea turtles; if observed, cease detonations.

 Commencement/recommencement conditions after a marine mammal or sea turtle sighting before or during the activity:

 The Navy will allow a sighted marine mammal or sea turtle to leave the mitigation zone prior to the initial start of the activity 

(by delaying the start) or during the activity (by not recommencing detonations) until one of the following conditions has 

been met: (1) the animal is observed exiting the mitigation zone; (2) the animal is thought to have exited the mitigation zone 

based on a determination of its course, speed, and movement relative to the intended detonation location; or (3) the 

mitigation zone has been clear from any additional sightings for 30 min.

 After completion of the activity (e.g., prior to maneuvering off station):

 When practical (e.g., when platforms are not constrained by fuel restrictions or mission-essential follow-on commitments),

observe the vicinity of where detonations occurred; if any injured or dead marine mammals or ESA-listed species are 

observed, follow established incident reporting procedures.

 If additional platforms are supporting this activity (e.g., providing range clearance), these assets will assist in the visual 

observation of the area where detonations occurred.

 Additional requirements:

 From March through September (sea turtle nesting season), the Navy will not conduct line charge testing at night.

 From October through March (Gulf sturgeon migration season), Navy will not conduct line charge testing except within a 

designated location on Santa Rosa Island.

During line charge testing, surface vessels deploy line charges to test the capability to safely clear surf 

zone areas for sea-based expeditionary forces. Line charges consist of a 350-ft. detonation cord with 

explosives lined from one end to the other end in a series of 5-lb. increments. Lookouts will have a 

better likelihood of detecting individual marine mammals and sea turtles that are in the near-range or 

central portion of the mitigation zone. Lookouts will be more likely to detect large visual cues (e.g., 

whale blows or large pods of dolphins) or the splashes of individual marine mammals than cryptic 

marine mammal species and sea turtles near the perimeter of the mitigation zone (e.g., near the 

shoreline). Observing for indicators of marine mammal and sea turtle presence will further help avoid or 

reduce potential impacts on these resources within the mitigation zones.

Bin E14 (2,500-lb. high blast explosive) is the largest explosive used in line charge testing. Mitigation will 

likely help avoid or reduce all or a portion of the potential for exposure to mortality, non-auditory injury, 

PTS, and higher levels of TTS during line charge testing.
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As described previously, the Phase III mitigation zone is based on the largest area within which it is 

practical for the Navy to implement mitigation. It is not practical to increase the mitigation zone because 

observations within the margin of increase would be unsafe and ineffective unless the Navy allocated 

additional platforms to the activity to observe for biological resources. The use of additional personnel 

and equipment (e.g., vessels) would be unsustainable due to increased operational costs and an 

exceedance of the available manpower and resources for this activity. Adding vessels to observe the 

mitigation zone would increase safety risks due to the presence of observation vessels within the vicinity 

of an explosive line charge.

Increasing the mitigation zone would result in a larger area over which detonations would need to be 

ceased in response to a sighting, and therefore would likely increase the number of times detonations

would be ceased. This would extend the length of the activity and significantly diminish realism in a way 

that would prevent the activity from meeting its intended objectives. For example, ceasing a detonation 

during the event would mean that the Navy would not be able to test the explosive array continuously

from one end to the other, which would impede the ability for surface vessels to effectively test the 

capability of the line charges to neutralize mine threats and clear surf zone areas for sea-based 

expeditionary forces as required during military missions and combat operations, and to meet testing 

requirements per required acquisition milestones or on an as-needed basis to meet operational 

requirements. Line charge testing only takes place during daylight hours from March through September 

as mitigation for sea turtle nesting; therefore, extending the length of the activity would result in a delay 

into the next day or next several days during that season, which would significantly impact the testing 

schedules of all event participants.

In summary, the operational community determined that implementing procedural mitigation for line 

charge testing beyond what is detailed in Table 5.3-16 would be incompatible with the practicality

assessment criteria for safety, sustainability and mission requirements.

5.3.3.11 Ship Shock Trials

The Navy will continue to implement procedural mitigation to avoid or reduce potential impacts on

marine mammals and sea turtles to from ship shock trials, as outlined in Table 5.3-17. The Navy will 

continue to provide detailed ship shock trial mitigation to NMFS for review and approval approximately 

1 year prior to each event. In Phase II, the ship shock trial mitigation zone was based on net explosive 

weight and the associated average ranges to PTS. When developing Phase III mitigation, the Navy 

analyzed the potential for increasing the size of this mitigation zone. The Navy determined that the 

current mitigation zone for ship shock trials is the largest area within which it is practical to implement 

mitigation for this activity; therefore, it will continue implementing this same mitigation zone for Phase 

III. The post-activity observations are a continuation from Phase II and will help the Navy determine if 

any resources were injured during the activity. The Navy will follow the incident reporting procedures 

outlined in Section 5.1.2.2.3 (Incident Reports) if an incident is detected at any time during the event, 

including during the post-activity observations.

The Navy is clarifying that it will require observation of the mitigation zone prior to the initial start of the 

activity to ensure the area is clear of applicable biological resources. The Navy has always verified that 

the mitigation zone is visually clear prior to conducting explosive activities and is more clearly capturing 

this current practice in the mitigation measures for Phase III. The Navy is adding a requirement that 

additional platforms already participating in the activity will support observing the mitigation zone 

before, during, and after the activity while performing their regular duties. There are typically multiple 
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platforms in the vicinity of ship shock trial activities (e.g., safety aircraft). When available, having 

additional personnel support observations of the mitigation zone will help increase the likelihood of 

detecting biological resources.

Table 5.3-17: Procedural Mitigation for Ship Shock Trials

Procedural Mitigation Description

Stressor or Activity

 Ship shock trials

Resource Protection Focus

 Marine mammals

 Sea turtles 

Number of Lookouts and Observation Platform

 At least 10 Lookouts or trained marine species observers (or a combination thereof) positioned either in an aircraft or on multiple 

vessels (i.e., a Marine Animal Response Team boat and the test ship) 

 If aircraft are used, Lookouts or trained marine species observers will be in an aircraft and on multiple vessels

 If aircraft are not used, a sufficient number of additional Lookouts or trained marine species observers will be used to provide 

vessel-based visual observation comparable to that achieved by aerial surveys

 If additional platforms are participating in the activity, personnel positioned in those assets (e.g., safety observers, evaluators) 

will support observing the mitigation zone for applicable biological resources while performing their regular duties.

Mitigation Requirements

 Mitigation zone:

 3.5 NM around the ship hull

 During event planning:

 The Navy will not conduct ship shock trials in the Jacksonville Operating Area during North Atlantic right whale calving season 

from November 15 through April 15.

 The Navy develops detailed ship shock trial monitoring and mitigation plans approximately 1-year prior to an event and will 

continue to provide these to NMFS for review and approval.

 Pre-activity planning will include selection of one primary and two secondary areas where marine mammal populations are 

expected to be the lowest during the event, with the primary and secondary locations located more than 2 NM from the 

western boundary of the Gulf Stream for events in the Virginia Capes Range Complex or Jacksonville Range Complex.

 If it is determined during pre-activity surveys that the primary area is environmentally unsuitable (e.g., observations of marine 

mammals or presence of concentrations of floating vegetation), the shock trial could be moved to a secondary site in 

accordance with the detailed mitigation and monitoring plan provided to NMFS.

 Prior to the initial start of the activity at the primary shock trial location (in intervals of 5 hours, 3 hours, 40 min., and immediately 

before the detonation):

 Observe the mitigation zone for floating vegetation; if observed, delay the start until the mitigation zone is clear.

 Observe the mitigation zone for marine mammals and sea turtles; if observed, delay triggering the detonation.

 During the activity:

 Observe the mitigation zone for marine mammals, sea turtles, large schools of fish, jellyfish aggregations, and flocks of 

seabirds; if observed, cease triggering the detonation.

 After completion of each detonation, observe the mitigation zone for marine mammals and sea turtles; if any injured or dead 

marine mammals or sea turtles are observed, follow established incident reporting procedures and halt any remaining 

detonations until the Navy can consult with NMFS and review or adapt the mitigation, if necessary.

 Commencement/recommencement conditions after a marine mammal or sea turtle sighting before or during the activity:

 The Navy will allow a sighted marine mammal or sea turtle to leave the mitigation zone prior to the initial start of the activity

(by delaying the start) or during the activity (by not recommencing detonations) until one of the following conditions has 

been met: (1) the animal is observed exiting the mitigation zone; (2) the animal is thought to have exited the mitigation zone 

based on a determination of its course, speed, and movement relative to the ship hull; or (3) the mitigation zone has been 

clear from any additional sightings for 30 min.

 After completion of the activity (during the following 2 days at a minimum, and up to 7 days at a maximum):

 Observe the vicinity of where detonations occurred; if any injured or dead marine mammals or ESA-listed species are 

observed, follow established incident reporting procedures.

 If additional platforms are supporting this activity (e.g., providing range clearance), these assets will assist in the visual 

observation of the area where detonations occurred.
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Lookouts positioned in aircraft will have the best vantage point for observing the mitigation zone. During 

small ship shock trials, aerial surveys are not always operationally feasible due to resource limitations; 

however, if vessels are used as the sole observation platform, the use of additional vessels will ensure 

that observations of the mitigation zone are comparable to what is achieved when aircraft are used.

The mitigation zone represents the maximum area that would likely be effective at avoiding or reducing 

impacts on marine mammals and sea turtles during ship shock trials based on the amount of time it 

takes for vessels and aircraft to patrol the area. The longer a vessel or aircraft spends transiting the 

survey area, the less focused the survey becomes at observing individuals that may be present close to 

the detonation location. Even with the intensive observation effort that will be used during ship shock 

trials, there is a chance that animals could enter the mitigation zone at one end while observation 

platforms are conducting observations in other locations. Lookouts will have a better likelihood of 

detecting marine mammals and sea turtles that are in the central portion of the mitigation zone (around 

the ship hull) and during closer-range observations but are not likely to detect these resources at the far 

side of the mitigation zone perimeter. At far distances, Lookouts will have a better likelihood of 

detecting large visual cues (e.g., whale blows or large pods of dolphins) than individual marine 

mammals, cryptic marine mammal species, and sea turtles. Observing for indicators of marine mammal 

and sea turtle presence will further help avoid or reduce potential impacts on these resources within the 

mitigation zone. The Navy will observe for additional marine mammal and sea turtle indicators during 

this activity (large schools of fish, jellyfish aggregations, and flocks of seabirds) as an added precaution.

Bin E17 has the longest predicted impact ranges for explosives used in ship shock trials in the Study 

Area. For the largest explosive in bin E17, the mitigation zone extends beyond the ranges to 50 percent 

non-auditory injury and 50 percent mortality for sea turtles and marine mammals. The mitigation zone 

extends beyond the average ranges to PTS for sea turtles and all marine mammal hearing groups that 

could potentially occur in the locations where this activity takes place except high-frequency cetaceans 

and low-frequency cetaceans (the mitigation zone extends into a portion of the average ranges to PTS 

for these hearing groups). Phocids and sirenians are unlikely to occur in the areas where this activity 

takes place. The mitigation zone also extends beyond the average ranges to TTS for mid-frequency 

cetaceans and into a portion of the average ranges to TTS for sea turtles and other marine mammals. 

Therefore, mitigation will help avoid or reduce all or a portion of the potential for exposure to mortality, 

non-auditory injury, PTS, and higher levels of TTS for the largest explosives in bin E17. Smaller explosives 

in bin E17 and explosives in smaller source bins (e.g., E16) have shorter predicted impact ranges; 

therefore, the mitigation zone will extend further beyond or cover a greater portion of the impact 

ranges for these explosives.

As described previously, the Phase III mitigation zone is based on the largest area within which it is 

practical for the Navy to implement mitigation. It is not practical to increase the mitigation zones

because observations within the margin of increase would be unsafe and ineffective unless the Navy 

allocated additional platforms to the activity to observe for biological resources. The use of additional 

personnel (Lookouts or trained marine species observers) and equipment (vessels or aircraft) would be 

unsustainable due to increased operational costs and an exceedance of the available manpower and 

resources for this activity. Adding aircraft to observe the mitigation zone could result in airspace 

conflicts with the event participants. This would either require the aircraft conducting the activity to 

modify their flights plans (which would reduce activity realism) or force the observing aircraft to position 

itself a safe distance away from the activity area (which would decrease observation effectiveness). 

Adding vessels to observe the mitigation zone would increase safety risks due to the presence of 
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observation vessels within the vicinity of high blast explosives. Alternatively, vessels would need to 

position themselves a safe distance from the activity, which would decrease observation effectiveness.

Increasing the mitigation zone would result in a larger area over which detonations would need to be 

ceased in response to a sighting, and therefore would likely increase the number of times detonations 

would be ceased. This would extend the length of the activity and significantly diminish realism in a way 

that would prevent the activity from meeting its intended objectives. Extending the length of the activity 

would require aircraft to depart the area to refuel. If multiple refueling events were required, the 

activity length would be extended by two to five times or more, which would decrease the ability for 

aircraft to safely and effectively maintain situational awareness of the activity area and increase safety 

risks due to increased pilot fatigue and accelerated fatigue-life of aircraft. Extending the length of the 

activity would also result in additional operational costs due to increased fuel consumption. Increasing 

the mitigation would significantly impact the schedules of the participants due to the logistical 

complexity of event coordination between participating aircraft carriers, support craft, fixed-wing 

aircraft, and rotary-wing aircraft. These delays would prevent the Navy from meeting testing 

requirements per required acquisition milestones or on an as-needed basis to meet operational 

requirements.

In summary, the operational community determined that implementing procedural mitigation for ship 

shock trials beyond what is detailed in Table 5.3-17 would be incompatible with the practicality

assessment criteria for safety, sustainability, and mission requirements.

5.3.4 PHYSICAL DISTURBANCE AND STRIKE STRESSORS

The Navy will implement procedural mitigation to avoid or reduce potential impacts on biological 

resources from the physical disturbance and strike stressors or activities discussed in the sections below.

Section 3.7.3.4 (Physical Disturbance and Strike Stressors) and Section 3.8.3.4 (Physical Disturbance and 

Strike Stressors) provide a full analysis of the potential impacts of physical disturbance and strikes on 

marine mammals and sea turtles, respectively. Appendix F (Military Expended Material and Direct Strike 

Impact Analysis) presents the impact footprints and direct strike calculations.

5.3.4.1 Vessel Movement

The Navy will continue to implement procedural mitigation to avoid or reduce the potential for vessel 

strikes of marine mammals and sea turtles, as outlined in Table 5.3-18. In addition to procedural 

mitigation, the Navy will implement mitigation for vessel movement within mitigation areas (see Section 

5.4.1, Mitigation Areas for Seafloor Resources; Section 5.4.2, Mitigation Areas off the Northeastern

United States; and Section 5.4.3, Mitigation Areas off the Mid-Atlantic and Southeastern United States).

The procedural mitigation measures for vessel movement are based on guidance from NMFS and the 

USFWS for vessel strike avoidance. When developing Phase III mitigation, the Navy analyzed the 

potential for implementing additional mitigation. The Navy identified a potential opportunity to develop 

a new mitigation measure for broadcasting North Atlantic right whale Dynamic Management Area 

information to Navy assets. The other procedural mitigation measures for vessel movement listed in 

Table 5.3-18 are a continuation from Phase II. Although the Navy is unable to position Lookouts on 

unmanned vessels, some vessels that operate autonomously have embedded sensors that aid in 

avoidance of large objects. The embedded sensors may help those unmanned vessels avoid marine 

mammal vessel strikes.
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Table 5.3-18: Procedural Mitigation for Vessel Movement

Procedural Mitigation Description

Stressor or Activity

 Vessel movement

 The mitigation will not be applied if: (1) the vessel’s safety is threatened, (2) the vessel is restricted in its ability to maneuver 

(e.g., during launching and recovery of aircraft or landing craft, during towing activities, when mooring, etc.), or (3) the vessel 

is operated autonomously.

Resource Protection Focus

 Marine mammals

 Sea turtles

Number of Lookouts and Observation Platform

 1 Lookout on the vessel that is underway

Mitigation Requirements

 Mitigation zones:

 500 yd. around whales

 200 yd. around other marine mammals (except bow-riding dolphins and pinnipeds hauled out on man-made navigational 

structures, port structures, and vessels)

 Within the vicinity of sea turtles

 During the activity:

 When underway, observe the mitigation zone for marine mammals and sea turtles; if observed, maneuver to maintain 

distance.

 When underway in the turning basins, channels, and waterways adjacent to Naval Station Mayport, the Navy will comply with 

federal, state, and local Manatee Protection Zones and reduce speed in accordance with established operational safety and 

security procedures. 

 When mooring pierside at Kings Bay, Georgia, the Navy will ensure proper fendering techniques (e.g., the use of buoys that 

keep submarines 20 ft. off the quay wall) to prevent submarines from injuring a manatee.

 Additional requirements:

 The Navy will broadcast 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. Platforms will use the information to assist their visual observation of 

applicable mitigation zones during training and testing activities and to aid in the implementation of procedural mitigation, 

including but not limited to mitigation for vessel movement.

 The Navy will ensure that small boats operating out of Naval Station Mayport will be fitted with manatee propeller guards. 

Pursuant to the Naval Station Mayport Integrated Natural Resource Management Plan, the Navy will provide manatee 

awareness education to Harbor Operations personnel, require that manatee sightings are communicated to other vessels in 

the vicinity, and maintain signage at select locations that will alert personnel of the potential presence of manatees and the 

requirements and procedures for reporting manatee sightings. For information on protective measures pertaining to activities 

not conducted under the Proposed Action, see the Integrated Natural Resource Management Plan for Naval Station Mayport.

 If a marine mammal or sea turtle vessel strike occurs, the Navy will follow the established incident reporting procedures.

As discussed in Section 5.3.1 (Environmental Awareness and Education), it is likely that the 

implementation of the Marine Species Awareness Training starting in 2007, and the additional U.S. Navy 

Afloat Environmental Compliance Training Series modules starting in 2014, has contributed to a 

reduction in marine mammal vessel strikes. The Navy is able to detect if a whale is struck due to the 

diligence of standard watch personnel and Lookouts stationed specifically to observe for marine 

mammals while a vessel is underway. In the unlikely event that a marine mammal vessel strike occurs, 

the Navy will notify the appropriate regulatory agency immediately or as soon as operational security 

considerations allow per the established incident reporting procedures described in Section 5.1.2.2.3

(Incident Reports). The Navy’s incident reports include relevant information pertaining to the incident, 

including but not limited to vessel speed.

The small mitigation zone sizes and close proximity to the observation platform will result in a high

likelihood that Lookouts will be able to detect marine mammals throughout the mitigation zones while 
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vessels are underway. A mitigation zone size is not specified for sea turtles to allow flexibility based on 

vessel type and mission requirements (e.g., small boats operating in a narrow harbor). The mitigation 

measures for Naval Station Mayport and Kings Bay, Georgia will further help avoid impacts on manatees 

at these locations. The mitigation measures for submarine fendering techniques at Kings Bay, Georgia

do not apply to other vessel types or locations (e.g., Naval Station Mayport) because of the unique 

method of mooring submarines to the Kings Bay wharf. Due to hull differences between submarines and 

the various surface ships, all vessels are not moored in the same manner. Submarine and surface ship 

berthing methods are primarily based on hull configuration and type of pier or quay wall within the port.

Dynamic Management Area information originates from NMFS. NMFS implements two types of vessel 

speed management areas off the U.S. East Coast, Seasonal Management Areas and Dynamic 

Management Areas, to reduce the likelihood of North Atlantic right whale vessel strikes. Under the 

regulations, the vessel speed restrictions are not mandatory for Federal agencies, such as the Navy. 

Seasonal Management Areas are located near ports, bay entrances, or areas where North Atlantic right 

whales could potentially occur. Seasonal Management Areas are in effect for up to 6 months every year, 

depending on the location. Unlike Seasonal Management Areas, which have static locations and time 

components based on potential animal occurrence, the locations and timing of Dynamic Management 

Areas fluctuate based on confirmed North Atlantic right whale detections. Dynamic Management Areas 

were in effect for approximately 3 months in 2018. Dynamic Management Areas cover extensive areas 

of water space that could overlap with essential Navy training and testing areas. Seasonal Management 

Areas overlap critical training and testing areas or are in proximity to Navy ports or pierside locations 

that are instrumental to training and testing in the Study Area (e.g., Naval Station Norfolk, Naval Station 

Mayport).

The Navy has developed the new mitigation measure to broadcast Dynamic Management Area 

information based on potential changes in North Atlantic right whale distribution. Platforms will use 

Dynamic Management Area information to assist their visual observation of applicable mitigation zones 

during training and testing activities. This will make units aware of North Atlantic right whale

aggregations to better plan and conduct activities to minimize interactions with this species. Not only 

will this mitigation measure help the Navy further avoid or reduce potential impacts on North Atlantic 

right whales from vessel movements, it will also help aid the implementation of applicable procedural 

mitigation measures for acoustic, explosive, and physical disturbance and strike stressors when Dynamic 

Management Areas are in effect.

In addition to procedural mitigation, the Navy will continue to implement mitigation for vessel 

movements within select mitigation areas. For example, the Navy will implement vessel speed 

restrictions in certain locations seasonally in response to sightings of North Atlantic right whales, as 

described in Section 5.4.3 (Mitigation Areas off the Mid-Atlantic and Southeastern United States) and

Section 5.4.2 (Mitigation Areas off the Northeastern United States). The Navy will implement a 10-knot 

speed restriction during certain portions of non-explosive torpedo activities in the Northeast North 

Atlantic Right Whale Mitigation Area. The Navy is able to implement a specific speed restriction for this 

activity due to the nature of how it is conducted. For example, during transits and normal firing, 

maintaining a speed of no more than 10 knots still allows the Navy to meet the activity’s intended 

objectives. 

As described in Section 2.3.3.2 (Vessel Safety), Navy vessels are required to operate in accordance with 

applicable navigation rules, including Inland Navigation Rules (33 Code of Federal Regulations 83) and 

International Regulations for Preventing Collisions at Sea (72 COLREGS), which were formalized in the 
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Convention on the International Regulations for Preventing Collisions at Sea, 1972. These rules require 

that vessels proceed at a safe speed so proper and effective action can be taken to avoid collision and so 

vessels can be stopped within a distance appropriate to the prevailing circumstances and conditions. In 

addition to complying with navigation requirements, Navy ships transit at speeds that are optimal for 

fuel conservation, to maintain ship schedules, and to meet mission requirements. Vessel captains use 

the totality of the circumstances to ensure the vessel is traveling at appropriate speeds in accordance 

with navigation rules. Depending on the circumstances, this may involve adjusting speeds during periods 

of reduced visibility or in certain locations.

As discussed in Section 3.0.3.3.4.1 (Vessels and In-Water Devices), large Navy ships typically operate at 

average speeds of between 10 and 15 knots, which for reference is slower than large commercial 

vessels, such as container ships that steam at approximately 24 knots during normal operations (Maloni 

et al., 2013). Operating vessels at speeds that are not optimal for fuel conservation or mission 

requirements would be unsustainable due to increased time on station and increased fuel consumption. 

Each ship has a limited amount of time that it can be underway based on target service requirements 

and ship schedules. Ship schedules are driven largely by training cycles, scheduled maintenance periods, 

certification schedules, and deployment requirements. Because of the complex logistical considerations 

involved with maintaining ship schedules, the Navy does not have the flexibility to extend the amount of 

time that ships are underway, which would result from vessel speed restriction mitigation. If the Navy 

were to incorporate vessel speed restrictions into event planning for approximately 3–6 months out of 

the year, ships would be unable to meet all of their requirements during their limited time available to 

be underway. This would hold true even if the restrictions only applied to transits to and from training 

or testing event locations and not during the events themselves. Therefore, it would not be practical for 

the Navy to implement speed restrictions within Dynamic Management Areas or Seasonal Management 

Areas.

Navy vessel operators need to train to proficiently operate vessels as they would during military 

missions and combat operations, including being able to react to changing tactical situations and 

evaluate system capabilities. For example, during training activities involving flight operations from an 

aircraft carrier, the vessel must maintain a certain wind speed over the deck to launch or recover 

aircraft. Depending on wind conditions, the aircraft carrier itself must travel at a certain speed to 

generate the wind required to launch or recover aircraft. Implementing vessel speed restrictions would

increase safety risks for Navy personnel and equipment and the public during the training event and 

would reduce skill proficiency in a way that would increase safety risks during military missions and 

combat operations. Furthermore, vessel speed restrictions would not allow the Navy to continue 

meeting its training requirements due to diminished realism of training exercises.

The Navy needs to test the full range of its vessel and system capabilities to ensure safety and 

functionality in conditions analogous to military missions and combat operations. For example, during 

non-explosive torpedo testing activities, the Navy must operate its vessels using speeds typical of 

military missions and combat operations to accurately test the functionality of its acoustic 

countermeasures and torpedo systems during firing on submarine and vessel targets. The Navy conducts 

some activities, such as Aircraft Carrier Sea Trials – Propulsion Testing, specifically to test the 

functionality of vessel propulsion systems, including maneuvering, full-power runs, and endurance runs. 

During this event, ships must operate across the full spectrum of capable speeds to accomplish the 

primary testing objectives. Vessel speed restrictions would not allow the Navy to continue meeting its 

testing program requirements due to diminished realism of testing events. Researchers, program 
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managers, and weapons system acquisition programs would be unable to conduct accurate acoustic 

research to meet research objectives and effectively test vessels and vessel-deployed systems and 

platforms before full-scale production or delivery to the fleet. Such testing is required to ensure 

functionality and accuracy in military mission and combat conditions per required acquisition milestones 

or on an as-needed basis to meet operational requirements.

In summary, the operational community determined that implementing procedural mitigation for vessel 

movements beyond what is detailed in Table 5.3-18 and implementing restrictions on vessel speed

beyond what is detailed in Table 5.4-2 and Table 5.4-3 (including speed restrictions in Dynamic 

Management Areas, Seasonal Management Areas, or other locations in the Study Area) would be 

incompatible with the practicality assessment criteria for safety, sustainability, and mission

requirements.

5.3.4.2 Towed In-Water Devices

The Navy will continue to implement procedural mitigation to avoid or reduce the potential for strike of 

marine mammals and sea turtles from towed in-water devices, as outlined in Table 5.3-19. Vessels 

involved in towing in-water devices will implement the mitigation described in Section 5.3.4.1 (Vessel 

Movement), in addition to the mitigation outlined in Table 5.3-19.

Table 5.3-19: Procedural Mitigation for Towed In-Water Devices

Procedural Mitigation Description

Stressor or Activity

 Towed in-water devices 

 Mitigation applies to devices that are towed from a manned surface platform or manned aircraft

 The mitigation will not be applied if the safety of the towing platform or in-water device is threatened

Resource Protection Focus

 Marine mammals

 Sea turtles

Number of Lookouts and Observation Platform

 1 Lookout positioned on the manned towing platform

Mitigation Requirements

 Mitigation zones:

 250 yd. around marine mammals

 Within the vicinity of sea turtles

 During the activity (i.e., when towing an in-water device):

 Observe the mitigation zone for marine mammals and sea turtles; if observed, maneuver to maintain distance.

The small mitigation zone size and proximity to the observation platform will result in a high likelihood 

that Lookouts will be able to detect marine mammals throughout the mitigation zone when manned 

vessels or manned aircraft are towing in-water devices. A mitigation zone size is not specified for sea 

turtles to allow flexibility based on towing platform type and mission requirements (e.g., small boats 

operating in a narrow harbor). 

The mitigation zones for towed in-water devices are based on the largest areas within which it is 

practical for the Navy to implement mitigation. When developing Phase III mitigation, the Navy analyzed 

the potential for increasing the size of the mitigation zones. Mission and safety requirements determine 

the operational parameters (e.g., course) for in-water device towing platforms. Towed in-water devices 

must be towed at certain speeds and water depths for stability, which are controlled in part by the

towing platform’s speed and directional movements. Because these devices are towed and not selfpropelled, they generally have limited maneuverability and are not able to make immediate course 

corrections. For example, during a Mine Countermeasure – Towed Mine Neutralization activity using 
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rotary-wing aircraft, towed devices are used to trigger mines and perform various other functions, such 

as detaching floating moored mines. A high degree of pilot skill is required in deploying devices, safely 

towing them at relatively low speeds and altitudes, and then recovering devices. The aircraft can safely 

alter course to shift the route of the towed device in response to a sighted marine mammal or sea turtle 

up to a certain extent (i.e., up to the size of the mitigation zone) while still maintaining the parameters 

needed for stable towing. However, the aircraft would be unable to further alter its course to more 

drastically course-correct the towed device without decreasing towing stability, which would have 

implications for safety of personnel and equipment.

5.3.4.3 Small-, Medium-, and Large-Caliber Non-Explosive Practice Munitions

The Navy will continue to implement procedural mitigation to avoid or reduce the potential for strike of 

marine mammals and sea turtles from small-, medium-, and large-caliber non-explosive practice 

munitions, as outlined in Table 5.3-20. In addition to procedural mitigation, the Navy will implement 

mitigation for small-, medium-, and large-caliber non-explosive practice munitions within mitigation 

areas (see Section 5.4.1, Mitigation Areas for Seafloor Resources and Section 5.4.3, Mitigation Areas off 

the Mid-Atlantic and Southeastern United States).

Table 5.3-20: Procedural Mitigation for Small-, Medium-, and Large-Caliber NonExplosive Practice Munitions

Procedural Mitigation Description

Stressor or Activity

 Gunnery activities using small-, medium-, and large-caliber non-explosive practice munitions

 Mitigation applies to activities using a surface target

Resource Protection Focus

 Marine mammals

 Sea turtles

Number of Lookouts and Observation Platform

 1 Lookout positioned on the platform conducting the activity

 Depending on the activity, the Lookout could be the same as the one described in Section 5.3.2.4 (Weapons Firing Noise).

Mitigation Requirements

 Mitigation zone:

 200 yd. around the intended impact location

 Prior to the initial start of the activity (e.g., when maneuvering on station):

 Observe the mitigation zone for floating vegetation; if observed, relocate or delay the start until the mitigation zone is clear.

 Observe the mitigation zone for marine mammals and sea turtles; if observed, relocate or delay the start of firing.

 During the activity:

 Observe the mitigation zone for marine mammals and sea turtles; if observed, cease firing.

 Commencement/recommencement conditions after a marine mammal or sea turtle sighting before or during the activity:

 The Navy will allow a sighted marine mammal or sea turtle to leave the mitigation zone prior to the initial start of the activity 

(by delaying the start) or during the activity (by not recommencing firing) until one of the following conditions has been met:

(1) the animal is observed exiting the mitigation zone; (2) the animal is thought to have exited the mitigation zone based on a 

determination of its course, speed, and movement relative to the intended impact location; (3) the mitigation zone has been 

clear from any additional sightings for 10 min. for aircraft-based firing or 30 min. for vessel-based firing; or (4) for activities 

using a mobile target, the intended impact location has transited a distance equal to double that of the mitigation zone size 

beyond the location of the last sighting.

The mitigation zone is conservatively designed to be several times larger than the impact footprint for 

large-caliber non-explosive practice munitions, which are the largest projectiles based on the military 

expended material impact footprints calculated in Appendix F (Military Expended Material and Direct 

Strike Impact Analysis). Small-caliber and medium-caliber non-explosive practice munitions have smaller
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impact footprints than large-caliber non-explosive practice munitions; therefore, the mitigation zone will 

extend even further beyond the impact footprints for these smaller projectiles.

Large-caliber gunnery activities involve vessels firing projectiles at a target located up to 6 NM down 

range. Small- and medium-caliber gunnery activities involve vessels or aircraft firing projectiles at targets 

located up to 4,000 yd. down range, although typically much closer. Lookouts will have a better 

likelihood of detecting marine mammals and sea turtles when observing mitigation zones around targets 

located close to the firing platform. When observing activities that use a target located far from the 

firing platform, Lookouts will be more likely to detect large visual cues (e.g., whale blows or large pods 

of dolphins) than individual marine mammals, cryptic marine mammal species, and sea turtles.

Observing for indicators of marine mammal and sea turtle presence will further help avoid or reduce 

potential impacts on these resources within the mitigation zone. Positioning additional observers closer 

to the targets would increase safety risks because these platforms would be located in the vicinity of an 

intended impact location or in the path of a projectile. 

5.3.4.4 Non-Explosive Missiles and Rockets

The Navy will continue to implement procedural mitigation to avoid or reduce the potential for strike of 

marine mammals and sea turtles from non-explosive missiles and rockets, as outlined in Table 5.3-21. In 

addition to procedural mitigation, the Navy will implement mitigation for non-explosive missiles and 

rockets within mitigation areas (see Section 5.4.1, Mitigation Areas for Seafloor Resources and Section 

5.4.3, Mitigation Areas off the Mid-Atlantic and Southeastern United States).

Table 5.3-21: Procedural Mitigation for Non-Explosive Missiles and Rockets

Procedural Mitigation Description

Stressor or Activity

 Aircraft-deployed non-explosive missiles and rockets

 Mitigation applies to activities using a surface target

Resource Protection Focus

 Marine mammals

 Sea turtles

Number of Lookouts and Observation Platform

 1 Lookout positioned in an aircraft

Mitigation Requirements

 Mitigation zone:

 900 yd. around the intended impact location

 Prior to the initial start of the activity (e.g., during a fly-over of the mitigation zone):

 Observe the mitigation zone for floating vegetation; if observed, relocate or delay the start until the mitigation zone is clear.

 Observe the mitigation zone for marine mammals and sea turtles; if observed, relocate or delay the start of firing.

 During the activity:

 Observe the mitigation zone for marine mammals and sea turtles; if observed, cease firing.

 Commencement/recommencement conditions after a marine mammal or sea turtle sighting prior to or during the activity:

 The Navy will allow a sighted marine mammal or sea turtle to leave the mitigation zone prior to the initial start of the activity 

(by delaying the start) or during the activity (by not recommencing firing) until one of the following conditions has been met:

(1) the animal is observed exiting the mitigation zone; (2) the animal is thought to have exited the mitigation zone based on a 

determination of its course, speed, and movement relative to the intended impact location; or (3) the mitigation zone has 

been clear from any additional sightings for 10 min. when the activity involves aircraft that have fuel constraints, or 30 min. 

when the activity involves aircraft that are not typically fuel constrained.

The mitigation zone for non-explosive missiles and rockets is conservatively designed to be several times 

larger than the impact footprint for the largest non-explosive missile based on the military expended 

material impact footprints calculated in Appendix F (Military Expended Material and Direct Strike Impact 

Analysis). Smaller non-explosive missiles and non-explosive rockets have smaller impact footprints than 
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the largest non-explosive missile used for these activities; therefore, the mitigation zone will extend 

even further beyond the impact footprints for these smaller projectiles.

Mitigation applies to activities using non-explosive missiles or rockets fired from aircraft at targets that 

are typically located up to 15 NM down range, and infrequently up to 75 NM down range. There is a 

chance that animals could enter the mitigation zone after the aircraft conducts its close-range mitigation 

zone observations and before firing begins (once the aircraft has transited to its firing position). Due to 

the distance between the mitigation zone and the observation platform, Lookouts will have a better 

likelihood of detecting marine mammals and sea turtles during the close-range observations and are less

likely to detect these resources once positioned at the firing location, particularly individual marine 

mammals, cryptic marine mammal species, and sea turtles. Observing for indicators of marine mammal 

and sea turtle presence will further help avoid or reduce potential impacts on these resources within the 

mitigation zone during the close-range observations. The mitigation only applies to aircraft-deployed 

missiles and rockets for the reasons discussed in Section 5.3.3.4 (Explosive Missiles and Rockets).

Positioning additional observers closer to the targets would increase safety risks because these 

platforms would be located in the vicinity of an intended impact location or in the path of a projectile.

5.3.4.5 Non-Explosive Bombs and Mine Shapes

The Navy will continue to implement procedural mitigation to avoid or reduce the potential for strike of 

marine mammals and sea turtles from non-explosive bombs and mine shapes, as outlined in Table 

5.3-22. In addition to procedural mitigation, the Navy will implement mitigation for non-explosive 

bombs and mine shapes within mitigation areas (see Section 5.4.1, Mitigation Areas for Seafloor 

Resources; Section 5.4.2, Mitigation Areas off the Northeastern United States; and Section 5.4.3, 

Mitigation Areas off the Mid-Atlantic and Southeastern United States).

Table 5.3-22: Procedural Mitigation for Non-Explosive Bombs and Mine Shapes

Procedural Mitigation Description

Stressor or Activity

 Non-explosive bombs

 Non-explosive mine shapes during mine laying activities

Resource Protection Focus

 Marine mammals

 Sea turtles

Number of Lookouts and Observation Platform

 1 Lookout positioned in an aircraft

Mitigation Requirements

 Mitigation zone:

 1,000 yd. around the intended target

 Prior to the start of the activity (e.g., when arriving on station):

 Observe the mitigation zone for floating vegetation; if observed, relocate or delay the start until the mitigation zone is clear.

 Observe the mitigation zone for marine mammals and sea turtles; if observed, relocate or delay the start of bomb 

deployment or mine laying.

 During the activity (e.g., during approach of the target or intended minefield location):

 Observe the mitigation zone for marine mammals and sea turtles; if observed, cease bomb deployment or mine laying.

 Commencement/recommencement conditions after a marine mammal or sea turtle sighting prior to or during the activity:

 The Navy will allow a sighted marine mammal or sea turtle to leave the mitigation zone prior to the initial start of the activity 

(by delaying the start) or during the activity (by not recommencing bomb deployment or mine laying) until one of the 

following conditions has been met: (1) the animal is observed exiting the mitigation zone; (2) the animal is thought to have 

exited the mitigation zone based on a determination of its course, speed, and movement relative to the intended target or 

minefield location; (3) the mitigation zone has been clear from any additional sightings for 10 min.; or (4) for activities using 

mobile targets, the intended target has transited a distance equal to double that of the mitigation zone size beyond the 

location of the last sighting.
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The mitigation zone for non-explosive bombs and mine shapes is conservatively designed to be several 

times larger than the impact footprint for the largest non-explosive bomb based on the military 

expended material impact footprints calculated in Appendix F (Military Expended Material and Direct 

Strike Impact Analysis). Smaller non-explosive bombs and mine shapes have smaller impact footprints 

than the largest non-explosive bomb used for these activities; therefore, the mitigation zone will extend 

even further beyond the impact footprints for these smaller military expended materials.

Activities involving non-explosive bombing and mine laying involve aircraft deploying munitions or mine 

shapes from a relatively steady altitude of approximately 1,500 ft. at a surface target or in an intended 

minefield located beneath the aircraft. Due to the mitigation zone size, proximity to the observation 

platform, and the good vantage point from an aircraft, Lookouts will be able to observe the entire 

mitigation zone during approach of the target or intended minefield location. Observing for indicators of 

marine mammal and sea turtle presence will further help avoid or reduce potential impacts on these 

resources within the mitigation zone.

5.4 MITIGATION AREAS TO BE IMPLEMENTED

The first section (Section 5.4.1, Mitigation Areas for Seafloor Resources) describes mitigation areas that 

are designed to avoid or reduce potential impacts on seafloor resources throughout the Study Area. The 

remaining sections are organized by geographic region.

5.4.1 MITIGATION AREAS FOR SEAFLOOR RESOURCES

As outlined in Table 5.4-1 and shown in Figure 5.4-1, Figure 5.4-2, and Figure 5.4-3, the Navy will 

implement mitigation to avoid or reduce potential impacts on biological or cultural resources that are 

not observable by Lookouts from the water’s surface (i.e., resources for which procedural mitigation 

cannot be implemented).

5.4.1.1 Resource Description

Seafloor resources fulfill important ecosystem functions. Live hard bottom habitats and artificial 

structures (e.g., artificial reefs, shipwrecks) provide attachment substrate for aquatic vegetation and 

invertebrates, such as corals, seaweed, seagrass, macroalgae, and sponges. These habitats in turn 

support a community of organisms, such as fish, shrimp, crabs, barnacles, worms, and sea cucumbers. 

Shallow-water coral reefs provide substrate, shelter, and food for hundreds of invertebrate species, sea 

turtles, fishes, and other biological resources. They are one of the most productive and diverse 

assemblages on Earth. 

Dive sites occur throughout nearshore areas of the Study Area where there are shipwrecks, artificial 

reefs, and shallow-water coral reefs, making these resources highly valuable from a socioeconomic 

standpoint. Similarly, submerged aquatic vegetation provides important habitat for commercially and 

recreationally important fish species. Historic shipwrecks are classified as archaeological resources and 

are an important part of maritime history. For additional information on the biological, cultural, and 

socioeconomic importance of seafloor resources and their associated ecosystem components, refer to 

Chapter 3.3 (Vegetation), Chapter 3.4 (Invertebrates), Chapter 3.5 (Habitats), Chapter 3.6 (Fishes), 

Chapter 3.7 (Marine Mammals), Chapter 3.8 (Reptiles), Chapter 3.10 (Cultural Resources), and Chapter 

3.11 (Socioeconomics). 
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Table 5.4-1: Mitigation Areas for Seafloor Resources

Mitigation Area Description

Stressor or Activity

 Explosives

 Physical disturbance and strikes

Resource Protection Focus

 Shallow-water coral reefs

 Live hard bottom

 Artificial reefs

 Submerged aquatic vegetation

 Shipwrecks

Mitigation Area Requirements (year-round)

 Within the anchor swing circle of shallow-water coral reefs, live hard bottom, artificial reefs, submerged aquatic vegetation, 

and shipwrecks:

 The Navy will not conduct precision anchoring (except in designated anchorages).

 Within a 350-yd. radius of live hard bottom, artificial reefs, submerged aquatic vegetation, and shipwrecks:

 The Navy will not conduct explosive mine countermeasure and neutralization activities or explosive mine neutralization 

activities involving Navy divers (except in designated locations, such as Truman Harbor and Demolition Key, where these 

resources will be avoided to the maximum extent practicable).

 The Navy will not place mine shapes, anchors, or mooring devices on the seafloor.

 Within a 350-yd. radius of shallow-water coral reefs:

 The Navy will not conduct explosive or non-explosive small-, medium-, and large-caliber gunnery activities using a surface 

target; explosive or non-explosive missile and rocket activities using a surface target; explosive or non-explosive bombing and

mine laying activities; explosive or non-explosive mine countermeasure and neutralization activities; and explosive or nonexplosive mine neutralization activities involving Navy divers.

 The Navy will not place mine shapes, anchors, or mooring devices on the seafloor.

 Within the Key West Range Complex:

 Vessels will operate within waters deep enough to avoid bottom scouring or prop dredging, with at least a 1-ft. clearance 

between the deepest draft of the vessel (with the motor down) and the seafloor at mean low water.

 Within the South Florida Ocean Measurement Facility Testing Range:

 The Navy will use real-time geographic information system and global positioning system (along with remote sensing 

verification) during deployment, installation, and recovery of anchors and mine-like objects and during deployment of bottomcrawling unmanned underwater vehicles in waters deeper than 10 ft. to avoid shallow-water coral reefs and live hard bottom.

 Vessels deploying anchors, mine-like objects, and bottom-crawling unmanned underwater vehicles will aim to hold a relatively 

fixed position over the intended mooring or deployment location using a dynamic positioning navigation system with global 

positioning system.

 The Navy will minimize vessel movement and drift in accordance with mooring installation and deployment plans and will 

conduct activities during sea and wind conditions that allow vessels to maintain position and speed control during deployment, 

installation, and recovery of anchors, mine-like objects, and bottom-crawling unmanned underwater vehicles.

 Vessels will operate within waters deep enough to avoid bottom scouring or prop dredging, with at least a 1-ft. clearance 

between the deepest draft of the vessel (with the motor down) and the seafloor at mean low water.

 The Navy will not anchor vessels or spud over shallow-water coral reefs and live hard bottom.

 The Navy will use semi-permanent anchoring systems that are assisted with riser buoys over soft bottom habitats to avoid 

contact of mooring cables with shallow-water coral reefs and live hard bottom.

5.4.1.2 Mitigation Area Assessment

Without mitigation, explosives and physical disturbance and strike stressors could potentially impact 

shallow-water coral reefs, live hard bottom, artificial reefs, submerged aquatic vegetation, shipwrecks, 

and their associated ecosystem components during certain training and testing activities in the Study 

Area. The Navy developed mitigation areas as either the anchor swing circle diameter or a 350-yd. radius 

around a seafloor resource, as indicated by the best available georeferenced data. Mitigating within the 

anchor swing circle will protect seafloor resources during precision anchoring activities when factoring in 

environmental conditions that could affect anchoring position and swing circle size, such as winds, 

currents, and water depth. For other activities applicable to the mitigation, a 350-yd. radius around a 
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seafloor resource is a conservatively sized mitigation area that will provide protection well beyond the 

maximum expected impact footprint (e.g., crater and expelled material radius) of the explosives and 

non-explosive practice munitions used in the Study Area. As described in Appendix F (Military Expended 

Material and Direct Strike Impact Analysis), the military expended material with the largest footprint 

that applies to the mitigation is an explosive mine with 650-lb. net explosive weight, which has an 

estimated impact footprint of approximately 14,800 square ft. and associated radius of 22.7 yd. The 350-

yd. mitigation zone is well beyond the maximum expected direct impact footprint for the activities listed 

in Table 5.4-1, and further mitigates some level of indirect impact from explosive disturbances. Other 

applicable explosive activities and non-explosive practice munitions have a smaller impact footprint; 

therefore, the mitigation area will result in additional protection during those activities. 

The seafloor resource mitigation areas will help the Navy avoid or reduce potential impacts from 

explosives and physical disturbance and strike stressors on sensitive seafloor resources and to any 

biological or cultural resources that inhabit, shelter, rest, feed, or occur in the mitigation areas. As 

described in Chapter 3.5 (Habitats), other habitats, such as soft bottom, are expected to recover 

relatively quickly from potential disturbances; therefore, there would be a limited benefit of mitigation 

for other habitat types. The Navy does not have mitigation specific to scallop beds or deep-sea coral 

reefs because training and testing activities do not use bottom-placed explosive charges in locations 

where these resources are known to occur, such as within the Northeast Range Complexes.

To facilitate mitigation implementation, the Navy will include maps of the best available georeferenced 

data for shallow-water coral reefs, artificial reefs, live hard bottom, submerged aquatic vegetation, and 

shipwrecks in its Protective Measures Assessment Protocol. The Navy will include data that most 

accurately represent the natural boundaries of seafloor resources, as described in Building and 

Maintaining a Comprehensive Database and Prioritization Scheme for Overlapping Habitat Data (U.S. 

Department of the Navy, 2018b). Data presented in Chapter 3.3 (Vegetation), Chapter 3.4 

(Invertebrates), Chapter 3.5 (Habitats), and Chapter 3.10 (Cultural Resources) will serve as the baseline 

of best available georeferenced data for seafloor resource mitigation areas. Mitigation areas apply to 

georeferenced resources because the Navy requires accurate resource identification and mapping for 

mitigation to be effective and practical to implement.

Input from the operational community indicates that the mitigation detailed in Table 5.4-1 is practical to 

implement. Implementing additional mitigation for other activities or types of seafloor resources would 

not allow the Navy to continue meeting its mission requirements to successfully accomplish military 

readiness objectives. Expanding the mitigation to protect additional seafloor features where marine 

species are known to occur (e.g., soft bottom, which provides habitat for resources such as worms and 

clams) would essentially result in the Navy not conducting training and testing activities along the entire 

U.S. Atlantic Coast and in the Gulf of Mexico. This would prohibit the Navy from accessing a majority of 

its ranges and operating areas and conducting the Proposed Action in environments that are analogous 

to where the military operates, or may need to operate in the future, which would prevent it from 

meeting its mission requirements. This would also push training and testing activities farther offshore, 

which would have implications for safety and sustainability. Moving activities farther offshore would 

increase the distance from aircraft emergency landing fields, critical medical facilities, and search and 

rescue capabilities; would require excessive time on station or time away from homeport for Navy 

personnel; and would result in significant increases to operational costs.
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Notes: AFTT: Atlantic Fleet Training and Testing; OPAREA: Operating Area; SINKEX: sinking exercise; VACAPES: Virginia Capes

Figure 5.4-1: Seafloor Resource Mitigation Areas off the Northeastern United States
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Notes: AFTT: Atlantic Fleet Training and Testing; OPAREA: Operating Area; SINKEX: sinking exercise; VACAPES: Virginia Capes

Figure 5.4-2: Seafloor Resource Mitigation Areas off the Mid-Atlantic and Southeastern United States
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Notes: AFTT: Atlantic Fleet Training and Testing; OPAREA: Operating Area

Figure 5.4-3: Seafloor Resource Mitigation Areas in the Gulf of Mexico
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5.4.2 MITIGATION AREAS OFF THE NORTHEASTERN UNITED STATES

As described in Table 5.4-2 and shown in Figure 5.4-4, the Navy will implement mitigation within 

mitigation areas off the northeastern United States to, in combination with procedural mitigation, effect 

the least practicable adverse impact on marine mammal species or stocks and their habitat.

Table 5.4-2: Mitigation Areas off the Northeastern United States

Mitigation Area Description

Stressor or Activity

 Sonar

 Explosives 

 Physical disturbance and strikes

Resource Protection Focus

 Marine mammals

Mitigation Area Requirements (year-round)

 Northeast North Atlantic Right Whale Mitigation Area:

 The Navy will report the total hours and counts of active sonar and in-water explosives used in the mitigation area (i.e., the 

northeast North Atlantic right whale critical habitat) in its annual training and testing activity reports submitted to NMFS.

 The Navy will minimize the use of low-frequency active sonar, mid-frequency active sonar, and high-frequency active sonar to 

the maximum extent practicable within the mitigation area.

 The Navy will not use Improved Extended Echo Ranging sonobuoys (within 3 NM of the mitigation area), explosive and nonexplosive bombs, in-water detonations, and explosive torpedoes within the mitigation area.

 For activities using non-explosive torpedoes within the mitigation area, the Navy will conduct activities during daylight hours 

in Beaufort sea state 3 or less. The Navy will use three Lookouts (one positioned on a vessel and two in an aircraft during 

dedicated aerial surveys) to observe the vicinity of the activity. An additional Lookout will be positioned on the submarine, 

when surfaced. Immediately prior to the start of the activity, Lookouts will observe for floating vegetation and marine 

mammals; if observed, the activity will not commence until the vicinity is clear or the activity is relocated to an area where 

the vicinity is clear. During the activity, Lookouts will observe for marine mammals; if observed, the activity will cease. To 

allow a sighted marine mammal to leave the area, the Navy will not recommence the activity until one of the following 

conditions has been met: (1) the animal is observed exiting the vicinity of the activity; (2) the animal is thought to have exited 

the vicinity of the activity based on a determination of its course, speed, and movement relative to the activity location; or (3) 

the area has been clear from any additional sightings for 30 min. During transits and normal firing, ships will maintain a speed 

of no more than 10 knots. During submarine target firing, ships will maintain speeds of no more than 18 knots. During vessel 

target firing, vessel speeds may exceed 18 knots for brief periods of time (e.g., 10–15 min.).

 Before vessel transits within the mitigation area, the Navy will conduct a web query or email inquiry to the National 

Oceanographic and Atmospheric Administration Northeast Fisheries Science Center’s North Atlantic Right Whale Sighting 

Advisory System to obtain the latest North Atlantic right whale sightings information. Vessels will use the sightings 

information to reduce potential interactions with North Atlantic right whales during transits. Vessels will implement speed 

reductions within the mitigation area after observing a North Atlantic right whale, if transiting within 5 NM of a sighting 

reported to the North Atlantic Right Whale Sighting Advisory System within the past week, and if transiting at night or during 

periods of reduced visibility.

 Gulf of Maine Planning Awareness Mitigation Area:

 The Navy will report the total hours and counts of active sonar and in-water explosives used in the mitigation area in its 

annual training and testing activity reports submitted to NMFS.

 The Navy will not conduct >200 hours of hull-mounted mid-frequency active sonar per year within the mitigation area.

 The Navy will not conduct major training exercises (Composite Training Unit Exercises or Fleet Exercises/Sustainment 

Exercises) within the mitigation area. If the Navy needs to conduct a major training exercise within the mitigation area in 

support of training requirements driven by national security concerns, it will confer with NMFS to verify that potential 

impacts are adequately addressed in this Final EIS/OEIS and associated consultation documents.

 Northeast Planning Awareness Mitigation Areas:

 The Navy will avoid conducting major training exercises (Composite Training Unit Exercises or Fleet Exercises/Sustainment 

Exercises) within the mitigation area to the maximum extent practicable. 

 The Navy will not conduct more than four major training exercises per year within the mitigation area (all or a portion of the 

exercise). If the Navy needs to conduct additional major training exercises in the mitigation area in support of training 

requirements driven by national security concerns, it will provide NMFS with advance notification and include the information 

in its annual training and testing activity reports submitted to NMFS.
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Notes: AFTT: Atlantic Fleet Training and Testing; OPAREA: Operating Area

Figure 5.4-4: Mitigation Areas and Habitats Considered off the Northeastern United States
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5.4.2.1 Resource Description

The Navy assessed the northeastern United States region for potential mitigation areas. The assessment 

included, but was not limited to, the following marine mammal areas that have been established by 

NMFS as critical habitat or identified by LaBrecque et al. (2015b) as biologically important areas (as 

shown in Figure 5.4-4 and described in the sections below):

 Fin whale feeding area in the northern Gulf of Maine (June through October)

 Fin whale feeding area in the southern Gulf of Maine (year-round)

 Fin whale feeding area east of Montauk Point (March through October)

 Harbor porpoise small and resident population in the Gulf of Maine (July through September)

 Humpback whale feeding area in the Gulf of Maine, Stellwagen Bank, and the Great South 

Channel (March through December)

 Minke whale feeding area in the central Gulf of Maine - Parker Ridge and Cashes Ledge (March 

through November)

 Minke whale feeding area in the southwestern Gulf of Maine and Georges Bank (March through 

November)

 North Atlantic right whale critical habitat (northeastern U.S. foraging area; year-round)

 North Atlantic right whale mating area in the central Gulf of Maine (November through January)

 North Atlantic right whale feeding area on Jeffreys Ledge (June through July, October through 

December)

 North Atlantic right whale feeding area on Cape Cod Bay and Massachusetts Bay (February 

through April)

 North Atlantic right whale feeding area in the Great South Channel and on the northern edge of 

Georges Bank (April through June)

 North Atlantic right whale migratory corridor along the U.S. East Coast (upper portion) 

(November through December, March through April)

 Sei whale feeding area in the Gulf of Maine (May through November)

5.4.2.1.1 Fin Whales

Three areas in the AFTT Study Area were identified as biologically important fin whale feeding areas by 

LaBrecque et al. (2015b): (1) June to October in the northern Gulf of Maine; (2) year-round in the 

southern Gulf of Maine; and (3) March to October east of Montauk Point, which is located off the 

eastern tip of Long Island, New York. These areas were substantiated through vessel-based survey data, 

photo-identification data, and expert judgment. 

New England waters are considered the primary feeding grounds for fin whales (Waring et al., 2016). Fin 

whales are often seen closer to shore after periodic patterns of upwelling (upward water motion) and 

the resultant increased prey density (Azzellino et al., 2008). This species is highly adaptable, often 

following its prey off the continental shelf (Azzellino et al., 2008; Panigada et al., 2008). Fin whales feed 

primarily in higher latitudes from March through October when primary prey availability is high (Mizroch 

et al., 1984a), but more recently have been found to also feed in more southerly latitudes (Silva et al., 

2013). An important fin whale feeding area is located south of New England and directly east of 

Montauk Point between the 15-meter (m) and 50-m contours (Hain et al., 1992). Though most of the 

published literature on fin whale feeding areas is based on data more than 10 years old, LaBrecque et al. 
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(2015b) noted that unpublished sighting data of feeding fin whales from the Provincetown Center for 

Coastal Studies (1984–2011) spatially coincide with previously published data, indicating that these 

feeding areas continue to be important to the species. Data from Waring et al. (2016) and Palka (2012)

also show that fin whales continue to use these areas at least seasonally. 

Fin whale sightings and acoustic detections are highest in New England waters during spring and 

summer (Hain et al., 1992; Morano et al., 2012b; Waring et al., 2014). Agler et al. (1993) reported that 

fin whales were seen in the southern Gulf of Maine from March to October, while fin whales in the 

northern Gulf of Maine were seen only from June to October. In the southwestern Gulf of Maine, 

Provincetown Center for Coastal Studies recorded sightings of feeding fin whales in all months of the 

year; therefore, feeding in the southern Gulf of Maine is considered to occur year-round (LaBrecque et 

al., 2015b). 

Multi-year photo-identification data from the Gulf of Maine and Massachusetts Bay shows that 

individual fin whales displayed site fidelity over successive years. There is evidence of site fidelity by 

females and potentially some segregation by sexual, maturational, or reproductive class in the feeding 

areas (Agler et al., 1993; Waring et al., 2016). Photo-identification records from 1974–1988 show that 

female fin whales exhibit feeding site fidelity in the lower Bay of Fundy, Seal Island, and Mt. Desert in

the northern Gulf of Maine and in the Great South Channel, Jeffreys Ledge, and Stellwagen Bank in the 

southern Gulf of Maine (Agler et al., 1993). Photo-identification records from 1980–1987 identified 156 

individual fin whales within the Massachusetts Bay area feeding grounds (Seipt et al., 1990). 

Approximately 62 percent of these individuals were observed more than once and 45 percent were 

photographed in multiple years (some as many as 8 years) (Seipt et al., 1990). 

For additional information about fin whale habitats and geographic range, see Section 3.7.2.2.4.2 

(Habitat and Geographic Range).

5.4.2.1.2 Harbor Porpoise

One area in the AFTT Study Area was identified as a biologically important area for a small and resident 

population of harbor porpoises in the Gulf of Maine from July through September (LaBrecque et al., 

2015b). The area was delineated based on NMFS vessel and aerial surveys, genetic analyses, strandings, 

and bycatch reports, which have identified the area as having high concentrations of harbor porpoises 

seasonally (LaBrecque et al., 2015b).

In the U.S. Atlantic Ocean, harbor porpoises occur from the Bay of Fundy to North Carolina. From July to 

September, harbor porpoises are generally concentrated in the northern Gulf of Maine and southern 

Bay of Fundy region in waters shallower than 150 m (Gaskin, 1977; Kraus et al., 1983; Palka, 1995a; 

Palka, 1995b), with a few sightings in the upper Bay of Fundy and on the northern edge of Georges Bank 

(Palka, 2000). From October to December and April to June, harbor porpoises are widely dispersed from 

New Jersey to Maine, with lower densities farther north and south. From January to March, 

intermediate densities of harbor porpoises are found in waters off New Jersey to North Carolina, and 

lower densities are found in waters off New York to New Brunswick, Canada (Waring et al., 2016).

Unlike other cetacean species that use the Gulf of Maine and Bay of Fundy in the summer, harbor 

porpoises do not appear to have seasonal migrations or well-defined migration routes in the region 

(LaBrecque et al., 2015b). Some portion of the population is thought to use the region year-round 

(National Marine Fisheries Service, 2014; National Oceanic and Atmospheric Administration, 2015). 

Satellite tagging from 1994 and 1995 showed that some harbor porpoises were commonly found in the 

waters around the 92-m isobath, suggesting that this area may be used for migrations from the Bay of 
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Fundy to the lower Gulf of Maine (Read & Westgate, 1997); however, additional data are needed to 

verify the species’ movement patterns.

For additional information about harbor porpoise habitats and geographic range, see Section 

3.7.2.3.27.2 (Habitat and Geographic Range).

5.4.2.1.3 Humpback Whales

One area in the AFTT Study Area was identified by LaBrecque et al. (2015b) as a biologically important 

area for humpback whale feeding from March to December. The feeding area includes the Gulf of 

Maine, Stellwagen Bank, and the Great South Channel. It has been substantiated through photoidentification data, aerial and vessel survey data, radio tracking data, and expert judgment (LaBrecque et 

al., 2015b).

Humpback feeding habitats are typically shallow banks or ledges with high seafloor relief (Hamazaki, 

2002; Payne et al., 1990a). In the western North Atlantic, humpback whales feed during spring, summer 

and fall over a large geographic range that includes the Gulf of Maine, Gulf of St. Lawrence, 

Newfoundland Grand Banks, Labrador Sea, West Greenland, and Scotian Shelf (Cetacean and Turtle 

Assessment Program, 1982; Kenney & Winn, 1986; Stevick et al., 2006; Whitehead, 1982). Roberts et al. 

(2016) habitat-based density modeling depicted the areas of highest occurrence to be located south of 

Jeffreys Ledge, including Stellwagen Bank, the Great South Channel, and western Georges Bank. 

Humpback whale ecology in the Gulf of Maine has been studied since the mid-1970s (Clapham & Mayo, 

1987; Clapham & Mattila, 1990; Clapham et al., 1993; Hazen et al., 2009; Payne et al., 1986; Weinrich et 

al., 1997; Weinrich & Kuhlberg, 1991). The Gulf of Maine stock of humpback whales was designated as a 

separate feeding stock based on the strong site fidelity displayed by individual whales within the region

(Waring et al., 2016). Humpback whales feed in the Gulf of Maine from March through December, with 

most feeding activity observed in June and July. Humpback whale distribution in this region has been 

largely correlated to abundance of prey species, although behavior and bathymetry are factors 

influencing foraging strategy (Payne et al., 1990b). Humpback whales are frequently piscivorous when in 

New England waters, feeding on herring (Clupea harengus), sand lance (Ammodytes spp.), and other 

small fishes. In the northern Gulf of Maine, euphausiids are also a frequent prey item (Paquet et al., 

1997). Payne et al. (1986) suggested that an increase in the number of humpback whale sightings in the 

southwest Gulf of Maine since 1978 was concurrent with an increase in the number of sand lance in the 

same area. However, a significant correlation between humpback whale sightings on Georges Bank 

where sand lance was abundant was not found. Researchers found that environmental factors, such as 

topography, combined with foraging behavior (and not solely prey distribution) influence humpback 

whale feeding distribution (Payne et al., 1986).

For additional information about humpback whale habitats and geographic range, see Section 

3.7.2.3.1.2 (Habitat and Geographic Range).

5.4.2.1.4 Minke Whales

Two areas in the AFTT Study Area were identified as biologically important areas for minke whale 

feeding from March to November by LaBrecque et al. (2015b): (1) Central Gulf of Maine around Parker 

Ridge and Cashes Ledges, and (2) waters shallower than 200-m in the southern and southwestern 

section of the Gulf of Maine, including Georges Bank, the Great South Channel, Cape Cod Bay, 

Massachusetts Bay, Stellwagen Bank, Cape Anne, and Jeffreys Ledge. Identification of these areas was 

substantiated through vessel-based survey data and expert judgment (LaBrecque et al., 2015b).
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Minke whales are most abundant in New England waters from May through September, including the 

Gulf of Maine, Cape Cod Bay, Great South Channel, and Georges Bank (Waring et al., 2016). Year-round 

acoustic monitoring in Stellwagen Bank (2006 and 2007–2010) detected minke whale vocalizations from 

August to mid-November, with 88 percent of detections made in September and October and only a few 

detections made from March to June (Risch et al., 2013). Minke whales appear to be largely absent in 

New England waters in winter (LaBrecque et al., 2015b; Risch et al., 2013). Roberts et al. (2016) habitatbased density modeling depicts a markedly higher density of minke whales in these areas from April 

through October.

Minke whales have been observed feeding in the Great South Channel and adjacent waters from March 

through November (LaBrecque et al., 2015b). During vessel-based surveys from 1988 to 2011, the 

Provincetown Center for Coastal Studies recorded 19 sightings of individual minke whales feeding in 

waters shallower than 150 m along the northern edge of Georges Bank, Great South Channel, and 

Stellwagen Bank, and off Race Point, Massachusetts (LaBrecque et al., 2015b). From 1998 to 2009, the 

Northeast Fisheries Science Center aerial survey team recorded 15 sightings of minke whales feeding 

during all survey months (March to July and October) in waters shallower than 200 m (LaBrecque et al., 

2015b). Twenty-one observations of surface feeding were recorded from March through September 

during surveys within the 100-m isobath in the Great South Channel, along Cape Anne, and at Jeffreys 

Ledge (Cetacean and Turtle Assessment Program, 1982). Between 1979 and 1992, there were 27 

confirmed sightings of minke whales surface feeding in Cape Cod Bay, Massachusetts Bay, and at 

Stellwagen Bank (Murphy, 1995). Feeding group size was recorded in 24 of the 27 sightings. Two 

sightings were of pairs, one sighting was of three individuals, and the remaining sightings were of single 

individuals. 

For additional information about minke whale habitats and geographic range, see Section 3.7.2.3.2.2 

(Habitat and Geographic Range).

5.4.2.1.5 North Atlantic Right Whales

One area in the AFTT Study Area has been designated by NMFS as critical habitat for North Atlantic right 

whale feeding, which includes the Gulf of Maine and Georges Bank region. As described in Section 

3.7.2.2.2.2 (Habitat and Geographic Range), NMFS designated the critical habitat in 2016 to replace two 

smaller critical habitats that had been previously designated in 1994. Overlapping this critical habitat are 

four areas that were identified by LaBrecque et al. (2015b) as biologically important areas for North 

Atlantic right whales: (1) a feeding area on Jeffreys Ledge (June through July, October through 

December), (2) feeding areas in Cape Cod Bay and Massachusetts Bay (February through April), (3) 

feeding areas in the Great South Channel and the northern edge of Georges Bank (April through June), 

and (4) a migration area (November through December, March through April). 

North Atlantic right whales primarily feed on copepods (a type of zooplankton) (Jefferson et al., 2015; 

Waring et al., 2016) off the northeastern United States between February and December (Baumgartner 

& Mate, 2003; Baumgartner et al., 2003; Kenney et al., 1986; Weinrich et al., 2000). North Atlantic right 

whales arrive in Cape Bod Bay and Massachusetts Bay to feed in late winter, with peak abundance in 

March and April (Hamilton & Mayo, 1990; Mayo et al., 2004; National Oceanic and Atmospheric 

Administration, 2012). Passive acoustic monitoring studies indicate that North Atlantic right whale 

presence and calls are persistent in Massachusetts Bay throughout most of the year, except during July 

and August (Morano et al., 2012a; Mussoline et al., 2012). Call rates have been found to be highest from 

January through May with a peak in April (Mussoline et al., 2012).
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Aerial surveys conducted by NMFS and the Provincetown Center for Coastal Studies in the springs of 

1999–2006 found North Atlantic right whales along the northern edge of Georges Bank, in the Great 

South Channel, in Georges Basin, and in various locations in the Gulf of Maine. The sightings data show 

that North Atlantic right whales display a strong seasonal occurrence in these areas (Pace & Merrick, 

2008). Most spring feeding in the Great South Channel and northern edge of Georges Bank takes place

from April to June with a peak in May (Cetacean and Turtle Assessment Program, 1982; Kenney et al., 

1995). Tagged North Atlantic right whales have been found to forage at the surface and near the

seafloor in the Great South Channel, depending on copepod depth in the water column (Baumgartner et 

al., 2011; Winn et al., 1995). 

Individual North Atlantic right whales and mother-calf pairs depart the Great South Channel for the Bay 

of Fundy and Roseway Basin in late summer and fall (Brown et al., 2009). During this time, whales have 

been observed feeding at Jeffreys Ledge in the western Gulf of Maine. Recorded feeding activity at 

Jeffreys Ledge has been compiled from Cetacean and Turtle Assessment Program (1982) surveys, whalewatching trips, and the North Atlantic right whale sightings database. Each source of data recognized

two seasonal peaks: summer sightings from July to August primarily of mother-calf pairs, and fall 

sightings from October to December of all age classes. Jeffreys Ledge may serve as a stopover feeding 

area, especially for whales transiting between more northerly waters (Weinrich et al., 2000). Sightings at

Jeffreys Ledge peak between October and November (Weinrich et al., 2000; Weinrich et al., 2005). Skim 

feeding and near-surface feeding have been observed during the fall (Longley, 2012; Weinrich et al., 

2000). Acoustic monitoring at Jeffreys Ledge (2004–2005) has detected North Atlantic right whale calls 

from November to May, with the highest call rates from November to February (Mussoline et al., 2012). 

More dedicated surveys during the fall and early winter, as well as studies of the physical and 

oceanographic characteristics of Jeffreys Ledge, would provide more insight into the importance of this 

area as habitat for North Atlantic right whales (Weinrich et al., 2000).

In addition to the feeding areas, one location in the AFTT Study Area was identified by LaBrecque et al. 

(2015b) as a biologically important area for North Atlantic right whale mating based on a demographic 

comparison of North Atlantic right whale habitats conducted by Cole et al. (2013). The mating area is in 

the central Gulf of Maine and includes the Outer Falls and Cashes Ledge. Some North Atlantic right 

whales (mostly pregnant females and juveniles) return to the calving grounds off the southeastern 

United States in December and January, but the location of the rest of the population during the winter 

months is currently unknown. It is believed that the remaining population resides in the cold, offshore 

waters off the northeastern United States where prey availability is high (Bort et al., 2015). Research 

suggests that North Atlantic right whales are present in the Gulf of Maine throughout the winter and 

may be using the central Gulf of Maine, including Outer Falls and Cashes Ledge, as a potential mating 

area (Bort et al., 2015; Cole et al., 2013). Cole et al. (2013) found that North Atlantic right whales 

aggregate in the central Gulf of Maine during their believed conception period from November to 

January. A large number of reproductively successful males and females occur in this area during these 

months, when compared to other regions that were analyzed, such as the Bay of Fundy, Great South 

Channel, and Jeffreys Ledge. About half of the North Atlantic right whale population was sighted in this 

area between 2002 and 2008. Slightly less than half the individuals were identified as males, including 

some that were known fathers. Passive acoustic monitoring conducted by Bort et al. (2015) also showed 

that the central Gulf of Maine is a seasonally important habitat for right whales, with male display and 

mating behaviors possibly occurring at high rates in this area. Cole et al. (2013) does not refute the idea 

of conception possibly occurring outside of the identified mating area during the believed conception 

period, or that this population may have another mating area that has yet to be identified. Longley 
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(2012) proposed that in addition to feeding, North Atlantic right whales may use Jeffreys Ledge for 

mating. The timing of North Atlantic right whale sightings at Jeffreys Ledge corresponds with the timing 

of when mating is believed to occur (Kraus et al., 2007); however, mating activities in this area have yet 

to be confirmed. A longer term dataset is needed to better understand how North Atlantic right whales 

use the central Gulf of Maine for mating (Cole et al., 2013). 

LaBrecque et al. (2015b) also identified a biologically important area for North Atlantic right whale 

migration off the U.S. Atlantic coast from November through December and March through April. 

Section 5.4.3.1.3 (North Atlantic Right Whales) presents a discussion of the southern portion of the 

migration habitat. In the northeast, the migration habitat overlaps a portion of the northeastern North 

Atlantic right whale critical habitat and feeding areas. North Atlantic right whales undertake large 

seasonal migrations. LaBrecque et al. (2015b) identified a migratory corridor along the East Coast of the 

United States. The migratory corridor is used by North Atlantic right whales during southward 

migrations in November and December to calving grounds, and northward migrations in March and April

to feeding areas, the Bay of Fundy, and other unknown areas (Kenney, 2008; Roberts et al., 2016; Whitt 

et al., 2013). The subset of the population that has been observed migrating between the northern 

feeding grounds and southern calving grounds includes reproductively mature and pregnant females, 

juveniles, and young calves (Federal Register 81 [17]: 4838-4874). North Atlantic right whales are 

believed to migrate along the continental shelf (Schick et al., 2009; Whitt et al., 2013); however, it is 

unknown if the whales use the whole shelf area or just the nearshore waters (LaBrecque et al., 2015b). 

Tagging results from an analysis by Schick et al. (2009) suggest that the migratory corridor is broader 

than was initially estimated, and that suitable habitat exists beyond 20 NM from the coast, a distance 

that is presumed to represent the primary migratory pathway (National Marine Fisheries Service, 2008). 

NMFS has not defined critical habitat for North Atlantic right whale migration due to the lack of 

information on migratory routes and the lack of data needed to identify essential physical and biological 

features (Federal Register 81 [17]: 4838-4874).

For additional information about North Atlantic right whale habitats and geographic range, see Section 

3.7.2.2.2.2 (Habitat and Geographic Range).

5.4.2.1.6 Sei Whales

One area in the AFTT Study Area was identified as a biologically important area for sei whale feeding 

from May to November by LaBrecque et al. (2015b). The identification of this area was substantiated 

thorough vessel and aerial survey data, feeding information from commercial whale watching trips, and 

expert judgment (LaBrecque et al., 2015b). The area extends from the 25-m contour off coastal Maine 

and Massachusetts to the 200-m contour in the central Gulf of Maine, including the northern shelf break 

area of Georges Bank. The feeding area also includes the southern shelf break area of Georges Bank 

from 100–2,000 m and the Great South Channel. 

The sei whale is the only rorqual species that seems to have evolved the ability to capture prey both by 

engulfment (as do the other rorquals) or by skimming on relatively low prey concentrations (as do North 

Atlantic right whales and bowhead whales) (Prieto et al., 2012). This adaptation is reflected in the 

variety of prey recorded for the species. The sei whale has the most extensive diet of any baleen whale, 

which includes copepods, euphausiids, amphipods, decapods, cephalopods, and fish. Prey preferences 

are highly dependent on ocean basin and swarming characteristics of the prey (Prieto et al., 2012). Sei 

whales in the North Atlantic are largely planktivorous, feeding primarily on copepods, and secondarily 

on euphausiids (Baumgartner et al., 2011; Cetacean and Turtle Assessment Program, 1982; Flinn et al., 

2002; Jonsgard & Darling, 1977; Kenney & Winn, 1986; Mizroch et al., 1984b; Prieto et al., 2012). 
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Baumgartner et al. (2011) suggest that the distribution and vertical migrations of copepods influence the 

distribution, abundance, and calling behaviors of sei whales in the southwestern Gulf of Maine. 

Baumgartner and Fratantoni (2008) found that sei whale calling rates increased during the day when 

vertically migrating copepods were at depth and decreased at night when the copepods had migrated to 

the surface. Sei whales may be unable to feed on deep layers of copepods, and their increased calling 

behavior during the day may be associated with a reduction in feeding on copepods and an increase in 

socializing with conspecifics or switching to a different prey species (Baumgartner & Fratantoni, 2008).

Sei whales were once believed to visit the inshore waters of the Gulf of Maine (including the Great 

South Channel) only occasionally in response to increases in the availability of copepods (Payne et al., 

1990b; Schilling et al., 1992). However, Baumgartner et al. (2011) found sei whales to be reasonably 

common in the Great South Channel in most years. Sightings from the Cetacean and Turtle Assessment 

Program (1982) and data from NMFS shipboard surveys (Waring et al., 2014) found peak abundances of 

sei whales in U.S. Atlantic waters in spring. This was particularly true along the shelf break of Georges 

Bank, into the Northeast Channel, and southwest to Hydrographer Canyon. Roberts et al. (2016) habitatbased density modeling depicts the highest sei whale densities in the LaBrecque et al. (2015b)-identified 

feeding areas in May and June. LaBrecque et al. (2015b) suggested that feeding activity in U.S. Atlantic 

waters was concentrated from May to November, with a peak in July and August; however, the authors 

did not specify locations.

For additional information about sei whale habitats and geographic range, see Section 3.7.2.2.5.2 

(Habitat and Geographic Range).

5.4.2.2 Mitigation Area Assessment

When developing Phase III mitigation, the Navy analyzed the potential for increasing mitigation areas in 

the Study Area. Based on its ongoing analysis of the best available science and potential mitigation 

measures, the Navy determined it can implement additional mitigation measures off the northeastern 

United States under the Proposed Action to enhance protection of marine mammals (including North 

Atlantic right whales) to the maximum extent practicable. In addition to evaluating areas for marine 

mammals, the Navy assessed the potential for developing mitigation areas for explosives within Habitat 

Areas of Particular Concern for sandbar and sand tiger sharks. The Navy does not plan to conduct 

training or testing activities involving explosives in sandbar and sand tiger shark Habitat Areas of 

Particular Concern off the northeastern United States; therefore, mitigation for explosives within these 

areas is not warranted.

New mitigation developed for Phase III includes: (1) enlarging the Northeast North Atlantic Right Whale 

Mitigation Area to cover the full extent of the northeast North Atlantic right whale critical habitat, (2) 

developing new special reporting requirements for the use of active sonar and in-water explosives 

within the Northeast North Atlantic Right Whale Mitigation Area, and (3) developing a new mitigation 

area known as the Gulf of Maine Planning Awareness Mitigation Area to limit hull-mounted midfrequency active sonar hours, not conduct major training exercises, and implement special reporting 

requirements for the use of active sonar and in-water explosives. The remaining mitigation measures 

presented in Table 5.4-2 are continuations from Phase II.

Mitigation areas off the northeastern United States will avoid or reduce impacts on one or more marine 

mammal species or stocks and their habitat, as summarized below:

 Northeast North Atlantic Right Whale Mitigation Area. The Navy has enlarged the mitigation 

area to cover the full extent of the northeast North Atlantic right whale critical habitat. 
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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. Conducting nonexplosive torpedo activities during daylight hours in Beaufort sea state 3 or less will help 

increase Lookout effectiveness during these activities. 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 training and testing activities. The North Atlantic Right 

Whale Sighting Advisory System is a National Oceanographic and Atmospheric Administration 

program that collects sightings information off the northeastern United States from aerial 

surveys, shipboard surveys, whale watching vessels, and opportunistic sources, such as the U.S. 

Coast Guard, commercial ships, fishing vessels, and the public. By expanding the size of the 

Northeast North Atlantic Right Whale Mitigation Area, the Navy will avoid or reduce potential 

impacts on other marine mammal species within key areas of biological importance, such as 

humpback whale, minke whale, sei whale, and fin whale feeding areas and a small and resident 

population of harbor porpoises. The Navy will also implement new special reporting procedures 

to report the total hours and counts of active sonar and in-water explosives used in the 

mitigation area in its annual training and testing activity reports submitted to NMFS. The special 

reporting requirements will aid the Navy and NMFS in continuing to analyze potential impacts of 

training and testing in this area.

 Gulf of Maine Planning Awareness Mitigation Area. Newly developed for Phase III, the Gulf of 

Maine Planning Awareness Mitigation Area extends throughout the Gulf of Maine and 

southward over Georges Bank. The mitigation will further help the Navy avoid or reduce 

potential impacts on marine mammals from active sonar during major training exercises within 

key areas of biological importance, including North Atlantic right whale critical habitat; a portion 

of the northern North Atlantic right whale migration area; North Atlantic right whale, humpback 

whale, minke whale, sei whale, and fin whale feeding areas; a North Atlantic right whale mating 

area; and a small and resident population of harbor porpoises. The Navy will also implement 

special reporting procedures to report the total hours and counts of active sonar and in-water 

explosives used in the mitigation area in its annual training and testing activity reports

submitted to NMFS. The special reporting requirements will aid the Navy and NMFS in 

continuing to analyze potential impacts of training and testing in this area.

 Northeast Planning Awareness Mitigation Areas. The Northeast Planning Awareness Mitigation 

Areas extend across the shelf break and contain underwater canyons that have been associated 

with marine mammal feeding and abundance, including within a portion of the Northeast 

Canyons and Seamounts National Marine Monument. They are situated among highly 

productive environments, such as persistent oceanographic features associated with upwellings

and steep bathymetric contours. Continuing the mitigation within the Northeast Planning 

Awareness Mitigation Areas will help the Navy further avoid or reduce potential impacts from 

active sonar during major training exercises on marine mammals that inhabit, feed in, mate in, 

or migrate through the northeast region. For example, the mitigation areas overlap a portion of 

the North Atlantic right whale northern migration habitat. Fin whales are known to follow prey 

off the continental shelf in this region (Azzellino et al., 2008; Panigada et al., 2008). Sei whales 

have high abundance in two of the mitigation areas along the shelf break of Georges Bank and 

near Hydrographer Canyon (Waring et al., 2014).
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The Navy conducts training and testing activities off the northeastern United States because this region 

provides valuable access to sea space and airspace conditions analogous to areas where the Navy 

operates or may need to operate in the future. The Navy uses the Northeast Range Complexes and 

adjacent waters to support torpedo exercises, tracking exercises, Civilian Port Defense – Homeland 

Security Anti-Terrorism/Force Protection exercises, missile and rocket exercises, Maritime Security 

Operations – Anti-Swimmer Grenades activities, gunnery exercises, submarine sonar maintenance and 

system checks, kilo dip tests, at-sea sonar testing, and other air warfare, anti-submarine warfare, mine 

warfare, expeditionary warfare, and surface warfare activities. The Navy also performs acoustic and 

oceanographic research in continental shelf areas off the northeastern United States. Research 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 

seafloor.

Training and testing schedules are based on national tasking, the number and duration of training cycles 

identified in the Optimized Fleet Response Plan and other training plans, forecasting of future testing 

requirements, and emerging requirements. When scheduling activities, the Navy considers the need to 

minimize sea space and airspace conflicts within the northeast region and throughout the entire Study 

Area. For example, the Navy schedules training and testing to minimize conflicts between its own 

activities and with consideration for public safety (e.g., safe distances from commercial or recreational 

fishing activities). Daily fluctuations in training and testing schedules and objectives could mean that, on 

any given day, vessels or aircraft may depend on discrete locations of sea space or airspace off the 

northeastern United States for discrete purposes.

The Navy selects training areas in this region to allow for the realistic tactical development of the myriad 

training scenarios that Navy units are required to complete to be mission effective. For example, the 

topography and bathymetry in this region consists of a wide continental shelf leading to the shelf break, 

which affords a wide range of opportunities to plan and execute training exercises to certify forces to 

deploy. The Navy selects the locations (e.g., pierside in Boston, Massachusetts) and scenarios for Civilian 

Port Defense – Homeland Security Anti-Terrorism/Force Protection exercises according to Department 

of Homeland Security strategic goals and evolving world events. The Navy chooses locations for other 

training activities based on proximity to training ranges (e.g., Boston Operating Area), available airspace 

(e.g., warning area W-107A in the Atlantic City Range Complex), unobstructed sea space (e.g., 

throughout the Narragansett Bay Operating Area), and aircraft emergency landing fields (e.g., Quonset 

Point Air National Guard Base, Quonset Point, Rhode Island).

The Navy conducts testing activities in the northeast region because it provides a variety of bathymetric 

and environmental conditions necessary to ensure functionality and accuracy of systems and platforms 

in areas analogous to where the military operates. Testing locations are typically located near systems 

command support facilities, which provide critical safety, platform, and infrastructure support and 

technical expertise necessary to conduct testing (e.g., proximity to air squadrons). The Naval Undersea 

Warfare Center Division, Newport Testing Range provides critical sea space for the use of active sonar 

during Anti-Submarine Warfare Mission Package Testing events and other testing activities. The Navy 

has used the same torpedo testing areas in this region for decades because these areas provide critical 

bathymetric features and consistency for comparative data collection.

The Navy selects locations for acoustic and oceanographic research in the northeast because this region 

has ideal water depths for important research on shallow-water acoustic propagation. The northeast 

also has seafloor types that are of particular interest for ocean acoustics research and an abundance of 
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three-dimensional bathymetric phenomena (e.g., Hudson Canyon). The region provides unique 

opportunities for the Navy to conduct acoustic and oceanographic research experiments to observe 

systems with different acoustic parameters (e.g., frequency, directionality, signal) under a variety of 

environmental conditions (e.g., wind, waves, pre- and post-storms). The Northeast Range Complexes 

provide one of the most appropriate environments to test mine countermeasure systems during 

Emerging Mine Countermeasure Technology Research events, when considering how mine systems

would be used by an adversary. Logistical support for acoustic and oceanographic research experiments 

is available from university research vessels and the Naval Undersea Warfare Center Division, Newport. 

The Navy requires flexibility in the timing of its use of active sonar and explosives in order to meet 

individual training and testing schedules and deployment schedules. Navy vessels, aviation squadrons, 

and testing programs have a limited amount of time available for training and testing. The Navy must 

factor in variables such as maintenance and weather when scheduling event locations and timing. Major 

training exercise locations may have to change during an exercise or during exercise planning based on 

assessments of unit performance or other conditions, such as weather and mechanical issues. This

precludes the ability to completely prohibit major training exercises from occurring in this region. The 

schedules of other training activities, such as explosive missile exercises, are driven by deployment 

requirements and national command authority assignments. 

The testing community is required to install and test systems on platforms at the locations where those 

platforms are stationed. Testing associated with new construction ships must occur in locations close to 

the shipbuilder’s facilities in the northeast for reasons associated with construction schedule, proximity 

to testing ranges and facilities, and safety. Additionally, the testing community has a need for rapid 

development to quickly resolve tactical deficiencies. For example, due to its positioning within the 

boundary of the Naval Undersea Warfare Center Division, Newport Testing Range, the Navy will not 

develop a mitigation area for one of the habitats considered in Section 5.4.2.1 (Resource Description), 

the area east of Montauk Point that was identified by LaBrecque et al. (2015b) as a biologically 

important area for fin whale feeding. Overall, training and testing schedules can be cyclical and are 

partially driven by geo-political situations, which precludes the Navy from implementing additional 

mitigation to reduce or eliminate the use of active sonar or explosives off the northeastern United 

States.

The Navy determined that enlarging the Northeast North Atlantic Right Whale Mitigation Area to cover 

the full extent of the northeast North Atlantic right whale critical habitat, developing the new Gulf of 

Maine Planning Awareness Mitigation Area, and continuing the mitigation within the Northeast Planning 

Awareness Mitigation Areas as described in Table 5.4-2 would be practical to implement under the 

Proposed Action. This determination was based on an operational assessment of past use of active 

sonar, explosives, and non-explosive practice munitions; projected future training and testing needs in 

the region; and consideration of fleet concentration areas in the Study Area. The mitigation areas off the 

northeastern United States as described in Table 5.4-2 represent the largest areas and highest level of 

mitigation within each area that is practical for the Navy to implement within this region under the 

Proposed Action. Further modifications of training and testing activities off the northeastern United 

States would have a significant impact on safety, sustainability, and the Navy’s ability to meet its mission 

requirements.

Expanding the mitigation areas in this region would encroach upon the primary water space where 

training and testing activities are scheduled to occur. Implementing additional mitigation off the 

northeastern United States would have a significant impact on the ability for units to meet their 
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individual training and certification requirements (impacting the ability to deploy with the required level 

of readiness necessary to accomplish their missions), to certify forces 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), and for program managers and weapons system acquisition programs to 

meet testing requirements and required acquisition milestones. Based on the Navy’s assessment, 

additional mitigation in this region would increase operational costs (due to extending distance offshore, 

which would increase fuel consumption, maintenance, and time on station to complete required 

training and testing activities), increase safety risks (associated with conducting training and testing at 

extended distances offshore and farther away from critical medical and search and rescue capabilities), 

and accelerate fatigue-life of aircraft and ships (leading to increased safety risk and higher maintenance 

costs). Furthermore, additional mitigation would significantly impact training and testing realism due to 

reduced access to necessary environmental or oceanographic conditions that replicate military mission 

and combat conditions. This would diminish the ability for Navy Sailors to train and become proficient in 

using sensors and weapon systems as required during military missions and combat operations. 

Prohibiting or modifying certain activities, such as Civilian Port Defense – Homeland Security AntiTerrorism/Force Protection exercises, would also result in impacts on national security.

The iterative and cumulative impact of all potential mitigation measures the Navy assessed, including 

certain mitigation measures suggested through public comments on the Draft EIS/OEIS, would deny 

national command authorities the flexibility to respond to national security challenges and effectively 

accomplish the training necessary for deployment. For example, additional limitations on the use of 

active sonar and explosives off the northeastern United States would require the Navy to shift its 

training activities to alternative locations farther offshore, farther south along the Eastern seaboard, or 

to the Gulf of Mexico. This would have significant impacts on safety, sustainability, and the ability to 

meet mission requirements within limited available timeframes. Likewise, requiring weapons system 

program managers and research, testing, and development program managers to use alternative areas 

within limited available timeframes would deny them the necessary flexibility to rapidly field or develop 

systems to meet testing program requirements and emerging requirements.

In summary, the Navy developed the mitigation areas identified in Table 5.4-2 to provide further 

protection for marine mammals in areas the best available science suggests are important for foraging, 

migrating, and reproduction. The mitigation will help the Navy avoid or reduce potential impacts on 

harbor porpoises and fin, humpback, minke, North Atlantic right, and sei whales within the mitigation 

areas. Further restrictions off the northeastern United States on the level, number, or timing (seasonal 

or time of day) of training and testing activities would be impractical to due implications for safety, 

sustainability, and mission requirements.

5.4.3 MITIGATION AREAS OFF THE MID-ATLANTIC AND SOUTHEASTERN UNITED STATES

As described in Table 5.4-3 and shown in Figure 5.4-5, the Navy will implement mitigation within 

mitigation areas off the mid-Atlantic and southeastern United States to, in combination with procedural 

mitigation, effect the least practicable adverse impact on marine mammal species or stocks and their 

habitat and to avoid or reduce potential impacts on sea turtles and sandbar sharks.
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Table 5.4-3: Mitigation Areas off the Mid-Atlantic and Southeastern United States

Mitigation Area Description

Stressor or Activity

 Sonar

 Explosives

 Physical disturbance and strikes

Resource Protection Focus

 Marine mammals

 Sea turtles

 Fish (sandbar sharks)

Mitigation Area Requirements

 Southeast North Atlantic Right Whale Mitigation Area (November 15 through April 15):

 The Navy will report the total hours and counts of active sonar and in-water explosives used within the mitigation area in its 

annual training and testing activity reports submitted to NMFS.

 The Navy will not conduct: (1) low-frequency active sonar (except as noted below), (2) mid-frequency active sonar (except as 

noted below), (3) high-frequency active sonar, (4) missile and rocket activities (explosive and non-explosive), (5) small-, 

medium-, and large-caliber gunnery activities, (6) Improved Extended Echo Ranging sonobuoy activities, (7) explosive and 

non-explosive bombing activities, (8) in-water detonations, and (9) explosive torpedo activities within the mitigation area.

 To the maximum extent practicable, the Navy will minimize the use of: (1) helicopter dipping sonar, (2) low-frequency active 

sonar and hull-mounted mid-frequency active sonar used for navigation training, and (3) low-frequency active sonar and hullmounted mid-frequency active sonar used for object detection exercises within the mitigation area.

 Before transiting or conducting training or testing activities within the mitigation area, 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. The Fleet Area Control and Surveillance Facility, Jacksonville will advise vessels of all reported whale sightings 

in the vicinity to help vessels and aircraft reduce potential interactions with North Atlantic right whales. Commander 

Submarine Force U.S. Atlantic Fleet will coordinate any submarine activities that may require approval from the Fleet Area 

Control and Surveillance Facility, Jacksonville. Vessels will use the 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 within the past 12 hours, or when operating in the mitigation area at night or during periods of poor visibility. 

 To the maximum extent practicable, vessels will minimize north-south transits in the mitigation area.

 Jacksonville Operating Area (November 15 through April 15):

 Navy units conducting training or testing activities in the Jacksonville Operating Area will initiate communication with the 

Fleet Area Control and Surveillance Facility, Jacksonville to obtain Early Warning System North Atlantic right whale sightings 

data. The Fleet Area Control and Surveillance Facility, Jacksonville will advise vessels of all reported whale sightings in the 

vicinity to help vessels and aircraft reduce potential interactions with North Atlantic right whales. Commander Submarine 

Force U.S. Atlantic Fleet will coordinate any submarine activities that may require approval from the Fleet Area Control and 

Surveillance Facility, Jacksonville. The Navy will use the reported sightings information as it plans specific details of events 

(e.g., timing, location, duration) to minimize potential interactions with North Atlantic right whales to the maximum extent 

practicable. The Navy will use the reported sightings information to assist visual observations of applicable mitigation zones

and to aid in the implementation of procedural mitigation.

 Southeast North Atlantic Right Whale Critical Habitat Special Reporting Area (November 15 through April 15):

 The Navy will report the total hours and counts of active sonar and in-water explosives used within the Special Reporting Area 

(i.e., southeast North Atlantic right whale critical habitat) in its annual training and testing activity reports submitted to NMFS.

 Mid-Atlantic Planning Awareness Mitigation Areas (year-round):

 The Navy will avoid conducting major training exercises within the mitigation area (Composite Training Unit Exercises or Fleet 

Exercises/Sustainment Exercises) to the maximum extent practicable. 

 The Navy will not conduct more than four major training exercises per year (all or a portion of the exercise) within the 

mitigation area. If the Navy needs to conduct additional major training exercises in the mitigation area in support of training 

requirements driven by national security concerns, it will provide NMFS with advance notification and include the information 

in its annual training and testing activity reports submitted to NMFS.

 Navy Cherry Point Range Complex Nearshore Mitigation Area (March through September):

 The Navy will not conduct explosive mine neutralization activities involving Navy divers in the mitigation area.

 To the maximum extent practicable, the Navy will not use explosive sonobuoys, explosive torpedoes, explosive mediumcaliber and large-caliber projectiles, explosive missiles and rockets, explosive bombs, explosive mines during mine 

countermeasure and neutralization activities, and anti-swimmer grenades in the mitigation area.
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Notes: AFTT: Atlantic Fleet Training and Testing; OPAREA: Operating Area; SINKEX: sinking exercise; VACAPES: Virginia Capes

Figure 5.4-5: Mitigation Areas and Habitats Considered off the Mid-Atlantic and Southeastern United States
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5.4.3.1 Resource Description

The Navy assessed the mid-Atlantic and southeastern United States region for potential mitigation 

areas. The assessment included, but was not limited to, the following areas that have been established

by NMFS as critical habitat or habitat with high marine mammal abundance, or identified by LaBrecque 

et al. (2015b) as biologically important areas (as shown in Figure 5.4-5 and described in the sections 

below):

 Bottlenose dolphin Northern North Carolina Estuarine System small and resident population 

(year-round)

 Bottlenose dolphin Southern North Carolina Estuarine System small and resident population 

(year-round)

 Bottlenose dolphin Charleston Estuarine System small and resident population (year-round)

 Bottlenose dolphin Southern Georgia Estuarine System small and resident population (yearround)

 Bottlenose dolphin Jacksonville Estuarine System small and resident population (year-round)

 Cape Hatteras Special Research Area (year-round)

 North Atlantic right whale critical habitat (southeastern U.S. calving area; mid-November 

through late April)

 North Atlantic right whale calving habitat in the southeast Atlantic (mid-November through late 

April)

 North Atlantic right whale migratory corridor along the U.S. East Coast (southern portion) 

(November through December, March through April)

The primary focus of the mitigation area assessment was for marine mammals; however, because the 

Navy assessed sea space throughout the region, many of the geographic areas considered for marine 

mammals are also known to be inhabited by non-marine mammal species, such as sea turtles. For 

example, the Navy assessed the potential for developing mitigation areas within nearshore habitats 

along the coast of North Carolina, which are inhabited by marine mammals, sea turtles, sharks, and a 

variety of other marine species.

5.4.3.1.1 Bottlenose Dolphins

Five areas that overlap the AFTT Study Area were identified by LaBrecque et al. (2015b) as biologically 

important areas for small and resident populations of bottlenose dolphins along the U.S. East Coast: (1) 

the Northern North Carolina Estuarine System Population, (2) the Southern North Carolina Estuarine 

System Population, (3) the Charleston Estuarine System Population, (4) the Southern Georgia Estuarine 

System Population, and (5) the Jacksonville Estuarine System Population. The areas were recognized 

through various methods, including photo-identification, vessel surveys, satellite tagging, and genetic 

analyses. The small and resident populations are individual stocks that use coastal waters as important 

reproductive, migration, and feeding areas. 

The bottlenose dolphin coastal morphotype is continuously distributed along the U.S. East Coast south 

of Long Island, New York, around the Florida peninsula, and along the Gulf of Mexico coast. Although 

the structure of the individually recognized stocks is somewhat uncertain, it appears to be complex. Not 

every portion of the coast appears to be a significantly important bottlenose dolphin habitat; however, 

scientific evidence suggests that important breeding grounds, migration habitat, and foraging grounds 

for the individually recognized bottlenose dolphin coastal morphotypes are scattered throughout 
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coastal waters. The Charleston Estuarine System Population has high site fidelity based on data collected 

through photo-identification, remote biopsy, capture-release, and radio-tracking (Speakman et al., 

2006). Within the Charleston Estuarine System population, 839 animals have been individually 

identified, with 115 animals being observed up to 10 times over periods up to 10 years. The Southern 

Georgia Estuarine System Population also has high genetic and site fidelity. Further studies are required 

to better understand the residency patterns of the Northern North Carolina Estuarine System 

Population, the Southern North Carolina Estuarine System Population, and the Jacksonville Estuarine 

System Population. Due to ongoing photo-identification studies (including Navy-funded monitoring 

efforts), the full habitat extent of several of these small and resident populations is subject to change as 

new information becomes available (LaBrecque et al., 2015b).

For additional information about bottlenose dolphin habitats and geographic range, see Section 

3.7.2.3.10.2 (Habitat and Geographic Range).

5.4.3.1.2 Cape Hatteras Special Research Area

NMFS designated the Cape Hatteras Special Research Area as part of the Pelagic Longline Take 

Reduction Plan in January 2009 (National Marine Fisheries Service, 2009a). The area was designated due 

to high rates of pilot whale and Risso’s dolphin bycatch in the U.S. East Coast Atlantic pelagic longline 

fishery. Unique oceanographic properties exist in the area due to how the Gulf Stream separates from 

the continental slope to the deep ocean, and southward-flowing continental shelf waters from the 

Middle Atlantic Bight converge with northward-flowing continental shelf waters from the South Atlantic 

Bight. These water flow patterns support upwelling events and high biodiversity, two features that 

indicate an area could have high value for marine mammal feeding. NMFS management measures for 

the Cape Hatteras Special Research Area apply to fisheries and not to Navy activities; however, the Navy 

considered this area due to its potential as an important marine mammal feeding area.

Numerous species of marine mammals occur in the Cape Hatteras Special Research Area, including

beaked, fin, humpback, minke, and sperm whales; and pilot whales, bottlenose, short-beaked common, 

Atlantic spotted, striped, Clymene, and Risso’s dolphins. The area is thought to be important for shortfinned pilot whale feeding and is associated with high species abundance (Thorne et al., 2017). The area 

is also used seasonally during migrations by numerous species and overlaps the North Atlantic right 

whale migration habitat identified by LaBrecque et al. (2015b).

Navy monitoring data supports this area as having high diversity and density of marine mammals, 

including extremely high encounter rates for beaked whales. The Navy has been conducting aerial and 

vessel-based surveys off Cape Hatteras since July 2009 and acoustic monitoring since 2011. Between 

2009 and 2015, 14 species or species groups were observed during vessel-based surveys, totaling more 

than 500 animals (Foley et al., 2015). Vessel-based surveys typically took place during the spring, 

summer, and fall. Aerial surveys were conducted year-round, with one to two survey days per month, 

depending on weather conditions. During aerial surveys conducted over 16 days in January and 

December 2015, 13 species were observed, totaling 160 sightings and more than 5,000 individual 

cetaceans (McAlarney et al., 2016). Species observed included bottlenose, Atlantic spotted, shortbeaked common, Risso’s, striped, and Clymene dolphins; and short-finned pilot, Cuvier’s beaked, True’s 

beaked, sperm, humpback, minke, fin, mesoplodont beaked, and Kogia whales.

Satellite tagging of several deep-diving marine mammal species has also recently been conducted in the 

Cape Hatteras Special Research Area. In 2015, satellite tags were deployed on bottlenose dolphins, 

Cuvier’s beaked whales, short-finned pilot whales, and short-beaked common dolphins (Baird et al., 
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2016). In 2017, satellite tags were deployed on short-finned pilot whales and Cuvier’s beaked whales 

(Baird et al., 2018). The findings from these studies indicate that while individuals have varying levels of 

site fidelity, the continental slope area off Cape Hatteras appears to be an important location for these 

species. One deep-diving species, the sperm whale, is found east and northeast of Cape Hatteras 

throughout winter months (Waring et al., 2015). Sperm whales inhabit the area year-round; however, 

distribution primarily shifts north in the summer. Pilot whales (primarily short-finned) are commonly 

observed in waters off Cape Hatteras, generally along the continental shelf edge (Waring et al., 2016). 

Some species, such as Cuvier’s beaked whales, remained near the slope within the Cape Hatteras Special 

Research Area, while other species, such as short-finned pilot whales, traveled into more northern and 

southern waters before returning to the Cape Hatteras Special Research Area (Baird et al., 2016).

5.4.3.1.3 North Atlantic Right Whales

An area off the southeastern United States has been designated by NMFS as critical habitat for North 

Atlantic right whale calving. The southern North Atlantic right whale critical habitat includes the coasts

of North Carolina, South Carolina, Georgia, and Florida. As described in Section 3.7.2.2.2.2 (Habitat and 

Geographic Range), NMFS designated the critical habitat in 2016 to replace a smaller critical habitat that 

had been previously designated in 1994. Overlapping the critical habitat are areas identified by 

LaBrecque et al. (2015b) as biologically important habitat for North Atlantic right whale calving from 

mid-November to late April and migration from November through December and March through April. 

Waters off the southeastern United States are the primary wintering ground for calving females, other 

adults, and juvenile North Atlantic right whales. These waters are the only known calving ground for 

North Atlantic right whales and are used from November to April. North Atlantic right whales typically 

give birth from December to March (Knowlton et al., 1994; Kraus et al., 2007). Most sightings of 

neonates and calves have occurred during aerial surveys off southern Georgia and northeastern Florida 

(Garrison, 2007; Hamilton et al., 2007). During passive acoustic monitoring and visual surveys conducted 

off Savannah, Georgia and Jacksonville, Florida from 2009–2011, North Atlantic right whales were 

detected between November and April at both survey locations. More calls and sightings were recorded 

off Jacksonville than Savannah (Soldevilla et al., 2014). Aerial surveys sponsored by the Navy offshore of 

Jacksonville, Florida between 2009 and 2016 resulted in the following sightings: (1) a single whale 

approximately 40 NM offshore, (2) a female giving birth 40 NM offshore in March 2010 (U.S. 

Department of the Navy, 2011), (3) three whales approximately 20–25 NM offshore, and (4) two whales 

approximately 10 NM from shore. In the fall and winter of 2009–2010, Navy-sponsored acoustic 

recorders were deployed between 60–150 kilometers offshore of Jacksonville. Although sightings 

typically occur most frequently within continental shelf waters from northeastern Florida to

southeastern Georgia during the fall and winter, there were no North Atlantic right whale vocalizations 

detected during this passive acoustic monitoring study (Charif et al., 2015).

Sighting rates within North Atlantic right whale calving habitat have shown a correlation with water 

temperature and depth. One study found sighting rates to be highest in waters with sea surface 

temperatures less than 22°C and water depths between 10–20 m (Good, 2008). Gowan and Ortega-Ortiz 

(2014) found that sea surface temperature and water depth are significant factors in predicting North 

Atlantic right whale abundance on calving grounds. Using temperature and depth as habitat predictors, 

calving could occur over continental shelf waters as far north as Cape Lookout, North Carolina (Good, 

2008; Keller et al., 2012). Navy-sponsored monitoring conducted off Cape Hatteras, North Carolina in 

2011 and in Onslow Bay, North Carolina in 2007 confirmed the winter occurrence of North Atlantic right 

whales in these areas (U.S. Department of the Navy, 2014). During surveys conducted off the coast of 
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North Carolina in the winters of 2001 and 2002, researchers sighted eight calves, suggesting that the 

calving grounds may extend as far north as Cape Fear, North Carolina (Waring et al., 2016). The species 

has also been observed in winter around Cape Canaveral, Florida (Keller et al., 2006) and off South 

Carolina (McLellan et al., 2004).

LaBrecque et al. (2015b) used aerial sightings data and habitat analyses of sea surface temperatures and 

water depths to delineate the North Atlantic right whale calving area as extending from Cape Lookout, 

North Carolina to Cape Canaveral, Florida. The area encompasses waters from the shoreline to the 25-m

isobath from mid-November through late April. Only a few sightings of calves have been reported

outside of this area, such as a calf apparently born in the Gulf of Maine in the spring of 2007 (Patrician et 

al., 2009) and a newborn with its mother sighted off Plymouth Harbor, New England in January 2013 

(LaBrecque et al., 2015b).

North Atlantic right whales undertake large seasonal migrations, with some of the population traveling 

to cold and productive waters during spring and summer to feed, to warmer waters during winter to 

calve, or to other unknown wintering areas (Kenney, 2008; Roberts et al., 2016; Whitt et al., 2013). 

LaBrecque et al. (2015b) identified a migratory corridor along the East Coast of the United States that is 

used by North Atlantic right whales during southward migrations to the calving grounds in November 

and December, and northward migrations to the feeding areas, the Bay of Fundy, and other unknown 

areas in March and April. The subset of the population that has been observed migrating between the 

northern feeding grounds and southern calving grounds includes reproductively mature and pregnant 

females, juveniles, and young calves (Federal Register 81 [17]: 4838-4874). North Atlantic right whales 

are believed to migrate along the continental shelf (Schick et al., 2009; Whitt et al., 2013); however, it is 

unknown if the whales use the whole shelf area, or just the nearshore waters (LaBrecque et al., 2015b). 

Analysis by Schick et al. (2009) of a tagging survey suggests that the migratory corridor is broader than 

was initially estimated and that suitable habitat exists beyond 20 NM from the coast, a distance that is 

presumed to represent the primary migratory pathway (National Marine Fisheries Service, 2008). NMFS 

has not defined critical habitat for North Atlantic right whale migration due to the lack of information on 

migratory routes and data needed to identify essential physical and biological features (Federal Register 

81 [17]: 4838-4874). Section 5.4.2.1.5 (North Atlantic Right Whales) presents a discussion of the 

northern portion of the North Atlantic right whale migration area.

Recent passive acoustic monitoring studies have detected the presence of North Atlantic right whales 

along the mid-Atlantic coast throughout the year (Hodge et al., 2015; Oedekoven et al., 2015; Salisbury 

et al., 2015; Whitt et al., 2013). North Atlantic right whales were acoustically detected across all seasons 

along the coastal waters of North Carolina and Georgia in 2009. Seasonal occurrence peaked during fall 

off Georgia and during winter off North Carolina; however, a secondary peak occurrence was also 

recorded from June to July off Georgia, a season during which North Atlantic right whales were not 

previously believed to be in this region (Hodge et al., 2015). North Atlantic right whales were detected 

every month from June 2012 to June 2013 between the Virginia coast and the continental shelf. Whales 

were detected more in fall when they are thought to be migrating to the south; however, a high number 

of calls were also detected in late winter and early spring when whales are thought to be migrating to 

the northern feeding grounds (Salisbury et al., 2015). Additional monitoring is needed over a longer time 

span to better understand the seasonal occurrence of North Atlantic right whales in mid-Atlantic waters.

For additional information about North Atlantic right whale habitats and geographic range, see Section 

3.7.2.2.2.2 (Habitat and Geographic Range).
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5.4.3.2 Mitigation Area Assessment

When developing Phase III mitigation, the Navy analyzed the potential for increasing mitigation areas in 

the Study Area. Based on its ongoing analysis of the best available science and potential mitigation 

measures, the Navy determined it can implement additional mitigation measures off the mid-Atlantic 

and southeastern United States under the Proposed Action to enhance protection of marine mammals 

(including North Atlantic right whales) to the maximum extent practicable. In addition to evaluating 

areas for marine mammals, the Navy assessed the potential for developing mitigation areas for 

explosives within Habitat Areas of Particular Concern for sandbar and sand tiger sharks. The Navy does 

not plan to conduct training or testing activities involving explosives in sandbar and sand tiger shark 

Habitat Areas of Particular Concern off the mid-Atlantic and southeastern United States except for one 

small mission-essential area in the Lower Chesapeake Bay and in the Navy Cherry Point Range Complex; 

therefore, mitigation for explosives within the areas off New Jersey and Delaware is not warranted.

Information about the Habitat Areas of Particular Concern off Virginia and the new mitigation area 

developed off North Carolina is presented below.

New mitigation developed for Phase III includes: (1) enlarging 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, (2) developing a new mitigation area known as the 

Southeast North Atlantic Right Whale Critical Habitat Special Reporting Area with special reporting 

requirements for the use of active sonar and in-water explosives, (3) developing new mitigation 

measures to use Early Warning System North Atlantic right whale sightings data in the Jacksonville 

Operating Area, and (4) expanding the mitigation requirements for nearshore areas of the Navy Cherry 

Point Range Complex to include additional types of explosives to the maximum extent practicable. The 

remaining mitigation measures presented in Table 5.4-3 are continuations from Phase II.

Mitigation areas off the mid-Atlantic and southeastern United States will avoid or reduce impacts on 

one or more marine mammal species or stocks and their habitat, as summarized below:

 Southeast North Atlantic Right Whale Mitigation Area. The Navy has expanded the existing 

Southeast North Atlantic Right Whale Mitigation Area northward approximately 50 NM along 

the coast of northern Georgia from the shoreline out to 10–12 NM. The Navy expanded the 

mitigation area to correlate with the occurrence of North Atlantic right whales to the maximum 

extent practicable based on readiness requirements. The mitigation area encompasses a portion 

of the North Atlantic right whale migration and calving areas identified by LaBrecque et al. 

(2015b) and a portion of the southeast North Atlantic right whale critical habitat. Mitigation to 

not conduct or to limit the use of active sonar to the maximum extent practicable (depending on 

the source) and to not conduct in-water detonations and certain activities using explosives and 

non-explosive practice munitions will help the Navy further avoid or reduce potential impacts on 

North Atlantic right whales in these key habitat areas seasonally. The Navy will implement 

special reporting procedures to report the total hours and counts of active sonar and in-water 

explosives used in the mitigation area in its annual training and testing activity reports 

submitted to NMFS. The special reporting requirements will aid the Navy and NMFS in 

continuing to analyze potential impacts of training and testing in the mitigation area. Mitigation 

for vessel movements includes minimizing north-south transits, implementing speed reductions 

after vessels observe a North Atlantic right whale, if they are within 5 NM of a sighting reported 

within the past 12 hours, or when operating in the mitigation area at night or during periods of 

poor visibility, and continuing to participate in and sponsor the Early Warning System. The Early 
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Warning System 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). Navy participants include the Fleet Area Control and 

Surveillance Facility, Jacksonville; Commander, Naval Submarine Forces, Norfolk, Virginia; and 

Naval Submarine Support Command. The Navy, U.S. Coast Guard, U.S. Army Corps of Engineers, 

and NMFS collaboratively sponsor daily aerial surveys from December 1 through March 31 

(weather permitting) to observe for North Atlantic right whales from the shoreline out to 

approximately 30–35 NM offshore. Aerial surveyors relay sightings information to all mariners 

transiting within the North Atlantic right whale calving habitat (e.g., commercial vessels, 

recreational boaters, Navy ships).

 Jacksonville Operating Area. The Navy has developed new mitigation measures for units 

conducting training or testing activities in the Jacksonville Operating Area. The mitigation 

measures to obtain and use Early Warning System North Atlantic right whale sightings data will

help vessels and aircraft reduce potential interactions with North Atlantic right whales in 

portions of the southeast North Atlantic right whale critical habitat and North Atlantic right 

whale migration and calving areas identified by LaBrecque et al. (2015b).

 Southeast North Atlantic Right Whale Critical Habitat Special Reporting Area. Newly developed 

for Phase III, the Southeast North Atlantic Right Whale Critical Habitat Special Reporting Area

covers the entire southeast North Atlantic right whale critical habitat. The Navy will implement 

special reporting procedures to report the total hours and counts of active sonar and in-water 

explosives used in the mitigation area (i.e., the southeast North Atlantic right whale critical 

habitat) in its annual training and testing activity reports submitted to NMFS. The special 

reporting requirements will aid the Navy and NMFS in continuing to analyze potential impacts of 

training and testing in this area.

 Mid-Atlantic Planning Awareness Mitigation Areas. The Mid-Atlantic Planning Awareness 

Mitigation Areas extend across large swaths of shelf break and contain underwater canyons 

associated with high marine mammal diversity (e.g., Norfolk Canyon). The mitigation areas are 

situated among highly productive environments, such as persistent oceanographic features 

associated with upwellings and steep bathymetric contours. Continuing the mitigation within 

the Mid-Atlantic Planning Awareness Mitigation Areas will help the Navy further avoid or reduce 

potential impacts from active sonar during major training exercises on marine mammals that 

inhabit, feed in, reproduce in, or migrate through the mid-Atlantic region. For example, during 

recent passive acoustic monitoring surveys in Norfolk Canyon, researchers detected 

vocalizations of blue, fin, minke, sei, sperm, beaked, Kogia, and humpback whales, as well as 

Risso’s dolphins and unidentified delphinid species (Hodge et al., 2016). The Mid-Atlantic 

Planning Awareness Mitigation Areas overlap a portion of the North Atlantic right whale 

migration habitat. The more southern mitigation area also overlaps much of the Cape Hatteras 

Special Research Area.

 Navy Cherry Point Range Complex Nearshore Mitigation Area. The Navy is continuing an 

existing mitigation measure to not conduct explosive mine neutralization activities involving 

Navy divers from March through September within the mitigation area, which is defined as 

within 3.2 NM of an estuarine inlet and within 1.6 NM of the shoreline in the Navy Cherry Point 

Range Complex. For Phase III, the Navy is expanding the mitigation requirements in this

mitigation area to include additional in-water explosives to the maximum extent practicable. 

The mitigation will help the Navy avoid or reduce potential impacts on sea turtles near nesting 
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beaches during the nesting season and on sandbar sharks in Habitat Areas of Particular Concern.

The mitigation area also overlaps a portion of the North Atlantic right whale migration area 

identified by LaBrecque et al. (2015b).

The Navy conducts training and testing activities off the mid-Atlantic and southeastern United States 

because this region provides valuable access to sea space and airspace conditions analogous to areas 

where the Navy operates or may need to operate in the future. 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. The Navy also uses 

waters off the mid-Atlantic and southeastern United States for testing components of air warfare, mine 

warfare, surface warfare, anti-submarine warfare, electronic warfare, vessels and vessel signatures, 

unmanned systems; and other components, such as chemical and biological simulant testing. The Navy 

conducts pierside sonar testing at Kings Bay, Georgia; Norfolk, Virginia; and Port Canaveral, Florida. 

Training and testing schedules are based on national tasking, the number and duration of training cycles 

identified in the Optimized Fleet Response Plan and other training plans, forecasting of future testing 

requirements, and emerging requirements. When scheduling activities, the Navy considers the need to 

minimize sea space and airspace conflicts within the mid-Atlantic and southeast region and throughout 

the Study Area. For example, the Navy schedules training and testing to minimize conflicts between its 

own activities and with consideration for public safety (e.g., safe distances from recreational boating

activities). Daily fluctuations in training and testing schedules and objectives could mean that, on any 

given day, vessels may depend on discrete locations in waters off the mid-Atlantic and southeastern 

United States for discrete purposes.

The Navy selects training areas in this region to allow for the realistic tactical development of the myriad 

training scenarios that Navy units are required to complete to be mission effective. For example, the 

topography and bathymetry in this region consists of a wide continental shelf leading to the shelf break, 

which affords a wide range of opportunities to plan and execute major training exercises to certify 

forces to deploy. Certain activities, such as deployment certification exercises that involve integration 

with multiple warfare components, require large areas of the littorals and open ocean for realistic and 

safe training. The Jacksonville Operating Area and Charleston Operating Area represent critical training 

sea spaces that are necessary to prepare naval forces for combat. Training in these areas, such as mine 

countermeasure training, is vital to ensure Navy units are familiar with this region and will be able to 

operate and defend the U.S. mainland from adversaries. The Navy selects the locations (e.g., pierside in 

Kings Bay, Georgia) and scenarios for Civilian Port Defense – Homeland Security Anti-Terrorism/Force 

Protection exercises according to Department of Homeland Security strategic goals and evolving world 

events. The Navy uses coastal areas along the U.S. East Coast for a limited number of inshore training 

activities, such as Kings Bay, Georgia; Charleston Harbor, South Carolina; and St. John’s River, Florida.

The Navy chooses locations for other training activities based on proximity to 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 target storage and deployment locations (e.g., Mayport, Florida).

The Navy conducts testing activities in the mid-Atlantic and southeast region because it provides a 

variety of bathymetric and environmental conditions necessary to ensure functionality and accuracy of 

systems and platforms in areas analogous to where the military operates. Testing locations are typically 

located near systems command support facilities, which provide critical safety, platform, and 

infrastructure support and technical expertise necessary to conduct testing (e.g., proximity to air 
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squadrons). One example of an important bathymetric feature that provides testing realism and access 

to necessary environmental or oceanographic conditions in this region is Blake Plateau, which starts at 

the Continental shelf slope and extends eastward. Other pierside, nearshore, and offshore waters 

provide critical environments for a multitude of testing activities in this region.

The Navy requires flexibility in the timing of its use of active sonar and explosives in order to meet 

individual training and testing schedules and deployment schedules. Navy vessels, aviation squadrons, 

and testing programs have a limited amount of time available for training and testing. The Navy must 

factor in variables such as maintenance and weather (e.g., hurricanes) when scheduling event locations 

and timing. The Navy can restrict the number of major training exercises within the Mid-Atlantic 

Planning Awareness Mitigation Areas because it is not tied to a specific range support structure in this 

area for these events. However, major training exercise locations may have to change during an exercise 

or during exercise planning based on assessments of unit performance or other conditions, such as 

weather and mechanical issues. This precludes the ability to completely prohibit major training exercises 

from occurring in this region. The schedules of other training activities, such as explosive missile 

exercises, are driven by deployment requirements and national command authority assignments. 

The testing community is required to install and test systems on platforms at the locations where those 

platforms are stationed. Testing associated with new construction ships must occur in locations close to 

the shipbuilder’s facilities in the mid-Atlantic for reasons associated with construction schedule, 

proximity to testing facilities, and safety. Additionally, the testing community has a need for rapid 

development to quickly resolve tactical deficiencies. Overall, training and testing schedules can be 

cyclical and are partially driven by geo-political situations, which precludes the Navy from implementing 

additional mitigation to reduce or eliminate the use of active sonar or explosives in this region.

The Navy determined that enlarging the Southeast North Atlantic Right Whale Mitigation Area, 

developing the new mitigation measures for the Jacksonville Operating Area and Southeast North 

Atlantic Right Whale Critical Habitat Special Reporting Area, and continuing the mitigation within the 

Mid-Atlantic Planning Awareness Mitigation Areas as described in Table 5.4-3 would be practical to 

implement under the Proposed Action. This determination was based on an operational assessment of 

past use of active sonar, explosives, and non-explosive practice munitions; projected future training and 

testing needs in the region; and consideration of fleet concentration areas in the Study Area. The 

mitigation areas off the mid-Atlantic and southeastern United States as described in Table 5.4-3

represent the largest areas and highest level of mitigation within each area that is practical for the Navy 

to implement within this region under the Proposed Action. The Navy received public comments on the 

Draft EIS/OEIS requesting additional mitigation, such as avoiding the Charleston Bump, expanding 

mitigation areas to encompass the full extent of the Cape Hatteras Special Research Area, developing 

new mitigation areas based on predicted animal densities, developing mitigation areas for bottlenose 

dolphin small and resident populations identified by LaBrecque et al. (2015b), and further expanding the 

Southeast North Atlantic Right Whale Mitigation Area eastward to mirror the boundary of the expanded 

critical habitat and northward to encompass all areas of high animal density. The Navy assessed the 

potential to implement these and other additional mitigation measures and determined that further 

modifications of training and testing activities off the mid-Atlantic and southeastern United States would 

have a significant impact on safety, sustainability, and the Navy’s ability to meet its mission 

requirements, as discussed below.

On 27 January 2016, NMFS issued a Final Rule (81 FR 4838) extending the North Atlantic right whale 

critical habitat northward and eastward from the prior designation. In the 2016 Final Rule, NMFS 
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determined that the essential features for the expanded critical habitat area were water depth, water 

temperature, and sea surface roughness. Through the critical habitat expansion process, NMFS 

determined that current and future Navy mitigation areas should be correlated with the occurrence of 

North Atlantic right whales, and not with the critical habitat boundary or its essential features (due to 

implications for national security that would result from the Navy being required to expand its 

mitigation area to mirror the boundaries of the expanded critical habitat). The best available density 

data for the Study Area shows that the Navy’s Southeast North Atlantic Right Whale Mitigation Area 

encompasses the areas of highest density in the region (Roberts et al., 2016; U.S. Department of the 

Navy, 2017b). Although North Atlantic right whales have been sighted on rare occasions east of the 

mitigation area, these animals were located outside of the higher use habitats that represent the 

primary occurrence of the population. Overall, most North Atlantic right whale sightings made during 

Navy and NMFS surveys have occurred in or very near the Southeast North Atlantic Right Whale 

Mitigation Area, which further indicates that the mitigation area may have the highest seasonal 

abundance of North Atlantic right whales in waters off the mid-Atlantic and southeastern United States.

The Navy will implement mitigation within the Southeast North Atlantic Right Whale Mitigation Area to 

minimize the use of active sonar to the maximum extent practicable during three active sonar activities 

seasonally: helicopter dipping, object detection exercises, and navigation training. Helicopter dipping 

activities, such as Kilo Dip (a functional check activity) need to occur close to an air station in the event 

of a system failure if all systems are not functioning properly. Extending these activities farther offshore 

would significantly increase safety risks for Navy personnel and equipment, and the public. It would be 

impractical to restrict the number of navigation training and object detection exercises due to 

implications for the safety of the ship and the personnel on board. These exercises are required to 

ensure ships can navigate safely and operate safely in a mine threat environment that is extremely 

dangerous and life-threatening. Additional restrictions (e.g., seasonal limitations) would preclude units 

from conducting the necessary training to safely operate in military missions and combat operations.

Further expansions of the mitigation areas in this region would require the Navy to relocate its training 

to alternative locations, such as farther offshore. Moving activities farther offshore would reduce a 

unit’s training opportunities during its limited available training timeframes (i.e., increased time spent

transiting to more distant training areas results in decreased time available for training). This would also 

result in training and testing activities being conducted in water conditions that do not accurately reflect 

the types of environments where military missions and combat operations occur. Increasing transit 

distances would result in additional fuel consumption and expenditures, which could serve as a limiting 

factor for Navy surface units whose available underway times are constrained by fuel expenses. 

Some activities, such as surface-to-surface and air-to-surface small-, medium-, and large-caliber gunnery 

activities and missile and rocket activities, must be conducted in proximity to the target storage and 

deployment location in Mayport, Florida. Targets used for these activities have limitations on how far 

offshore they can be safely employed and controlled. For example, remote control jet ski targets stored 

at Naval Station Mayport would not be able to transit beyond the Southeast North Atlantic Right Whale 

Mitigation Area in challenging seas. Shifting events farther offshore would preclude the Navy from safely 

employing and controlling the targets necessary to conduct these training and testing activities, which 

would significantly impact the Navy’s ability to effectively complete the events.

Certain nearshore areas serve as critical training and testing locations for the use of explosives in this 

region. For example, the Navy’s explosive ordnance disposal training location off the coast of Virginia is 

vital due to its existing target setup, ideal bottom structure, and good bottom depth to safely train Navy 
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divers with explosives. Explosive ordnance disposal teams can be required to deploy with 3-weeks’ 

notice, which presents a need to constantly train to maintain readiness for combat operations. 

Relocating this activity to a location that does not have these features would increase safety risks and 

diminish the effectiveness of training events. Similarly, implementing seasonal restrictions on the use of 

explosive ordnance at this location (e.g., within sandbar shark Habitat Areas of Particular Concern off 

Virginia) would prevent the Navy from meeting its readiness requirements.

The Navy also uses select inshore areas along the U.S. East Coast, such as Kings Bay, Georgia; Charleston 

Harbor, South Carolina; and St. John’s River, Florida for a limited number of training activities. These 

waters overlap the habitat extent of bottlenose dolphins within the Southern Georgia Estuarine System 

Population, Charleston Estuarine System Population, and Jacksonville Estuarine System Population

(respectively), which were identified by LaBrecque et al. (2015b) as biologically important areas for 

bottlenose dolphins. It is critical for national security that the Navy’s inshore training activities, such as 

Civilian Port Defense – Homeland Security Anti-Terrorism/Force Protection exercises, occur in these 

inshore areas as planned to provide training realism and access to the necessary environmental 

conditions. Because the Navy conducts a limited number of training activities within inshore areas, 

implementing additional mitigation would not result in an avoidance or reduction of impacts on 

bottlenose dolphins in these areas.

Expanding the mitigation areas in this region would encroach upon the primary water space where 

training and testing activities are scheduled to occur. Implementing additional mitigation off the midAtlantic and southeastern United States would have a significant impact on the ability for units to meet 

their individual training and certification requirements (impacting the ability to deploy with the required 

level of readiness necessary to accomplish their missions), to certify forces 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), and for program managers and weapons system acquisition programs to 

meet testing requirements and required acquisition milestones. Based on the Navy’s assessment,

additional mitigation in this region would increase operational costs (due to extending distance offshore, 

which would increase fuel consumption, maintenance, and time on station to complete required 

training and testing activities), increase safety risks (associated with conducting training and testing at 

extended distances offshore and farther away from critical medical and search and rescue capabilities), 

and accelerate fatigue-life of aircraft and ships (leading to increased safety risk and higher maintenance 

costs). Furthermore, additional mitigation would significantly impact training and testing realism due to 

reduced access to necessary environmental or oceanographic conditions that replicate military mission 

and combat conditions. This would diminish the ability for Navy Sailors to train and become proficient in 

using sensors and weapon systems as required during military missions and combat operations. 

The iterative and cumulative impact of all potential mitigation measures the Navy assessed, including 

certain mitigation measures suggested through public comments on the Draft EIS/OEIS, would deny 

national command authorities the flexibility to respond to national security challenges and effectively 

accomplish the training necessary for deployment. For example, additional limitations on the use of 

active sonar and explosives off the mid-Atlantic and southeastern United States would require the Navy 

to shift its training activities to alternative locations farther offshore, farther north or south along the 

Eastern seaboard, or to the Gulf of Mexico. This would have significant impacts on safety, sustainability, 

and the ability to meet mission requirements within limited available timeframes. Likewise, requiring

weapons system program managers and research, testing, and development program managers to use 
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alternative areas within limited available timeframes would deny them the necessary flexibility to 

rapidly field or develop systems to meet testing program requirements and emerging requirements.

In summary, the Navy developed the mitigation areas identified in Table 5.4-3 to provide further 

protection for marine mammals in areas the best available science suggests are important for foraging, 

migrating, and reproduction. The mitigation will help the Navy avoid or reduce potential impacts on 

numerous species, including North Atlantic right whales. Further restrictions in the mid-Atlantic and 

southeast region on the level, number, or timing (seasonal or time of day) of training or testing activities 

would be impractical to due implications for safety, sustainability, and mission requirements.

5.4.4 MITIGATION AREAS IN THE GULF OF MEXICO 

As described in Table 5.4-4 and shown in Figure 5.4-6, the Navy will implement mitigation within 

mitigation areas in the Gulf of Mexico to, in combination with procedural mitigation, effect the least 

practicable adverse impact on marine mammal species or stocks and their habitat. 

Table 5.4-4: Mitigation Areas in the Gulf of Mexico

Mitigation Area Description

Stressor or Activity

 Sonar

 Explosives

Resource Protection Focus

 Marine mammals

Mitigation Area Requirements (year-round)

 Bryde’s Whale Mitigation Area:

 The Navy will report the total hours and counts of active sonar and in-water explosives used in the mitigation area in its 

annual training and testing activity reports submitted to NMFS.

 The Navy will not conduct >200 hours of hull-mounted mid-frequency active sonar per year within the mitigation area.

 The Navy will not use explosives (except during mine warfare activities) within the mitigation area.

 Gulf of Mexico Planning Awareness Mitigation Areas:

 The Navy will avoid conducting major training exercises (Composite Training Unit Exercises or Fleet Exercises/Sustainment 

Exercises) within the mitigation areas to the maximum extent practicable. 

 The Navy will not conduct any major training exercises within the mitigation areas (all or a portion of the exercise) under 

Alternative 1.

 The Navy will not conduct more than one major training exercise per year within the mitigation areas (all or a portion of the 

exercise) under Alternative 2.

 If the Navy needs to conduct additional major training exercises within the mitigation areas in support of training 

requirements driven by national security concerns (more than the numbers identified above), it will confer with NMFS to 

verify that potential impacts are adequately addressed in this Final EIS/OEIS and associated consultation documents.

5.4.4.1 Resource Description

The Navy assessed the Gulf of Mexico region for potential mitigation areas. The assessment included, 

but was not limited to, the following areas that were identified by LaBrecque et al. (2015a) as 

biologically important areas (as shown in Figure 5.4-6 and described in the sections below):

 Bottlenose dolphin Aransas Pass small and resident area (year-round)

 Bottlenose dolphin Mississippi Sound small and resident area (year-round)

 Bottlenose dolphin St. Joseph Bay small and resident area (year-round)

 Bryde’s whale small and resident population in the Gulf of Mexico (year-round)

 Sperm whale habitat in Mississippi Canyon (year-round)

 Sperm whale habitat west of Key West and the Dry Tortugas (year-round)
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Note: AFTT: Atlantic Fleet Training and Testing; OPAREA: Operating Area

Figure 5.4-6: Mitigation Areas and Habitats Considered in the Gulf of Mexico
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5.4.4.1.1 Bottlenose Dolphins

Three areas in the AFTT Study Area were identified by LaBrecque et al. (2015a) as biologically important 

areas for small and resident populations of bottlenose dolphins in the Gulf of Mexico: (1) Aransas Pass, 

(2) Mississippi Sound, and (3) St. Joseph Bay. The areas were recognized through various methods, 

including photo-identification, vessel surveys, satellite tagging, and genetic analyses. The small and 

resident populations are individual stocks that use the coastal waters as reproductive, migration, and 

feeding areas (LaBrecque et al., 2015a). 

The bottlenose dolphin coastal morphotype is continuously distributed along the U.S. East Coast south 

of Long Island, New York; around the Florida peninsula; and along the Gulf of Mexico coast. Although 

the structure of the individually recognized stocks is somewhat uncertain, it appears to be complex. Not 

every portion of the coast appears to be a significantly important marine mammal habitat; however, 

scientific evidence suggests that important breeding grounds, migration habitat, and foraging grounds 

for the individually recognized bottlenose dolphin coastal morphotypes are scattered throughout 

coastal waters. In the Gulf of Mexico, the Aransas Pass area displays a low level of site fidelity yearround with the most recent study reporting that 35 of 782 individually identified animals were resighted over 3 years (1991–1994) (Weller, 1998). In the Gulf of Mexico, the Mississippi Sound area 

contains animals that display greater site fidelity, with the most recent study reporting that up to 71 

individuals display year-round residency and up to 109 animals displayed seasonal fidelity (Mackey, 

2010). The St. Joseph Bay area also contains a small portion of St. Andrew Bay, with potential mixing of 

animals between the two areas (LaBrecque et al., 2015a); however, only St. Joseph Bay is located within 

the Study Area. Within St. Joseph Bay, a resident population of between 78 and 152 animals was

identified (Balmer et al., 2008). Animals from the St. Joseph Bay population are known to move into the 

mouth of St. Andrew Bay and into nearshore waters (LaBrecque et al., 2015a). Due to ongoing photoidentification studies (including Navy-funded monitoring efforts), the full habitat extent of several of 

these small and resident populations is subject to change as new information becomes available 

(LaBrecque et al., 2015a, 2015b).

For additional information about bottlenose dolphin habitats and geographic range, see Section 

3.7.2.3.10.2 (Habitat and Geographic Range).

5.4.4.1.2 Bryde’s Whales

One area in the AFTT Study Area was identified by LaBrecque et al. (2015a) as a biologically important 

area for a small and resident population of Bryde’s whales in the Gulf of Mexico. The area was identified 

through vessel and aerial surveys, passive acoustic monitoring, and genetic analyses (LaBrecque et al., 

2015a). A recent genetic analysis suggests that the population found in this area is genetically distinct 

from other Bryde’s whales (Rosel & Wilcox, 2014). The Gulf of Mexico subspecies of Bryde’s whale was 

proposed for listing as endangered under the Endangered Species Act in December 2016. The 2016 

NMFS status review for this species stated that the biologically important area for Bryde’s whale 

identified by LaBrecque et al. (2015a) would be better defined as out to the 400-m depth contour and to 

Mobile Bay, Alabama (Rosel et al., 2016).

Bryde’s whales are thought to be the most common baleen whale in the Gulf of Mexico (Würsig et al., 

2000). They are the only baleen whale known to occur year-round in this region (Jefferson & Schiro, 

1997). The population is small (estimated 33 individuals) and resident to the Gulf of Mexico (Rosel et al., 

2016). Bryde’s whales have been observed exclusively within the northeastern Gulf of Mexico and there 

is evidence to suggest that this area is more important for this species than any other area within the 
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Gulf of Mexico. Most Bryde's whale sighting records in the northern Gulf of Mexico are from NMFS 

abundance surveys (Waring et al., 2016) that were conducted during spring and summer months over 

several years (Davis & Fargion, 1996; Davis et al., 2000; Hansen et al., 1995; Hansen et al., 1996; 

Jefferson & Schiro, 1997; Maze-Foley & Mullin, 2006; Mullin & Hoggard, 2000; Mullin & Fulling, 2004). 

During surveys conducted throughout the oceanic waters of the U.S. Gulf of Mexico, Bryde’s whales 

have been observed between the 100-m and 300-m isobaths in the northeastern Gulf of Mexico. The 

most recent NMFS Gulf of Mexico abundance survey took place during summer 2009. Three Bryde’s 

whale sightings were recorded seaward of the 100-m depth contour (Waring et al., 2016). More recent 

surveys in the Gulf of Mexico have been conducted by the Atlantic Marine Assessment Program for 

Protected Species. During a 2011 survey in the northeastern Gulf of Mexico, three Bryde’s whale 

sightings were reported along the 200-m depth contour (National Marine Fisheries Service, 2011). 

Passive acoustic recorders deployed in DeSoto Canyon over 53 days recorded 680 calls attributed to 

Bryde’s whales (Širović et al., 2014). Calls were consistently recorded between March and July, and in 

October and January. It was noted that there was a lack of calls during November and December. During 

those times when calls were detected, there was a peak in late June with a relatively high number of 

calls also recorded in later March, early April, and early January (Širović et al., 2014). In addition to 

sightings and acoustic data, there are stranding records in the Gulf of Mexico from throughout the year 

(Würsig et al., 2000). Further studies are required to understand how Bryde’s whales use the 

northeastern Gulf of Mexico for biological life processes, such as reproduction and feeding.

For additional information about Bryde’s whale habitats and geographic range, see Section 3.7.2.3.3.2 

(Habitat and Geographic Range).

5.4.4.1.3 Sperm Whales

Two areas in the AFTT Study Area have been suggested as potentially important areas for sperm whales 

in the Gulf of Mexico: Mississippi Canyon and an area west of Dry Tortugas, Florida. Animals within the

Northern Gulf of Mexico Stock have been determined to be genetically distinct from other sperm whale 

stocks (Jochens et al., 2008; Waring et al., 2016).

Aerial and line transect surveys in the northern Gulf of Mexico indicate that numerous marine mammal 

species, including sperm whales, are widely distributed throughout the northern Gulf of Mexico yearround. Most sperm whale sightings in the Gulf of Mexico have occurred in waters greater than 200 m, 

over the upper continental slope, and out to deeper waters (more than 2,000 m) (Baumgartner et al., 

2001; Davis et al., 2000; Mullin et al., 1994a; Waring et al., 2016). Researchers have identified the

Mississippi Canyon and the Mississippi River Delta as an area where sperm whales are sighted 

consistently throughout the year (Baumgartner et al., 2001; Davis et al., 1998; Maze-Foley & Mullin, 

2006; Mullin et al., 1994b; Mullin & Fulling, 2004; Ruiz-Cooley & Engelhaupt, 2010; Weller et al., 2000). 

The Mississippi Canyon region is noted as being important sperm whale habitat (Davis et al., 1998; 

Weller et al., 2000). A summer 2009 NMFS vessel survey in the northern Gulf of Mexico reported 39 

sperm whale sightings, of which at least 2 were within the Mississippi Canyon area (National Marine 

Fisheries Service, 2009b). It is thought that the Mississippi River plume and its associated high primary 

productivity may be the reason that sperm whales aggregate in the area and may be an important 

feeding habitat during years when biological productivity is high (Jochens et al., 2008; Mullin et al., 

2004; Weller et al., 2000). Prey species and their relation to sperm whale distribution patterns have not 

yet been identified for this area (Jochens et al., 2008). However, researchers have found a correlation 

between the influx of nutrients from the Mississippi River, water flow patterns, and the distribution and 

abundance of sperm whales (Biggs et al., 2005; Jochens et al., 2008). Photo-identification, while limited, 
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also suggests that sperm whales in the northern Gulf of Mexico may exhibit differing levels of site 

fidelity within this region on an annual basis (Jochens et al., 2008; Weller et al., 2000). 

Researchers have identified a second potential sperm whale aggregation location as the southeastern 

region of the northern Gulf of Mexico, an area west of the Dry Tortugas (Maze-Foley & Mullin, 2006; 

Mullin & Fulling, 2004; Mullin et al., 2004). Surveys conducted by NMFS Southeast Fisheries Science 

Center and the Bureau of Ocean Energy Management in the southeastern portion of the Gulf of Mexico 

between June and August of 2012 resulted in observations of 29 sperm whales, all in water deeper than 

1,000 m and within the area west of the Dry Tortugas (National Marine Fisheries Service, 2013). This 

area is thought to have high levels of primary productivity that are influenced by the Loop Current and 

other dynamic water flow patterns, such as the Tortugas Gyre (Mullin & Fulling, 2004). Sperm whales 

have been observed in multiple seasons within the area, particularly in locations with steep bathymetry 

(National Marine Fisheries Service, 2013). Further studies are required to understand how sperm whales 

use these areas in the Gulf of Mexico for biological life processes, such as reproduction and feeding.

For additional information about sperm whale habitats and geographic range, see Section 3.7.2.2.6.2 

(Habitat and Geographic Range).

5.4.4.2 Mitigation Area Assessment

When developing Phase III mitigation, the Navy analyzed the potential for increasing mitigation areas in 

the Study Area. Based on its ongoing analysis of the best available science and potential mitigation 

measures, the Navy determined it can implement additional mitigation measures in the Gulf of Mexico

under the Proposed Action to enhance protection of marine mammals (including Bryde’s whales) to the 

maximum extent practicable. New mitigation developed for Phase III includes: (1) developing a new 

mitigation area known as the Bryde’s Whale Mitigation Area with special reporting requirements and 

restrictions on the use of hull-mounted mid-frequency active sonar and in-water explosives, and (2) 

enlarging the more eastern Gulf of Mexico Planning Awareness Mitigation Area to include the extended 

area identified by NMFS in its 2016 Bryde’s whale status review (Rosel et al., 2016). The remaining 

mitigation measures presented in Table 5.4-4 are continuations from Phase II.

Mitigation areas in the Gulf of Mexico will avoid or reduce impacts on one or more marine mammal 

species or stocks and their habitat, as summarized below:

 Bryde’s Whale Mitigation Area. Newly developed for Phase III, the Bryde’s Whale Mitigation 

Area covers the extent of the Bryde’s whale small and resident population area identified by 

LaBrecque et al. (2015a), including the extended area identified by NMFS in its 2016 Bryde’s 

whale status review (Rosel et al., 2016). Mitigation to limit annual hours of mid-frequency active 

sonar use and to not use in-water explosives (except during mine warfare activities) will help the 

Navy avoid or reduce potential impacts on the small and resident population of Bryde’s whales. 

To accomplish the mitigation for explosives, the Navy has adjusted the boundaries of the 

northern Gulf of Mexico ship shock trial area. The ship shock trial area is being relocated 5 NM 

from the western boundary of the Bryde’s Whale Mitigation Area. This will help the Navy avoid 

the potential for Bryde’s whales to be exposed to explosives during ship shock trials within the 

mitigation area. The Navy will implement special reporting procedures to report the total hours 

and counts of active sonar and in-water explosives used in the mitigation area in its annual 

training and testing activity reports submitted to NMFS. The special reporting requirements will 

aid the Navy and NMFS in continuing to analyze potential impacts of training and testing in this 

area.
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 Gulf of Mexico Planning Awareness Mitigation Areas. 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 identified by LaBrecque et al. (2015a) and the extended area 

identified by NMFS in its 2016 Bryde’s whale status review (Rosel et al., 2016). The Gulf of 

Mexico Planning Awareness Mitigation Areas overlap most of the Mississippi Canyon sperm 

whale habitat area and a portion of sperm whale habitat area west of the Dry Tortugas 

discussed in Section 5.4.4.1.3 (Sperm Whales). They extend across large swaths of shelf break 

and contain underwater canyons associated with marine mammal abundance (e.g., Mississippi 

Canyon, DeSoto Canyon). The mitigation areas are situated among highly productive 

environments, such as persistent oceanographic features associated with upwellings and steep 

bathymetric contours. Mitigation within the Gulf of Mexico Planning Awareness Mitigation 

Areas will help the Navy further avoid or reduce potential impacts from active sonar during 

major training exercises on marine mammals that inhabit, feed in, reproduce in, or migrate 

through these areas.

The Navy conducts training and testing activities in the Gulf of Mexico because this region provides 

valuable access to sea space and airspace conditions analogous to areas where the Navy operates or 

may need to operate in the future. The Gulf of Mexico encompasses part of the primary water space in 

the AFTT Study Area where certain unit-level training, integrated training, and deployment certification 

exercises occur, such as mine warfare training. The Gulf of Mexico also supports composite training unit 

exercises under Alternative 2. The Gulf of Mexico is also important for testing components of air 

warfare, mine warfare, surface warfare, anti-submarine warfare, electronic warfare, vessels and vessel 

signatures, unmanned systems; and other areas including submersibles, line charges, and semistationary equipment testing. The Navy conducts pierside sonar testing and propulsion testing during 

sea trials near Pascagoula, Mississippi.

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, forecasting of future testing 

requirements, and emerging requirements. When scheduling activities, the Navy considers the need to 

minimize sea space and airspace conflicts within the Gulf of Mexico and throughout the entire Study 

Area. For example, the Navy schedules training and testing to minimize conflicts between its own 

activities and with consideration for public safety (e.g., safe distances from recreational boating 

activities). Daily fluctuations in training and testing schedules and objectives could mean that, on any 

given day, vessels may depend on discrete locations of the Gulf of Mexico for discrete purposes. 

The Navy selects training areas in this region to allow for the realistic tactical development of the myriad 

training scenarios Navy units are required to complete to be mission effective. Certain activities, such as 

deployment certification exercises that involve integration with multiple warfare components, require 

large areas of the littorals and open ocean for realistic and safe training. The Navy chooses training 

locations based on proximity to 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), and aircraft emergency landing fields 

(e.g., Naval Air Station Pensacola). The Navy selects the locations (e.g., pierside in Corpus Christi, Texas)

and scenarios for Civilian Port Defense – Homeland Security Anti-Terrorism/Force Protection exercises 

according to Department of Homeland Security strategic goals and evolving world events.

The Navy conducts testing activities in the Gulf of Mexico because it provides a variety of bathymetric 

and environmental conditions necessary to ensure functionality and accuracy of systems and platforms 
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in areas analogous to where the military operates. Testing locations are typically located near systems 

command support facilities, which provide critical safety, platform, and infrastructure support and 

technical expertise necessary to conduct testing (e.g., proximity to air squadrons). Naval Surface 

Warfare Center, Panama City Division Testing Range provides critical capabilities for meeting littoral and 

expeditionary maneuver warfare requirements by providing research, development, test, and evaluation

and in-service engineering for expeditionary maneuver warfare, operations in extreme environments, 

mine warfare, maritime operations, and coastal operations. The Navy has designated the Key West 

Operating Area as a back-up location for sonobuoy lot acceptance testing when the primary area of San 

Clemente Island, California is not available. The Key West Operating Area is particularly valuable due to 

the favorable weather conditions (e.g., low sea state) that are typical of the area.

The Navy requires flexibility in the timing of its use of active sonar and explosives in order to meet 

individual training and testing schedules and deployment schedules. Navy vessels, aviation squadrons, 

and testing programs have a limited amount of time available for training and testing. The Navy must 

factor in variables such as maintenance and weather (e.g., hurricanes) when scheduling event locations 

and timing. The Navy can restrict the number of major training exercises within the Gulf of Mexico 

Planning Awareness Mitigation Areas because it is not tied to a specific range support structure in this 

area for these events. However, major training exercise locations may have to change during an exercise 

or during exercise planning based on assessments of unit performance or other conditions, such as 

weather and mechanical issues. This precludes the ability to completely prohibit major training exercises 

from occurring in the entire region.

The testing community is required to install and test systems on platforms at the locations where those 

platforms are stationed. Testing associated with new construction ships must occur in locations close to 

the shipbuilder’s facilities in the Gulf of Mexico for reasons associated with construction schedule, 

proximity to testing facilities, and safety. Additionally, the testing community has a need for rapid 

development to quickly resolve tactical deficiencies. Overall, training and testing schedules can be 

cyclical and are partially driven by geo-political situations, which precludes the Navy from implementing 

additional mitigation to reduce or eliminate the use of active sonar or explosives in the Gulf of Mexico. 

The Navy determined that enlarging the more eastern Gulf of Mexico Planning Awareness Mitigation 

Area, developing the new Bryde’s Whale Mitigation Area, and continuing the other mitigation measures

as described in Table 5.4-4 would be practical to implement under the Proposed Action. This 

determination was based on an operational assessment of past use of active sonar, explosives, and nonexplosive practice munitions; projected future training and testing needs in the region; and 

consideration of fleet concentration areas in the Study Area. The mitigation areas in the Gulf of Mexico

as described in Table 5.4-4 represent the largest areas and highest level of mitigation within each area 

that is practical for the Navy to implement within this region under the Proposed Action. Further 

modifications of training and testing activities in the Gulf of Mexico, such as developing mitigation areas 

for bottlenose dolphin small and resident population areas identified by LaBrecque et al. (2015a) or for 

dolphin habitat associated with the Deepwater Horizon oil spill, would have a significant impact on 

safety, sustainability, and the Navy’s ability to meet its mission requirements, as discussed below.

Further expansions of the mitigation areas in this region would require the Navy to relocate its activities

to alternative locations, such as farther offshore. Moving activities farther offshore would reduce a 

unit’s training opportunities during its limited available training timeframes (i.e., increased time spent 

transiting to more distant training areas results in decreased time available for training). This would also 

result in training and testing activities being conducted in water conditions that do not accurately reflect 
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the types of environments where military missions and combat operations occur. Increasing transit 

distances would result in additional fuel consumption and expenditures, which could serve as a limiting 

factor for Navy surface units whose available underway times are constrained by fuel expenses. 

The Navy uses select inshore areas in the Gulf of Mexico for a limited number of training and testing 

activities. These waters overlap the habitat extent of bottlenose dolphins within the Aransas Pass, 

Mississippi Sound, and St. Joseph Bay small and resident populations identified by LaBrecque et al. 

(2015a). It is critical for national security that the Navy’s inshore activities, such as Civilian Port Defense 

– Homeland Security Anti-Terrorism/Force Protection exercises, occur in these inshore areas as planned 

to provide realism and access to the necessary environmental conditions. Because the Navy conducts a 

limited number of activities within inshore areas, implementing additional mitigation would not result in 

an avoidance or reduction of impacts on bottlenose dolphins in these areas.

Expanding the mitigation areas in this region would encroach upon the primary water space where 

training and testing activities are scheduled to occur. Implementing additional mitigation in the Gulf of 

Mexico would have a significant impact on the ability for units to meet their individual training and 

certification requirements (impacting the ability to deploy with the required level of readiness necessary 

to accomplish their missions), to certify forces 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), and for program managers and weapons system acquisition programs to meet testing 

requirements and required acquisition milestones. Based on the Navy’s assessment, additional 

mitigation in this region would increase operational costs (due to extending distance offshore, which 

would increase fuel consumption, maintenance, and time on station to complete required training and 

testing activities), increase safety risks (associated with conducting training and testing at extended 

distances offshore and farther away from critical medical and search and rescue capabilities), and 

accelerate fatigue-life of aircraft and ships (leading to increased safety risk and higher maintenance 

costs). Furthermore, additional mitigation would significantly impact training and testing realism due to 

reduced access to necessary environmental or oceanographic conditions that replicate military mission 

and combat conditions. This would diminish the ability for Navy Sailors to train and become proficient in 

using sensors and weapon systems as required during military missions and combat operations. 

The iterative and cumulative impact of all potential mitigation measures the Navy assessed, including 

certain mitigation measures suggested through public comments on the Draft EIS/OEIS, would deny 

national command authorities the flexibility to respond to national security challenges and effectively 

accomplish the training necessary for deployment. For example, additional limitations on the use of 

active sonar and explosives in the Gulf of Mexico would require the Navy to shift its training activities to 

alternative locations further offshore or to areas along the Eastern seaboard. This would have significant 

impacts on safety, sustainability, and the ability to meet mission requirements within limited available 

timeframes. Likewise, requiring weapons system program managers and research, testing, and 

development program managers to use alternative areas within limited available timeframes would 

deny them the necessary flexibility to rapidly field or develop systems to meet testing program 

requirements and emerging requirements.

In summary, the Navy developed the mitigation areas identified in Table 5.4-4 to provide further 

protection for marine mammals in areas the best available science suggests are important to small and 

resident populations of Bryde’s whales and sperm whales. The mitigation will help the Navy avoid or 

reduce potential impacts from active sonar or explosives on these species. Further restrictions in the 
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Gulf of Mexico on the level, number, or timing (seasonal or time of day) of training or testing activities 

would be impractical to due implications for safety, sustainability, and mission requirements.

5.5 MEASURES CONSIDERED BUT ELIMINATED

As described in Section 5.2 (Mitigation Development Process), the Navy conducted a detailed review and 

assessment of each potential mitigation measure individually and then all potential mitigation measures 

collectively to determine if, as a whole, the mitigation will be effective at avoiding or reducing impacts

and practical to implement. The assessment included consideration of mitigation recommendations 

received during scoping, through public comments, and during consultations for Phase III and past 

environmental compliance documents applicable to the Study Area. The operational community 

determined that implementing mitigation beyond what is detailed in Section 5.3 (Procedural Mitigation 

to be Implemented) and Section 5.4 (Mitigation Areas to be Implemented) would be incompatible with 

the practicality assessment criteria for safety, sustainability, and mission requirements. Information 

about why implementing additional mitigation measures for active sonar, explosives, active and passive 

acoustic monitoring devices, thermal detection systems, third-party observers, foreign navy mitigation, 

reporting requirements, and permission schemes would be impractical is provided in the sections below. 

Information about why implementing additional geographic mitigation would be impractical is provided 

in Section 5.4 (Mitigation Areas to be Implemented).

When analyzing all potential mitigation measures collectively, the operational community determined 

that adopting the additional mitigation measures beyond what is included in this Final EIS/OEIS would 

essentially result in the Navy losing access to the significant majority of its required sea space and 

airspace. Additional measures would restrict or prohibit Navy training and testing along the U.S. East 

coast and throughout the Gulf of Mexico except in very narrow circumstances. For example, blanket 

limitations or restrictions on the level, number, or timing (seasonal or time of day) of training and

testing activities within discrete or broad-scale areas of water (e.g., embayments and large swaths of the 

littorals and open ocean), or other areas vital to mission requirements would prevent the Navy from 

accessing its ranges, operating areas, facilities, or range support structures necessary to meet the 

purpose and need of the Proposed Action. As described in Section 5.2.3 (Practicality of Implementation), 

the Navy requires extensive sea space so that individual training and testing activities can occur at 

sufficient distances so they 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 required

during military missions and combat operations. The Navy also needs to maintain access to sea space

with the unique, challenging, and diverse environmental and oceanographic features (e.g., bathymetry, 

topography, surface fronts, and variations in sea surface temperature) analogous to military mission and 

combat conditions to achieve the highest skill proficiency and most accurate testing results possible. 

Threats to national security are constantly evolving. The Navy requires the ability to adapt training and 

testing to meet these emerging threats. Restricting access to broad-scale areas of water would impact 

the ability for Navy training and testing to evolve as the threat evolves. Eliminating opportunities for the 

Navy to train and test in a myriad of at-sea conditions would put U.S. forces at a tactical disadvantage 

during military missions and combat operations. This would also present a risk to national security if 

adversaries were to be alerted to the environmental conditions within which the U.S. Navy is prohibited 

from training and testing. Restricting large areas of ocean or other smaller areas at sea that are critical 

to Navy training and testing would make training and concealment much more difficult and would 

adversely impact the Navy’s ability to perform its statutory mission.
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5.5.1 ACTIVE SONAR

When assessing and developing mitigation, the Navy considered reducing active sonar training and 

testing hours, modifying active sonar sound sources, implementing time-of-day restrictions and 

restrictions during surface ducting conditions, replacing active sonar training and testing with synthetic 

activities (e.g., computer simulated training), and implementing active sonar ramp-up procedures. As 

discussed in Chapter 2 (Description of Proposed Action and Alternatives), Section 5.2.3 (Practicality of 

Implementation), and Appendix A (Navy Activity Descriptions), training and testing activities are planned 

and scheduled based on numerous factors and data inputs, such as compliance with the Optimized Fleet 

Response Plan. Information on why training and testing with active sonar is essential to national security 

is presented in Section 5.3.2.1 (Active Sonar). The Navy uses active sonar during military readiness 

activities only when it is essential to training missions or testing program requirements since active 

sonar has the potential to alert opposing forces to the operating platform’s presence. Passive sonar and 

other available sensors are used in association with active sonar to the maximum extent practicable. 

The Navy currently uses, and will continue to use, computer simulation to augment training and testing 

whenever possible. As discussed in Section 1.4.1 (Why the Navy Trains), simulators and synthetic 

training are critical elements that provide early skill repetition and enhance teamwork; however, they 

cannot duplicate the complexity faced by Sailors during military missions and combat operations for the 

types of active sonar used under the Proposed Action (e.g., hull-mounted mid-frequency active sonar). 

Just as a pilot would not be ready to fly solo after simulator training, a Navy Commander cannot allow 

military personnel to engage in military missions and combat operations based merely on simulator 

training. Similarly, in testing a system that is being developed, simulation can be used during the initial 

stages of development, but ultimately the system must be tested under conditions analogous to those 

faced during military missions and combat operations. Systems that have undergone maintenance need 

to be tested, and not simulated, to ensure that the system is operating correctly. 

Sonar operators must train to effectively handle bottom bounce and sound passing through changing 

currents, eddies, and across changes in ocean temperature, pressure, salinity, depth, and in surface 

ducting conditions. Sonar systems must be tested in these conditions to ensure functionality and 

accuracy in military mission and combat conditions. The Navy tests its active sonar systems in areas 

analogous to where the Navy trains and operates. This includes a nighttime testing requirement for 

some active sonar systems, and a requirement to test in a variety of locations and environmental 

conditions depending on the testing program objectives. Training and testing in good visibility (e.g., 

daylight, favorable weather conditions) and low visibility (e.g., nighttime, inclement weather conditions) 

is vital because environmental differences between day and night and varying weather conditions affect 

sound propagation and the detection capabilities of sonar. Temperature layers that move up and down 

in the water column and ambient noise levels can vary significantly between night and day. This affects 

sound propagation and how sonar systems function and are operated.

Submarines may hide in the higher ambient noise levels of shallow coastal waters and surface ducts. 

Surface ducting occurs when water conditions, such as temperature layers and lack of wave action,

result in little sound energy penetrating beyond a narrow layer near the surface of the water. Avoiding 

surface ducting conditions would be impractical because ocean conditions contributing to surface 

ducting change frequently and surface ducts can be of varying duration. Surface ducting can also lack 

uniformity and may or may not extend over a large geographic area, making it difficult to determine 

where to reduce power and for what periods. Submarines have long been known to take advantage of 

the phenomena associated with surface ducting to avoid being detected by sonar. When surface ducting 
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occurs, active sonar becomes more useful near the surface but less useful at greater depths. As noted by 

the U.S. Supreme Court in Winter v. Natural Resources Defense Council, Inc., 555 U.S. 7 (2008), because 

surface ducting conditions occur relatively rarely and are unpredictable, it is especially important for the 

Navy to be able to train under these conditions when they occur. Training with active sonar in these

conditions is a critical component of military readiness because sonar operators need to learn how 

sonar transmissions are altered due to surface ducting, how submarines may take advantage of them, 

and how to operate sonar effectively under these conditions. Reducing power or shutting down active 

sonar based on environmental conditions as a mitigation would affect a Commander’s ability to develop 

the tactical picture. It would also prevent sonar operators from training in conditions analogous to those 

faced during military missions and combat operations, such as during periods of low visibility. 

Active sonar signals are designed explicitly to provide optimum performance at detecting underwater 

objects (e.g., submarines) in a variety of acoustic environments. The Navy assessed the potential for 

implementing active sonar signal modification as mitigation. At this time, the science on the differences 

in potential impacts of up or down sweeps of the sonar signal (e.g., different behavioral reactions) is 

extremely limited and requires further development. If future studies indicate that modifying active

sonar signals (i.e., up or down sweeps) could be an effective mitigation approach, then the Navy will 

investigate if and how the mitigation would affect the sonar's performance.

Active sonar equipment power levels are set consistent with mission requirements. Active sonar rampup procedures are used during seismic surveys and some foreign navy sonar activities. Ramping up 

involves slowly increasing sound levels over a certain length of time until the optimal source level is 

reached. The intent of ramping up a sound source is to alert marine mammals with a low sound level to 

deter them from the area and avoid higher levels of sound exposure. The best available science does not 

suggest that ramp-up would be an effective mitigation tool for U.S. Navy active sonar training and 

testing activities under the Proposed Action. Wensveen et al. (2017) found that active sonar ramp-up 

was not an effective method for reducing impacts on humpback whales because most whales did not 

display strong behavioral avoidance to the sonar signals. The study suggested that sonar ramp-up could 

potentially be more effective for other more behaviorally responsive species but would likely also 

depend on the context of exposure. For example, ramp-up would be less effective if animals have a 

strong motivation not to move away from their current location, such as when foraging. Dunlop et al. 

(2016) and von Benda-Beckmann et al. (2014) found that implementing ramp-up as mitigation may be 

effective for some activities in some situations. Additionally, von Benda-Beckmann et al. (2014) found 

that the main factors limiting ramp-up effectiveness for a typical anti-submarine warfare activity are a 

high source level, a moving sonar source, and long silences between consecutive sonar transmissions.

Based on the source levels, vessel speeds, and sonar transmission intervals that will be used during 

typical active sonar activities under the Proposed Action, the Navy has determined that ramp-up would 

be an ineffective mitigation measure for the active sonar activities analyzed in this document.

Implementing active sonar ramp-up procedures during training or testing under the Proposed Action 

would not be representative of military mission and combat conditions and would significantly impact 

training and testing realism. For example, during an anti-submarine warfare exercise using active sonar, 

ramp-ups have the potential to alert opponents (e.g., target submarines) to the transmitting vessel’s 

presence. This would defeat the purpose of the training by allowing the target submarine to detect the 

searching unit and take evasive measures, thereby denying the sonar operator the opportunity to learn 

how to locate the submarine. Similarly, testing program requirements determine test parameters to 

accurately determine whether a system is meeting its operational and performance requirements; 
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therefore, implementing ramp-up during testing activities would impede the Navy’s ability to collect 

essential data for evaluation of a system’s capabilities.

Reducing realism in training impedes the ability for Navy Sailors to train and become proficient in using 

active sonar, erodes capabilities, and reduces perishable skills. These impacts would result in a 

significant risk to personnel safety during military missions and combat operations and would prevent 

units from meeting their individual training and certification requirements. Therefore, implementing 

additional mitigation that would reduce training realism would ultimately prevent units from deploying 

with the required level of readiness necessary to accomplish their missions and impede the Navy’s 

ability to certify forces to deploy to meet national security tasking. Reducing realism in testing would 

impact the ability of researchers, program managers, and weapons system acquisition programs to 

conduct accurate acoustic research and effectively test systems and platforms (and components of 

these systems and platforms) before full-scale production or delivery to the fleet. These tests are 

required to ensure functionality and accuracy in military mission and combat conditions per required 

acquisition milestones or on an as-needed basis to meet operational requirements.

5.5.2 EXPLOSIVES

When assessing and developing mitigation, the Navy considered reducing the number and size of 

explosives and limiting the locations and time of day of explosive training and testing in the Study Area.

As discussed in Chapter 2 (Description of Proposed Action and Alternatives), Section 5.2.3 (Practicality of 

Implementation), and Appendix A (Navy Activity Descriptions), the locations and timing of the training 

and testing activities that use explosives vary throughout the Study Area based on range scheduling, 

mission requirements, testing program requirements, and standard operating procedures for safety and 

mission success. The Navy’s suite of mitigation includes extensive mitigation areas for explosives, 

including avoiding seafloor resource areas throughout the Study Area and important marine mammal 

habitats in the northeast, mid-Atlantic, southeast, and Gulf of Mexico. The Navy determined that,

beyond what is described in Section 5.4 (Mitigation Areas to be Implemented), it would be impractical to 

develop additional mitigation areas to limit the locations of explosive training and testing activities. 

Activities that involve explosive ordnance are inherently different from those that involve non-explosive 

practice munitions. For example, critical components of an explosive Bombing Exercise Air-to-Surface 

include the assembly, loading, delivery, and assessment of the explosive bomb. The explosive bombing 

training exercise starts with ground personnel, who must practice the building and loading of explosive 

munitions. Training includes the safe handling of explosive material, configuring munitions to precise 

specifications, and the loading of munitions onto aircraft. Aircrew must then identify a target and safely 

deliver fused munitions, discern if the bomb was assembled correctly, and determine bomb damage 

assessments based on how and where the explosive detonated. An air-to-surface bombing exercise

using non-explosive practice munitions can train aircrews on valuable skills to locate and accurately 

deliver munitions on a target; however, it cannot effectively replicate the critical components of an 

explosive activity in terms of assembly, loading, delivery, and assessment of an explosive bomb. 

Reducing the number and size of explosives or diminishing activity realism by implementing time of day 

or geographic restrictions for additional explosive training exercises would impede the ability for Navy 

Sailors to train and become proficient in using explosive weapon systems (which would result in a 

significant risk to personnel safety during military missions and combat operations), and would 

ultimately prevent units from meeting their individual training and certification requirements (which 

would prevent them from deploying with the required level of readiness necessary to accomplish their 

missions) and impede the Navy’s ability to certify forces to deploy to meet national security tasking. 
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Similar to training, the Navy is required to test its explosives to quantify the compatibility of weapons 

with the platform from which they will be launched or released in military missions and combat 

operations. Such testing requires the use of the actual explosive ordnance that will be used during 

training exercises, military missions, and combat operations. Reducing the number and size of explosives 

or diminishing activity realism by implementing time of day or geographic restrictions for additional

explosive testing events would impact the ability of researchers, program managers, and weapons 

system acquisition programs to effectively test systems and platforms (and components of these 

systems and platforms). Such testing must be conducted before full-scale production or delivery to the 

fleet to ensure functionality and accuracy in military mission and combat conditions per required 

acquisition milestones or on an as-needed basis to meet operational requirements.

5.5.3 ACTIVE AND PASSIVE ACOUSTIC MONITORING DEVICES

When assessing and developing mitigation, the Navy considered using active and passive acoustic 

monitoring devices as procedural mitigation. During Surveillance Towed Array Sensor System lowfrequency active sonar (which is not part of the Proposed Action), the Navy uses a specially-designed

adjunct high-frequency marine mammal monitoring active sonar known as “HF/M3” to mitigate 

potential impacts. HF/M3 can only be towed at slow speeds and operates like a fish finder used by 

commercial and recreational fishermen. Installing the HF/M3 adjunct system on the tactical sonar ships

used under the Proposed Action would have implications for safety and mission requirements due to 

impacts on speed and maneuverability. Furthermore, installing the system would significantly increase

costs associated with designing, building, installing, maintaining, and manning the equipment. The Navy 

will not install the HF/M3 system or other adjunct marine mammal monitoring devices as mitigation 

under the Proposed Action. However, Navy assets with passive acoustic monitoring capabilities that are 

already participating in an activity will continue to monitor for marine mammals, as described in Section 

5.2.1 (Procedural Mitigation Development) and Section 5.3 (Procedural Mitigation to be Implemented).

Significant manpower and logistical constraints make constructing and maintaining additional passive 

acoustic monitoring systems for each training and testing activity under the Proposed Action 

impractical. Diverting platforms with passive acoustic monitoring capabilities to monitor training and 

testing events would impact their ability to meet their mission requirements and would reduce the 

service life of those systems.

The Navy is continuing to improve its capabilities to use range instrumentation to aid in the passive 

acoustic detection of marine mammals. For example, at the Southern California Offshore Range, the 

Pacific Missile Range Facility off Kauai, Hawaii, and the Atlantic Undersea Test and Evaluation Center in 

the Bahamas, the Navy can monitor instrumented ranges in real-time or through data recorded by 

hydrophones. The Navy has sponsored numerous studies that have produced meaningful results on 

marine mammal occurrence, distribution, and behavior on these ranges through the U.S. Navy Marine 

Species Monitoring Program. For information on the U.S. Navy Marine Species Monitoring Program, see 

Section 3.0.1.1 (Marine Species Monitoring and Research Programs) and Section 5.1.2.2.1 (Marine 

Species Research and Monitoring Programs).

The Navy’s instrumented ranges are helping to facilitate a better understanding of the species that are 

present in those areas. However, instrumented ranges do not have the capabilities to be used effectively 

for mitigation. To develop an estimated position for an individual marine mammal, the animal’s 

vocalizations must be detected on at least three hydrophones. The vocalizations must be loud enough to 

provide the required signal to noise ratio on those hydrophones. The hydrophones must have the 

required bandwidth and dynamic range to capture that signal. Detection capabilities are generally 
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degraded under noisy conditions that affect signal to noise ratio, such as high sea state. The ability to 

detect and develop an estimated position for marine mammals on the Navy’s instrumented ranges 

depends of numerous factors, such as behavioral state, species, location relative to the hydrophones, 

and location on the range. For example, only vocalizing animals can be detected, and species vocalize at 

varying rates, call types, and source levels. The Navy’s hydrophones cannot track the real-time locations 

of individual animals with dispersed and directional vocalizations with the level of precision needed for 

effective mitigation. Even marine mammals that have been vocalizing for extended periods of time have 

been known to stop vocalizing for hours at a time, which would prevent the Navy from obtaining or 

maintaining an accurate estimate of that animal’s location. In addition, the Navy does not currently have 

the capability to perform data processing for large baleen whales in real-time. Determining if an animal 

is located within a mitigation zone within the timeframes required for mitigation would be prohibited by 

the amount of time it takes to process the data.

If a vocalizing animal is detected on only one or two hydrophones, estimating its location is not possible, 

and the location of the animal would be assigned generally within the detection radius around each 

hydrophone. The detection radius of a hydrophone is typically much larger than the mitigation zone for 

the activities conducted on instrumented ranges. The Navy does not have a way to verify if that 

vocalizing animal is located within the mitigation zone or at a location down range. Mitigating for 

passive acoustic detections based on unknown animal locations would essentially increase the 

mitigation zone sizes for each activity to that of the hydrophone detection radius. Increasing the 

mitigation zone sizes beyond what is described for each activity is impractical for the reasons described 

throughout Section 5.3 (Procedural Mitigation to be Implemented). 

In summary, although the Navy is continuing to improve its capabilities to use range instrumentation to 

aid in the passive acoustic detection of marine mammals, at this time it would not be effective or 

practical for the Navy to monitor instrumented ranges for real-time mitigation or to construct additional 

instrumented ranges as a tool to aid in the implementation of mitigation.

5.5.4 THERMAL DETECTION SYSTEMS

Thermal detection technology is designed to allow observers to detect the difference in temperature 

between a surfaced marine mammal (i.e., the body or blow of a whale) and the environment (i.e., the 

water and air). Although thermal detection may be reliable in some applications and environments, 

current technologies are limited by their: (1) reduced performance in certain environmental conditions, 

(2) inability to detect certain animal characteristics and behaviors, (3) low sensor resolution and narrow 

fields of view, and (4) high cost and low lifecycle (Boebel, 2017; Zitterbart et al., 2013).

Thermal detection systems can be effective at detecting some types of marine mammals in a limited 

range of marine environmental conditions. Current thermal detection systems have proven more 

effective at detecting large whale blows than the bodies of small animals, particularly at a distance 

(Zitterbart et al., 2013). The effectiveness of current technologies has not been demonstrated for small 

marine mammals. Thermal detection systems exhibit varying degrees of false positive detections (i.e., 

incorrect notifications) due in part to their low sensor resolution and reduced performance in certain 

environmental conditions. False positive detections may incorrectly identify other features (e.g., birds, 

waves, boats) as marine mammals. In one study, Zitterbart et al. (2013) reported a false positive rate 

approaching one incorrect notification per 4 min. of observation. 

Thermal detection systems are generally thought to be most effective in cold environments, which have 

a large temperature differential between an animal’s temperature and the environment. Two studies 
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that examined the effectiveness of thermal detection systems for marine mammal observations are 

Zitterbart et al. (2013), which tested a thermal detection system and automatic algorithm in polar 

waters between 34–50 degrees Fahrenheit, and a Navy-funded study in subtropical and tropical waters. 

Zitterbart et al. (2013) found that current technologies have limitations regarding temperature and 

survey conditions (e.g., rain, fog, sea state, glare, ambient brightness), for which further effectiveness 

studies are required. The Office of Naval Research Marine Mammals and Biology program funded a 

project (2013-2018) to test the thermal limits of infrared-based automatic whale detection technology. 

This project is focused on capturing whale spouts at two different locations featuring subtropical and 

tropical water temperatures, optimizing detector/classifier performance on the collected data, and 

testing system performance by comparing system detections with concurrent visual observations. 

The Navy has also been investigating the use of thermal detection systems with automated marine 

mammal detection algorithms for future mitigation during training and testing, including on 

autonomous platforms. For example, the Defense Advanced Research Projects Agency funded six initial 

studies to test and evaluate infrared-based thermal detection technologies and algorithms to 

automatically detect marine mammals on an unmanned surface vehicle. Based on the outcome of these 

initial studies, follow-on efforts and testing are planned for 2018-2019. 

Thermal detection systems are currently used by some specialized U.S. Air Force aircraft for marine 

mammal mitigation. These systems are specifically designed for and integrated into Air Force aircraft 

and cannot be added to Navy aircraft. Only certain Navy aircraft have specialized infrared capabilities, 

and these capabilities are only for fine-scale targeting within a narrow field of view. The only thermal 

imagery sensors aboard Navy surface ships are associated with specific weapons systems, and these 

sensors are not available on all vessels. These sensors are typically used only in select training events, 

have a limited lifespan before requiring expensive replacement, and are not optimized for marine 

mammal observations within the Navy’s mitigation zones. For example, as described in Section 5.3.3.3

(Explosive Medium-Caliber and Large-Caliber Projectiles), Lookouts are required to observe a 1,000-yd. 

mitigation zone around the intended impact location during explosive large-caliber gunnery activities. In 

addition to observing for marine mammals, one of the activity’s mission-essential requirements is for 

event participants, including Lookouts, to maintain focus on the mitigation zone to ensure the safety of 

Navy personnel and equipment and the public. Lookouts would not be able to observe the 1,000-yd. 

mitigation zone using the Navy’s thermal imagery sensors due to their narrow fields of view and 

technological design specific to fine-scale targeting. Such observations would be ineffective for marine 

mammals and would prevent Lookouts from effectively maintaining focus on the activity area and 

implementing mission-essential safety protocols. 

The effectiveness of even the most advanced commercially available thermal detection systems with 

technological designs specific to marine mammal observations is highly dependent on environmental 

conditions, animal characteristics, and animal behaviors (Zitterbart et al., 2013). Considering the range 

of environmental conditions and diversity of marine mammal species found throughout the Study Area, 

the use of thermal detection systems would be less effective than the traditional techniques currently 

employed by the Navy, such as naked-eye scanning, hand-held binoculars, and high-powered binoculars 

mounted on a ship deck. Furthermore, high false positive rates of thermal detection systems could 

result in the Navy implementing mitigation for features incorrectly identified as marine mammals. 

Increasing the instances of mitigation implementation based on incorrectly-identified features would 

have significant impacts on the ability for training and testing activities to accomplish their intended 

objectives, without providing any mitigation benefit to the species. In addition, thermal detection 
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systems are designed to detect marine mammals and do not have the capability to detect other 

resources for which the Navy is required to implement mitigation. Requiring Lookouts to use thermal 

detection systems would prevent them from detecting and mitigating for sea turtles and other biological 

resources (e.g., floating vegetation, jellyfish aggregations, large schools of fish). 

As discussed in Section 5.3 (Procedural Mitigation to be Implemented), the Navy’s procedural mitigation 

measures include the maximum number of Lookouts the Navy can assign to each activity based on 

available manpower and resources. It would be impractical to add personnel to serve as additional 

Lookouts for the sole purpose of thermal detection system use. For example, the Navy does not have 

available manpower to add Lookouts to use thermal detection systems in tandem with existing Lookouts 

who are using traditional observation techniques.

In summary, thermal detection systems have not been sufficiently studied both in terms of their 

effectiveness within the environmental conditions found in the Study Area and their compatibility with 

Navy training and testing. 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. The assessment will include an 

evaluation of the budget and acquisition process (including costs associated with designing, building, 

installing, maintaining, and manning equipment that is expensive and has a relatively short lifecycle 

before key system components need replacing); logistical and physical considerations for device 

installment, repair, and replacement (e.g., conducting engineering studies to ensure there is no 

electronic or power interference with existing shipboard systems); manpower and resource 

considerations for training personnel to effectively operate the equipment; and considerations of 

potential security and classification issues. New system integration on Navy assets can entail up to 5 to 

10 years of effort to account for acquisition, engineering studies, and development and execution of 

systems training. The Navy will provide information to NMFS about the status and findings of Navyfunded thermal detection studies and any associated practicality assessments at the annual adaptive 

management meetings. Information about the Navy’s adaptive management program is included in 

Section 5.1.2.2.1.1 (Adaptive Management).

5.5.5 THIRD-PARTY OBSERVERS

When assessing and developing mitigation, the Navy considered increasing the use of third-party 

observers during training and testing to aid in the implementation of procedural mitigation. The use of 

third-party observers to conduct pre- or post-activity biological resource observations would be an 

ineffective mitigation because marine mammals would likely move into or out of the activity area, and 

mitigation must be implemented at the time the activity is taking place. The Navy will use third-party

observers in combination with Lookouts for ship shock trials primarily because of the requirement to 

conduct marine species monitoring for multiple days after the event, which would detract Navy 

personnel from essential tasks related to mission objectives. 

There are significant manpower and logistical constraints that make using third-party observers for 

every training and testing activity under the Proposed Action impractical. Training and testing activities 

often occur simultaneously and in various regions throughout the Study Area, some of which last for 

days or weeks at a time. Having third-party observers embark on Navy vessels or aircraft would result in

safety and security clearance issues. Training and testing event planning includes careful consideration 
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of capacity limitations when placing personnel on participating aircraft and vessels. The Navy is unable 

to add third-party observers on a ship or substitute a Navy Lookout with a third-party observer without 

causing a berthing shortage or exceedance of other space limitations, or impacting the ability for 

Lookouts to complete their other mission-essential duties. The use of third-party observers also presents

national security concerns due to the requirement to provide advance notification of specific times and 

locations of Navy platform movements and activities (e.g., vessels using active sonar).

Reliance on the availability of third-party personnel for mitigation would be impractical because training 

and testing activity timetables oftentimes cannot be precisely fixed and are instead based on the freeflow development of tactical situations. Waiting for third-party aircraft or vessels to complete surveys, 

refuel, or transit on station would extend the length of the activity in a way that would diminish realism 

and delay training and testing schedules. Hiring third-party civilian vessels or aircraft to observe 

additional Navy training and testing activities would also be unsustainable due to the significant 

associated costs. Because many training and testing activities take place offshore, the amount of time 

observers would spend on station would be limited due to aircraft fuel restrictions. Fuel restrictions and 

distance from shore would increase safety risks should mechanical problems arise. The presence of 

civilian aircraft or vessels in the vicinity of training and testing activities would present increased safety 

risks due to airspace conflicts and proximity to explosives. 

5.5.6 FOREIGN NAVY MITIGATION

When assessing and developing mitigation, the Navy considered adopting the mitigation measures 

implemented by foreign navies. Mitigation measures are carefully developed for and assessed by each 

individual navy based on the potential impacts of their activities on the biological resources that live in 

their Study Areas, and the practicality of mitigation implementation based on their training mission and 

testing program requirements and the resources available for mitigation. The U.S. Navy’s readiness 

considerations differ from those of foreign navies based on each navy’s strategic reach, global mission, 

country-specific legal requirements, and geographic considerations. Most non-U.S. navies do not 

possess an integrated strike group and do not have integrated training requirements. The U.S. Navy’s 

training is built around the integrated warfare concept and is based on the U.S. Navy’s capabilities, the 

threats faced, the operating environment, and the overall mission. For this reason, not all measures

developed for foreign navies would be effective at reducing impacts of U.S. Navy training or testing, or 

practical to implement by the U.S. Navy (and vice versa). For example, some navies implement active 

sonar ramp-up as mitigation for marine mammals; however, as described in Section 5.5.1 (Active Sonar), 

the U.S. Navy determined that active sonar ramp-up would be an ineffective mitigation measure for 

training and testing activities under the Proposed Action and would be impractical to implement 

because it would significantly impact training and testing realism. 

The U.S. Navy will implement the mitigation measures as described in Section 5.3 (Procedural Mitigation 

to be Implemented) and Section 5.4 (Mitigation Areas to be Implemented) because they have been 

determined to be effective at avoiding or reducing impacts from the Proposed Action and practical to 

implement by the U.S. Navy. Many of these measures are the same as, or comparable to, those 

implemented by foreign navies. For example, most navies implement some form of procedural 

mitigation to cease certain activities if a marine mammal is observed in a mitigation zone (Dolman et al., 

2009). Some navies also implement geographic mitigation to restrict activities within particularly 

important marine mammal breeding, feeding, or migration habitats. The U.S. Navy will implement 

several mitigation measures and environmental compliance initiatives that are not implemented by 

foreign navies. For example, as discussed in Section 5.1.2.2 (Monitoring, Research, and Reporting 
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Initiatives), the U.S. Navy will continue to sponsor scientific monitoring and research and comply with 

stringent reporting requirements.

5.5.7 REPORTING REQUIREMENTS

When assessing and developing mitigation, the Navy considered increasing its reporting requirements, 

such as additional reporting of vessel speeds and marine species observations. As discussed in Section 

5.1.2.2 (Monitoring, Research, and Reporting Initiatives), the Navy developed its reporting requirements 

in conjunction with NMFS and the USFWS to be consistent with mission requirements and balance the 

usefulness of the information to be collected with the practicality of collecting it. The Navy’s training and 

testing activity reports and incident reports are designed to verify mitigation implementation; comply 

with current permits, authorizations, and consultation requirements; and improve future environmental 

analyses. The Navy reports to NMFS if mitigation was implemented during sinking exercises and ship 

shock trials (e.g., number of times explosive detonations were delayed due to marine mammal

sightings). For major training exercises, the Navy’s annual training and testing activity reports include 

information on each individual marine mammal sighting related to mitigation implementation. In the 

unlikely event a that a marine mammal vessel strike occurs, the Navy provides NMFS with relevant 

information pertaining to the incident, including but not limited to vessel speed.

Additional administrative reporting would be ineffective as mitigation because it would not result in 

modifications to training or testing activities or further avoidance or reductions of potential impacts. For 

example, additional administrative reporting of vessel speed data would not result in modifications to 

vessel speeds (e.g., speed restrictions) or reduce the already low potential for marine mammal vessel 

strikes. Lookouts are not trained to make species-specific identification and would not be able to 

provide detailed scientific data if more detailed marine species observation reports were to be required.

Furthermore, the Navy does not currently maintain a record management system to collect, archive, 

analyze, and report marine species observation or vessel speed data for every training and testing 

activity and all vessel movements. For example, the speed of Navy vessels can fluctuate an unlimited 

number of times during training and testing events. Developing and implementing a record 

management system of this magnitude would be unduly cost prohibitive and place a significant 

administrative burden on vessel operators and activity participants. Burdening operational 

Commanders, vessel operators, and event participations with requirements to complete additional 

administrative reporting would distract them from preparing a ready force and focusing on missionessential tasks. Additional reporting requirements would draw event participants’ attention away from 

the complex tactical tasks they are primarily obligated to perform, such as driving a warship or engaging 

in a gunnery event, which would adversely impact Navy personnel safety, public safety, and the 

effectiveness of training or testing. 

As part of the U.S. Navy Marine Species Monitoring Program, the Navy conducted 5 years of monitoring 

before, during, and after several types of events involving the use of explosives in the Study Area. For 

example, the Navy submitted annual marine mammal monitoring reports for mine neutralization 

exercises in the Virginia Capes Range Complex under its Phase I and Phase II MMPA permits. These 

reports were designed, in part, to address if the Navy’s mitigation measures for explosives were 

effective at avoiding injury and mortality of marine mammals. The Navy’s monitoring reports detailed all 

marine mammal sightings and if mitigation was implemented during each event. The Navy did not 

observe any dead or injured marine mammals during these monitoring events. There has not been a 

demonstrated utility for, or benefit of, continuing to collect and report similar marine species 

observation and mitigation data for training and testing activities under the Proposed Action. 
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5.5.8 PERMISSION SCHEMES

Following publication of the 2013 Hawaii-Southern California Training and Testing (HSTT) Final EIS/OEIS, 

a 2015 settlement agreement temporarily prohibited or restricted Navy activities within specific areas in 

the HSTT Study Area. The temporary settlement measures were derived pursuant to negotiations with 

plaintiffs and were 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 temporary settlement agreement did not constitute a concession by 

the Navy as to the potential impacts of its activities on marine mammals or other species. The 

settlement terms do not extend ad infinitum, were agreed to only for the purpose of settling the 

lawsuit, and were never intended to be a framework for how the Navy develops future mitigation.

The Navy's adoption of temporary restrictions on its activities as part of a relatively short-term 

settlement does not mean that those restrictions are supported by the best available science or are 

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. For example, an activity permission scheme is impractical

and unwarranted in the AFTT Study Area based on the extensive level of Navy Senior Leadership review 

and approval of mitigation measures that will be implemented under the Proposed Action. The 

mitigation measures described in Section 5.3 (Procedural Mitigation to be Implemented) and Section 5.4

(Mitigation Areas to be Implemented) 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.

As described in Chapter 2 (Description of Proposed Action and Alternatives) and Chapter 3 (Affected 

Environment and Environmental Consequences), the Navy conducts thousands of discrete training and 

testing activities, many involving active sonar and explosives. In most cases, activities are small-scale 

unit-level training activities or testing events with minor potential to impact the environment. To require 

that each individual event be approved at an elevated level of command would essentially paralyze Navy 

decision-making as senior Commanders would be focused on approving otherwise minor and minimally 

impactful activities. For major training exercises, senior Commanders are already part of the planning 

and approval processes. Burdening operational Commanders with requirements to complete additional 

administrative tasks would distract them from preparing a ready force. At the most fundamental level, a

training and testing activity permission scheme within the AFTT Study Area would run 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. Requiring additional permission for training and testing 

activities in the AFTT Study Area would be impractical because it would not be compatible with meeting 

the purpose and need of the Proposed Action. The Navy will continue to institutionalize mitigation 

procedures and tools to facilitate Navywide environmental compliance and reduce administrative 

burdens, such as the Protective Measures Assessment Protocol discussed in Section 5.2 (Mitigation 

Development Process) and Section 5.3.1 (Environmental Awareness and Education). 

5.6 MITIGATION SUMMARY

Table 5.6-1 and Table 5.6-2 summarize the mitigation measures that the Navy will implement under 

Alternative 1 or Alternative 2 of the Proposed Action. Figure 5.6-1 displays the mitigation areas in the 

Study Area. Unless specified otherwise in the tables, the mitigation applies year-round. For specific 
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requirements, additional information, and clarifications to the table summaries, see Section 5.3

(Procedural Mitigation to be Implemented) and Section 5.4 (Mitigation Areas to be Implemented).

Table 5.6-1: Summary of Procedural Mitigation

Stressor or Activity Mitigation Zones Sizes and Other Requirements Protection Focus

Environmental Awareness 

and Education

 Afloat Environmental Compliance Training program for applicable personnel Marine mammals,

Sea turtles

Active Sonar Depending on sonar source: 

 1,000 yd. power down, 500 yd. power down, and 200 yd. shut down 

 200 yd. shut down

Marine mammals,

Sea turtles

Air Guns  150 yd. Marine mammals,

Sea turtles

Pile Driving  100 yd. Marine mammals,

Sea turtles

Weapons Firing Noise  30° on either side of the firing line out to 70 yd. Marine mammals,

Sea turtles

Aircraft Overflight Noise  Distance from shore in the Virginia Capes Range Complex and Fisherman 

Island National Wildlife Refuge during explosive mine neutralization 

activities involving Navy divers (piping plovers and other nesting birds)

 Distance from shore in the Dry Tortugas Islands for supersonic flights (Fort 

Jefferson and roseate terns)

Birds,

Cultural resources

Explosive Sonobuoys  600 yd. Marine mammals,

Sea turtles

Explosive Torpedoes  2,100 yd. Marine mammals,

Sea turtles

Explosive Medium-Caliber 

and Large-Caliber Projectiles

 1,000 yd. (large-caliber projectiles)

 600 yd. (medium-caliber projectiles during surface-to-surface activities) 

 200 yd. (medium-caliber projectiles during air-to-surface activities)

Marine mammals,

Sea turtles

Explosive Missiles and 

Rockets

 2,000 yd. (21–500 lb. net explosive weight)

 900 yd. (0.6–20 lb. net explosive weight)

Marine mammals,

Sea turtles

Explosive Bombs  2,500 yd. Marine mammals,

Sea turtles

Sinking Exercises  2.5 NM Marine mammals,

Sea turtles

Explosive Mine

Countermeasure and 

Neutralization Activities

 2,100 yd. (6–650 lb. net explosive weight)

 600 yd. (0.1–5 lb. net explosive weight)

Marine mammals,

Sea turtles

Explosive Mine Neutralization 

Activities Involving Navy 

Divers

 1,000 yd. (21–60 lb. net explosive weight for positive control charges and 

charges using time-delay fuses)

 500 yd. (0.1–20 lb. net explosive weight for positive control charges)

Marine mammals,

Sea turtles

Maritime Security Operations 

– Anti-Swimmer Grenades

 200 yd. Marine mammals,

Sea turtles

Line Charge Testing  900 yd. Marine mammals,

Sea turtles,

Gulf sturgeon

Ship Shock Trials  3.5 NM Marine mammals, 

Sea turtles

Vessel Movement  500 yd. (whales)

 200 yd. (other marine mammals)

 Vicinity (sea turtles)

 North Atlantic right whale Dynamic Management Area notification messages

Marine mammals,

Sea turtles

Towed In-Water Devices  250 yd. (marine mammals)

 Vicinity (sea turtles)

Marine mammals, 

Sea turtles

Small-, Medium-, and LargeCaliber Non-Explosive 

Practice Munitions

 200 yd. Marine mammals, 

Sea turtles

Non-Explosive Missiles and 

Rockets

 900 yd. Marine mammals, 

Sea turtles

Non-Explosive Bombs and 

Mine Shapes

 1,000 yd. Marine mammals,

Sea turtles
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Table 5.6-2: Summary of Mitigation Areas

Summary of Mitigation Area Requirements

Mitigation Areas for Shallow-water Coral Reefs

 The Navy will not conduct precision anchoring (except in designated anchorages), explosive or non-explosive mine countermeasure and 

neutralization activities, explosive or non-explosive mine neutralization activities involving Navy divers, explosive or non-explosive small-, 

medium-, and large-caliber gunnery activities using a surface target, explosive or non-explosive missile and rocket activities using a 

surface target, or explosive or non-explosive bombing or mine laying activities.

 The Navy will not place mine shapes, anchors, or mooring devices on the seafloor.

 Within the Key West Range Complex, vessels will operate within waters deep enough to avoid bottom scouring or prop dredging, with at 

least a 1-ft. clearance between the deepest draft of the vessel (with the motor down) and the seafloor at mean low water.

 Within the South Florida Ocean Measurement Facility Testing Range, the Navy will implement additional measures for shallow-water 

coral reefs, such as using real-time positioning and remote sensing information to avoid shallow-water coral reefs during deployment, 

installation, and recovery of anchors and mine-like objects, and during deployment of bottom-crawling unmanned underwater vehicles.

Mitigation Areas for Live Hard Bottom, Artificial Reefs, Submerged Aquatic Vegetation, and Shipwrecks

 The Navy will not conduct precision anchoring (except in designated anchorages), explosive mine countermeasure and neutralization 

activities, or explosive mine neutralization activities involving Navy divers, and will not place mine shapes, anchors, or mooring devices 

on the seafloor (except in designated locations).

 Within the Key West Range Complex, vessels will operate within waters deep enough to avoid bottom scouring or prop dredging, with at 

least a 1-ft. clearance between the deepest draft of the vessel (with the motor down) and the seafloor at mean low water.

 Within the South Florida Ocean Measurement Facility Testing Range, the Navy will implement additional measures for live hard bottom, 

such as using real-time positioning and remote sensing information to avoid live hard bottom during deployment, installation, and 

recovery of anchors and mine-like objects, and during deployment of bottom-crawling unmanned underwater vehicles.

Northeast North Atlantic Right Whale Mitigation Area

 The Navy will report the total hours and counts of active sonar and in-water explosives used in the mitigation area in its annual training 

and testing activity reports.

 The Navy will minimize use of active sonar to the maximum extent practicable and will not use explosives that detonate in the water.

 The Navy will conduct non-explosive torpedo testing during daylight hours in Beaufort sea state 3 or less using three Lookouts (one on a 

vessel, two in an aircraft during aerial surveys) and an additional Lookout on the submarine when surfaced; during transits, ships will 

maintain a speed of no more than 10 knots; during firing, ships will maintain a speed of no more than 18 knots except brief periods of 

time during vessel target firing. 

 Vessels will obtain the latest North Atlantic right whale sightings data and implement speed reductions after they observe a North 

Atlantic right whale, if within 5 NM of a sighting reported within the past week, and when operating at night or during periods of reduced 

visibility.

Gulf of Maine Planning Awareness Mitigation Area

 The Navy will report the total hours and counts of active sonar and in-water explosives used in the mitigation area in its annual training 

and testing activity reports.

 The Navy will not conduct major training exercises and will not conduct >200 hours of hull-mounted mid-frequency active sonar per year.

Northeast Planning Awareness Mitigation Areas and Mid-Atlantic Planning Awareness Mitigation Areas

 The Navy will avoid conducting major training exercises to the maximum extent practicable. 

 The Navy will not conduct more than four major training exercises per year.

Southeast North Atlantic Right Whale Mitigation Area (November 15 – April 15)

 The Navy will report the total hours and counts of active sonar and in-water explosives used in the mitigation area in its annual training 

and testing activity reports.

 The Navy will not use active sonar except as necessary for navigation training, object detection training, and dipping sonar.

 The Navy will not expend explosive or non-explosive ordnance.

 Vessels will obtain the latest North Atlantic right whale sightings data; will implement speed reductions after they observe a North 

Atlantic right whale, if within 5 NM of a sighting reported within the past 12 hours, and when operating at night or during periods of 

reduced visibility; and will minimize north-south transits to the maximum extent practicable.

Jacksonville Operating Area (November 15 – April 15)

 Navy units conducting training or testing activities in the Jacksonville Operating Area will obtain and use Early Warning System North 

Atlantic right whale sightings data as they plan specific details of events to minimize potential interactions with North Atlantic right 

whales to the maximum extent practicable. The Navy will use the reported sightings information to assist visual observations of 

applicable mitigation zones and to aid in the implementation of procedural mitigation.

Southeast North Atlantic Right Whale Critical Habitat Special Reporting Area (November 15 – April 15)

 The Navy will report the total hours and counts of active sonar and in-water explosives used in the mitigation area in its annual training 

and testing activity reports.
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Table 5.6-2: Summary of Mitigation Areas (continued)

Summary of Mitigation Area Requirements

Navy Cherry Point Range Complex Nearshore Mitigation Area (March – September)

 The Navy will not conduct explosive mine neutralization activities involving Navy divers in the mitigation area.

 To the maximum extent practicable, the Navy will not use explosive sonobuoys, explosive torpedoes, explosive medium-caliber and largecaliber projectiles, explosive missiles and rockets, explosive bombs, explosive mines during mine countermeasure and neutralization 

activities, and anti-swimmer grenades in the mitigation area.

Bryde’s Whale Mitigation Area

 The Navy will report the total hours and counts of active sonar and in-water explosives used in the mitigation area in its annual training 

and testing activity reports.

 The Navy will not conduct >200 hours of hull-mounted mid-frequency active sonar per year and will not use explosives (except during 

explosive mine warfare activities).

Gulf of Mexico Planning Awareness Mitigation Areas

 The Navy will avoid conducting major training exercises to the maximum extent practicable. 

 The Navy will not conduct any major training exercises under Alternative 1 and no more than one per year under Alternative 2.
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Notes: AFTT: Atlantic Fleet Training and Testing

Figure 5.6-1: Summary of Mitigation Areas in the Study Area
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5.0 References

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A. Ainslie. (2014). Modeling effectiveness of gradual increases in source level to mitigate effects 

of sonar on marine mammals. Conservation Biology, 28(1), 119–128. 
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Marine Mammal Stock Assessments–2013 (NOAA Technical Memorandum NMFS-NE-228). 

Woods Hole, MA: U.S. Department of Commerce, National Marine Fisheries Service.

Waring, G. T., K. Maze-Foley, and P. E. Rosel, (Eds.). (2015). U.S. Atlantic and Gulf of Mexico Marine 

Mammal Stock Assessments–2014 (NOAA Technical Memorandum NMFS-NE-231). Woods Hole, 

MA: U.S. Department of Commerce, National Marine Fisheries Service.

Waring, G. T., E. Josephson, K. Maze-Foley, P. E. Rosel, B. Byrd, T. V. N. Cole, L. Engleby, L. P. Garrison, J. 

Hatch, A. Henry, S. C. Horstman, J. Litz, M. C. Lyssikatos, K. D. Mullin, C. Orphanides, R. M. Pace, 

D. L. Palka, M. Soldevilla, and F. W. Wenzel. (2016). U.S. Atlantic and Gulf of Mexico Marine 

Mammal Stock Assessments–2015 (NOAA Technical Memorandum NMFS-NE-238). Woods Hole, 

MA: U.S. Department of Commerce, National Marine Fisheries Service.

Weinrich, M., M. Martin, R. Griffiths, J. Bove, and M. Schilling. (1997). A shift in distribution of humpback 

whales, Megaptera novaeangliae, in response to prey in the southern Gulf of Maine. Fishery 

Bulletin, 95(4), 826–836. 

Weinrich, M. T., and A. E. Kuhlberg. (1991). Short-term association patterns of humpback whale 

(Megaptera novaeangliae) groups on their feeding grounds in the southern Gulf of Maine. 

Canadian Journal of Zoology, 69(12), 3005–3011. 

Weinrich, M. T., R. D. Kenney, and P. K. Hamilton. (2000). Right whales (Eubalaena glacialis) on Jeffreys 

Ledge: A habitat of unrecognized importance? . Marine Mammal Science, 16(2), 326–337. 

Weinrich, M. T., K. Sardi, and C. Pekarcik. (2005). Fall boat-based surveys on Jeffrey’s Ledge for North 

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(PhD. Dissertation). Texas A&M University, College Station, TX.

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Winn, H. E., J. D. Goodyear, R. D. Kenney, and R. O. Petricig. (1995). Dive patterns of tagged right whales 

in the Great South Channel. Continental Shelf Research, 15(4-5), 593–611. 
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College Station, TX: Texas A&M University Press.

Zitterbart, D. P., L. Kindermann, E. Burkhardt, and O. Boebel. (2013). Automatic round-the-clock 

detection of whales for mitigation from underwater noise impacts. PLoS ONE, 8(8), e71217. 
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Table of Contents

Final 

Environmental Impact Statement/Overseas Environmental Impact Statement 

Atlantic Fleet Training and Testing

TABLE OF CONTENTS

6 REGULATORY CONSIDERATIONS ___________________________________________________6-1

6.1 Consistency with Regulatory Considerations...............................................................6-1

6.1.1 Coastal Zone Management Act Compliance..........................................................6-5

6.1.2 Marine Protected Areas.........................................................................................6-7

6.1.2.1 State Marine Protected Areas .............................................................6-41

6.1.2.2 National Estuarine Research Reserves ................................................6-41

6.1.2.3 National Wildlife Refuges ....................................................................6-41

6.1.2.4 Gear Restricted Areas..........................................................................6-41

6.1.2.5 National Parks and Seashores..............................................................6-41

6.1.2.6 National Marine Sanctuaries ...............................................................6-42

6.1.3 Magnuson-Stevens Fishery Conservation and Management Act........................6-65

6.2 Relationship Between Short-Term Use of the Environment and 

Maintenance and Enhancement of Long-Term Productivity.......................................6-66

6.3 Irreversible or Irretrievable Commitment of Resources.............................................6-67

6.4 Energy Requirements and Efficiency Initiatives.........................................................6-68

List of Figures

Figure 6.1-1: Location of National System of Marine Protected Areas within the Northeast 

and Mid-Atlantic Portion of the Study Area .......................................................................6-37

Figure 6.1-2: Location of National System of Marine Protected Areas within the Southeast 

Atlantic Portion of the Study Area......................................................................................6-38

Figure 6.1-3: Location of National System of Marine Protected Areas within the Gulf of 

Mexico Portion of the Study Area ......................................................................................6-39

Figure 6.1-4: Location of National System of Marine Protected Areas within the Caribbean 

Portion of the Study Area ...................................................................................................6-40

Figure 6.1-5: Location of National Marine Sanctuaries within the Northeast and MidAtlantic Portion of the Study Area......................................................................................6-43

Figure 6.1-6: Location of National Marine Sanctuaries within the Southeast Atlantic and 

Gulf of Mexico Portion of the Study Area...........................................................................6-49
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List of Tables

Table 6.1-1: Summary of Environmental Compliance for the Proposed Action........................................6-2

Table 6.1-2: National System of Parks and Marine Protected Areas within the Study Area...................6-10
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6 REGULATORY CONSIDERATIONS

In accordance with the Council on Environmental Quality regulations for implementing the National 

Environmental Policy Act (NEPA), federal agencies shall, to the fullest extent possible, integrate the 

requirements of NEPA with other planning and environmental review procedures required by law or by 

agency practice so that all such procedures run concurrently rather than consecutively. This chapter 

summarizes environmental compliance for the Proposed Action, consistency with other federal, state, 

and local plans, policies, and regulations not considered in Chapter 3 (Affected Environment and 

Environmental Consequences); the relationship between short-term impacts and the maintenance and 

enhancement of long-term productivity in the affected environment; irreversible and irretrievable 

commitments of resources; and energy conservation.

6.1 CONSISTENCY WITH REGULATORY CONSIDERATIONS

Implementation of the Proposed Action for the Atlantic Fleet Training and Testing (AFTT) Environmental 

Impact Statement (EIS)/Overseas Environmental Impact Statement (OEIS), would comply with applicable 

federal, state, and local laws, regulations, and executive orders. The United States (U.S.) Department of 

the Navy (Navy) is consulting with and will continue to consult with regulatory agencies, as appropriate, 

during the NEPA process and prior to implementation of the Proposed Action to ensure that 

requirements are met. Table 6.1-1 summarizes the additional environmental compliance requirements 

not specifically assessed in the resource chapters. Documentation of consultation and coordination with 

regulatory agencies is provided in Appendix J (Agency Correspondence).
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Table 6.1-1: Summary of Environmental Compliance for the Proposed Action

Laws, Executive Orders, 

International Standards, and 

Guidance Status of Compliance

LAWS

Abandoned Shipwreck Act (43 

United States Code [U.S.C.]

sections 2101-2106)

For abandoned shipwrecks in U.S. Territorial Waters, the federal 

government asserts title to the resource. See Section 3.10 (Cultural 

Resources) for assessment and conclusion that the Proposed Action is 

consistent with the act.

Act to Prevent Pollution from 

Ships (33 U.S.C. sections 1901-

1915)

The Act to Prevent Pollution from Ships applies to U.S. vessels worldwide 

and implements the requirements of annexes I (Oil Pollution), II (Noxious 

Liquid Substances Carried in Bulk), V (Ship-Generated Garbage), and VI (Air 

Pollution) of the International Convention for the Prevention of Pollution 

from Ships for the United States. This act excludes warships and naval 

auxiliaries from the preventive measures in annexes I, II, and VI. Annex V 

requires Navy ships and submarines to comply fully with discharge 

restrictions applicable outside of "special areas" designated under annex V 

and places limitations on Navy ship discharges within annex V special 

areas. Requirements associated with the Act to Prevent Pollution from 

Ships are implemented in accordance with the Navy Environmental and 

Natural Resources Program Manual and related Navy guidance documents 

governing waste management, pollution prevention, and recycling. At sea, 

the Navy complies with these policies and operates in a manner that 

minimizes or eliminates any adverse effects to the marine environment. 

See Section 3.2 (Sediments and Water Quality) for the assessment.

Antiquities Act 

(16 U.S.C. sections 431-433)

In accordance with Navy procedures, the Proposed Action is consistent 

with the act’s objectives for protection of archaeological and historical 

sites and objects, preservation of cultural resources, and the public's 

access to them. See Section 3.10 (Cultural Resources) for the assessment.

Coastal Zone Management Act 

(16 U.S.C. sections 1451-1464)

The Navy has complied with the coastal zone federal consistency 

requirements for those states/territories whose coastal uses or resources 

may be affected by the Proposed Action (as discussed in Section 6.1.1).

Historic Sites Act 

(16 U.S.C. sections 461–467)

In accordance with Navy procedures, the Proposed Action is consistent 

with the national policy for the preservation of historic sites, buildings, 

and objects of national significance. See Chapter 3.10 (Cultural Resources) 

for the assessment.

Magnuson-Stevens Fishery 

Conservation and Management 

Act (16 U.S.C. sections 1801–

1882)

The Navy has prepared an Essential Fish Habitat Assessment as a separate 

document. The Proposed Action will have an adverse effect on Essential 

Fish Habitat and managed species. The Navy consulted with the National 

Marine Fisheries Service (NMFS) for affected species and their habitats (as 

discussed in Section 6.1.3). 

Migratory Bird Treaty Act 

(16 U.S.C. sections 703–712)

Implementation of the Proposed Action is not anticipated to result in 

significant adverse effects on migratory birds; therefore, the Navy does 

not need to confer with the U.S. Fish and Wildlife Service (USFWS). See 

Section 3.9 (Birds and Bats) for the assessment.
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Table 6.1-1: Summary of Environmental Compliance for the Proposed Action (continued)

Laws, Executive Orders, 

International Standards, and 

Guidance Status of Compliance

National Fishery Enhancement Act 

(33 U.S.C. sections 2101-2106)

The Proposed Action is consistent with regulations administered by NMFS 

and U.S. Army Corps of Engineers concerning artificial reefs in the 

navigable waters of the United States. Impacts to artificial reefs are 

covered in the Essential Fish Habitat Assessment.

National Historic Preservation Act 

(16 U.S.C. sections 470 et seq.)

The Navy consulted with State Historic Preservation Officers under

Section 106 of this Act. See Section 3.10 (Cultural Resources) for the 

assessment.

National Marine Sanctuaries Act 

(16 U.S.C. sections 1431-1445c-1)

Five National Marine Sanctuaries administered by National Oceanic and 

Atmospheric Administration Office of National Marine Sanctuaries lie 

within the Study Area. These are discussed further in Section 6.1.2.6

(National Marine Sanctuaries).

 Activities the Navy proposes to conduct in the Gerry E. Studds 

Stellwagen Bank National Marine Sanctuary are consistent with the 

activities considered when the Sanctuary was designated and are 

consistent with Navy activities and planning during the development of 

the most recent management plan. The Navy consulted under Section 

304(d).

 The Navy does not propose to conduct any new activities in the Monitor

National Marine Sanctuary that would cause significant impacts on

sanctuary resources. Furthermore, the Navy does not propose to 

increase the level of existing activities within the sanctuary from what 

was previously considered at the time of sanctuary designation. The 

Navy did not consult under Section 304(d).

 Activities the Navy proposes to conduct in Gray’s Reef National Marine 

Sanctuary are consistent with the activities exempted when the 

sanctuary was designated and are consistent with Navy activities and 

planning during the development of the most recent management plan.

The Navy consulted under Section 304(d).

 Activities the Navy proposes to conduct in the Florida Keys National 

Marine Sanctuary are within the classes of activities exempted from 

requiring a permit as of the effective date of the sanctuary regulations 

and are consistent with Navy activities and planning included in the 

most recent management plan. The Navy consulted under Section 

304(d).

 Activities the Navy proposes to conduct in Flower Garden Banks National 

Marine Sanctuary are consistent with the activities exempted when the 

sanctuary was designated and are consistent with Navy activities and 

planning during the development of the most recent management plan.

The Navy did not consult under Section 304(d).
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Table 6.1-1: Summary of Environmental Compliance for the Proposed Action (continued)

Laws, Executive Orders, 

International Standards, and 

Guidance Status of Compliance

Resource Conservation and 

Recovery Act (42 U.S.C. section 

6901 et seq.) / Military Munitions 

Rule

Under the Resource Conservation and Recovery Act, the Military 

Munitions Rule identifies when conventional and chemical military 

munitions are considered solid waste. Military munitions are not 

considered solid waste based on two conditions stated in the 40 Code of 

Federal Regulations (CFR) section 266.202(a)(1)(i-iii). Specifically, 

munitions are not considered hazardous waste when: 1. Used for their 

intended purpose, including training of military personnel and explosive 

emergency response specialists; research and development activities; and 

when recovered, collected, and destroyed during range clearance events. 

2. Unused and being repaired, reused, recycled, reclaimed, disassembled, 

reconfigured, or subjected to other material recovery activities. These two 

conditions cover the uses of munitions included in the Proposed Action; 

therefore, the Resource Conservation and Recovery Act does not apply.

Rivers and Harbors Act (33 U.S.C. 

section 401 et seq.)

 Under the Rivers and Harbors Act, a U.S. Army Corps of Engineers 

permit is required when construction is proposed in navigable waterways. 

The Navy will acquire U.S. Army Corps of Engineers permits where 

applicable.

Submerged Lands Act of 1953 (43 

U.S.C. sections 1301–1315)

The Proposed Action occurs within state waters as released to state 

authority through the Submerged Lands Act. The U.S. retained navigable 

servitude and rights or powers in those waters for purposes of navigation 

and national defense among other uses. Therefore, the Navy's activities 

are compatible with the state's rights of ownership, management, leasing, 

use, and development of lands and natural resources recognized under 

the Submerged Lands Act.

Sunken Military Craft Act (Public 

Law 108–375, 10 U.S.C. section

113 Note and 118 Stat. 2094–

2098)

The Sunken Military Craft Act does not apply to actions taken by, or at the 

direction of, the United States. See Section 3.10 (Cultural Resources) for 

the assessment.

R.M.S. Titanic Maritime Memorial 

Preservation Act (16 U.S.C. 

sections 450rr-450rr-6)

In accordance with Navy procedures, implementation of the Proposed 

Action would not affect efforts to designate the shipwreck of the R.M.S.

Titanic as an international maritime memorial and the development of 

international guidelines for reasonable research, exploration, and, if 

appropriate salvage activities with respect to the shipwreck.

EXECUTIVE ORDERS

Executive Order 11990, Protection 

of Wetlands

In accordance with Navy procedures, implementation of the Proposed 

Action would not affect wetlands as defined in Executive Order 11990. 

The action being analyzed takes place at sea; therefore, no terrestrial 

wetlands would be impacted by the Proposed Action. However, the 

Proposed Action does overlap with some areas that contain coastal and 

emergent wetlands. See Section 3.3 (Vegetation) for more details.

Executive Order 12898, Federal 

Actions to Address Environmental 

Justice in Minority Populations 

and Low-Income Populations

In accordance with Navy procedures, the Proposed Action would not 

result in any disproportionately high and adverse human health or 

environmental effects on minority or low-income populations. See Section 

3.0.3.2 (Resources and Issues Eliminated from Further Consideration).
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Table 6.1-1: Summary of Environmental Compliance for the Proposed Action (continued)

Laws, Executive Orders, 

International Standards, and 

Guidance Status of Compliance

Executive Order 12962, 

Recreational Fisheries

In accordance with Navy procedures, the Proposed Action would not 

affect federal agencies’ ability to fulfill certain duties with regard to 

promoting the health and access of the public to recreational fishing 

areas. See Section 3.11 (Socioeconomics) for the assessment.

Executive Order 13045, Protection 

of Children from Environmental 

Health Risks and Safety Risks

In accordance with Navy procedures, the Proposed Action would not 

result in disproportionate environmental health or safety risks to children. 

See Section 3.0.3.2 (Resources and Issues Eliminated from Further 

Consideration).

Executive Order 13089, Coral Reef 

Protection

The Navy has prepared this EIS/OEIS in accordance with requirements 

that federal agencies whose actions affect U.S. coral reef ecosystems shall 

provide for the implementation of measures needed to research, monitor, 

manage, and restore them, including reducing impacts from pollution and 

sedimentation. See Section 3.4 (Invertebrates) for the assessment.

Executive Order 13112, Invasive 

Species

In accordance with Navy procedures, the Proposed Action would not 

increase the number of or introduce new invasive species nor require the 

Navy to take measures to avoid introduction and spread of those species. 

Naval vessels are exempt from 33 CFR Part 151 Subpart D, Ballast Water 

Management for Control of Nonindigenous Species in Waters of the 

United States; however, the Navy follows ballast water protocols as 

required by DoD Manual 4716.60 Volume 3.

Executive Order 13158, Marine 

Protected Areas

The Navy has prepared this EIS/OEIS in accordance with requirements for 

the protection of existing national system of marine protected areas. See 

Section 6.1.2 (Marine Protected Areas) for more information.

Executive Order 13175, 

Consultation and Coordination 

with Indian Tribal Governments

In accordance with Navy procedures, the Proposed Action would not have 

substantial direct effects on one or more Indian tribes, on the relationship 

between the federal government and Indian tribes, or on the distribution 

of power and responsibilities between the federal government and Indian 

tribes. See Section 8.4.4 (Federally-Recognized Tribes) for federallyrecognized tribes that were provided notification letters of the AFTT 

EIS/OEIS.

Executive Order 13840, Ocean 

Policy to Advance the Economic, 

Security, and Environmental 

Interests of the United States

The Proposed Action is consistent with the National Ocean Policy to 

Advance the Economic, Security, and Environmental Interests of the 

United States.

Executive Order 13834,

Efficient Federal Operations

The Proposed Action is consistent with the federal government's goals to 

reduce waste, cut costs, enhance the resilience of federal infrastructure 

and operations, and enable more effective accomplishment of its mission.

INTERNATIONAL STANDARDS

International Convention for the 

Prevention of Pollution from Ships

The Proposed Action does include vessel operation and incidental 

discharges from ships; however, Navy vessels operating in the Study Area 

comply with applicable law and regulations, minimizing or eliminating 

potential impact from discharges from ships.

6.1.1 COASTAL ZONE MANAGEMENT ACT COMPLIANCE

The Coastal Zone Management Act of 1972 (16 U.S.C. sections 1451-1464) encourages coastal states to 

be proactive in managing coastal zone uses and resources. The act established a voluntary coastal 
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planning program and required participating states to submit a Coastal Management Plan to the 

National Oceanic and Atmospheric Administration for approval. Under the act, federal actions that have 

an effect on a coastal use or resources are required to be consistent, to the maximum extent 

practicable, with the enforceable policies of federally approved Coastal Management Plans. 

The Coastal Zone Management Act defines the coastal zone as extending offshore “to the outer limit of 

State title and ownership under the Submerged Lands Act” (i.e., 3 nautical miles [NM] from the 

shoreline, 9 NM for the west coast of Florida, Texas, and Puerto Rico). The coastal zone extends inland 

only to the extent necessary to control the shoreline, but the inland extent is not relevant to the 

Proposed Action.

A federal agency may submit a consistency determination, a negative determination, or a de minimis

exemption for review of their activities. A federal agency submits a consistency determination when it 

determines that its activity may have either a direct or an indirect reasonably foreseeable effect on a 

state coastal use or resource. The consistency determination should include a brief statement indicating 

whether the proposed activity will be undertaken in a manner consistent to the maximum extent 

practicable with the enforceable policies of the management program according to15 CFR section 

930.39. The consistency determination should be based on evaluation of the relevant enforceable 

policies of the management program. According to 15 CFR section 930.35, “if a Federal agency 

determines that there will not be coastal effects, then the Federal agency shall provide the State 

agencies with a negative determination for a Federal agency activity: (1) Identified by a State agency on 

its list, as described in section 930.34(b), or through case-by-case monitoring of unlisted activities; or (2) 

Which is the same as or is similar to activities for which consistency determinations have been prepared 

in the past; or (3) For which the Federal agency undertook a thorough consistency assessment and 

developed initial findings on the coastal effects of the activity.” Thus, a negative determination must be 

submitted to a state if the agency determines no coastal effects and one or more of the triggers above is 

met. De minimis exemptions are activities proposed by the federal agency that have already been 

reviewed and approved by the state (after allowing for public review and comment), and those that the

state has recognized as having insignificant direct or indirect (secondary or cumulative) effects on its 

coastal resources.

In accordance with the Coastal Zone Management Act, the Navy has reviewed the enforceable policies 

of each state’s federally approved Coastal Zone Management Plan relevant to the Study Area. There are 

18 states (Maine, New Hampshire, Massachusetts, Rhode Island, Connecticut, New York, New Jersey, 

Delaware, Maryland, Virginia, North Carolina, South Carolina, Georgia, Florida, Alabama, Louisiana, 

Mississippi, and Texas) and two U.S. territories (Puerto Rico and U.S. Virgin Islands) whose coastal zones 

are located within the Study Area. The Navy determined that no activities are proposed within or in 

proximity to the coastal zones of Puerto Rico and the U.S. Virgin Islands, and therefore no activities 

would cause reasonably foreseeable effects on coastal uses or resources against which to analyze 

enforceable policies. As such, the Navy was not required to submit a negative determination pursuant to 

15 CFR 930.35. The remaining states do include activities within or in proximity to the activities 

proposed that may have reasonably foreseeable effects on coastal uses or resources, and are therefore 

subject to consistency requirements. Based on an evaluation of the effects of the Proposed Action 

discussed in this EIS/OEIS and the enforceable policies of each state’s Coastal Zone Management Plan, 

and pursuant to 15 CFR section 930.39, the Navy submitted consistency determinations to each of the 

18 states in March of 2018. The Navy either received concurrence or assumed concurrence (due to lack 

of response, in accordance with 15 CFR section 930.41) from 16 of the 18 states. Delaware provided 
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conditional concurrence, to which the Navy and Delaware agreed upon clarification of the condition. 

Georgia objected to the Navy’s consistency determination. A series of exchanges between the Navy and 

Georgia were unable to result in Georgia withdrawing its objection. The Navy notified Georgia, pursuant

to 15 CFR 930.43, with its intent to proceed with the Proposed Action over the state’s objection. Official 

correspondence between the Navy and each of the state agencies is provided in Appendix J.

6.1.2 MARINE PROTECTED AREAS

Many areas of the marine environment have some level of federal, state, or local management or 

protection. Marine protected areas are designated and managed at all levels of government by a variety 

of agencies and have been established by more than 100 legal authorities. Marine protected areas vary 

widely in purpose, managing agencies, management approaches, level of protection, and restrictions on 

human uses. They have been designated to achieve objectives ranging from the conservation of 

biodiversity, to the preservation of sunken historic vessels, to the protection of spawning species 

important to commercial and recreational fisheries. The levels of protection provided by these marine 

protected areas range from fully protected reserves (i.e., no take of any species is permitted) to sites 

allowing multiple uses including fishing, recreation, and industrial uses (National Marine Protected Areas 

Center, 2008).

Executive Order 13158, Marine Protected Areas (Federal Register 65(105): 34909-34911, May 26, 2000), 

directs the National Oceanic and Atmospheric Administration to establish a National Marine Protected 

Areas Center charged with developing a national system of marine protected areas, and with 

maintaining a list of sites formally accepted into the national system. A full list of areas accepted in the 

national system of marine protected areas is available from the National Marine Protected Areas Center. 

Executive Order 13158 requires each federal agency whose actions affect the natural or cultural 

resources protected by a marine protected area to identify such actions, and in taking such actions, 

avoid harm to those natural and cultural resources to the maximum extent practicable. Pursuant to 

Section 5 of Executive Order 13158, agency requirements apply only to the natural or cultural resources 

specifically afforded protection by the sites recognized in the List of National System Marine Protected 

Areas (National Marine Protected Areas Center, 2013). Although many sites contain coastal (within the 

continental shelf) lands and islands, only the resources of the protected coastal and ocean waters, and 

the submerged lands thereunder, are subject to Section 5 of Executive Order 13158 (National Park 

Service, 2006a). 

All resources of the marine protected areas located within the Study Area have been incorporated into 

the analyses in Sections 3.1 (Air Quality), 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), and 3.9 (Birds and 

Bats). In accordance with Executive Order 13158, the Navy has considered the potential impacts of its 

proposed activities under the Preferred Alternative (Alternative 1) to the national system of marine 

protected areas that contain marine waters within the Study Area, factoring in Navy standard operating 

procedures and mitigation when applicable to the stressor and resource. The Navy implements standard 

operating procedures for aircraft safety, which involves pilots of Navy aircraft making every attempt to 

avoid large flocks of birds to reduce the safety risk involved with a potential bird strike. Since 2011, the 

Navy has required that all Navy flying units report all bird strikes through the Web-Enabled Safety 

System Aviation Mishap and Hazard Reporting System. The standard operating procedures for aircraft 

safety could result in a secondary benefit to birds through a reduction in the potential for aircraft strike. 

The Navy also has several standard operating procedures for vessel safety. For example, ships operated 

by or for the Navy have personnel assigned to stand watch at all times, day and night, when moving 
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through the water (underway). Watch personnel undertake extensive training in accordance with the 

U.S. Navy Lookout Training Handbook or civilian equivalent. A primary duty of watch personnel is to 

ensure safety of the ship, and this includes the requirement to detect and report all objects and 

disturbances sighted in the water that may be indicative of a threat to the ship and its crew, such as 

debris, a periscope, surfaced submarine, or surface disturbance. Per standard operating procedures, 

watch personnel also report any marine mammals sighted that have the potential to be in the direct 

path of the ship as a standard collision avoidance procedure. The Navy also implements mitigation 

measures to avoid or reduce the potential for vessel strikes, including maneuvering to avoid marine 

mammals and sea turtles. Navy vessels are required to operate in accordance with applicable navigation 

rules, including Inland Navigation Rules (33 CFR 83) and International Regulations for Preventing 

Collisions at Sea (72 COLREGS). These rules require that vessels at all times proceed at a safe speed so 

that proper and effective action can be taken to avoid collision and so they can be stopped within a 

distance appropriate to the prevailing circumstances and conditions. The standard operating procedures 

for vessel safety could result in a secondary benefit to marine species through a reduction in the 

potential for vessel strike. For a full discussion of standard operating procedures, see Section 2.3.3 

(Standard Operating Procedures).

In addition to standard operating procedures, the Navy will implement mitigation to avoid potential 

impacts from sonar, explosives, and physical disturbance and strike stressors on applicable resources. 

For example, as described in Section 5.3.4 (Physical Disturbance and Strike Stressors), mitigation for 

vessel movements includes training Lookouts and watch personnel with the Marine Species Awareness 

Training (which provides information on sighting cues, visual observation tools and techniques, and 

sighting notification procedures), and requiring underway vessels to maneuver to maintain a specified 

distance from marine mammals and maneuver to avoid marine mammals and sea turtles. For a full 

discussion of mitigation, see Chapter 5 (Mitigation).

Table 6.1-2 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. As described in 

Chapter 2 (Description of Proposed Action and Alternatives), many training and testing activities could 

occur anywhere in the Study Area with proper range clearance (See Figure 2.3-1 and Table 2.3-5). These 

activities include:

 air warfare testing (air combat maneuver test; air platform/vehicle testing; intelligence, 

surveillance, and reconnaissance [does not typically occur in the coastal zone]);

 anti-submarine warfare (non-explosive torpedo exercise could occur anywhere within the study 

area with proper range clearance; explosive torpedo exercise would only occur greater than 3 

NM from shore; tracking exercise occurs anywhere in the study area where proper water depth 

[typically 120 ft. and greater] exists);

 electronic warfare operations;

 expeditionary warfare (dive and salvage operations; personnel insertion/extraction);

 mine warfare (mine countermeasure exercise – surface, - ship sonar; submarine mine exercise; 

marine mammal systems; mine neutralization; submarine launched mobile mining; civilian port 

defense);

 surface warfare (maritime security operations); and

 other training activities (sonar maintenance and system checks; submarine navigation; 

submarine under ice certification; waterborne training; surface ship object detection).
Atlantic Fleet

Training and Testing Final EIS/OEIS September 2018

6-9

6.0 Regulatory Considerations

Because the activities listed above are unlikely to occur in shallow nearshore waters, the impacts of such 

activities on marine protected areas located nearshore will not be considered further in this document. 

Military activities are sometimes exempted from the prohibitions applicable to marine protected areas. 

In cases where the military conducted activities within an area prior to its establishment as a marine 

protected area, those activities are often incorporated into the area’s management plan. Management 

policies specific to military activities are described below for the five different types of marine protected 

areas found in the Study Area (Table 6.1-2). Marine protected areas (not including National Marine 

Sanctuaries) located within the Study Area are shown in Figure 6.1-1, Figure 6.1-2, Figure 6.1-3, and 

Figure 6.1-4. The National Marine Sanctuaries located within the Study Area are shown in Figure 6.1-5

and Figure 6.1-6.
Atlantic Fleet

Training and Testing Final EIS/OEIS September 2018

6-10

6.0 Regulatory Considerations

Table 6.1-2: National System of Parks and Marine Protected Areas within the Study Area

Marine 

Protected Area

Figure/

Reference 

Number

Location within the Study 

Area Protection Focus

Summary of Relevant 

Regulations

Navy Proposed Activities 

Under the Preferred Alternative and 

Marine Protected Area Considerations

State and Territorial Marine Protected Areas

Blue Crab 

Sanctuary 

(established in 

1994; 2,448 

square 

kilometers [km2] 

in size)

Figure 6.1-1

(1)

Virginia:

Chesapeake Bay; overlaps 

mine warfare training 

areas, borders the 

VACAPES Range Complex 

and VACAPES OPAREA, 

and abuts pierside 

location at Joint 

Expeditionary Base Little 

Creek, Virginia Beach, 

Virginia

Focal Resource 

(Blue crab 

[Callinectes 

sapidus])

State regulations apply. 

Harvest restrictions are not 

applicable to Navy activities 

(Virginia Marine Resources 

Commission, 2015).

Ship signature testing activities and surface 

ship and submarine sonar testing activities 

would occur pierside at Little Creek; however, 

these activities are not expected to impact the 

blue crab or Blue Crab Sanctuary.

Kiptopeke State 

Park (established 

in 1992; 2 km2in 

size)

Figure 6.1-1

(2)

Virginia:

Lower Chesapeake Bay, 1 

NM from mine warfare 

training area

Ecosystem 

(migratory birds)

State regulations apply: 

prohibited to cut or scar any 

plant or tree, or to collect any 

plant or animal, except as 

authorized by permit (Virginia 

State Parks, 2017).

The resources protected by this area could be 

briefly exposed to aircraft overflights; 

however, overflights are not likely to harm the 

area’s protected natural resources. No other 

proposed activities are expected to occur in 

the area. Therefore, no impacts are expected 

within Kiptopeke State Park.

Arrecifes de la 

Cordillera 

Natural Reserve 

(established in 

1980; 101 km2in

size)

Figure 6.1-4

(3)

Puerto Rico:

Other AFTT Areas

Ecosystem 

(mangroves, 

lagoons, beaches, 

coral reefs)

Prohibited: access to islands 

that have colonies of nesting 

birds; camping (Arrecifes de 

la Cordillera Natural Reserve, 

2009).

The resources protected by this area could be 

briefly exposed to aircraft overflights; 

however, overflights are not likely to harm the 

area’s protected natural resources. No other 

proposed activities are expected to occur in 

the area. Therefore, no impacts are expected 

within Arrecifes de la Cordillera Natural 

Reserve.
Atlantic Fleet

Training and Testing Final EIS/OEIS September 2018

6-11

6.0 Regulatory Considerations

Table 6.1-2: National System of Parks and Marine Protected Areas within the Study Area (continued)

Marine 

Protected Area

Figure/

Reference 

Number

Location within the Study 

Area Protection Focus

Summary of Relevant 

Regulations

Navy Proposed Activities 

Under the Preferred Alternative and 

Marine Protected Area Considerations

Isla de Desecheo 

Marine Reserve 

(established in 

2000; 6 km2in 

size)

Figure 6.1-4

(4)

Puerto Rico: 

Other AFTT Areas

Ecosystem (coral 

reefs)

Prohibited: taking of any 

species or resource from the 

Marine Reserve. No sitespecific management plan is 

currently in place (National 

Oceanic and Atmospheric 

Administration, 2009).

The resources protected by this area could be 

briefly exposed to aircraft overflights; 

however, overflights are not likely to harm the 

area’s protected natural resources. No other 

proposed activities are expected to occur in 

the area. Therefore, no impacts are expected 

within Isla de Desecheo Marine Reserve.

Tres Palmas de 

Rincón Marine 

Reserve 

(established in 

2004; 1 km2 in 

size)

Figure 6.1-4

(5)

Puerto Rico: 

Other AFTT Areas

Focal Resource 

(Elkhorn coral 

[Acropora 

palmata])

Prohibited: modification of 

aquatic habitat that is 

essential for vulnerable 

species (Tres Palmas de 

Rincón Marine Reserve, 

2009).

The resources protected by this area could be 

briefly exposed to aircraft overflights; 

however, overflights are not likely to harm the 

area’s protected natural resources. No other 

proposed activities are expected to occur in 

the area. Therefore, no impacts are expected 

within Tres Palmas de Rincón Marine Reserve.

St. Croix East 

End Marine Park 

(established in 

2003; 150 km2in 

size)

Figure 6.1-4

(6)

U.S. Virgin Islands: 

Other AFTT Areas

Ecosystem 

(mangroves, reefs, 

invertebrates, 

seagrass beds, sea 

turtles)

State regulations apply, 

including designated areas in 

which no take of any 

resources is allowed; speed or 

other vessel restrictions; and 

restriction on the removal of 

coral or live rock (U.S. Virgin 

Islands Department of 

Planning and Natural 

Resources, 2002).

The resources protected by this area could be 

briefly exposed to aircraft overflights; 

however, overflights are not likely to harm the 

area’s protected natural resources. No other 

proposed activities are expected to occur in 

the area. Therefore, no impacts are expected 

within St. Croix East End Marine Park.

St. Thomas East 

End Reserves 

(established in 

2011; 9 km2in 

size)

Figure 6.1-4

(7)

U.S. Virgin Islands: 

Other AFTT Areas

Ecosystem 

(mangroves, reefs, 

seagrass beds)

Prohibited: vessel anchoring, 

except in designated zones, 

which is allowed for a 

maximum of 7 days (U.S. 

Virgin Islands Department of 

Planning and Natural 

Resources, 2011).

The resources protected by this area could be 

briefly exposed to aircraft overflights; 

however, overflights are not likely to harm the 

area’s protected natural resources. No other 

proposed activities are expected to occur in 

the area. Therefore, no impacts are expected 

within St. Thomas East End Reserves.
Atlantic Fleet

Training and Testing Final EIS/OEIS September 2018

6-12

6.0 Regulatory Considerations

Table 6.1-2: National System of Parks and Marine Protected Areas within the Study Area (continued)

Marine 

Protected Area

Figure/

Reference 

Number

Location within the Study 

Area Protection Focus

Summary of Relevant 

Regulations

Navy Proposed Activities 

Under the Preferred Alternative and 

Marine Protected Area Considerations

Federal/State Partnership Marine Protected Areas

National Estuarine Research Reserves

Waquoit Bay 

National 

Estuarine 

Research 

Reserve 

(established in 

1988; 11 km2in 

size)

Figure 6.1-1

(8)

Massachusetts: 

Portion located within 

Naval Undersea Warfare 

Center Division Newport 

Testing Range 

Ecosystem (coastal 

and estuarine 

habitats)

Prohibited: dredging in Areas 

of Critical Environmental 

Concern is prohibited except 

for the sole purpose of 

fisheries and wildlife 

management (Waquoit Bay 

National Estuarine Research 

Reserve, 2014).

The resources protected by this area could be 

briefly exposed to aircraft overflights; 

however, overflights are not likely to harm the 

area’s protected natural resources. No other 

proposed activities are expected to occur in 

the area. Therefore, no impacts are expected 

within Waquoit Bay National Estuarine 

Research Reserve.

Jacques 

Cousteau 

Estuarine 

Research 

Reserve 

(established in 

1998; 480 km2in 

size)

Figure 6.1-1

(9)

New Jersey:

Overlaps W-107 of the 

Atlantic City OPAREA, 

Northeast Range 

Complexes

Ecosystem (coastal 

and estuarine 

watershed, 

including habitat 

for migratory 

birds, wading 

birds, fish, and ESA 

listed birds, sea 

turtles and marine 

mammals)

Prohibited: most 

construction, dredging, and 

mining operations that would 

alter the shape of the ocean 

bottom or reduce fishery 

productivity (Jacques 

Cousteau National Estuarine 

Research Reserve, 2009).

The resources protected by this area could be 

briefly exposed to aircraft overflights; 

however, overflights are not likely to harm the 

area’s protected natural resources. No other 

proposed activities are expected to occur in 

the area. Therefore, no impacts are expected 

within Jacques Cousteau Estuarine Research 

Reserve.
Atlantic Fleet

Training and Testing Final EIS/OEIS September 2018

6-13

6.0 Regulatory Considerations

Table 6.1-2: National System of Parks and Marine Protected Areas within the Study Area (continued)

Marine 

Protected Area

Figure/

Reference 

Number

Location within the Study 

Area Protection Focus

Summary of Relevant 

Regulations

Navy Proposed Activities 

Under the Preferred Alternative and 

Marine Protected Area Considerations

Guana Tolomato 

Matanzas 

National 

Estuarine 

Research 

Reserve 

(established in 

1999; 260 km2in 

size)

Figure 6.1-2

(10)

Florida:

Other AFTT Areas, 

bordering JAX OPAREA, 

mine warfare warning 

area W-158E of JAX Range 

Complex

Ecosystem 

(aquatic reserve 

for preservation of 

natural conditions 

and conservation 

of biodiversity, 

including ESA

listed marine 

mammals, sea 

turtles, and shore 

birds)

No alteration of physical 

conditions within the reserve 

shall be permitted except for 

public navigation or to 

enhance the quality of the 

reserve.

Other uses or human activity 

may be permitted if 

determined to be compatible 

(Guana Tolomato Matanzas 

National Estuarine Research 

Reserve, 2009).

Proposed activities that could reasonably be 

expected to occur in the area include: search 

and rescue and aircraft overflights. However, 

search and rescue activities and aircraft 

overflights are not likely to impact the area’s 

protected natural resources. Therefore, no 

impacts are expected within Guana Tolomato 

Matanzas National Estuarine Research 

Reserve.

Rookery Bay 

National 

Estuarine 

Research 

Reserve 

(established in 

1978; 391 km2in 

size)

Figure 6.1-2

(11)

Florida:

Other AFTT Areas (within 

10 NM of W-174 of Key 

West Range Complex)

Ecosystem (birds, 

fish, West Indian 

manatees 

[Trichechus 

manatus], sea 

turtles)

Prohibited: removing, 

damaging, or introducing any 

live animals or plants (except 

for fishing), or introducing 

any physical components 

from or to the reserve; use or 

possession of firearms; any 

activity that degrades 

ambient water quality; 

approaching islands beyond 

posted boundary areas in the 

vicinity of nesting birds; 

anchoring longer than 2 days 

(Florida Department of 

Environmental Protection, 

2013).

The resources protected by this area could be 

briefly exposed to aircraft overflights; 

however, overflights are not likely to harm the 

area’s protected natural resources. No other 

proposed activities are expected to occur in 

the area. Therefore, no impacts are expected 

within the Rookery Bay National Estuarine 

Research Reserve.
Atlantic Fleet

Training and Testing Final EIS/OEIS September 2018

6-14

6.0 Regulatory Considerations

Table 6.1-2: National System of Parks and Marine Protected Areas within the Study Area (continued)

Marine 

Protected Area

Figure/

Reference 

Number

Location within the Study 

Area Protection Focus

Summary of Relevant 

Regulations

Navy Proposed Activities 

Under the Preferred Alternative and 

Marine Protected Area Considerations

Jobos Bay 

National 

Estuarine 

Research 

Reserve 

(established in 

1981; 10 km2in 

size)

Figure 6.1-4

(12)

Puerto Rico: 

Other AFTT Areas

Ecosystem 

(mangroves, 

seagrass beds, 

coral reefs, 

manatees, sea 

turtles)

Prohibited: motor vehicles; 

anchoring of boats, unless in 

designated areas (Jobos Bay

National Estuarine Research 

Reserve, 2008).

The resources protected by this area could be 

briefly exposed to aircraft overflights; 

however, overflights are not likely to harm the 

area’s protected natural resources. No other 

proposed activities are expected to occur in 

the area. Therefore, no impacts are expected 

within Jobos Bay National Estuarine Research 

Reserve.

Federal Marine Protected Areas

National Wildlife Refuges

Cross Island 

National Wildlife 

Refuge 

(established in 

1980; 7 (km2) in 

size)

Figure 6.1-1

(13)

Maine:

Other AFTT Areas

Ecosystem 

(restoring and 

managing colonies 

of nesting 

seabirds)

Prohibited: Seabird islands 

are closed to the public 

during the nesting season, 1 

April through 31 August (U.S. 

Fish and Wildlife Service, 

2015f).

The resources protected by this area could be 

briefly exposed to aircraft overflights; 

however, overflights are not likely to harm the 

area’s protected natural resources. No other 

proposed activities are expected to occur in 

the area. Therefore, no impacts are expected 

within Cross Island National Wildlife Refuge.

Monomoy 

National Wildlife 

Refuge 

(established in 

1944; 37 km2in 

size)

Figure 6.1-1

(14)

Massachusetts: 

Within 2 NM of Boston 

OPAREA, Northeast Range 

Complexes

Focal Resource 

(habitat for 

migratory birds, 

including the 

federally 

protected piping 

plover [Charadrius 

melodus] and 

roseate tern 

[Sterna dougallii])

Prohibited: destruction, 

disturbance and removal of 

wildlife, vegetation, and 

government property.

Closed areas apply between 

15 April and 15 September 

(U.S. Fish and Wildlife Service, 

2015e).

Unmanned vehicle development and payload 

testing is planned to occur in proximity to this 

marine protected area. The resources 

protected by this area could also be briefly 

exposed to aircraft overflights. However, the 

proposed activities are not likely to impact the 

area’s protected natural resources.
Atlantic Fleet

Training and Testing Final EIS/OEIS September 2018

6-15

6.0 Regulatory Considerations

Table 6.1-2: National System of Parks and Marine Protected Areas within the Study Area (continued)

Marine 

Protected Area

Figure/

Reference 

Number

Location within the Study 

Area Protection Focus

Summary of Relevant 

Regulations

Navy Proposed Activities 

Under the Preferred Alternative and 

Marine Protected Area Considerations

Nomans Land 

Island National 

Wildlife Refuge 

(established in 

1970; 3 km2in 

size)

Figure 6.1-1

(15)

Massachusetts:

Located within Naval 

Undersea Warfare Center 

Division Newport Testing 

Range

Focal Resource 

(habitat for 

migratory birds)

Prohibited: any public use 

due to the potential safety 

risk of unexploded ordinance 

(U.S. Fish and Wildlife Service, 

2013).

The resources protected by this area could be 

briefly exposed to aircraft overflights; 

however, overflights are not likely to harm the 

area’s protected natural resources. No other 

proposed activities are expected to occur in 

the area. Therefore, no impacts are expected 

within Nomans Land Island National Wildlife 

Refuge.

Cape May 

National Wildlife 

Refuge 

(established in 

1989; 87 km2in 

size)

Figure 6.1-1

(16)

New Jersey:

Other AFTT Areas

Ecosystem 

(nesting habitat 

for piping plover, 

shorebirds, and 

migratory birds)

Prohibited: disturbing, 

injuring, destroying, collecting 

plants, wildlife, or other 

natural objects (U.S. Fish and 

Wildlife Service, 2014a).

The resources protected by this area could be 

briefly exposed to aircraft overflights; 

however, overflights are not likely to harm the 

area’s protected natural resources. No other 

proposed activities are expected to occur in 

the area. Therefore, no impacts are expected 

within Cape May National Wildlife Refuge.

Chincoteague 

National Wildlife 

Refuge

(established in 

1943; 74 km2in 

size)

Figure 6.1-1

(17)

Virginia:

Other AFTT Areas

Ecosystem 

(migratory birds)

Prohibited: disturbing or 

collecting plants and animals 

or artifacts; launching, 

landing or operating 

unmanned aircraft (U.S. Fish 

and Wildlife Service, 2016c).

The resources protected by this area could be 

briefly exposed to aircraft overflights; 

however, overflights are not likely to harm the 

area’s protected natural resources. No other 

proposed activities are expected to occur in 

the area. Therefore, no impacts are expected 

within Chincoteague National Wildlife Refuge.
Atlantic Fleet

Training and Testing Final EIS/OEIS September 2018

6-16

6.0 Regulatory Considerations

Table 6.1-2: National System of Parks and Marine Protected Areas within the Study Area (continued)

Marine 

Protected Area

Figure/

Reference 

Number

Location within the Study 

Area Protection Focus

Summary of Relevant 

Regulations

Navy Proposed Activities 

Under the Preferred Alternative and 

Marine Protected Area Considerations

Fisherman Island 

National Wildlife 

Refuge 

(established in 

1969; 9 km2in 

size)

Figure 6.1-1

(18)

Virginia:

Lower Chesapeake Bay, 1 

NM from mine warfare 

training area

Ecosystem 

(migratory birds)

Prohibited: commercial and 

recreational fishing (U.S. Fish 

and Wildlife Service, 2004).

The resources protected by this area could be 

briefly exposed to aircraft overflights; 

however, as discussed in Chapter 5 

(Mitigation), the Navy will implement 

mitigation to avoid potential impacts from 

rotary-wing aircraft overflights on piping 

plovers and other nesting birds during 

explosive ordnance disposal activities, 

including maneuvering to maintain a specified 

distance from the beach within the Virginia 

Capes Range Complex (except when transiting 

from Norfolk Naval Station to waters offshore) 

and from Fisherman Island National Wildlife 

Refuge off the coast of Cape Charles, Virginia 

(when transiting from Norfolk Naval Station to 

waters offshore). Therefore, no impacts are 

expected within Fisherman Island National 

Wildlife Refuge.

Plum Tree Island 

National Wildlife 

Refuge 

(established in 

1972; 20 km2in 

size)

Figure 6.1-1

(19)

Virginia:

Other AFTT Areas

Focal Resource 

(estuarine 

habitats)

Prohibited: public use due to 

fragile habitats and safety 

concerns associated with 

former use as a bombing 

range; anchoring or bottom 

disturbance on refuge-owned 

bottoms (U.S. Fish and 

Wildlife Service, 2016b).

The resources protected by this area could be 

briefly exposed to aircraft overflights; 

however, overflights are not likely to harm the 

area’s protected natural resources. No other 

proposed activities are expected to occur in 

the area. Therefore, no impacts are expected 

within Plum Tree Island National Wildlife 

Refuge.
Atlantic Fleet

Training and Testing Final EIS/OEIS September 2018

6-17

6.0 Regulatory Considerations

Table 6.1-2: National System of Parks and Marine Protected Areas within the Study Area (continued)

Marine 

Protected Area

Figure/

Reference 

Number

Location within the Study 

Area Protection Focus

Summary of Relevant 

Regulations

Navy Proposed Activities 

Under the Preferred Alternative and 

Marine Protected Area Considerations

Pea Island 

National Wildlife 

Refuge 

(established in 

1937; 19 km2in 

size)

Figure 6.1-1

and Figure 

6.1-2 (20)

North Carolina:

Other AFTT Areas

Ecosystem 

(migratory birds 

and wetland 

protection)

Prohibited: taking, 

possessing, injuring, 

disturbing, damaging, 

destroying, or collecting any 

plant or animal (U.S. Fish and 

Wildlife Service, 2016a).

The resources protected by this area could be 

briefly exposed to aircraft overflights; 

however, overflights are not likely to harm the 

area’s protected natural resources. No other 

proposed activities are expected to occur in 

the area. Therefore, no impacts are expected 

within Pea Island National Wildlife Refuge.

Cape Romain 

National Wildlife

Refuge 

(established in 

1930; 248 km2in 

size)

Figure 6.1-2

(21)

South Carolina:

Other AFTT Areas, 1 NM 

from Charleston OPAREA, 

Charleston mine warfare 

alternate location #3

Ecosystem 

(loggerhead sea 

turtle [Caretta 

caretta], 

waterfowl, and 

shorebirds

including the 

piping plover)

Prohibited: accessing Marsh 

Island or White Banks Island 

from 15 February through 15 

September to protect nesting 

birds (U.S. Fish and Wildlife 

Service, 2015d).

The resources protected by this area could be 

briefly exposed to aircraft overflights; 

however, overflights are not likely to harm the 

area’s protected natural resources. No other 

proposed activities are expected to occur in 

the area. Therefore, no impacts are expected 

within Cape Romain National Wildlife Refuge.

Cedar Keys 

National Wildlife 

Refuge 

(established in 

1929; 3 km2in 

size)

Figure 6.1-2

(22)

Florida:

Other AFTT Areas

Ecosystem 

(wilderness island 

areas; nesting and 

breeding ground 

for colonial birds, 

wading birds and 

shorebirds)

Prohibited: injuring, 

disturbing, or destroying any 

plant or animal

Closed areas: interiors of all 

islands (except Atsena Otie 

Key). Seahorse Key and a 300 

foot zone around the island is 

closed to all public entry from 

1 March until 30 June (U.S. 

Fish and Wildlife Service, 

2015c).

The resources protected by this area could be 

briefly exposed to aircraft overflights; 

however, overflights are not likely to harm the 

area’s protected natural resources. No other 

proposed activities are expected to occur in 

the area. Therefore, no impacts are expected 

within Cedar Keys National Wildlife Refuge.
Atlantic Fleet

Training and Testing Final EIS/OEIS September 2018

6-18

6.0 Regulatory Considerations

Table 6.1-2: National System of Parks and Marine Protected Areas within the Study Area (continued)

Marine 

Protected Area

Figure/

Reference 

Number

Location within the Study 

Area Protection Focus

Summary of Relevant 

Regulations

Navy Proposed Activities 

Under the Preferred Alternative and 

Marine Protected Area Considerations

Chassahowitzka 

National Wildlife 

Refuge 

(established in 

1943; 150 km2in 

size)

Figure 6.1-2

(23)

Florida:

Other AFTT Areas

Ecosystem 

(estuarine habitat, 

waterfowl, West 

Indian manatees)

Restricted vessel speed in 

posted zones between 1 April 

and 31 August.

Prohibited: firearms and 

weapons except during 

designated hunts (U.S. Fish 

and Wildlife Service, 2017b).

The resources protected by this area could be 

briefly exposed to aircraft overflights; 

however, overflights are not likely to harm the 

area’s protected natural resources. No other 

proposed activities are expected to occur in 

the area. Therefore, no impacts are expected 

within Chassahowitzka National Wildlife 

Refuge.

Great White 

Heron National 

Wildlife Refuge 

(established in 

1938; 844 km2in 

size)

Figure 6.1-2

(24)

Florida:

Other AFTT Areas, within 

10 NM of Key West 

OPAREA and Key West 

Range Complex

Ecosystem 

(wading birds, 

coral reefs)

Prohibited: hunting or 

discharging firearms; feeding 

or harassing wildlife; landing 

airplanes, helicopters, or 

ultralights; personal 

watercraft, hovercrafts, or 

airboats (U.S. Fish and 

Wildlife Service, 2015b).

Closed areas: most back 

country islands; public access 

is limited to some refuge 

managed and stateowned/refuge managed 

islands during daylight hours 

(U.S. Fish and Wildlife Service, 

2017a).

The resources protected by this area could be 

briefly exposed to aircraft overflights; 

however, overflights are not likely to harm the 

area’s protected natural resources. No other 

proposed activities are expected to occur in 

the area. Therefore, no impacts are expected 

within the Great White Heron National 

Wildlife Refuge.
Atlantic Fleet

Training and Testing Final EIS/OEIS September 2018

6-19

6.0 Regulatory Considerations

Table 6.1-2: National System of Parks and Marine Protected Areas within the Study Area (continued)

Marine 

Protected Area

Figure/

Reference 

Number

Location within the Study 

Area Protection Focus

Summary of Relevant 

Regulations

Navy Proposed Activities 

Under the Preferred Alternative and 

Marine Protected Area Considerations

Key West 

National Wildlife 

Refuge 

(established in 

1908; 856 km2in 

size)

Figure 6.1-2

(25)

Florida:

Bordering Key West 

OPAREA and Key West 

Range Complex

Focal Resource 

(breeding grounds 

for native birds 

and other wildlife)

Prohibited: hunting or 

discharging firearms; feeding 

or harassing wildlife; landing 

airplanes, helicopters, or 

ultralights; personal 

watercraft, hovercrafts, or 

airboats 

Closed Areas: some beach 

sections on Boca Grande Key 

and Woman Key to protect 

sensitive plants and wildlife; 

all beach sections above 

mean high tide line (U.S. Fish 

and Wildlife Service, 2015a).

The resources protected by this area could be 

briefly exposed to aircraft overflights; 

however, overflights are not likely to harm the 

area’s protected natural resources. No other 

proposed activities are expected to occur in 

the area. Therefore, no impacts are expected 

within the Key West National Wildlife Refuge.

Lower Suwannee 

National Wildlife 

Refuge 

(established in 

1979; 341 km2in 

size)

Figure 6.1-2

(26)

Florida:

Other AFTT Areas

Ecosystem (West 

Indian manatees, 

Gulf sturgeon 

[Acipenser 

oxyrinchus 

desotoi], 

shorebirds and 

wading birds)

Prohibited: collecting plants, 

animals, minerals, antlers, or 

artifacts; discharging 

firearms, except when in 

accordance with refuge 

hunting regulations (U.S. Fish 

and Wildlife Service, 2015h).

The resources protected by this area could be 

briefly exposed to aircraft overflights; 

however, overflights are not likely to harm the 

area’s protected natural resources. No other 

proposed activities are expected to occur in 

the area. Therefore, no impacts are expected 

within the Lower Suwannee National Wildlife 

Refuge.

Merritt Island 

National Wildlife 

Refuge 

(established in 

1963; 562 km2in 

size

Figure 6.1-2

(27)

Florida: 

Other AFTT Areas, 3 NM 

from JAX OPAREA

Focal Resource 

(habitat for 

migratory birds)

Prohibited: use of air thrust 

boats, hover craft, or 

personal watercraft; feeding, 

capturing, or harassing 

wildlife; picking or cutting 

vegetation (U.S. Fish and 

Wildlife Service, 2016f).

The resources protected by this area could be 

briefly exposed to aircraft overflights; 

however, overflights are not likely to harm the 

area’s protected natural resources. No other 

proposed activities are expected to occur in 

the area. Therefore, no impacts are expected 

within Merritt Island National Wildlife Refuge.
Atlantic Fleet

Training and Testing Final EIS/OEIS September 2018

6-20

6.0 Regulatory Considerations

Table 6.1-2: National System of Parks and Marine Protected Areas within the Study Area (continued)

Marine 

Protected Area

Figure/

Reference 

Number

Location within the Study 

Area Protection Focus

Summary of Relevant 

Regulations

Navy Proposed Activities 

Under the Preferred Alternative and 

Marine Protected Area Considerations

National Key 

Deer Refuge 

(established in 

1954; 561 km2in 

size)

Figure 6.1-2

(28)

Florida:

Other AFTT Areas (within 

10 NM of Key West 

OPAREA and Key West 

Range Complex)

Focal Resource 

(protect and 

preserve Key deer 

(Odocoileus

virginianus 

clavium) and other 

wildlife resources 

in the Florida Keys)

Prohibited: feeding, 

capturing, or harassing 

wildlife; hunting or 

discharging firearms (U.S. Fish 

and Wildlife Service, 2015g).

The resources protected by this area could be 

briefly exposed to aircraft overflights; 

however, overflights are not likely to harm the 

area’s protected natural resources. No other 

proposed activities are expected to occur in 

the area. Therefore, no impacts are expected 

within the National Key Deer Refuge.

St. Marks 

National Wildlife 

Refuge 

(established in 

1931; 449 km2in

size)

Figure 6.1-2

(29)

Florida:

Other AFTT Areas

Ecosystem 

(shorebirds, 

marine mammals, 

American alligator 

[Alligator 

mississippiensis], 

sea turtles)

Prohibited: taking artifacts, 

natural features, animals, or 

plants; boats 16 October 

through 14 March, only nonmotorized boats or boats 

with electric motors are 

allowed at other times (U.S. 

Fish and Wildlife Service, 

2016e).

The resources protected by this area could be 

briefly exposed to aircraft overflights; 

however, overflights are not likely to harm the 

area’s protected natural resources. No other 

proposed activities are expected to occur in 

the area. Therefore, no impacts are expected 

within St. Marks National Wildlife Refuge.

Ten Thousand 

Islands National 

Wildlife Refuge 

(established in 

1996; 141 km2in 

size)

Figure 6.1-2

(30)

Florida:

Other AFTT Areas

Ecosystem (birds, 

manatees, sea 

turtles, 

mangroves)

Prohibited: hunting, except 

duck hunting (U.S. Fish and 

Wildlife Service, 2016d).

The resources protected by this area could be 

briefly exposed to aircraft overflights; 

however, overflights are not likely to harm the 

area’s protected natural resources. No other 

proposed activities are expected to occur in 

the area. Therefore, no impacts are expected 

within the Ten Thousand Islands National 

Wildlife Refuge.

Breton National 

Wildlife Refuge 

(established in 

1904; 31 km2in 

size)

Figure 6.1-3

(31)

Louisiana:

Other AFTT Areas

Ecosystem 

(nesting or 

wintering birds)

Prohibited: carrying, 

possessing, or discharging 

firearms; entry into the 

nesting areas and any 

disturbance of the nesting 

colonies (U.S. Fish and 

Wildlife Service, 2006a).

The resources protected by this area could be 

briefly exposed to aircraft overflights; 

however, overflights are not likely to harm the 

area’s protected natural resources. No other 

proposed activities are expected to occur in 

the area. Therefore, no impacts are expected 

within Breton National Wildlife Refuge.
Atlantic Fleet

Training and Testing Final EIS/OEIS September 2018

6-21

6.0 Regulatory Considerations

Table 6.1-2: National System of Parks and Marine Protected Areas within the Study Area (continued)

Marine 

Protected Area

Figure/

Reference 

Number

Location within the Study 

Area Protection Focus

Summary of Relevant 

Regulations

Navy Proposed Activities 

Under the Preferred Alternative and 

Marine Protected Area Considerations

Delta National 

Wildlife Refuge 

(established in 

1935; 206 km2in

size)

Figure 6.1-3

(32)

Louisiana:

Other AFTT Areas

Ecosystem 

(waterfowl, 

American alligator)

No area-specific regulations 

apply to Navy activities (U.S. 

Fish and Wildlife Service, 

2014b).

The resources protected by this area could be 

briefly exposed to aircraft overflights; 

however, overflights are not likely to harm the 

area’s protected natural resources. No other 

proposed activities are expected to occur in 

the area. Therefore, no impacts are expected 

within the Delta National Wildlife Refuge.

Shell Keys 

National Wildlife 

Refuge 

(established in 

1907; 0.02 km2

in size)

Figure 6.1-3

(33)

Louisiana:

Other AFTT Areas

Ecosystem 

(nesting birds)

Prohibited: public access (U.S. 

Fish and Wildlife Service, 

2008).

The resources protected by this area could be 

briefly exposed to aircraft overflights; 

however, overflights are not likely to harm the 

area’s protected natural resources. No other 

proposed activities are expected to occur in 

the area. Therefore, no impacts are expected 

within the Shell Keys National Wildlife Refuge.

Sandy Point 

National Wildlife 

Refuge

(established in 

1984; 2 km2in 

size)

Figure 6.1-4

(34)

U.S. Virgin Islands: 

Other AFTT Areas

Ecosystem (sea 

turtles)

Prohibited: vehicles, horses, 

and dogs; power boats 

landing on the beach; boat 

anchors or anchor lines 

extending onto the beach 

(U.S. Fish and Wildlife Service, 

2017c).

The resources protected by this area could be 

briefly exposed to aircraft overflights; 

however, overflights are not likely to harm the 

area’s protected natural resources. No other 

proposed activities are expected to occur in 

the area. Therefore, no impacts are expected 

within the Sandy Point National Wildlife 

Refuge.

Gear Restricted Areas

Lydonia Canyon 

Gear Restricted 

Area 

(established in 

2009; 98 km2in 

size)

Figure 6.1-1

(35)

Massachusetts: 

Other AFTT Areas

Focal Resource 

(Tilefish 

[Lopholatilus 

chamaeleonticeps])

Fishing gear restrictions are 

not applicable to Navy; 

however, they are intended 

to prevent damage to bottom 

habitat (National Marine 

Fisheries Service, 2011).

Navy training and testing activities that release 

military expended materials are expected to 

occur in the vicinity of this area. This area is 

considered a Habitat Area of Particular 

Concern; all applicable analysis will be 

included in the Essential Fish Habitat 

Assessment.
Atlantic Fleet

Training and Testing Final EIS/OEIS September 2018

6-22

6.0 Regulatory Considerations

Table 6.1-2: National System of Parks and Marine Protected Areas within the Study Area (continued)

Marine 

Protected Area

Figure/

Reference 

Number

Location within the Study 

Area Protection Focus

Summary of Relevant 

Regulations

Navy Proposed Activities 

Under the Preferred Alternative and 

Marine Protected Area Considerations

Oceanographer 

Canyon Gear 

Restricted Area 

(established in 

2009; 205 km2in 

size)

Figure 6.1-1

(36)

Massachusetts:

Other AFTT Areas

Focal Resource 

(Tilefish)

Fishing gear restrictions are 

not applicable to Navy; 

however, they are intended 

to prevent damage to bottom 

habitat (National Marine 

Fisheries Service, 2011).

Navy training and testing activities that release 

military expended materials are expected to 

occur in the vicinity of this area. This area is 

considered a Habitat Area of Particular 

Concern; all applicable analysis will be 

included in the Essential Fish Habitat 

Assessment.

Veatch Canyon 

Gear Restricted 

Area 

(established in 

2009; 68 km2in 

size)

Figure 6.1-1

(37)

Massachusetts:

Within W-105 of the 

Narragansett Bay OPAREA, 

Northeast Range 

Complexes

Focal Resource 

(Tilefish)

Fishing gear restrictions are 

not applicable to Navy; 

however, they are intended 

to prevent damage to bottom 

habitat (National Marine 

Fisheries Service, 2011).

Navy training and testing activities that release 

military expended materials are expected to 

occur in the vicinity of this area. This area is 

considered a Habitat Area of Particular 

Concern; all applicable analysis will be 

included in the Essential Fish Habitat 

Assessment.

Norfolk Canyon 

Gear Restricted 

Area 

(established in 

2009; 85 km2in 

size)

Figure 6.1-1

(38)

Virginia:

Overlaps W-386 of the 

VACAPES OPAREA (Surface 

Area Grid 8C)

Focal Resource 

(Tilefish)

Fishing gear restrictions are 

not applicable to Navy; 

however, they are intended 

to prevent damage to bottom 

habitat (National Marine 

Fisheries Service, 2011).

Navy training and testing activities that release 

military expended materials and/or include 

use of active sonar are expected to occur in 

the vicinity of this area. This area is considered 

a Habitat Area of Particular Concern; all 

applicable analysis will be included in the 

Essential Fish Habitat Assessment.

National Parks and Seashores

Acadia National 

Park (established 

in 1919; 307 km2

in size)

Figure 6.1-1

(39)

Maine: 

Other AFTT Areas, within 

6.5 NM of Boston OPAREA

Ecosystem (natural 

and cultural 

heritage)

Prohibited: use of unmanned 

aircraft (National Park 

Service, 2017c).

The resources protected by this area could be 

briefly exposed to aircraft overflights; 

however, overflights are not likely to harm the 

area’s protected natural or cultural resources. 

No other proposed activities are expected to 

occur in the area. Therefore, no impacts are 

expected within Acadia National Park.
Atlantic Fleet

Training and Testing Final EIS/OEIS September 2018

6-23

6.0 Regulatory Considerations

Table 6.1-2: National System of Parks and Marine Protected Areas within the Study Area (continued)

Marine 

Protected Area

Figure/

Reference 

Number

Location within the Study 

Area Protection Focus

Summary of Relevant 

Regulations

Navy Proposed Activities 

Under the Preferred Alternative and 

Marine Protected Area Considerations

Boston Harbor 

Islands National 

Recreation Area

(established in 

1996; 12 km2in 

size)

Figure 6.1-1

(40)

Massachusetts: 

Adjacent to the Boston 

OPAREA

Ecosystem (natural 

and cultural 

heritage)

No area-specific regulations 

apply to Navy activities

(National Park Service, 

2015a).

The resources protected by this area could be 

briefly exposed to aircraft overflights and 

small boat movement; however, overflights 

and small boat movement are not likely to 

harm the area’s protected natural or cultural 

resources. No other proposed activities are 

expected to occur in the area. Therefore, no 

impacts are expected within Boston Harbor 

Islands National Recreation Area.

Cape Cod 

National 

Seashore 

(established in 

1961; 164 km2in 

size)

Figure 6.1-1

(41)

Massachusetts: 

Adjacent to the Boston 

OPAREA

Ecosystem 

(marine, estuarine, 

fresh water and 

terrestrial 

habitats; breeding 

habitat for piping 

plover)

Prohibited: launching, 

landing, or operating an 

unmanned aircraft from or on 

lands and waters of the 

National Seashore; launching 

or recovering vessels, except 

in designated locations 

(National Park Service, 

2016c).

The resources protected by this area could be 

briefly exposed to aircraft overflights; 

however, overflights are not likely to harm the 

area’s protected natural resources. No other 

proposed activities are expected to occur in 

the area. Therefore, no impacts are expected 

within Cape Cod National Seashore.

Fire Island 

National 

Seashore 

(established in 

1964; 80 km2in 

size)

Figure 6.1-1

(42)

New York: 

Located within Naval 

Undersea Warfare Center 

Division Newport Testing 

Range

Ecosystem 

(nesting habitat 

for piping plover 

and roseate tern; 

population of 

seabeach 

amaranth 

[Amaranthus 

pumilus])

Prohibited: launching, 

landing, or operating an 

unmanned aircraft from or on 

lands and waters of the 

National Seashore (National 

Park Service, 2014a).

The resources protected by this area could be 

briefly exposed to aircraft overflights; 

however, overflights are not likely to harm the 

area’s protected natural resources. No other 

proposed activities are expected to occur in 

the area. Therefore, no impacts are expected 

within Fire Island National Seashore.
Atlantic Fleet

Training and Testing Final EIS/OEIS September 2018

6-24

6.0 Regulatory Considerations

Table 6.1-2: National System of Parks and Marine Protected Areas within the Study Area (continued)

Marine 

Protected Area

Figure/

Reference 

Number

Location within the Study 

Area Protection Focus

Summary of Relevant 

Regulations

Navy Proposed Activities 

Under the Preferred Alternative and 

Marine Protected Area Considerations

Gateway 

National 

Recreational 

Area 

(established in 

1972; 109 km2in 

size)

Figure 6.1-1

(43)

New York/New Jersey:

Other AFTT Areas (Sandy 

Hook Bay, less than 2 NM 

from the pier of Naval 

Weapons Station Earle, 

New Jersey)

Ecosystem 

(nesting habitat 

for piping plover, 

shorebirds, and 

migratory birds; 

salt marshes)

Prohibited: landing vessels on 

ocean beaches between 15 

March and Labor Day; vessel 

operations within Spermaceti 

Cove or within 46 m of 

marshes (36 CFR section 1.5) 

(National Park Service, 

2011a). 

National Park Service 

Management Policies (2006) 

apply (36 CFR § 7.29) 

(National Park Service, 

2006a).

The Navy would conduct homeland security 

and anti-terrorism/force protection training 

activities in the waters around the nearby 

Naval Weapons Station Earle, New Jersey; 

however, these proposed activities are not 

expected to occur in the marine protected 

area. The resources protected by this area 

could also be briefly exposed to aircraft 

overflights; however, overflights are not likely 

to harm the area’s protected natural 

resources. Therefore, no impacts are expected 

within Gateway National Recreational Area.

Assateague 

Island National 

Seashore 

(established in 

1965; 198 km2in 

size)

Figure 6.1-1

(44)

Maryland/Virginia: 

Other AFTT Areas, within 3 

NM of VACAPES OPAREA 

and W-386 of VACAPES 

Range Complex

Ecosystem (barrier 

island and aquatic 

habitats and 

species, natural 

coastal 

environment and 

processes) 

Prohibited: personal 

watercraft beaching on the 

ocean side of the island 

unless in an emergency (36 

CFR section 7.65) (National 

Park Service, 2011b).

The resources protected by this area could be 

briefly exposed to aircraft overflights; 

however, overflights are not likely to harm the 

area’s protected natural resources. No other 

proposed activities are expected to occur in 

the area. Therefore, no impacts are expected 

within Assateague Island National Seashore.

Colonial National 

Historical Park

(established in 

1930; 54 km2in 

size)

Figure 6.1-1

(45)

Virginia: 

Within 30 NM of VACAPES 

OPAREA, adjacent to York 

River

Ecosystem (natural 

and cultural 

heritage)

No area-specific regulations 

apply to Navy activities

(National Park Service, 

2017a).

The resources protected by this area could be 

briefly exposed to aircraft overflights and 

small boat movement; however, overflights 

and small boat movement are not likely to 

harm the area’s protected natural or cultural 

resources. No other proposed activities are 

expected to occur in the area. Therefore, no 

impacts are expected within Colonial National 

Historic Park.
Atlantic Fleet

Training and Testing Final EIS/OEIS September 2018

6-25

6.0 Regulatory Considerations

Table 6.1-2: National System of Parks and Marine Protected Areas within the Study Area (continued)

Marine 

Protected Area

Figure/

Reference 

Number

Location within the Study 

Area Protection Focus

Summary of Relevant 

Regulations

Navy Proposed Activities 

Under the Preferred Alternative and 

Marine Protected Area Considerations

Fort Monroe 

National 

Monument

(established in 

2011; 2 km 2in 

size)

Figure 6.1-1

(46)

Virginia: 

Lower Chesapeake Bay, 

within 19 NM of VACAPES 

OPAREA

Ecosystem (natural 

and cultural 

heritage)

No area-specific regulations 

apply to Navy activities

(National Park Service, 

2016a).

The resources protected by this area could be 

briefly exposed to aircraft overflights and 

small boat movement; however, overflights

and small boat movement are not likely to 

harm the area’s protected natural or cultural 

resources. No other proposed activities are 

expected to occur in the area. Therefore, no 

impacts are expected within Fort Monroe 

National Monument.

Cape Hatteras 

National 

Seashore 

(established in 

1937; 126 km2in 

size)

Figure 6.1-1

and Figure 

6.1-2 (47)

North Carolina: 

Other AFTT Areas, 3 NM 

from VACAPES and Cherry 

Point OPAREAs

Ecosystem (barrier 

island habitat; 

nesting habitat for 

sea turtles and 

migratory birds; 

population of 

seabeach 

amaranth)

Prohibited: launching, 

landing, or operating an 

unmanned aircraft from or on 

lands and waters of the 

National Seashore (National 

Park Service, 2016b).

The resources protected by this area could be 

briefly exposed to aircraft overflights; 

however, overflights are not likely to harm the 

area’s protected natural resources. No other 

proposed activities are expected to occur in 

the area. Therefore, no impacts are expected 

within Cape Hatteras National Seashore.

Cape Lookout 

National 

Seashore 

(established in 

1966; 113 km2 in 

size)

Figure 6.1-1

and Figure 

6.1-2 (48)

North Carolina: 

Other AFTT Areas, 3 NM 

from Cherry Point OPAREA

Ecosystem (barrier 

island and marsh 

habitats)

Prohibited: launching, 

landing, or operating an 

unmanned aircraft from or on 

lands and waters of the 

National Seashore; entry of 

vehicles into any area 

designated as a bird or turtle 

nesting area (National Park 

Service, 2015c).

The resources protected by this area could be 

briefly exposed to aircraft overflights; 

however, overflights are not likely to harm the 

area’s protected natural resources. No other 

proposed activities are expected to occur in 

the area. Therefore, no impacts are expected 

within Cape Lookout National Seashore.
Atlantic Fleet

Training and Testing Final EIS/OEIS September 2018

6-26

6.0 Regulatory Considerations

Table 6.1-2: National System of Parks and Marine Protected Areas within the Study Area (continued)

Marine 

Protected Area

Figure/

Reference 

Number

Location within the Study 

Area Protection Focus

Summary of Relevant 

Regulations

Navy Proposed Activities 

Under the Preferred Alternative and 

Marine Protected Area Considerations

Fort Sumter 

National 

Monument

(established in 

1948; 1.3 km2in 

size)

Figure 6.1-2

(49)

South Carolina: 

Located within the Cooper 

River, within 5.5 NM of 

Charleston OPAREA

Ecosystem (natural 

and cultural 

heritage)

No area-specific regulations 

apply to Navy activities

(National Park Service, 

2017e).

The resources protected by this area could be 

briefly exposed to aircraft overflights and 

small boat movement; however, overflights 

and small boat movement are not likely to 

harm the area’s protected natural or cultural 

resources. No other proposed activities are 

expected to occur in the area. Therefore, no 

impacts are expected within Fort Sumter 

National Monument.

Cumberland 

Island National 

Seashore 

(established in 

2009; 68 km2in 

size)

Figure 6.1-2

(50)

Georgia:

Other AFTT Areas

Ecosystem (barrier 

island and marsh 

habitats)

Prohibited: operating 

unmanned aircraft in the 

National Seashore (National 

Park Service, 2014c).

The resources protected by this area could be 

briefly exposed to aircraft overflights; 

however, overflights are not likely to harm the 

area’s protected natural resources. No other 

proposed activities are expected to occur in 

the area. Therefore, no impacts are expected 

within Cumberland Island National Seashore.

Fort Caroline 

National 

Memorial 

(established in 

1953; 0.8 km2in 

size)

Figure 6.1-2

(51)

Florida: 

Adjacent to St. Johns

River, within 8 NM of JAX 

OPAREA

Ecosystem (natural 

and cultural 

heritage)

No area-specific regulations 

apply to Navy activities

(National Park Service, 

2017d).

The resources protected by this area could be 

briefly exposed to aircraft overflights and 

small boat movement; however, overflights 

and small boat movement are not likely to 

harm the area’s protected natural or cultural 

resources. No other proposed activities are 

expected to occur in the area. Therefore, no 

impacts are expected within Fort Carolina 

National Memorial.
Atlantic Fleet

Training and Testing Final EIS/OEIS September 2018

6-27

6.0 Regulatory Considerations

Table 6.1-2: National System of Parks and Marine Protected Areas within the Study Area (continued)

Marine 

Protected Area

Figure/

Reference 

Number

Location within the Study 

Area Protection Focus

Summary of Relevant 

Regulations

Navy Proposed Activities 

Under the Preferred Alternative and 

Marine Protected Area Considerations

Biscayne 

National Park 

(established in 

1968; 706 km2in 

size)

Figure 6.1-2

(52)

Florida:

Other AFTT Areas, 

bordering South Florida 

Ocean Measurement 

Facility Testing Range

Ecosystem (corals, 

sea turtles, 

smalltooth sawfish 

[Pristis pectinata], 

West Indian 

manatee, 

American 

crocodile 

[Crocodylus 

acutus], least tern 

[Sterna 

antillarum], 

Johnson’s seagrass 

[Halophila 

johnsonii])

State regulations and 

National Park Service 

Management Policies apply

(National Park Service, 

2006a). 

Lobster and sponge closed 

areas. Tropical fish are 

protected (National Park 

Service, 2006b).

The resources protected by this area could be 

briefly exposed to aircraft overflights; 

however, overflights are not likely to harm the 

area’s protected natural resources. No other 

proposed activities are expected to occur in 

the area. Therefore, no impacts are expected 

within Biscayne National Park.

Canaveral 

National 

Seashore 

(established in 

1975; 237 km2in 

size)

Figure 6.1-2

(53)

Florida:

Other AFTT Areas

Ecosystem (sea 

turtles)

Prohibited: vessels operating 

or anchoring within 500 feet 

of the mean low tide line on 

any part of the National 

Seashore (National Park 

Service, 2014b).

The resources protected by this area could be 

briefly exposed to aircraft overflights; 

however, overflights are not likely to harm the 

area’s protected natural resources. No other 

proposed activities are expected to occur in 

the area. Therefore, no impacts are expected 

within Canaveral National Seashore.
Atlantic Fleet

Training and Testing Final EIS/OEIS September 2018

6-28

6.0 Regulatory Considerations

Table 6.1-2: National System of Parks and Marine Protected Areas within the Study Area (continued)

Marine 

Protected Area

Figure/

Reference 

Number

Location within the Study 

Area Protection Focus

Summary of Relevant 

Regulations

Navy Proposed Activities 

Under the Preferred Alternative and 

Marine Protected Area Considerations

Dry Tortugas 

National Park 

(established in 

1935; 263 km2in 

size)

Figure 6.1-2

(54)

Florida:

Entirely within W-174B of 

Key West Range Complex,

5 NM from Key West 

OPAREA

Ecosystem (corals) Prohibited: anchoring outside 

of designated areas and 

times; operating a vessel in

certain areas; discharging 

most materials; damaging or 

disturbing any living or dead 

organisms; allowing a vessel 

to strike or damage any 

immobile organism attached 

to the seabed; allowing a 

chain, rope, etc., to cause 

damage to coral, seagrasses, 

or submerged cultural 

resources.

Closed areas apply (36 CFR 

section 7.27).

The resources protected by this area could be 

briefly exposed to aircraft overflights; 

however, overflights are not likely to harm the 

area’s protected natural resources. Section 

3.10.2.3.2 (Tortugas Military Operations Area) 

contains additional details regarding these 

activities. No other proposed activities are 

expected to occur in the area; therefore, no 

impacts are expected within the Dry Tortugas 

National Park.

Everglades 

National Park 

(established in 

1934; 6,253 km2

in size)

Figure 6.1-2

(55)

Florida:

Other AFTT Areas

Ecosystem 

(subtropical 

wilderness, 

mangrove forest, 

wading birds, 

reptiles)

Prohibited: disturbance of 

aquatic life, except as 

allowable for fishing.

Vessel closure areas and 

landing restrictions apply (36 

CFR section 7.45).

The resources protected by this area could be 

briefly exposed to aircraft overflights; 

however, overflights are not likely to harm the 

area’s protected natural resources. No other 

proposed activities are expected to occur in 

the area. Therefore, no impacts are expected 

within the Everglades National Park.

Gulf Islands 

National 

Seashore

(established in 

1971; 710 km2in 

size)

Figure 6.1-3

(56)

Florida: 

Adjacent to Panama City 

OPAREA

Ecosystem (natural 

and cultural 

heritage)

Prohibited: launching, 

landing, or operating an

unmanned aircraft from or on 

lands and waters of the 

National Seashore (National 

Park Service, 2017b).

The resources protected by this area could be 

briefly exposed to aircraft overflights; 

however, overflights are not likely to harm the 

area’s protected natural or cultural resources. 

No other proposed activities are expected to 

occur in the area. Therefore, no impacts are 

expected within Gulf Islands National 

Seashore.
Atlantic Fleet

Training and Testing Final EIS/OEIS September 2018

6-29

6.0 Regulatory Considerations

Table 6.1-2: National System of Parks and Marine Protected Areas within the Study Area (continued)

Marine 

Protected Area

Figure/

Reference 

Number

Location within the Study 

Area Protection Focus

Summary of Relevant 

Regulations

Navy Proposed Activities 

Under the Preferred Alternative and 

Marine Protected Area Considerations

Padre Island 

National 

Seashore 

(established in 

1962; 533 km2in 

size)

Figure 6.1-3

(57)

Texas: 

Other AFTT Areas, 3 NM 

from Corpus Christi 

OPAREA

Ecosystem (barrier 

island habitat; 

nesting habitat for 

sea turtles and 

migratory birds)

Prohibited: launching, 

landing, or operating an 

unmanned aircraft from or on 

lands and waters of the 

National Seashore; launching 

hard hull motorized vessels 

from all beaches (National 

Park Service, 2016d).

The resources protected by this area could be 

briefly exposed to aircraft overflights; 

however, overflights are not likely to harm the 

area’s protected natural resources. No other 

proposed activities are expected to occur in 

the area. Therefore, no impacts are expected 

within Padre Island National Seashore.

Buck Island Reef 

National 

Monument 

(established in 

1961; 77 km2in 

size)

Figure 6.1-4

(58)

U.S. Virgin Islands: 

Other AFTT Areas

Ecosystem (coral 

reefs, sea turtles, 

reef fishes)

No take of any resources is 

allowed.

Prohibited: operating a 

watercraft in such a manner 

as to cause damage to any 

underwater feature; 

maneuvering watercraft 

within waters that contain 

marked swimming trails or 

interpretive signs; anchoring 

(36 CFR section 7.73).

The resources protected by this area could be 

briefly exposed to aircraft overflights; 

however, overflights are not likely to harm the 

area’s protected natural resources. No other 

proposed activities are expected to occur in 

the area. Therefore, no impacts are expected 

within Buck Island Reef National Monument.

Christiansted 

National Historic 

Site (established 

in 1952; 0.1 km2

in size)

Figure 6.1-4

(59)

U.S. Virgin Islands: 

Other AFTT Areas

Ecosystem (natural 

and cultural 

heritage)

No area-specific regulations 

apply to Navy activities

(National Park Service, 

2015b).

The resources protected by this area could be 

briefly exposed to aircraft overflights; 

however, overflights are not likely to harm the 

area’s protected natural or cultural resources. 

No other proposed activities are expected to 

occur in the area. Therefore, no impacts are 

expected within Christiansted National 

Historic Site.
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Table 6.1-2: National System of Parks and Marine Protected Areas within the Study Area (continued)

Marine 

Protected Area

Figure/

Reference 

Number

Location within the Study 

Area Protection Focus

Summary of Relevant 

Regulations

Navy Proposed Activities 

Under the Preferred Alternative and 

Marine Protected Area Considerations

Salt River Bay 

National Historic 

Park and 

Ecological 

Preserve 

(established in 

1992; 4 km2in 

size)

Figure 6.1-4

(60)

U.S. Virgin Islands: 

Other AFTT Areas

Ecosystem 

(mangrove forests, 

estuaries, coral 

reefs, submarine 

canyon)

Firearms may be legally 

possessed as provided under 

state, local, and federal 

regulations (National Park 

Service, 2010). National Park 

Service Management Policies 

apply (National Park Service, 

2006a).

The resources protected by this area could be 

briefly exposed to aircraft overflights; 

however, overflights are not likely to harm the 

area’s protected natural resources. No other 

proposed activities are expected to occur in 

the area. Therefore, no impacts are expected 

within the Salt River Bay National Historic Park 

and Ecological Preserve.

Virgin Islands 

Coral Reef 

National 

Monument 

(established in 

2001; 52 km2in 

size)

Figure 6.1-4

(61)

U.S. Virgin Islands: 

Other AFTT Areas 

(partially overlaps the 

North Atlantic Gyre Open 

Ocean Area)

Ecosystem (coral 

reefs, seagrass 

beds, sea turtles, 

humpback whale 

[Megaptera 

novaeangliae] and 

many marine 

mammals, reef 

fishes)

No take of any resources is 

allowed.

Prohibited: operating a 

watercraft in such a manner 

as to cause damage to any 

underwater feature; casting 

or dragging an anchor or 

other mooring device (36 CFR

section 7.46).

The resources protected by this area could be 

briefly exposed to aircraft overflights; 

however, overflights are not likely to harm the 

area’s protected natural resources. No other 

proposed activities are expected to occur in 

the area. Therefore, no impacts are expected 

within the Virgin Islands Coral Reef National 

Monument.
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Table 6.1-2: National System of Parks and Marine Protected Areas within the Study Area (continued)

Marine 

Protected Area

Figure/

Reference 

Number

Location within the Study 

Area Protection Focus

Summary of Relevant 

Regulations

Navy Proposed Activities 

Under the Preferred Alternative and 

Marine Protected Area Considerations

Virgin Islands 

National Park 

(established in 

1956; 60 km2in 

size)

Figure 6.1-4

(62)

U.S. Virgin Islands: 

Other AFTT Areas

Ecosystem 

(tropical coastal 

and marine 

ecosystem, 

including 

mangroves, corals, 

and tropical fishes)

Prohibited: operating a 

watercraft or casting or 

dragging an anchor or other 

mooring device in such a 

manner as to cause damage 

to any underwater feature; 

maneuvering watercraft 

within waters that contain 

marked swimming trails or 

interpretive signs.

Prohibited: taking any form of 

marine life in Trunk Bay and 

in other waters containing 

underwater signs and 

markers (36 CFR section

7.74).

The resources protected by this area could be 

briefly exposed to aircraft overflights; 

however, overflights are not likely to harm the 

area’s protected natural resources. No other 

proposed activities are expected to occur in 

the area. Therefore, no impacts are expected 

within the Virgin Islands National Park.
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Table 6.1-2: National System of Parks and Marine Protected Areas within the Study Area (continued)

Marine 

Protected Area

Figure/

Reference 

Number

Location within the Study 

Area Protection Focus

Summary of Relevant 

Regulations

Navy Proposed Activities 

Under the Preferred Alternative and 

Marine Protected Area Considerations

National Marine Sanctuaries

Gerry E. Studds 

Stellwagen Bank 

National Marine 

Sanctuary

Figure 6.1-5 Massachusetts: 

Bordering Boston OPAREA

Ecosystem (natural 

and cultural 

heritage)

See Section 6.1.2.6.1 for 

details.

Navy activities carried out in the sanctuary are 

conducted in accordance with sanctuary 

regulations; Navy will not conduct prohibited 

activities in the sanctuary, thus, is not required 

to obtain a permit. The Navy does not propose 

to conduct any new activities in the sanctuary 

that are likely to destroy, cause the loss of, or 

injure sanctuary resources or qualities. Since 

activities conducted near the sanctuary could 

potentially result in harassment takes to 

marine mammals when they are within the 

Sanctuary under the MMPA (defined as an 

injury to a sanctuary resource by the Office of 

National Marine Sanctuaries) the Navy 

consulted under Section 304(d) of the National 

Marine Sanctuaries Act. On 15 May 2018, in an 

injury determination letter in response to the 

Navy’s sanctuary resource statement, the 

Office of National Marine Sanctuaries 

concluded that the Proposed Action is likely to 

cause injury to sanctuary resources, but given 

ongoing research and current Navy 

mitigations, no sanctuary-specific 

recommendations were issued under this 

consultation.
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Table 6.1-2: National System of Parks and Marine Protected Areas within the Study Area (continued)

Marine 

Protected Area

Figure/

Reference 

Number

Location within the Study 

Area Protection Focus

Summary of Relevant 

Regulations

Navy Proposed Activities 

Under the Preferred Alternative and 

Marine Protected Area Considerations

Monitor National 

Marine 

Sanctuary

Figure 6.1-5 North Carolina: 

20 NM from VACAPES 

OPAREA

Focal Resource 

(cultural heritage –

shipwreck of the 

Civil War ironclad, 

USS Monitor)

See Section 6.1.2.6.2 for 

details.

Navy activities carried out in the sanctuary are 

conducted in accordance with sanctuary 

regulations; Navy will not conduct prohibited 

activities in the sanctuary, thus, is not required 

to obtain a permit. The Navy does not propose 

to conduct any new activities in the sanctuary 

that are likely to destroy, cause the loss of, or 

injure sanctuary resources or qualities. Since 

activities conducted outside the sanctuary 

would not potentially result in harassment 

takes under the MMPA (defined as an injury to 

a sanctuary resource by the Office of National 

Marine Sanctuaries) the Navy has not 

consulted under Section 304(d) of the National 

Marine Sanctuaries Act.
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Table 6.1-2: National System of Parks and Marine Protected Areas within the Study Area (continued)

Marine 

Protected Area

Figure/

Reference 

Number

Location within the Study 

Area Protection Focus

Summary of Relevant 

Regulations

Navy Proposed Activities 

Under the Preferred Alternative and 

Marine Protected Area Considerations

Gray’s Reef 

National Marine 

Sanctuary

Figure 6.1-6 Georgia: 

Entirely within Jacksonville 

OPAREA

Ecosystem (natural 

heritage – live 

bottom reef)

See Section 6.1.2.6.3 for 

details.

Navy activities carried out in the sanctuary are 

conducted in accordance with sanctuary 

regulations; Navy will not conduct prohibited 

activities in the sanctuary, thus, is not required 

to obtain a permit. The Navy does not propose 

to conduct any new activities in the sanctuary 

that are likely to destroy, cause the loss of, or 

injure sanctuary resources or qualities. Since 

activities conducted in and around the 

sanctuary could potentially result in 

harassment takes under the MMPA (defined 

as an injury to a sanctuary resource by the 

Office of National Marine Sanctuaries) the 

Navy consulted under Section 304(d) of the 

National Marine Sanctuaries Act. On 15 May 

2018, in an injury determination letter in 

response to the Navy’s sanctuary resource 

statement, the Office of National Marine 

Sanctuaries concluded that the Proposed 

Action is likely to cause injury to sanctuary 

resources, but given ongoing research and 

current Navy mitigations, no sanctuary-specific 

recommendations were issued under this 

consultation.
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Table 6.1-2: National System of Parks and Marine Protected Areas within the Study Area (continued)

Marine 

Protected Area

Figure/

Reference 

Number

Location within the Study 

Area Protection Focus

Summary of Relevant 

Regulations

Navy Proposed Activities 

Under the Preferred Alternative and 

Marine Protected Area Considerations

Florida Keys 

National Marine 

Sanctuary

Figure 6.1-6 Florida: 

Bordering Key West 

OPAREA

Ecosystem (natural 

and cultural 

heritage: world’s 

third largest 

barrier reef, 

shipwrecks)

See Section 6.1.2.6.4 for 

details.

Navy activities carried out in the sanctuary are 

conducted in accordance with sanctuary 

regulations; Navy will not conduct prohibited 

activities in the sanctuary, thus, is not required 

to obtain a permit. The Navy does not propose 

to conduct any new activities in the sanctuary 

that are likely to destroy, cause the loss of, or 

injure sanctuary resources or qualities. Since 

activities conducted in and around the 

sanctuary could potentially result in 

harassment takes under the MMPA (defined 

as an injury to a sanctuary resource by the 

Office of National Marine Sanctuaries) the 

Navy consulted under Section 304(d) of the 

National Marine Sanctuaries Act. On 15 May 

2018, in an injury determination letter in 

response to the Navy's sanctuary resource 

statement, the Office of National Marine 

Sanctuaries recommended that the Navy 

continue to obtain updated data regarding sea 

turtle densities to support higher resolution 

modeling to further evaluate potential impacts 

to sea turtles from explosive stressors in

Florida Keys National Marine Sanctuary.
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Table 6.1-2: National System of Parks and Marine Protected Areas within the Study Area (continued)

Marine 

Protected Area

Figure/

Reference 

Number

Location within the Study 

Area Protection Focus

Summary of Relevant 

Regulations

Navy Proposed Activities 

Under the Preferred Alternative and 

Marine Protected Area Considerations

Flower Garden 

Banks National 

Marine 

Sanctuary

Figure 6.1-6 Texas: 

70 NM from Corpus Christi 

OPAREA

Ecosystem (natural 

and cultural 

heritage)

See Section 6.1.2.6.5 for 

details.

Navy activities carried out in the sanctuary are 

conducted in accordance with sanctuary 

regulations; Navy will not conduct prohibited 

activities in the sanctuary, thus, is not required 

to obtain a permit. The Navy does not propose 

to conduct any new activities in the sanctuary 

that are likely to destroy, cause the loss of, or 

injure sanctuary resources or qualities. Since 

activities conducted outside the sanctuary 

would not potentially result in harassment 

takes under the MMPA (defined as an injury to 

a sanctuary resource by the Office of National 

Marine Sanctuaries) the Navy has not 

consulted under Section 304(d) of the National 

Marine Sanctuaries Act.

Source: List of national system marine protected areas in the Study Area and their protection focuses (National Marine Protected Areas Center, 2013)

Notes: Other AFTT Areas include areas outside of range complexes and testing ranges but still within the AFTT Study Area. Other AFTT Area events typically refer to those events that 

occur while vessels are in transit.

AFTT: Atlantic Fleet Training and Testing; JAX: Jacksonville; OPAREA: Operating Area; VACAPES: Virginia Capes.
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Notes: AFTT: Atlantic Fleet Training and Testing; OPAREA: Operating Area; SINKEX: Sinking Exercise; VACAPES: Virginia Capes

Figure 6.1-1: Location of National System of Marine Protected Areas within the Northeast and Mid-Atlantic Portion of the Study Area
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Notes: AFTT: Atlantic Fleet Training and Testing; OPAREA: Operating Area; SINKEX: Sinking Exercise; VACAPES: Virginia Capes

Figure 6.1-2: Location of National System of Marine Protected Areas within the Southeast Atlantic Portion of the Study Area 
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Notes: AFTT: Atlantic Fleet Training and Testing; OPAREA: Operating Area

Figure 6.1-3: Location of National System of Marine Protected Areas within the Gulf of Mexico Portion of the Study Area
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Notes: AFTT: Atlantic Fleet Training and Testing

Figure 6.1-4: Location of National System of Marine Protected Areas within the Caribbean Portion of the Study Area
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6.1.2.1 State Marine Protected Areas

State governments have established marine protected areas, including state parks and species-specific 

sanctuaries, for the management of fisheries, nursery grounds, shellfish beds, recreation, tourism, and 

other uses. These areas have a diverse array of conservation objectives, from protecting ecological 

functions, to preserving shipwrecks, to maintaining traditional or cultural interaction with the marine 

environment. There are two state marine protected areas and five territorial marine protected areas in 

the Study Area (see Table 6.1-2 and Figure 6.1-1 through Figure 6.1-4).

6.1.2.2 National Estuarine Research Reserves

National Estuarine Research Reserve System sites protect estuarine land and water and provide habitat 

for wildlife. These sites also provide educational opportunities for students, teachers, and the public and 

serve as laboratories for scientists (15 CFR Part 921). The National Estuarine Research Reserve Program 

was established through the Coastal Zone Management Act and is administered in coordination with the 

National Marine Sanctuary System. Each reserve is managed by a state agency or university with input 

from local partners on a site-specific basis. There are five National Estuarine Research Reserves in the 

Study Area that are included in the National System of marine protected (see Table 6.1-2 and Figure 

6.1-1 through Figure 6.1-4).

6.1.2.3 National Wildlife Refuges

National Wildlife Refuges are managed by the USFWS in accordance with Executive Order 12996, 

Management and General Public Use of the National Wildlife Refuge System, the National Wildlife 

Refuge System Administration Act of 1966, and the National Wildlife Refuge System Improvement Act of 

1997. The National Wildlife Refuge System serves as a national network of lands and waters for the 

conservation, management, and where appropriate, restoration of fish, wildlife, and plant resources and 

habitats. National wildlife refuges are managed on a site-specific basis. Activities conducted within a 

refuge must not impair existing wildlife-dependent recreational uses or reduce the potential of the 

refuge to provide quality, compatible, wildlife-dependent recreation into the future. The USFWS is 

directed to continue, consistent with existing laws and interagency agreements, authorized or permitted 

refuge uses necessary to facilitate military preparedness; however, new agreements permitting military 

preparedness activities on refuges are discouraged (U.S. Fish and Wildlife Service, 2006b). There are 22

National Wildlife Refuges in the Study Area (see Table 6.1-2 and Figure 6.1-1 through Figure 6.1-4).

6.1.2.4 Gear Restricted Areas

The NMFS is responsible for overseeing Regional Fishery Management Councils that are established 

under the Magnuson-Stevens Act. These councils are used to create and implement Fishery 

Management Plans, which help conserve and manage important fisheries in the United States (50 CFR

Chapter 6). One management strategy used is the creation of Gear Restricted Areas, some of which are 

included in the National System of marine protected areas. There are four Gear Restricted Areas in the 

Study Area (see Table 6.1-2 and Figure 6.1-1 through Figure 6.1-4).

6.1.2.5 National Parks and Seashores

The National Park Service administers all National Parks, National Seashores, and some of the National 

Recreation Areas and National Monuments to conserve the scenery and the natural and historic objects 

and wildlife contained within. Park managers control all park usage to ensure that park resources and 

values are preserved for the future; they must always seek ways to avoid, or to minimize to the greatest 

extent practicable, adverse impacts on park resources and values. In general, military activities are 
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discouraged in parks; the use of weaponry is not allowed, and unacceptable impacts from aircraft 

overflights (e.g., flights that unreasonably interfere with the atmosphere of peace and tranquility, or the 

natural soundscape maintained within the park) should be avoided. Unacceptable impacts are those 

that fall short of impairment but are still not acceptable within a particular park’s environment, as 

determined by the professional judgment of the park manager in accordance with National Park Service 

Management Policies 2006 (National Park Service, 2006a). Military services may request the use of park 

areas for noncombat exercises. Permits are approved at the discretion of the park superintendent. 

There are nine National Seashores, two Marine National Monuments, five National Parks, two National 

Monuments, two National Recreation Areas, two National Historic Parks, one National Historic 

Memorial, one National Historic Site, and one National Historic Park and Ecological Preserve in the Study 

Area (see Table 6.1-2 and Figure 6.1-1 through Figure 6.1-4).

6.1.2.6 National Marine Sanctuaries

Under the Marine Protection, Research, and Sanctuaries Act of 1972 (also known as the National Marine 

Sanctuaries Act), the National Oceanic and Atmospheric Administration establishes a national marine 

sanctuary for marine areas with special conservation, recreational, ecological, historical, cultural, 

archaeological, scientific, educational, or aesthetic qualities. The National Marine Sanctuaries Act and

federal regulations prohibit destroying, causing the loss of, or injuring any sanctuary resource managed 

under the law or regulations for that sanctuary (16 U.S.C. section 1436(a); 15 CFR Part 922). National 

Marine Sanctuaries are managed on a site-specific basis, and each sanctuary has site-specific regulatory 

prohibitions. Each sanctuary also has site-specific regulatory exemptions from the prohibitions for 

certain military activities. 

Additionally, section 304(d) of the National Marine Sanctuaries Act requires federal agencies to consult 

with the Office of National Marine Sanctuaries whenever their proposed actions are likely to destroy, 

cause the loss of, or injure a sanctuary resource. Within the Study Area, there are five National Marine 

Sanctuaries included in the List of National System Marine Protected Areas. The National Marine 

Sanctuaries within the Study Area are mapped in Figure 6.1-5 and Figure 6.1-6. The sanctuaries are 

described in additional detail below, along with a summary of the potential environmental impacts of 

the proposed training and testing activities anticipated to occur within or within the vicinity of each 

sanctuary. Where appropriate, the Navy has prepared a Sanctuary Resources Statement describing its 

proposed actions and potential effects on sanctuary resources, which has been submitted to the Office 

of National Marine Sanctuaries to initiate National Marine Sanctuaries Act section 304(d) consultation.

6.1.2.6.1 Gerry E. Studds Stellwagen Bank National Marine Sanctuary

The Gerry E. Studds Stellwagen Bank National Marine Sanctuary is located within the Northeast U.S. 

Continental Shelf Large Marine Ecosystem in the eastern portion of Massachusetts Bay between Cape 

Ann and Cape Cod and the southwest corner of the Gulf of Maine (Figure 6.1-5). The sanctuary includes 

an area of nearly 638 square nautical miles (NM2) and was designated in 1992 to preserve the area’s 

natural and historic resources, including nearly 50 shipwrecks (National Oceanic and Atmospheric 

Administration, 2010). Stellwagen Bank provides habitat for invertebrates, sea turtles including the 

leatherback and Kemp’s ridley, and 17 species of cetaceans (National Marine Sanctuary Program, 

2007b). The area supports important feeding grounds for the fin, humpback, sei, and North Atlantic right 

whale. A diversity of seabird species dominated by loons, fulmars, shearwaters, storm petrels, 

cormorants, phalaropes, alcids, gulls, jaegers, and terns use the area for foraging (National Oceanic and 

Atmospheric Administration, 2010). Human uses of the Gerry E. Studds Stellwagen Bank National 

Marine Sanctuary include commercial shipping, recreational fishing, whale watching, and scuba diving.
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Notes: AFTT: Atlantic Fleet Training and Testing; OPAREA: Operating Area; SINEX: Sinking Exercise; VACAPES: Virginia Capes

Figure 6.1-5: Location of National Marine Sanctuaries within the Northeast and Mid-Atlantic Portion of the Study Area
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Regulations for the Gerry E. Studds Stellwagen Bank National Marine Sanctuary prohibit the following 

(15 CFR section 922.142(a)): 

(1) (i) Discharging or depositing, from within the boundary of the sanctuary, any material 

or other matter except:

(A) Fish, fish parts, chumming materials or bait used in or resulting from 

traditional fishing operations in the sanctuary;

(B) Biodegradable effluent incidental to vessel use and generated by marine 

sanitation devices approved in accordance with Section 312 of the Federal 

Water Pollution Control Act, as amended, 33 U.S.C. 1322 et seq.;

(C) Water generated by routine vessel operations (e.g., cooling water, deck wash 

down and graywater as defined by Section 312 of the Federal Water Pollution 

Control Act) excluding oily wastes from bilge pumping; or

(D) Engine exhaust.

(ii) Discharging or depositing, from beyond the boundary of the sanctuary, any material 

or other matter, except those listed in paragraphs (a)(1)(i) (A) through (D) of this 

section, that subsequently enters the sanctuary and injures a sanctuary resource or 

quality.

(2) Exploring for, developing or producing industrial materials within the sanctuary.

(3) Drilling into, dredging or otherwise altering the seabed of the sanctuary; or constructing, 

placing or abandoning any structure, material or other matter on the seabed of the 

sanctuary, except as an incidental result of:

(i) Anchoring vessels;

(ii) Traditional fishing operations; or

(iii) Installation of navigation aids.

(4) Moving, removing or injuring, or attempting to move, remove or injure, a sanctuary 

historical resource. This prohibition does not apply to moving, removing or injury resulting 

incidentally from traditional fishing operations.

(5) Taking any marine reptile, marine mammal or seabird in or above the sanctuary, except as 

permitted by the Marine Mammal Protection Act, as amended, (MMPA), 16 U.S.C. 1361 et 

seq., the Endangered Species Act, as amended, (ESA), 16 U.S.C. 1531 et seq., and the 

Migratory Bird Treaty Act, as amended, (MBTA), 16 U.S.C. 703 et seq. 

(6) Lightering [cargo transfer between vessels] in the sanctuary.

(7) Possessing within the sanctuary (regardless of where taken, moved or removed from), 

except as necessary for valid law enforcement purposes, any historical resource, or any 

marine mammal, marine reptile or seabird taken in violation of the MMPA, ESA or MBTA.

(8) Interfering with, obstructing, delaying or preventing an investigation, search, seizure or 

disposition of seized property in connection with enforcement of the Act or any regulation 

or permit issued under the Act.

The Stellwagen Bank National Marine Sanctuary regulations state that all Department of Defense (DoD) 

military activities are to be carried out in a manner that avoids to the maximum extent practicable any 

adverse impacts on sanctuary resources and qualities (15 CFR section 922.142(c)(1)(i)). Activities carried 
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out by the DoD may be exempted from sanctuary prohibitions after consultation with the Office of 

National Marine Sanctuaries (15 CFR section 922.142(c)(1)(ii)).

The Gerry E. Studds Stellwagen Bank National Marine Sanctuary Management Plan and Environmental 

Assessment was released in June 2010 (National Oceanic and Atmospheric Administration, 2010) and 

considered Navy activities at the time of the document. Specifically, the document stated that the Navy 

rarely conducts activities within the Sanctuary. This is due to the shallow depths within the boundaries 

of the Sanctuary which are unsuitable for submarine operations as well as crowded waters which make 

warfare training exercises difficult to execute. Naval ships transit the Sanctuary several times a year 

primarily to access the Port of Boston. During these transits, the ships follow standard operating 

procedures that direct the posting of a Lookout for whales and avoiding discharges in the Sanctuary. 

Some training and testing activities in deep waters (greater than 200 meters) beyond the Sanctuary may 

have the potential to acoustically disturb some Sanctuary resources. This information is still accurate 

today. Additionally, the Navy uses a software program (Protective Measures Assessment Protocol) to 

determine which mitigation measures are necessary when training and testing in and around the 

Sanctuary.

The Navy considered all proposed training and testing activities that could occur within the Stellwagen 

Bank National Marine Sanctuary and identified that the proposed activities could fall into the following 

categories:

1. The following platforms, sources, or items that are part of Navy activities may be used 

within the Gerry E. Studds Stellwagen Bank National Marine Sanctuary, because they 

(1) are not prohibited under the sanctuary regulations, and (2) are carried out in a manner 

that avoids to the maximum extent practicable any adverse impacts on sanctuary 

resources and qualities (15 CFR section 922.142(c)(1)(i)):

 Aircraft and Aerial Targets

Aircraft and aerial targets are expected to cause only a minor and temporary behavioral 

reaction due to noise for marine mammals (reactions do not rise to the level of take under 

the MMPA), sea turtles, or fishes that may be present in the area. In addition to possible 

minor behavioral reactions due to noise, there is slight potential for seabirds to be struck 

by aircraft or aerial targets. As discussed in Section 2.3.3 (Standard Operating Procedures), 

the Navy implements standard operating procedures for aircraft safety that will reduce 

the potential for aircraft strikes. Targets are not expendable and will not be discharged 

into the waters of the Sanctuary. For a more detailed discussion of potential impacts to 

these resources from the use of aircraft and aerial targets, see the following sections:

Section 3.6.3.4.2 (Impacts from Aircraft and Aerial Targets) for fishes

Section 3.7.3.4.2 (Impacts from Aircraft and Aerial Targets) for marine mammals

Section 3.8.3.4.2 (Impacts from Aircraft and Aerial Targets) for reptiles

Section 3.9.3.4.2 (Impacts from Aircraft and Aerial Targets) for birds, which 

includes discussion of applicable seabirds

 Vessels and in-water devices (that do not make contact with seafloor)

Noise from vessels and in-water devices (excluding sonar and other active acoustic 

sources) is expected to cause only a minor and temporary behavioral reaction for marine 
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mammals (reactions do not rise to the level of take under the MMPA), sea turtles, 

seabirds, or fishes that may be present in the area. There is potential for marine 

mammals, sea turtles, seabirds, floating vegetation, invertebrates, and large slow-moving 

fish species, to be struck by or to collide with vessels. As discussed in section 2.3.3 

(Standard Operating Procedures), the Navy implements standard operating procedures 

for vessel and towed in-water device safety that will reduce the marine mammal strike 

potential. As discussed in Section 5.3.4 (Physical Disturbance and Strike Stressors), the 

Navy will implement mitigation to further reduce the potential for marine mammal strikes 

by vessels and in-water devices. For a more detailed discussion of potential impacts to 

these resources from the use of vessels and in-water devices, see the following sections:

Section 3.3.3.4.1 (Impacts from Vessels and In-Water Devices) for vegetation

Section 3.4.3.4.1 (Impacts from Vessels and In-Water Devices) for invertebrates

Section 3.6.3.4.1 (Impacts from Vessels and In-Water Devices) for fishes

Section 3.7.3.4.1 (Impacts from Vessels and In-Water Devices) for marine 

mammals

Section 3.8.3.4.1 (Impacts from Vessels and In-Water Devices) for reptiles

Section 3.9.3.4.1 (Impacts from Vessels and In-Water Devices) for birds

2. The following platforms, sources, or items that are part of Navy activities, but are not 

planned to be used within the Gerry E. Studds Stellwagen Bank National Marine Sanctuary 

(including a 2.7 NM buffer) as part of the Proposed Action:

 Sonar and other active acoustic sources 

 Explosives detonated in-air, at the surface, or underwater

 Military expended materials

 Seafloor devices

The Navy’s Proposed Action is consistent with the activities that were occurring when the Stellwagen 

Bank National Marine Sanctuary was designated, as well as during the development of the 2010 

Management Plan. Navy activities carried out in the Sanctuary are conducted in a manner that avoids to 

the maximum extent practicable any adverse impacts on sanctuary resources and qualities. The Navy 

does not propose to conduct any new activities in the Sanctuary that may affect sanctuary resources or 

qualities of those resources. Further, the Navy does not propose to increase the level of existing 

activities within the Sanctuary from what was previously considered at the time of sanctuary 

designation. Since activities conducted near the sanctuary could potentially result in harassment takes 

under the MMPA to marine mammals when they are within the Sanctuary (defined as an injury to a 

sanctuary resource by the Office of National Marine Sanctuaries) the Navy consulted under Section 

304(d) of the National Marine Sanctuaries Act. On 15 May 2018, in an injury determination letter in 

response to the Navy’s sanctuary resource statement, the Office of National Marine Sanctuaries 

concluded that the Proposed Action is likely to cause injury to sanctuary resources, but given ongoing 

research and current Navy mitigations, no sanctuary-specific recommendations were issued under this 

consultation.

6.1.2.6.2 Monitor National Marine Sanctuary

The Monitor National Marine Sanctuary is located within the Southeast U.S. Continental Shelf Large 

Marine Ecosystem off the coast of Cape Hatteras, North Carolina (Figure 6.1-5). The geographical extent 

of the sanctuary is defined by the shipwreck and its surrounding 1 NM diameter area. The Sanctuary 
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includes the column of water extending from the ocean surface to the seabed. The sanctuary was 

established in 1975 to preserve the historical and cultural artifacts of the USS Monitor shipwreck, the 

nation’s first ironclad warship. The Monitor serves as a valuable national heritage and naval cultural 

specimen (Office of National Marine Sanctuaries, 2013).

Regulations for the Monitor National Marine Sanctuary prohibit the following (15 CFR 922.61): 

(a) Anchoring in any manner, stopping, remaining, or drifting without power at any time;

(b) Any type of subsurface salvage or recovery operation;

(c) Diving of any type, whether by an individual or by a submersible;

(d) Lowering below the surface of the water any grappling, suction, conveyor, dredging or 

wrecking device;

(e) Detonating below the surface of the water any explosive or explosive mechanism;

(f) Drilling or coring the seabed;

(g) Lowering, laying, positioning or raising any type of seabed cable or cable-laying device;

(h) Trawling; or

(i) Discharging waste material into the water in violation of any Federal statute or regulation.

Free passage through the Sanctuary is not a prohibited activity under the Sanctuary regulations, and 

therefore, is permissible. The Monitor National Marine Sanctuary does not have specific military 

exemptions from the applicable Office of National Marine Sanctuaries Regulations (15 CFR sections

922.60–62). 

The Monitor National Marine Sanctuary Final Management Plan and Environmental Assessment was 

released in February 2013 (Office of National Marine Sanctuaries, 2013).

To ensure compliance with the Office of National Marine Sanctuaries Regulations, the Navy considered 

all proposed training and testing activities that could occur within the sanctuary. All activities would be 

conducted in a manner that avoids to the maximum extent practicable any adverse impacts on 

sanctuary resources. The Navy concluded that the proposed activities could fall into the following two 

categories:

1. The following platforms, sources, or items that are part of Navy activities may be used 

within the Monitor National Marine Sanctuary because they are not prohibited under the 

sanctuary regulations:

 Aircraft and Aerial Targets

Aircraft and aerial targets would have no impact on the Monitor shipwreck, as all targets 

are recovered and will not reach the ocean floor.

 Vessels and in-water devices (that do not make contact with seafloor)

The Monitor National Marine Sanctuary allows transit of vessels through the sanctuary. 

Furthermore, vessels and in-water devices would have no impact on the Monitor 

shipwreck.

 Sonar and other active acoustic sources

Sonar and other active acoustic sources would have no impact on the Monitor shipwreck.

 Electromagnetic devices 
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Electromagnetic devices would have no impact on the Monitor shipwreck.

2. The following platforms, sources, or items that are part of Navy activities, but are not 

planned to be used within Monitor National Marine Sanctuary (including a 2.7 NM buffer) 

as part of the Proposed Action:

 Explosives detonated in-air, at the surface, or underwater

 Military expended materials

 Seafloor devices

The Navy does not propose to conduct any new activities that would cause significant impacts on 

sanctuary resources. Furthermore, the Navy does not propose to increase the level of existing activities 

within the Monitor National Marine Sanctuary from what was previously considered at the time of 

sanctuary designation. Since none of the Navy’s training and testing activities proposed to be conducted 

within or in the vicinity of Monitor National Marine Sanctuary are likely to injure sanctuary resources, 

the Navy has determined that it is not required to engage in section 304(d) consultation under the 

National Marine Sanctuaries Act.

6.1.2.6.3 Gray’s Reef National Marine Sanctuary

The Gray’s Reef National Marine Sanctuary is located within the Southeast U.S. Continental Shelf Large 

Marine Ecosystem 16.5 NM off Sapelo Island, Georgia (Figure 6.1-6). The sanctuary includes an area of 

approximately 17 NM2 and was designated in 1981 to preserve the area’s open ocean and live bottom 

habitat. Gray’s Reef National Marine Sanctuary is the only marine protected area in the region that 

focuses on protection and conservation of all natural marine resources (National Marine Sanctuary 

Program, 2006). Gray’s Reef supports an unusual assemblage of temperate and tropical species. A series 

of rock ledges and sand expanses have created deep burrows, troughs, and caves that support bottomdwelling plants and animals, such as sponges, barnacles, sea fans, hard coral, crabs, lobsters, and snails. 

The diverse topography provides habitat for a diverse fish community, with an estimated 200 species, 

including black sea bass (Centropristis striata), snapper (Lutjanidae spp.), grouper (Epinephelinae spp.), 

and mackerel (Scombridae spp.). Gray’s Reef is an important area for resting and foraging for both adult 

and juvenile loggerhead sea turtles throughout the year. Atlantic spotted dolphins and bottlenose 

dolphins are the most common marine mammals at the sanctuary; however, the highly endangered 

North Atlantic right whale has been observed during winter migration and calving season. Pelagic birds 

observed at Gray’s reef include gulls, petrels, shearwaters, Northern Gannet, phalaropes, jaegers, and 

terns (National Marine Sanctuary Program, 2006).
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Notes: AFTT: Atlantic Fleet Training and Testing; OPAREA: Operating Area

Figure 6.1-6: Location of National Marine Sanctuaries within the Southeast Atlantic and Gulf of Mexico Portion of the Study Area
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Numerous cover types are found on the sanctuary’s ledges, including macroalgae, sponges, tunicates, 

coral, and gorgonians; sessile invertebrates are the most diverse and abundant components, while 

corals are less common and form smaller colonies than in tropical regions (Bauer et al., 2008). The 

primary coral species in Gray’s Reef National Marine Sanctuary is the branching coral Oculina 

arbuscula—present on 75 percent of ledge sites, but contributing to a small percentage of overall cover. 

Sessile benthic organisms are susceptible to both direct and indirect damage from marine debris, 

ranging from abrasion by lines and wires, to entanglement (particularly Oculina sp.), to algal fouling and 

eventual coral death (Bauer et al., 2008). 

General regulations for the Gray’s Reef National Marine Sanctuary prohibit the following (15 CFR section

922.92(a)): 

(1) Dredging, drilling into, or otherwise altering in any way the submerged lands of the 

sanctuary (including bottom formations).

(2) Constructing any structure other than a navigation aid, or constructing, placing, or 

abandoning any structure, material, or other matter on the submerged lands of the

Sanctuary except weighted marker buoys that are continuously tended and used during 

otherwise lawful fishing or diving activities and that are not attached to a vessel and not 

capable of holding a boat at anchor. Weights used with a marker buoy shall not have a 

combined weight of more than 10 pounds, shall be attached with not greater than onefourth inch (1/4′′) line and shall be removed from the Sanctuary within twelve (12) hours 

of deployment. Any weighted marker buoy that is not continuously tended may be 

removed by the Assistant Administrator or designee or an authorized officer, without 

notice.

(3) Discharging or depositing any material or other matter except:

(i) Fish or fish parts, bait, or chumming materials;

(ii) Effluent from marine sanitation devices; and

(iii) Vessel cooling water.

(4) Operating a watercraft other than in accordance with the Federal rules and regulations 

that would apply if there were no sanctuary.

(5) (i) Injuring, catching, harvesting, or collecting, or attempting to injure, catch, harvest, 

or collect, any marine organism, or any part thereof, living or dead, within the 

sanctuary by any means except by use of rod and reel, and handline gear;

(ii) There shall be a rebuttable presumption that any marine organism or part thereof 

referenced in this paragraph found in the possession of a person within the 

sanctuary has been collected from the sanctuary.

(6) Using any fishing gear within the sanctuary except rod and reel, and handline gear, or for 

law enforcement purposes.

(7) Using underwater any explosives, or devices that produce electric charges underwater.

(8) Breaking, cutting, damaging, taking, or removing any bottom formation.

(9) Moving, removing, damaging, or possessing, or attempting to move, remove, damage, or 

possess, any sanctuary historical resource.

(10) Anchoring, or attempting to anchor, any vessel in the Sanctuary, except as provided in 

paragraph (d) of this section when responding to an emergency threatening life, property, 

or the environment.

(11) Possessing or carrying any fishing gear within the sanctuary except:
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(i) Rod and reel, and handline gear;

(ii) Fishing gear other than rod and reel, handline gear, and spearfishing gear, provided 

that it is stowed on a vessel and not available for immediate use;

(iii) Spearfishing gear provided that it is stowed on a vessel, not available for immediate 

use, and the vessel is passing through the sanctuary without interruption; and

(iv) For law enforcement purposes.

In addition to the prohibitions outlined in 15 CFR section 922.92(a), which apply throughout the 

Sanctuary, the following activities are prohibited and thus unlawful for any person to conduct or cause 

to be conducted within the research area (15 CFR section 922.94):

(a)

(1) Injuring, catching, harvesting, or collecting, or attempting to injure, catch, harvest, 

or collect, any marine organism, or any part thereof, living or dead.

(2) There shall be a rebuttable presumption that any marine organism or part thereof 

referenced in this paragraph found in the possession of a person within the research 

area has been collected from the research area.

(b) Using any fishing gear, or possessing, or carrying any fishing gear unless such gear is 

stowed and not available for immediate use while on board a vessel transiting through the 

research area without interruption or for valid law enforcement purposes.

(c) Diving.

(d) Stopping a vessel in the research area.

All activities carried out by the DoD within the sanctuary at the time of designation were considered 

essential for national defense, and therefore, are not subject to the sanctuary’s general prohibitions. 

These activities include surface and aerial gunnery, bombing, torpedo and missile activities, as well as 

vessel and submarine maneuvers, and aircraft overflights (typically above 1,500 feet or beyond a 1 NM 

radius of the sanctuary). The exemption of additional activities having significant impacts shall be 

determined in consultation between the Office of National Marine Sanctuaries and the DoD.

The Gray’s Reef National Marine Sanctuary Final Environmental Assessment for Implementation of the 

Sanctuary Management Plan and New Regulations was released in July 2014 (Office of National Marine 

Sanctuaries, 2014). Specifically, the document states:

Ongoing and proposed military activities, primarily U.S. Navy Atlantic Fleet Training and 

Testing operations, including active sonar, have the potential to adversely impact the 

habitat and living marine resources of the affected environment. The extent of these 

activities, however, and the potential to affect GRNMS biological and physical resources is 

unknown due to national defense protocols.

The Navy considered all proposed training and testing activities that could occur within the sanctuary, 

and identified that the proposed activities could fall into the following categories:

1. The following platforms, sources, or items that are part of Navy activities may be used 

within the Gray’s Reef National Marine Sanctuary because they were carried out at the 

time the regulations were promulgated and therefore are not prohibited:

 Aircraft and Aerial Targets
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Aircraft and aerial targets are expected to cause only a minor and temporary behavioral 

reaction due to noise for marine mammals (reactions do not rise to the level of take under 

the MMPA), sea turtles, birds, or fishes that may be present in the area. However, in 

addition to behavioral reactions due to noise, there is potential for seabirds to be struck 

by aircraft or aerial targets. As discussed in Section 2.3.3 (Standard Operating Procedures), 

the Navy implements standard operating procedures for aircraft safety that will reduce 

the potential for aircraft strikes. For a more detailed discussion of potential impacts to 

these resources from the use of aircraft and aerial targets, see the following sections:

Section 3.6.3.4.3 (Impacts from Aircraft and Aerial Targets) for fishes

Section 3.7.3.4.3 (Impacts from Aircraft and Aerial Targets) for marine mammals

Section 3.8.3.4.3 (Impacts from Aircraft and Aerial Targets) for reptiles

Section 3.9.3.4.3 (Impacts from Aircraft and Aerial Targets) for birds, which 

includes discussion of applicable seabirds

 Vessels and in-water devices (that do not make contact with seafloor)

Noise from vessels and in-water devices (excluding sonar and other active acoustic 

sources) is expected to cause only a minor and temporary behavioral reaction for marine 

mammals (reactions do not rise to the level of take under the MMPA), sea turtles, 

seabirds, or fishes that may be present in the area. There is potential for marine 

mammals, sea turtles, seabirds, floating vegetation, invertebrates, and large slow-moving 

fish species, to be struck by or to collide with vessels. As discussed in Section 2.3.3 

(Standard Operating Procedures), the Navy implements standard operating procedures 

for vessel and towed in-water device safety that will reduce the marine mammal strike 

potential. As discussed in Section 5.3.4 (Physical Disturbance and Strike Stressors), the 

Navy will implement mitigation to further reduce the potential for marine mammal strikes 

by vessels and in-water devices. For a more detailed discussion of potential impacts to 

these resources from the use of vessels and in-water devices, see the following sections:

Section 3.3.3.4.1 (Impacts from Vessels and In-Water Devices) for vegetation

Section 3.4.3.4.1 (Impacts from Vessels and In-Water Devices) for invertebrates

Section 3.6.3.4.1 (Impacts from Vessels and In-Water Devices) for fishes

Section 3.7.3.4.1 (Impacts from Vessels and In-Water Devices) for marine 

mammals

Section 3.8.3.4.1 (Impacts from Vessels and In-Water Devices) for reptiles

Section 3.9.3.4.1 (Impacts from Vessels and In-Water Devices) for birds

 Explosives detonated in-air or at the surface (includes gunnery, bombing, torpedoes, 

and missiles)

Explosives detonated in-air or at the surface could impact marine mammals, sea turtles, 

birds, invertebrates, floating vegetation, or fishes that may be present in the area. Impacts 

are expected to range from temporary behavioral reactions to injury, damage, or death. 

As discussed in Section 5.3.3 (Explosive Stressors), the Navy will implement mitigation to 

avoid impacts from explosives on marine mammals and sea turtles. For a more detailed 

discussion of potential impacts to these resources from the use of explosives detonated 

in-air or at the surface, see the following sections:
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Section 3.3.3.2.1 (Impacts from Explosives) for vegetation

Section 3.4.3.2.1 (Impacts from Explosives) for invertebrates

Section 3.6.3.2.1 (Impacts from Explosives) for fishes

Section 3.7.3.2.1 (Impacts from Explosives) for marine mammals

Section 3.8.3.2.1 (Impacts from Explosives) for reptiles

Section 3.9.3.2.1 (Impacts from Explosives) and Section 3.9.3.1.3 (Impacts from

Air Guns) for birds

 Military expended materials resulting from exempted activities

Military expended materials resulting from exempted activities include fragments from 

high-explosive munitions, non-explosive practice munitions, and targets. These items 

could directly strike marine mammals, sea turtles, birds, invertebrates, floating 

vegetation, or fishes that may be present in the area. However, the probability of military 

expended materials directly striking a marine resource is extremely low. As discussed in 

Section 5.3.4 (Physical Disturbance and Strike Stressors) and Section 5.4.1 (Mitigation 

Areas for Seafloor Resources), the Navy will implement mitigation to avoid impacts from 

military expended materials on marine mammals, sea turtles, and applicable seafloor 

resources. For a more detailed discussion of potential impacts to these resources from the 

use of non-explosive practice munitions fired in-air or at the surface, see the following 

sections:

Section 3.3.3.4.3 (Impacts from Military Expended Materials) for vegetation

Section 3.4.3.4.3 (Impacts from Military Expended Materials) for invertebrates

Section 3.5.3.4.3 (Impacts from Military Expended Materials) for habitats

Section 3.6.3.4.3 (Impacts from Military Expended Materials) for fishes

Section 3.7.3.4.3 (Impacts from Military Expended Materials) for marine 

mammals

Section 3.8.3.4.3 (Impacts from Military Expended Materials) for reptiles

Section 3.9.3.4.3 (Impacts from Military Expended Materials) for birds

2. The following platforms, sources, or items that are part of Navy activities were not 

conducted at the time that the sanctuary regulations were promulgated but may be used 

within the Gray’s Reef National Marine Sanctuary because they would not cause 

significant impacts on sanctuary resources:

 Sonar and other active acoustic sources

Sonar and other active acoustic sources are expected to cause only a minor and 

temporary behavioral reaction for invertebrates (cephalopods and crustaceans), diving 

birds, or fished that may be present in the area. No effect is anticipated to corals. There is 

potential for marine mammals and sea turtles to be injured (permanent threshold shifts in 

hearing) from sonar and other active acoustic sources. However, due to the water depth 

in the vicinity of the sanctuary, the types of active sonar and other acoustic sources that 

could be used would typically be limited to lower source levels and higher frequency 

systems such as mine-hunting, bottom mapping and underwater communication type 

systems. Regarding the more powerful hull-mounted mid-frequency sonars, the types of 

activities that could occur would typically be limited to maintenance, testing or mine 

countermeasure training, and these events would typically be less than an hour in the 
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vicinity of the sanctuary. Therefore, the likelihood of causing significant impacts on 

sanctuary resources, including marine mammals or sea turtles, is low. As discussed in 

Section 5.3.2 (Acoustic Stressors), the Navy will implement mitigation to avoid impacts 

from sonar on marine mammals and sea turtles. For a more detailed discussion of 

potential impacts to these resources from the use of sonar and other active acoustic 

sources, see the following sections:

Section 3.4.3.1.2 (Impacts from Sonar and Other Transducers) for invertebrates

Section 3.6.3.1.2 (Impacts from Sonar and Other Transducers) for fishes

Section 3.7.3.1.2 (Impacts from Sonar and Other Transducers) for marine 

mammals

Section 3.8.3.1.2 (Impacts from Sonar and Other Transducers) for reptiles

Section 3.9.3.1.2 (Impacts from Sonar and Other Transducers) for birds

 Electromagnetic devices 

Electromagnetic devices are expected to cause only a minor and temporary behavioral 

reaction for marine mammals (reactions do not rise to the level of take under the MMPA), 

sea turtles, birds, invertebrates (arthropods, such as lobsters), or fishes that may be 

present in the area. For a more detailed discussion of potential impacts to these resources 

from the use of electromagnetic devices, see the following sections:

Section 3.4.3.3.1 (Impacts from In-Water Electromagnetic Devices) and Section 

3.4.3.3.2 (Impacts from In-Air Electromagnetic Devices) for invertebrates

Section 3.6.3.3.1 (Impacts from In-Water Electromagnetic Devices) and Section 

3.6.3.3.2 (Impacts from In-Air Electromagnetic Devices) for fishes

Section 3.7.3.3.1 (Impacts from In-Water Electromagnetic Devices) and Section 

3.7.3.3.2 (Impacts from In-Air Electromagnetic Devices) for marine mammals

Section 3.8.3.3.1 (Impacts from In-Water Electromagnetic Devices) and Section 

3.8.3.3.2 (Impacts from In-Air Electromagnetic Devices) for reptiles

Section 3.9.3.3.1 (Impacts from In-Water Electromagnetic Devices) and Section 

3.9.3.3.2 (Impacts from In-Air Electromagnetic Devices) for birds

3. The following platforms, sources, or items are part of Navy activities, but are not planned 

to be used within the Gray’s Reef National Marine Sanctuary (including a 2.7 NM buffer) 

as part of the Proposed Action:

 Explosives detonated underwater

 Military expended materials resulting from non-exempted activities

 Seafloor devices

The Navy’s Proposed Action is consistent with the activities that were occurring when the Gray’s Reef 

National Marine Sanctuary was designated, as well as during the development of the 2014 Management 

Plan. The Navy does not propose to conduct any new activities that would cause significant impacts on 

Sanctuary resources. Furthermore, the Navy does not propose to increase the level of existing activities 

within the Sanctuary from what was previously considered at the time of sanctuary designation. Since 

activities conducted in and around the sanctuary could potentially result in harassment takes under the 

MMPA (defined as an injury to a sanctuary resource by the Office of National Marine Sanctuaries) the 

Navy consulted under section 304(d) of the National Marine Sanctuaries Act. On 15 May 2018, in an 
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injury determination letter in response to the Navy’s sanctuary resource statement, the Office of 

National Marine Sanctuaries concluded that the Proposed Action is likely to cause injury to sanctuary 

resources, but given ongoing research and current Navy mitigations, no sanctuary-specific reasonable 

and prudent alternatives were issued under this consultation.

6.1.2.6.4 Florida Keys National Marine Sanctuary

The Florida Keys National Marine Sanctuary is located within portions of the Southeast U.S. Continental 

Shelf, Caribbean Sea, and Gulf of Mexico Large Marine Ecosystems (Figure 6.1-6). The geographical 

extent of the sanctuary encompasses an area 2,900 NM2, including waters surrounding the 126 mile 

long Florida Keys archipelago, Florida Bay, and portions of the Gulf of Mexico and Atlantic Ocean

(National Marine Sanctuary Program, 2007a). The sanctuary was established in 1990 to preserve 

historical, cultural, and natural resources, including coral reefs, shipwrecks, seagrass beds, and fisheries. 

The Florida Keys National Marine Sanctuary contains a complex marine ecosystem that supports a 

variety of unique and nationally significant habitats: seagrass meadows, mangrove islands, and 

extensive living coral reefs. The ecosystem supports more than 6,000 species of plants, fish, and 

invertebrates, including the nation’s only coral reef that lies next to the continent and one of the largest 

seagrass communities in the hemisphere (National Marine Sanctuary Program, 2007a). 

Management of the Florida Keys National Marine Sanctuary involves a zoning strategy, with regulations 

applicable to either the entire sanctuary or to specific zones. Regulations focus on reducing direct and 

indirect threats to the reef by protecting ecologically important habitats and resources and improving 

water quality. Sanctuary-wide regulations prohibit the following (15 CFR section 922.163(a)): 

(1) Mineral and hydrocarbon exploration, development and production. Exploring for, 

developing, or producing minerals or hydrocarbons within the sanctuary.

(2) Removal of, injury to, or possession of coral or live rock. 

(i) Moving, removing, taking, harvesting, damaging, disturbing, touching, breaking, 

cutting, or otherwise injuring, or possessing (regardless of where taken from) any 

living or dead coral, or coral formation, or attempting any of these activities, except 

as permitted under 50 CFR part 622.

(ii) Harvesting, or attempting to harvest, any live rock from the sanctuary, or possessing 

(regardless of where taken from) any live rock within the sanctuary, except as 

authorized by a permit for the possession or harvest from aquaculture operations in 

the Exclusive Economic Zone, issued by the National Marine Fisheries Service 

pursuant to applicable regulations under the appropriate Fishery Management Plan, 

or as authorized by the applicable State authority of competent jurisdiction within 

the sanctuary for live rock cultured on State submerged lands leased from the State 

of Florida, pursuant to applicable State law. See section 370.027, Florida Statutes 

and implementing regulations.

(3) Alteration of, or construction on, the seabed. Drilling into, dredging, or otherwise altering 

the seabed of the sanctuary, or engaging in prop-dredging; or constructing, placing or 

abandoning any structure, material, or other matter on the seabed of the sanctuary, 

except as an incidental result of:

(i) Anchoring vessels in a manner not otherwise prohibited by this part (see sections

922.163(a)(5)(ii) and 922.164(d)(1)(v));
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(ii) Traditional fishing activities not otherwise prohibited by this part;

(iii) Installation and maintenance of navigational aids by, or pursuant to valid 

authorization by, any Federal, State, or local authority of competent jurisdiction;

(iv) Harbor maintenance in areas necessarily associated with federal water resource 

development projects in existence on July 1, 1997, including maintenance dredging 

of entrance channels and repair, replacement, or rehabilitation of breakwaters or 

jetties;

(v) Construction, repair, replacement, or rehabilitation of docks, seawalls, breakwaters, 

piers, or marinas with less than ten slips authorized by any valid lease, permit, 

license, approval, or other authorization issued by any Federal, State, or local 

authority of competent jurisdiction.

(4) Discharge or deposit of materials or other matter. 

(i) Discharging or depositing, from within the boundary of the sanctuary, any material 

or other matter, except:

(A) Fish, fish parts, chumming materials, or bait used or produced incidental to 

and while conducting a traditional fishing activity in the sanctuary;

(B) Water generated by routine vessel operations (e.g., deck wash down and 

graywater as defined in Section 312 of the Federal Water Pollution Control 

Act), excluding oily wastes from bilge pumping; or

(C) Cooling water from vessels or engine exhaust;

(ii) Discharging or depositing, from beyond the boundary of the sanctuary, any material 

or other matter that subsequently enters the sanctuary and injures a sanctuary 

resource or quality, except:

(A) Those listed in paragraph (a)(4)(i)(A) through (a)(4)(i)(C) of this section;

(B) Sewage incidental to vessel use and generated by a marine sanitation device 

approved in accordance with Section 312 of the Federal Water Pollution 

Control Act, as amended, 33 U.S.C. 1322 et seq.; 

(C) Those authorized under Monroe County land use permits; or

(D) Those authorized under State permits.

(5) Operation of vessels. 

(i) Operating a vessel in such a manner as to strike or otherwise injure coral, seagrass, 

or any other immobile organism attached to the seabed, including, but not limited 

to, operating a vessel in such a manner as to cause prop-scarring.

(ii) Having a vessel anchored on living coral other than hard bottom in water depths 

less than 40 feet when visibility is such that the seabed can be seen.

(iii) Except in officially marked channels, operating a vessel at a speed greater than 

4 knots or in manner which creates a wake:

(A) Within an area designated idle speed only/no wake;

(B) Within 100 yards of navigational aids indicating emergent or shallow reefs 

(international diamond warning symbol);
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(C) Within 100 yards of the red and white “divers down” flag (or the blue and 

white “alpha” flag in Federal waters);

(D) Within 100 yards of residential shorelines; or

(E) Within 100 yards of stationary vessels.

(iv) Operating a vessel in such a manner as to injure or take wading, roosting, or nesting 

birds or marine mammals.

(v) Operating a vessel in a manner which endangers life, limb, marine resources, or 

property.

(vi) Having a marine sanitation device that is not secured in a manner that prevents 

discharges or deposits of treated and untreated sewage. Acceptable methods 

include, but are not limited to, all methods that have been approved by the U.S. 

Coast Guard (at 33 CFR section 159.7(b) and (c)).

(6) Conduct of diving/snorkeling without flag. Diving or snorkeling without flying in a 

conspicuous manner the red and white “divers down” flag (or the blue and white “alpha” 

flag in Federal waters).

(7) Release of exotic species. Introducing or releasing an exotic species of plant, invertebrate, 

fish, amphibian, or mammals into the sanctuary.

(8) Damage or removal of markers. Marking, defacing, or damaging in any way or displacing, 

removing, or tampering with any official signs, notices, or placards, whether temporary or 

permanent, or with any navigational aids, monuments, stakes, posts, mooring buoys, 

boundary buoys, trap buoys, or scientific equipment.

(9) Movement of, removal of, injury to, or possession of sanctuary historical resources. 

Moving, removing, injuring, or possessing, or attempting to move, remove, injure, or 

possess, a sanctuary historical resource.

(10) Take or possession of protected wildlife. Taking any marine mammal, sea turtle, or seabird 

in or above the sanctuary, except as authorized by the Marine Mammal Protection Act, as 

amended, (MMPA), 16 U.S.C. 1361 et seq., the Endangered Species Act, as amended, 

(ESA), 16 U.S.C. 1531 et seq., and the Migratory Bird Treaty Act, as amended, (MBTA) 

16 U.S.C. 703 et seq. 

(11) Possession or use of explosives or electrical charges. Possessing, or using explosives, 

except powerheads, or releasing electrical charges within the sanctuary.

(12) Harvest or possession of marine life species. Harvesting, possessing, or landing any marine 

life species, or part thereof, within the sanctuary, except in accordance with rules 68B–42 

of the Florida Administrative Code, and such rules shall apply mutatis mutandis (with 

necessary editorial changes) to all Federal and State waters within the sanctuary.

(13) Interference with law enforcement. Interfering with, obstructing, delaying or preventing 

an investigation, search, seizure, or disposition of seized property in connection with 

enforcement of the Acts or any regulation or permit issued under the Acts.

The prohibitions listed above and at 15 CFR section 922.164 do not apply to existing classes of DoD 

military activities conducted prior to the effective date of these regulations as identified in the EIS and 

Management Plan for the sanctuary (15 CFR section 922.163(d)(1)). New military activities in the 

sanctuary are allowed and may be exempted from the prohibitions summarized after consultation 

between the Office of National Marine Sanctuaries and the Navy pursuant to Section 304(d) of the 

National Marine Sanctuary Act. An activity is considered new when it is modified so it is likely to destroy, 

cause the loss of, or injure a sanctuary resource or quality in a manner significantly greater than was 
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considered in a previous consultation under section 304(d) of the National Marine Sanctuary Act. All 

military activities shall be carried out in a manner that avoids to the maximum extent practicable any 

adverse impacts on Sanctuary resources and qualities.

The Navy has played an important role in the lower Florida Keys since the early 1800s. Existing classes of 

DoD military activities conducted prior to the effective date of sanctuary regulations and identified in 

the original Final Management Plan/EIS for the Florida Keys National Sanctuary (National Marine 

Sanctuary Program, 1996) include:

 Research on radar and missile systems and test missile operations and evaluation

 Underwater explosives testing (including weapon systems testing and shock testing of ship 

hull designs) in “Site A” 

 Mine countermeasure research

 Corrosion and coatings tests

 Acoustic research

 General air operations

 Air combat maneuvering

 Air-to-surface ordnance (inert ordnance and smoke markers) at Patricia Range 

 Submarine activities (including firing and recovery of non-explosive torpedoes outside 

sanctuary)

 Sonobuoy testing and diver training (typically includes recovery of sonobuoys)

 Special warfare activities at Fleming Key

 Search and rescue

 General transits, anchoring in designated areas, moorings, and pierside maintenance at 

Naval Air Station Key West piers

 Harbor management

 Fuel deliveries

The Florida Keys National Marine Sanctuary Revised Management Plan was released in December 2007 

(National Marine Sanctuary Program, 2007a). The 2007 revised management plan does not alter the

exemptions of the original 1996 management plan/environmental impact statement (National Marine 

Sanctuary Program, 1996).

To ensure compliance with the Office of National Marine Sanctuaries Regulations, the Navy considered 

all proposed training and testing activities that could occur within the sanctuary. All activities would be 

conducted in a manner that avoids to the maximum extent practicable any adverse impacts on 

sanctuary resources. The Navy concluded that the proposed activities could fall into the following 

categories:

1. The following platforms, sources, or items that are part of Navy activities may be used 

within the Florida Keys National Marine Sanctuary because they are either exempted from 

the prohibitions as pre-existing activities (i.e., were conducted prior to the effective date 

of these regulations) or do not involve prohibited activities:

 Aircraft and Aerial Targets

Aircraft and aerial targets are expected to cause only a minor and temporary behavioral 

reaction due to noise for marine mammals (reactions do not rise to the level of take under 

the MMPA), sea turtles, birds, or fishes that may be present in the area. However, in 
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addition to behavioral reactions due to noise, there is potential for seabirds to be struck 

by aircraft or aerial targets. As discussed in Section 2.3.3 (Standard Operating Procedures), 

the Navy implements standard operating procedures for aircraft safety that will reduce 

the potential for aircraft strikes. For a more detailed discussion of potential impacts to 

these resources from the use of aircraft and aerial targets, see the following sections:

Section 3.6.3.4.2 (Impacts from Aircraft and Aerial Targets) for fishes

Section 3.7.3.4.2 (Impacts from Aircraft and Aerial Targets) for marine mammals

Section 3.8.3.4.2 (Impacts from Aircraft and Aerial Targets) for reptiles

Section 3.9.3.4.2 (Impacts from Aircraft and Aerial Targets) for birds, which 

includes discussion of applicable seabirds

 Vessels and in-water devices (that do not make contact with seafloor)

Noise from vessels and in-water devices (excluding sonar and other active acoustic 

sources) is expected to cause only a minor and temporary behavioral reaction for marine 

mammals (reactions do not rise to the level of take under the MMPA), sea turtles, 

seabirds, or fishes that may be present in the area. There is potential for marine 

mammals, sea turtles, seabirds, floating vegetation, invertebrates, and large slow-moving 

fish species, to be struck by or to collide with vessels. As discussed in Section 2.3.3 

(Standard Operating Procedures), the Navy implements standard operating procedures 

for vessel and towed in-water device safety that will reduce the marine mammal strike 

potential. As discussed in Section 5.3.4 (Physical Disturbance and Strike Stressors), the 

Navy will implement mitigation to further reduce the potential for marine mammal strikes 

by vessels and in-water devices. For a more detailed discussion of potential impacts to 

these resources from the use of vessels and in-water devices, see the following sections:

Section 3.3.3.4.1 (Impacts from Vessels and In-Water Devices) for vegetation

Section 3.4.3.4.1 (Impacts from Vessels and In-Water Devices) for invertebrates

Section 3.6.3.4.1 (Impacts from Vessels and In-Water Devices) for fishes

Section 3.7.3.4.1 (Impacts from Vessels and In-Water Devices) for marine 

mammals

Section 3.8.3.4.1 (Impacts from Vessels and In-Water Devices) for reptiles

Section 3.9.3.4.1 (Impacts from Vessels and In-Water Devices) for birds

 Sonar and other active acoustic sources (including mine countermeasure research, 

acoustic research, submarine activities, sonobuoy testing, and special warfare 

activities)

Sonar and other active acoustic sources are expected to cause only a minor and 

temporary behavioral reaction for marine mammals, sea turtles, invertebrates 

(cephalopods and crustaceans), diving birds, or fishes that may be present in the area. No 

effect is anticipated to corals. There is potential for marine mammals and sea turtles to be 

injured (permanent threshold shifts in hearing) from sonar and other active acoustic 

sources. As discussed in Section 5.3.2 (Acoustic Stressors), the Navy will implement 

mitigation to avoid impacts from sonar on marine mammals and sea turtles. For a more 

detailed discussion of potential impacts to these resources from the use of sonar and 

other active acoustic sources, see the following sections:
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Section 3.4.3.1.2 (Impacts from Sonar and Other Transducers) for invertebrates

Section 3.6.3.1.2 (Impacts from Sonar and Other Transducers) for fishes

Section 3.7.3.1.2 (Impacts from Sonar and Other Transducers) for marine 

mammals

Section 3.8.3.1.2 (Impacts from Sonar and Other Transducers) for reptiles

Section 3.9.3.1.2 (Impacts from Sonar and Other Transducers) for birds

2. The following platforms, sources, or items that are part of Navy activities but were not 

conducted as of the effective date of the regulations may be used within the Florida Keys 

National Marine Sanctuary because they are not a prohibited activity under the sanctuary 

regulations:

 Electromagnetic devices

Electromagnetic devices are expected to cause only a minor and temporary behavioral 

reaction for marine mammals (reactions do not rise to the level of take under the MMPA), 

sea turtles, birds, invertebrates (arthropods, such as lobsters), or fish that may be present 

in the area. For a more detailed discussion of potential impacts to these resources from 

the use of electromagnetic devices, see the following sections:

Section 3.4.3.3.2 (Impacts from In-Water Electromagnetic Devices) and Section 

3.4.3.3.3 (Impacts from In-Air Electromagnetic Devices) for invertebrates

Section 3.6.3.3.2 (Impacts from In-Water Electromagnetic Devices) and Section 

3.6.3.3.3 (Impacts from In-Air Electromagnetic Devices) for fishes

Section 3.7.3.3.2 (Impacts from In-Water Electromagnetic Devices) and Section 

3.7.3.3.3 (Impacts from In-Air Electromagnetic Devices) for marine mammals

Section 3.8.3.3.2 (Impacts from In-Water Electromagnetic Devices) and Section 

3.8.3.3.3 (Impacts from In-Air Electromagnetic Devices) for reptiles

Section 3.9.3.3.2 (Impacts from In-Water Electromagnetic Devices) and Section 

3.9.3.3.3 (Impacts from In-Air Electromagnetic Devices) for birds

3. The following platforms, sources, or items that are part of Navy activities, but are not 

planned to be used within the Florida Keys National Marine Sanctuary (including a 2.7 NM 

buffer) as part of the Proposed Action:

 Sonar and other active acoustic sources (not included in activities listed in Category 1 

above)

 Explosives detonated in-air, at the surface, or underwater (with the exception of limpet 

mine events which occur within the Sanctuary boundaries)

 Military expended materials

 Seafloor devices 

Activities the Navy proposes to conduct in the Florida Keys National Marine Sanctuary are within the 

classes of activities exempted from requiring a permit as of the effective date of the sanctuary 

regulations and are consistent with Navy activities and planning included in the most recent 

management plan. Navy activities have not been modified as to be more likely to destroy, cause the loss

of, or injure a sanctuary resource or quality in a manner significantly greater than was previously 

considered when exempted or in the management plan. Further, the Navy does not propose to increase 

the level of existing activities within the sanctuary from what was previously considered at the time of 
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sanctuary designation. Since activities conducted in and around the sanctuary could potentially result in 

harassment takes under the MMPA (defined as an injury to a sanctuary resource by the Office of 

National Marine Sanctuaries) the Navy consulted under section 304(d) of the National Marine 

Sanctuaries Act. On 15 May 2018, in an injury determination letter in response to the Navy's sanctuary 

resource statement, the Office of National Marine Sanctuaries recommended, and Navy concurred, that 

the Navy continue to obtain updated data regarding sea turtle densities to support future higher 

resolution modeling to further evaluate potential impacts to sea turtles from explosive stressors in 

Florida Keys National Marine Sanctuary.

6.1.2.6.5 Flower Garden Banks National Marine Sanctuary

The Flower Garden Banks National Marine Sanctuary is located within the northwestern portion of the 

Gulf of Mexico Large Marine Ecosystem, nearly 96 NM offshore of Texas and Louisiana (Figure 6.1-6). 

The Flower Garden Banks National Marine Sanctuary was designated in 1992 to include East Flower 

Garden Bank and West Flower Garden Bank, and was expanded in 1996 to include Stetson Bank. Now 

encompassing an area of 42.34 NM2, the sanctuary is designed to preserve the ecological and 

recreational value of three areas of coral reef that exist atop salt domes rising from the ocean floor. The 

East and West Flower Garden Banks coral reef ecosystem and associated biological communities 

support nearly 280 fish species, as well as loggerhead and hawksbill sea turtles, and a variety of shark, 

ray, and invertebrate species. Shark species found at the sanctuary include scalloped hammerhead 

sharks, sandbar sharks, tiger sharks, spinner sharks, and whale sharks (Office of National Marine 

Sanctuaries, 2008). Stetson Bank is primarily habitat for sponge communities, but is also scattered with 

coral colonies and provides habitat for diverse fish and plant assemblages (Moretzsohn et al., 2011). The 

sanctuary is used for recreational fishing and diving, which in some isolated cases has degraded the 

quality of reef habitat because of damage from anchoring (Office of National Marine Sanctuaries, 2008). 

General regulations for Flower Garden Banks National Marine Sanctuary prohibit the following (15 CFR

section 922.122(a)): 

(1) Exploring for, developing, or producing oil, gas, or minerals except outside of all noactivity zones and provided all drilling cuttings and drilling fluids are shunted to the 

seabed through a downpipe that terminates an appropriate distance, but no more than 

ten meters, from the seabed.

(2) (i) Anchoring any vessel within the sanctuary.

(ii) Mooring any vessel within the sanctuary, except that vessels 100 feet (30.48 

meters) or less in registered length may moor to a sanctuary mooring buoy.

(iii) Mooring a vessel in the sanctuary without clearly displaying the blue and white 

International Code flag “A” (“alpha” dive flag) or the red and white “sports diver” 

flag whenever a SCUBA diver from that vessel is in the water and removing the 

“alpha” dive flag or “sports diver” flag after all SCUBA divers exit the water and 

return back on board the vessel, consistent with U.S. Coast Guard guidelines relating 

to sports diving as contained within “Special Notice to Mariners” (00–208) for the 

Gulf of Mexico.

(3) (i) Discharging or depositing from within or into the sanctuary any material or other 

matter except:
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(A) Fish, fish parts, chumming materials, or bait used in or resulting from fishing 

with conventional hook and line gear in the sanctuary, provided that such 

discharge or deposit occurs during the conduct of such fishing within the 

sanctuary;

(B) Clean effluent generated incidental to vessel use by an operable Type I or 

Type II marine sanitation device (U.S. Coast Guard classification) approved in 

accordance with Section 312 of the Federal Water Pollution Control Act, as 

amended 33 U.S.C. 1322. Vessel operators must lock marine sanitation 

devices in a manner that prevents discharge or deposit of untreated sewage;

(C) Clean vessel deck wash down, clean vessel engine cooling water, clean vessel 

generator cooling water, clean bilge water, or anchor wash;

(D) Engine exhaust;

(E) In areas of the sanctuary outside the no-activity zones, drilling cuttings and 

drilling fluids necessarily discharged incidental to the exploration for, 

development of, or production of oil or gas in those areas and in accordance 

with the shunting requirements of paragraph (a)(1) of this section unless such 

discharge injures a sanctuary resource or quality.

(ii) Discharging or depositing, from beyond the boundaries of the sanctuary, any 

material or other matter, except those listed in paragraphs (a)(3)(i)(A) through (D) of 

this section, that subsequently enters the sanctuary and injures a sanctuary 

resource or quality.

(4) Drilling into, dredging, or otherwise altering the seabed of the sanctuary (except as 

allowed under paragraph (c) of this section); or constructing, placing, or abandoning any 

structure, material, or other matter on the seabed of the sanctuary.

(5) Injuring or removing, or attempting to injure or remove, any coral or other bottom 

formation, coralline algae or other plant, marine invertebrate, brine-seep biota, or 

carbonate rock within the sanctuary.

(6) Taking any marine mammal or turtle within the sanctuary, except as permitted by 

regulations, as amended, promulgated under the Marine Mammal Protection Act, as 

amended, 16 U.S.C. 1361 et seq., and the Endangered Species Act, as amended, 16 U.S.C. 

1531 et seq. 

(7) Killing, injuring, attracting, touching, or disturbing a ray or whale shark in the sanctuary. 

Notwithstanding the above, the incidental and unintentional injury to a ray or whale shark 

as a result of fishing with conventional hook and line gear is exempted from this 

prohibition.

(8) Injuring, catching, harvesting, collecting, or feeding, or attempting to injure, catch, 

harvest, collect, or feed, any fish within the sanctuary by use of bottom longlines, traps, 

nets, bottom trawls, or any other gear, device, equipment, or means except by use of 

conventional hook and line gear.

(9) Possessing within the sanctuary (regardless of where collected, caught, harvested or 

removed), except for valid law enforcement purposes, any carbonate rock, coral or other 

bottom formation, coralline algae or other plant, marine invertebrate, brine-seep biota, or 

fish (except for fish caught by use of conventional hook and line gear).

(10) Possessing or using within the sanctuary, except possessing while passing without 

interruption through it or for valid law enforcement purposes, any fishing gear, device, 

equipment or means except conventional hook and line gear.
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(11) Possessing, except for valid law enforcement purposes, or using explosives or releasing 

electrical charges within the sanctuary.

The prohibitions listed above do not apply to activities being carried out by the DoD as of the effective 

date of sanctuary designation. Pre-existing Navy activities will be carried out in a manner that minimizes 

any adverse impact on sanctuary resources and qualities. New activities may be carried out by the DoD 

if they do not have the potential for any significant adverse impacts on sanctuary resources or qualities. 

New activities with the potential for significant adverse impacts on sanctuary resources or qualities may 

be exempted after consultation between the Office of National Marine Sanctuaries and the DoD. If it is 

determined that an activity may be carried out, such activity shall be carried out in a manner that 

minimizes any adverse impact on sanctuary resources and qualities (15 CFR section 922.122(e)(1)). 

Activities that were carried out prior to the effective date of the sanctuary designation and identified in 

the original Final EIS/Management Plan for the Flower Garden Banks National Sanctuary (National 

Marine Sanctuary Program, 1991) include:

 Carrier maneuvers

 Missile testing and development

 Rocket firing

 Air-to-air gunnery

 Air-to-surface gunnery

 Minesweeping operations

 Submarine operations

 Air combat maneuvers

 Aerobatic training

 Instrument training 

The Flower Garden Banks National Marine Sanctuary Final Management Plan was released in April 2012

(Office of National Marine Sanctuaries, 2012), which included a summary of the revised environmental 

impact statement and contained the revised regulations as an appendix. The 2012 revised management 

plan does not alter the exemptions of the original 1991 management plan/environmental impact 

statement (National Marine Sanctuary Program, 1991).

The Navy considered all proposed training and testing activities that could occur within the sanctuary. 

All activities would be conducted in a manner that avoids to the maximum extent practicable any 

adverse impacts on sanctuary resources. The Navy concluded that the proposed activities could fall into 

the following two categories:

1. The following platforms, sources, or items that are part of Navy activities may be used 

within the Flower Garden Banks National Marine Sanctuary because they (1) do not have 

the potential for any significant adverse impacts on sanctuary resources or qualities, and 

(2) are carried out in a manner that minimizes any adverse impact on sanctuary resources 

and qualities:

 Aircraft and Aerial Targets

Aircraft and aerial targets are expected to cause only a minor and temporary behavioral 

reaction due to noise for marine mammals (reactions do not rise to the level of take under 

the MMPA), sea turtles, birds, or fishes that may be present in the area. However, in 

addition to behavioral reactions due to noise, there is potential for seabirds to be struck 
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by aircraft or aerial targets. As discussed in Section 2.3.3 (Standard Operating Procedures), 

the Navy implements standard operating procedures for aircraft safety that will reduce 

the potential for aircraft strikes. For a more detailed discussion of potential impacts to 

these resources from the use of aircraft and aerial targets, see the following sections:

Section 3.6.3.4.2 (Impacts from Aircraft and Aerial Targets) for fishes

Section 3.7.3.4.2 (Impacts from Aircraft and Aerial Targets) for marine mammals

Section 3.8.3.4.2 (Impacts from Aircraft and Aerial Targets) for reptiles

Section 3.9.3.4.2 (Impacts from Aircraft and Aerial Targets) for birds, which 

includes discussion of applicable seabirds

 Vessels and in-water devices

Noise from vessels and in-water devices (excluding sonar and other active acoustic 

sources) is expected to cause only a minor and temporary behavioral reaction for marine 

mammals (reactions do not rise to the level of take under the MMPA), sea turtles, 

seabirds, or fishes that may be present in the area. There is potential for marine 

mammals, sea turtles, seabirds, floating vegetation, invertebrates, and large slow-moving 

fish species, to be struck by or to collide with vessels. As discussed in Section 2.3.3 

(Standard Operating Procedures), the Navy implements standard operating procedures 

for vessel and towed in-water device safety that will reduce the marine mammal strike 

potential. As discussed in Section 5.3.4 (Physical Disturbance and Strike Stressors), the 

Navy will implement mitigation to further reduce the potential for marine mammal strikes 

by vessels and in-water devices. For a more detailed discussion of potential impacts to 

these resources from the use of vessels and in-water devices, see the following sections:

Section 3.3.3.4.1 (Impacts from Vessels and In-Water Devices) for vegetation

Section 3.4.3.4.1 (Impacts from Vessels and In-Water Devices) for invertebrates

Section 3.6.3.4.1 (Impacts from Vessels and In-Water Devices) for fishes

Section 3.7.3.4.1 (Impacts from Vessels and In-Water Devices) for marine 

mammals

Section 3.8.3.4.1 (Impacts from Vessels and In-Water Devices) for reptiles

Section 3.9.3.4.1 (Impacts from Vessels and In-Water Devices) for birds

 Sonar and other non-impulsive acoustic sources

Sonar and other active acoustic sources are expected to cause only a minor and 

temporary behavioral reaction for marine mammals (reactions do not rise to the level of 

take under the MMPA), sea turtles, invertebrates (cephalopods and crustaceans), diving 

birds, or fishes that may be present in the area. No effect is anticipated to corals. For a 

more detailed discussion of potential impacts to these resources from the use of sonar 

and other active acoustic sources, see the Sanctuary Resource Statement (Section 1[ii] 

Flower Garden Bank National Marine Sanctuary) and the following sections of this 

FEIS/OEIS:

Section 3.4.3.1.2 (Impacts from Sonar and Other Transducers) for invertebrates

Section 3.6.3.1.2 (Impacts from Sonar and Other Transducers) for fishes

Section 3.7.3.1.2 (Impacts from Sonar and Other Transducers) for marine 

mammals
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Section 3.8.3.1.2 (Impacts from Sonar and Other Transducers) for reptiles

Section 3.9.3.1.2 (Impacts from Sonar and Other Transducers) for birds

 Electromagnetic devices

Electromagnetic devices are expected to cause only a minor and temporary behavioral 

reaction for marine mammals (reactions do not rise to the level of take under the MMPA), 

sea turtles, birds, invertebrates (arthropods, such as lobsters), or fishes that may be 

present in the area. For a more detailed discussion of potential impacts to these resources 

from the use of electromagnetic devices, see the following sections:

Section 3.4.3.3.1 (Impacts from In-Water Electromagnetic Devices) and Section 

3.4.3.3.2 (Impacts from In-Air Electromagnetic Devices) for invertebrates

Section 3.6.3.3.1 (Impacts from In-Water Electromagnetic Devices) and Section 

3.6.3.3.2 (Impacts from In-Air Electromagnetic Devices) for fishes

Section 3.7.3.3.1 (Impacts from In-Water Electromagnetic Devices) and Section 

3.7.3.3.2 (Impacts from In-Air Electromagnetic Devices) for marine mammals

Section 3.8.3.3.1 (Impacts from In-Water Electromagnetic Devices) and Section 

3.8.3.3.2 (Impacts from In-Air Electromagnetic Devices) for reptiles

Section 3.9.3.3.1 (Impacts from In-Water Electromagnetic Devices) and Section 

3.9.3.3.2 (Impacts from In-Air Electromagnetic Devices) for birds

2. The following platforms, sources, or items are part of Navy activities, but that are not 

planned to be used within the Flower Garden Banks National Marine Sanctuary (including 

a 2.7 NM buffer) as part of the Proposed Action:

 Explosives detonated in-air, at the surface or underwater

 Military expended materials 

 Seafloor devices

Activities the Navy proposes to conduct in Flower Garden Banks National Marine Sanctuary are 

consistent with the activities exempted when the sanctuary was designated and are consistent with 

Navy activities and planning during the development of the most recent management plan. The Navy 

does not propose to conduct any new activities that could have significant adverse impacts on sanctuary 

resources or qualities. Further, the Navy does not propose to increase the level of existing activities 

within the sanctuary from what was previously considered at the time of sanctuary designation. Since 

none of the Navy’s training and testing activities proposed to be conducted within or in the vicinity of 

Flower Garden Banks National Marine Sanctuary are likely to injure sanctuary resources, the Navy has 

determined that it is not required to engage in section 304(d) consultation under the National Marine 

Sanctuaries Act.

6.1.3 MAGNUSON-STEVENS FISHERY CONSERVATION AND MANAGEMENT ACT

The Magnuson-Stevens Fishery Conservation and Management Act of 1976 (16 United U.S.C. section 

1801–1891[d]), as amended by the 1996 Sustainable Fisheries Act (Public Law 104–297), and the 

Magnuson-Stevens Fishery Conservation and Management Reauthorization Act of 2006 (Public Law 109-

479), governs marine fisheries management in U.S. waters in order to promote long-term economic and 

biological sustainability for fisheries up to 200 NM from shore. Its main objectives are to prevent 

overfishing, rebuild overfished stocks, increase long-term economic and social benefits, and ensure a 

safe and sustainable supply of seafood (National Oceanic and Atmospheric Administration Fisheries, 
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2017). The Sustainable Fisheries Act of 1996 amended the law to establish procedures that identify, 

conserve, and enhance Essential Fish Habitat for species regulated under a federal fisheries 

management plan. 

Consultation with the National Oceanic and Atmospheric Administration’s National Marine Fisheries 

Service on all actions or proposed actions that may adversely affect Essential Fish Habitat is required for 

federal action agencies under section 305(b)(2) of the Magnuson-Stevens Act. The Navy submitted 

Essential Fish Habitat Assessments associated with the Proposed Action to the two regional offices with 

jurisdiction within the AFTT Study Area, Greater Atlantic Regional Fisheries Office and Southeast 

Regional Fisheries Office, in February 2018. 

The Essential Fish Habitat Assessments included a description of the Navy’s Proposed Action and 

included the following:

 activities and Essential Fish Habitat designations that differ from the previous AFTT EIS/OEIS for 

which there was a consultation completed in 2012; 

 an overview of the Essential Fish Habitat designated within the consultation areas reviewed by 

the Greater Atlantic Regional Fisheries Office and Southeast Regional Fisheries Office, 

respectively; 

 an analysis of the individual stressor and combined stressor effects of the proposed activity; 

 the Navy’s determinations regarding the effects of the proposed activity; 

 and proposed mitigation measures designed to minimize potential effects from the proposed 

activities.

With the application of the standard operating procedures and mitigation measures, the Proposed 

Action (occurring at inshore, pierside and at-sea locations) would have no more than a minimal overall 

impact on habitats designated as Essential Fish Habitat or Habitat Areas of Particular Concern in the 

Greater Atlantic Regional Fisheries Office and Southeast Regional Fisheries Office consultation areas. 

The vast majority of unavoidable impacts would be to the relatively abundant and resilient soft bottom 

or low relief/ephemeral hard bottom communities in the offshore portion of the AFTT Study Area. The 

chance of Proposed Action stressors impacting relatively high relief hard bottom, where deep-sea corals 

and other sedentary invertebrate beds are concentrated, is considered unlikely but not discountable.

Pursuant to the Essential Fish Habitat requirements of the Magnuson-Stevens Fishery Conservation and 

Management Act and implementing regulations, a subset of stressors associated with the proposed 

training and testing activities (pile driving/extraction, air guns, in-water explosives, military expended 

materials, seafloor devices, and explosive byproduct contaminants) “may adversely affect” Essential Fish 

Habitat in the Greater Atlantic Regional Fisheries Office and Southeast Regional Office consultation 

areas. Mitigations designed to reduce impacts to Essential Fish Habitat have been incorporated into the 

Proposed Action (see Sections 5.4.1, Mitigation Areas for Seafloor Resources, and 5.4.3, Mitigation Areas 

off the Mid-Atlantic and Southeastern United States, for more details).

6.2 RELATIONSHIP BETWEEN SHORT-TERM USE OF THE ENVIRONMENT AND 

MAINTENANCE AND ENHANCEMENT OF LONG-TERM PRODUCTIVITY

In accordance with the Council on Environmental Quality regulations (40 CFR Part 1502), this EIS/OEIS 

analyzes the relationship between the short-term impacts on the environment and the effects those 

impacts may have on the maintenance and enhancement of the long-term productivity of the affected 

environment. Impacts that narrow the range of beneficial uses of the environment are of particular 
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concern. This means that choosing one option may reduce future flexibility in pursuing other options, or 

that committing a resource to a certain use may often eliminate the possibility for other uses of that 

resource. The Navy, in partnership with NMFS, is committed to furthering understanding of marine 

resources and to developing ways to lessen or eliminate the impacts that Navy training and testing 

activities may have on these resources. For example, the Navy and NMFS collaborate on the Integrated 

Comprehensive Monitoring Program for marine species to assess the impacts of training activities on 

marine species and investigate population-level trends in marine species distribution, abundance, and 

habitat use in various range complexes and geographic locations where Navy training occurs.

The Proposed Action could result in both short- and long-term environmental impacts. However, these 

are not expected to result in any impacts that would reduce environmental productivity, permanently 

narrow the range of beneficial uses of the environment, or pose long-term risks to health, safety, or 

general welfare of the public. The Navy is committed to sustainable military range management, 

including co-use of the Study Area with the general public and commercial and recreational interests. 

This commitment to co-use of the Study Area would maintain long-term accessibility of the AFTT 

EIS/OEIS training and testing areas. Sustainable range management practices are specified in range 

complex management plans under the Navy’s Range Sustainment Program. Among other benefits, these 

practices protect and conserve natural and cultural resources and preserve access to training areas for 

current and future training requirements while addressing potential encroachments that threaten to 

impact range and training area capabilities.

6.3 IRREVERSIBLE OR IRRETRIEVABLE COMMITMENT OF RESOURCES

NEPA requires that environmental analyses include identification of “any irreversible and irretrievable 

commitments of resources which would be involved in the Proposed Action should it be implemented” 

(42 U.S.C. section 4332). Irreversible and irretrievable resource commitments are related to the use of 

nonrenewable resources and the impacts that the uses of these resources have on future generations. 

Irreversible impacts primarily result from the use or destruction of a specific resource (e.g., energy or 

minerals) that cannot be replaced within a reasonable time. Irretrievable resource commitments involve 

the loss in value of an affected resource that cannot be restored as a result of the action (e.g., the 

disturbance of a cultural site).

For the Proposed Action, most resource commitments would be neither irreversible nor irretrievable. 

Most impacts would be short term and temporary, or long lasting but within historical or desired 

conditions. Because there would be no building or facility construction, the consumption of material 

typically associated with such construction (e.g., concrete, metal, sand, fuel) would not occur. Energy 

typically associated with construction activities would not be expended and irretrievably lost. 

Implementation of the Proposed Action would require fuels used by aircraft and vessels. Since fixed- and 

rotary-wing aircraft and ship activities may increase or decrease relative to the baseline, total fuel use 

would fluctuate depending on the year under the Proposed Action. Therefore, total fuel consumption 

would fluctuate depending on the year under the Proposed Action (Section 6.4, Energy Requirements 

and Conservation Potential of Alternatives and Efficiency Initiatives), and this nonrenewable resource 

would be considered irretrievably lost (see Chapter 4, Cumulative Impacts, and the following discussion 

on the Navy’s Climate Change Roadmap).
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6.4 ENERGY REQUIREMENTS AND EFFICIENCY INITIATIVES

The DoD consumed approximately 1.3 percent of the total U.S. oil and petroleum consumption in Fiscal 

Year 2013. It is the largest single user in the nation (Burke, 2014). The Navy consumes approximately 26 

percent of the total DoD share (U.S. Department of Defense, 2016). In Fiscal Year 2013, the Navy 

consumed almost 90 million barrels of liquid fuel (Burke, 2014). In 2016 the DoD published a new 

Operational Energy Strategy to update the 2011 strategy and transform the way energy is consumed in 

military operations; the strategy sets the overall direction for operational energy security (U.S. 

Department of Defense, 2016). The 2016 strategy shifts focus towards three objectives: 1) increasing 

future warfighting capability by including energy throughout future force development; 2) identifying 

and reducing logistic and operational risks from operational energy vulnerabilities; 3) and enhancing the 

force’s mission effectiveness with updated equipment and improvements in training, exercises and 

operations (U.S. Department of Defense, 2016). 

Pursuant to the operational strategy report in 2011, the DoD published an implementation plan to 

integrate operational energy considerations and transformation into existing programs, processes, and 

institutions (U.S. Department of Defense, 2012). These documents will provide guidance to the DoD in 

how to better use energy resources and transform the way we power current and future forces.

Training and testing activities within the Study Area would result in an increase in energy demand over 

the No Action Alternative. The increased energy demand would arise from an increase in fuel 

consumption, mainly from aircraft and vessels participating in training and testing. Aircraft fuel 

consumption is estimated to remain fairly consistent across both Action Alternatives. Vessel fuel 

consumption is estimated to increase by approximately 35 percent per year under Alternative 2, 

compared to Alternative 1. Conservative assumptions were made in developing the estimates, and 

therefore the actual amount of fuel consumed during training and testing events may be less than 

estimated. The alternatives could result in a net cumulative reduction in the global energy (fuel) supply. 

Energy requirements would be subject to any established energy efficiency practices. The use of energy 

sources has been minimized wherever possible without compromising safety, training, or testing 

activities. No additional efficiency measures related to direct energy consumption by the proposed 

activities are identified. The Navy’s energy vision given in the Operational Energy Strategy report (U.S. 

Department of Defense, 2016) is consistent with energy conservation practices and states that the Navy 

values energy as a strategic resource, understands how energy security is fundamental to executing our 

mission afloat and ashore, and is resilient to any potential energy future.

The Navy is committed to improving energy security and environmental stewardship by reducing its 

reliance on fossil fuels. The Navy is actively developing and participating in energy, environmental, and 

climate change initiatives that will help conserve the world’s resources for future generations. The Navy 

Climate Change Roadmap identifies actions the Navy is taking to implement Executive Order 13653, 

Preparing the United States for the Impacts of Climate Change. 

Two Navy programs—the Operational Energy Program and the Naval Sea Systems Command’s Fleet 

Readiness, Research and Development Program—are helping the fleet better manage fuel via improved 

operating procedures and long-term initiatives. The Operational Energy Program encourages the 

operation of ships in the most efficient manner while conducting their mission and supporting the 

Navy's efforts to treat energy as a combat enabler. The Naval Sea Systems Command’s Fleet Readiness, 

Research, and Development Program includes the High-Efficiency Heating, Ventilating, and Air 

Conditioning and the Hybrid Electric Drive for DDG-51 class ships, which are improvements to existing 
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shipboard technologies that will both help with fleet readiness and decrease the ships’ energy 

consumption and greenhouse gas emissions. These initiatives are expected to greatly reduce the 

consumption of fossil fuels (Section 3.1, Air Quality). Furthermore, to offset the impact of its expected 

near-term increased fuel demands and achieve its goals to reduce fossil fuel consumption and 

greenhouse gas emissions, the Navy has launched the first vessels of its “Great Green Fleet in San Diego”

(Olson, 2016). The Great Green Fleet was a year-long, Department of the Navy initiative that 

demonstrated the sea service’s efforts to transform its energy use (U.S. Department of the Navy, 2016). 

The Great Green Fleet’s centerpiece was a Carrier Strike Group that deployed on alternative fuels 

including nuclear power for the carrier, and a blend of advanced biofuel made from beef fat and 

traditional petroleum for its escort ships (U.S. Department of the Navy, 2016). Throughout 2016, other 

platforms included ships, aircraft, amphibious and expeditionary forces, and shore installations from the 

Department of the Navy participated in the Great Green Fleet by using energy efficient systems, 

operational procedures, and/or alternative fuel during the course of planned mission functions 

throughout the world (U.S. Department of the Navy, 2016).
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6.0 References

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Orders. St. Marys, GA: U.S. Department of the Interior, National Park Service. Retrieved from 

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from https://www.nps.gov/boha/learn/management/lawsandpolicies.htm.

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Designations, Closures, Permit Requirements and Other Restrictions Imposed Under 

Discretionary Authority. Washington, DC: U.S. Department of the Interior, National Park Service. 

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Designations, Closures, Permit Requirements and Other Restrictions Imposed Under 

Discretionary Authority. Washington, DC: U.S. Department of the Interior, National Park Service. 

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Designations, Closures, Permit Requirements and Other Restrictions Imposed Under 

Discretionary Authority. Washington, DC: U.S. Department of the Interior, National Park Service. 

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National Park Service. (2016d). Padre Island National Seashore, Superintendent's Compendium of 

Designations, Closures, Permit Requirements and Other Restrictions Imposed Under 

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Washington, DC: U.S. Department of the Interior, National Park Service.

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Condition Report 2008. Silver Spring, MD: U.S. Department of Commerce, National Oceanic and 

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Office of National Marine Sanctuaries. (2012). Flower Garden Banks National Marine Sanctuary Final 

Management Plan. Silver Spring, MD: U.S. Department of Commerce, National Oceanic and 

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Plan and Environmental Assessment. Silver Spring, MD: U.S. Department of Commerce, National 

Oceanic and Atmospheric Administration, Office of National Marine Sanctuaries.

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DC: Refuge Management. Retrieved from http://www.fws.gov/policy/603fw1.html.
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an/STEER_Management_Plan_Final_low.pd.

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752-10 et seq., Retrieved from http://www.mrc.state.va.us/regulations/FR752.shtm.

Virginia State Parks. (2017). Kiptopeke State Park Trail Guide. Cape Charles, VA: Virginia Department of

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Table of Contents

Final 

Environmental Impact Statement/Overseas Environmental Impact Statement 

Atlantic Fleet Training and Testing

TABLE OF CONTENTS

7 LIST OF PREPARERS _____________________________________________________________7-1

List of Figures 

This section does not contain figures.

List of Tables

This section does not contain tables.
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7 LIST OF PREPARERS

The Atlantic Fleet Training and Testing Environmental Impact Statement (EIS)/Overseas Environmental 

Impact Statement (OEIS) was prepared collaboratively between the Navy and contractor staff.

U.S. Department of the Navy

Sarah Bowman (Naval Facilities Engineering Command Atlantic), Environmental Planner 

M.E.M., Coastal Environmental Management

B.S., Biology

Years of Experience: 15

Jocelyn Borcuk (Naval Undersea Warfare Center, Division Newport), Biologist/Environmental Planner

B.S., Marine Biology

Years of Experience: 8

Victoria Bowman (Space and Naval Warfare Systems Command ), Environmental Scientist 

B.A., Psychology

Years of Experience: 7

Laura Busch (United States Fleet Forces Command), Natural and Cultural Resources Program Manager

M.Ag., Rangeland Ecology and Management

M.S., Beef Cattle Science

B.S., Agriculture Economics

Years of Experience: 16

Benjamin Colbert (Naval Sea Systems Command), Environmental Protection Specialist, Environmental 

Planning Branch

B.S., Organizational Leadership

Years of Experience: 9

Lesley Dobbins-Noble (Naval Facilities Engineering Command Atlantic), NEPA Operations and Range 

Sustainment Branch Head 

M.S., Biology

B.S., Biology

Years of Experience: 19

Amy Farak (United States Fleet Forces Command), Natural Resources Specialist 

B.S., Marine Biology

Years of Experience: 17

Nora Gluch (Naval Sea Systems Command), Environmental Management and Policy Division Director

M.E.M., Coastal Environmental Management

B.A., Sociology

Years of Experience: 12

Jaime Gormley (Naval Facilities Engineering Command Atlantic), Marine Resources Specialist 

M.E.M., Coastal Environmental Management

B.A., Marine Biology

Years of Experience: 8
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7.0 List of Preparers

Elizabeth Henderson (Space and Naval Warfare Systems Command), Bioacoustic Scientist 

Ph.D., Biological Oceanography

M.S., Wildlife and Fisheries Sciences

B.A., Psychobiology 

Years of Experience: 20

Peter Hulton (Naval Undersea Warfare Center, Division Newport), Technical Project Manager, Marine 

Species Modeling Team

B.S., Mechanical Engineering 

Years of Experience: 34

Keith Jenkins (Space and Naval Warfare Systems Command), Marine Resources Specialist

M.S., Fisheries Oceanography

B.S., Marine Biology 

Years of Experience: 17

Sarah Kotecki (Space and Naval Warfare Systems Command), Engineer

B.S., Civil and Environmental Engineering 

Years of Experience: 17

Todd Kraft (United States Fleet Forces Command), Environmental Planner

LLM, International Environmental Law 

J.D., Law

B.A., Public Justice and Sociology 

Years of Experience: 14

Tara Moll (Naval Undersea Warfare Center, Division Newport), Marine Biologist 

M.S., Biological Sciences

B.S., Marine Biology 

Years of Experience: 12

Jene Nissen (United States Fleet Forces Command), Acoustics Policy Manager

M.S., Applied Engineering

B.S., Electrical Engineering 

Years of Experience: 33

Nicholas Paraskevas (Naval Air Systems Command), Deputy, Environmental and Energy Programs

B.S., Aerospace and Ocean Engineering 

Years of Experience: 42

Jennifer Paulk (Naval Air Systems Command), Environmental Scientist

M.S., Physiology

B.S., Psychology 

Years of Experience: 21

Kelly Proctor (Naval Facilities Engineering Command Atlantic), Environmental Planner

M.S., Biology

B.S., Biology

Years of Experience: 12
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Training and Testing Final EIS/OEIS September 2018

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7.0 List of Preparers

Raymond Soukup (Office of Naval Research), Physicist

M.A., Mathematical Statistics

B.S., Physics

Years of Experience: 29

Greg Thompson (United States Fleet Forces Command), Environmental Planner 

M.S., Environmental Science 

B.S., Forestry and Wildlife Science

M.B.A.

Years of experience: 24

Contractors

Danny Heilprin (ManTech International), Senior Marine Biologist

M.S., Marine Sciences

B.A., Aquatic Biology

Years of Experience: 31

Taylor Houston (ManTech International), Natural Resource Specialist

B.S., Natural Resource Management

Years of Experience: 17

Cynthia M. LeDoux-Bloom (ManTech International), Senior Marine Biologist

Ph.D., Animal Biology (fish behavior)

M.S., Natural Science (marine fishes)

B.S., Biology (marine emphasis)

Years of experience: 24

Karyn Palma (ManTech International), Technical Editor 

B.A., Environmental Studies

Years of Experience: 22

Heather Turner (ManTech International), Marine Biologist

M.A.S., Marine Biodiversity and Conservation 

B.S., Environmental Science 

Years of Experience: 9

Karen Waller (ManTech International), Senior Environmental Scientist

B.S., Public Affairs 

Years of Experience: 27

Brian D. Wauer (ManTech International), Project Manager

B.S., Administrative Management 

B.S., Industrial Management 

Years of Experience: 32

Lawrence Wolski (ManTech International), Marine Scientist 

M.S., Marine Sciences 

B.S., Biology 

Years of Experience: 19
Atlantic Fleet

Training and Testing Final EIS/OEIS September 2018

7-4

7.0 List of Preparers

Mike Zickel (ManTech International), Senior Environmental Scientist

M.S., Marine Estuarine Environmental Sciences

B.S., Physics 

Years of Experience: 19

Brad Boykin (Leidos, Inc.), Environmental Scientist

M.S., Biotechnology 

B.S., Biomedical Science 

Years of Experience: 13

Janet Clarke, (Leidos, Inc.), Research Biologist

M.A., Anthropology 

B.S., Wildlife Management 

Years of Experience: 34

Ronald Combs (Leidos, Inc.), Senior Environmental Scientist

M.S., Biology 

B.S., Biology 

B.S., Business Administration 

Years of Experience: 16

Luis Diaz, (Leidos, Inc.), Environmental Engineer

M.E., Environmental Engineering

B.S., Aerospace Engineering 

Years of Experience: 21

Vicky Frank (Leidos, Inc.), Senior Environmental Scientist

B.A., General Biology/Cell Biology 

Years of Experience: 29

Karen Green (Leidos, Inc.), Senior Environmental Scientist

M.S., Biology 

B.S., Marine Biology 

Years of Experience: 32

Meike Holst (LGL Limited, Environmental Research Associates), Marine Ecologist

M.Sc., Environmental Biology and Ecology 

B.Sc., Zoology 

Years of Experience: 16

Jamie McKee (Leidos, Inc.), Senior Project Manager

B.S., Marine Biology 

Years of Experience: 33

Mike Nation (Leidos, Inc.), GIS Data Analyst

B.S., Environmental Science/Policy 

Years of Experience: 16
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7.0 List of Preparers

Tara Utsey (Leidos), Senior Publication Specialist

B.A., Liberal Arts 

Years of Experience: 25

Jennifer Combs (Leidos), Senior Copyeditor

B.S., Communications, Journalism

Years of Experience: 29

Carl Nielsen (ESS Group, Inc.), Principal Benthic Ecologist

M.S., Fisheries and Wildlife

B.A., Biology 

Years of Experience: 26

Amanda Robydek (Leidos, Inc.), Marine Scientist

B.S., Environmental Science 

Years of Experience: 9

Bernice Tannenbaum (Leidos, Inc.), Senior Environmental Scientist

Ph.D., Animal Behavior

B.S., Zoology

Years of Experience: 36

Carmen Ward (Leidos, Inc.), Program Manager

M.S., Environmental Engineering

B.S., Chemical Engineering

Years of Experience: 27

Stephanie Wilson (ESS Group, Inc.), Senior Marine Biologist

M.S., Marine Biology (Fisheries) 

B.S., Marine and Freshwater Biology, Statistics Minor 

Years of Experience: 20

Lewis Albee (Cardno), Program Manager

M.S., Limnology

B.A., Biology

Years of Experience: 27

Stephen Anderson (Cardno), Environmental Scientist

B.A., Environmental Science 

Years of Experience: 8

Blake Claypool (Cardno), Environmental Scientist

B.S., Biology 

Years of Experience: 18

Michael Dungan, (Cardno), Senior Ecologist

Ph.D., Ecology and Evolutionary Biology 

B.A., Zoology 

Years of Experience: 36
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7.0 List of Preparers

Lesley Hamilton (Cardno), Senior Air Quality Specialist

B.A., Chemistry 

Years of Experience: 29

Michael Harrison (Cardno), Environmental Scientist

M.S., Environmental Science 

B.S., Biology

Years of Experience: 13

SunTemple Helgren (Cardno), Senior Project Manager

B.S., Geography, Environmental Studies Concentration 

Years of Experience: 22

John Lowenthal (Cardno), Biologist

M.S., Plant Ecology 

B.S., Biology 

Years of Experience: 31

Kevin Martin (Cardno), Senior Environmental Planner

M.P., Urban and Environmental Planning

B.A., Economics

Years of Experience: 23

Christopher Noddings (Cardno), Biologist

M.S., Environmental Science and Management

B.A., Environmental Systems

Years of Experience: 13

Amy Paulson (Cardno), Environmental Planner

M.S., Conservation and Sustainable Development

B.S., Biology 

Years of Experience: 21

Clint Scheuerman (Cardno), Environmental Scientist

M.A., Biological Sciences 

B.S., Biological Sciences 

Years of Experience: 14

Sharon Simpson (Cardno), Project Coordinator

A.S., Science

Years of Experience: 14

Robert Wardwell (Cardno), Quality Control Manager

M.S., Environmental Science

M.B.A., Transportation/Logistics

B.A., Economics

Years of Experience: 41

Kimberly Wilson (Cardno), Document Production Manager

Years of Experience: 31
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7.0 List of Preparers

Sarah Rider (G2 Software Systems), Marine Resources Specialist

M.E.M., Coastal Environmental Management

B.S., Marine Science

Years of Experience: 11

Cameron Martin (National Marine Mammal Foundation), Environmental Scientist 

B.S., Environmental Science 

Years of Experience: 4

Michelle Tishler (National Marine Mammal Foundation), Marine Resources Specialist

M.S., Marine Biology

B.S., Wildlife Ecology and Conservation, Fisheries and Aquatic Sciences Minor

Years of Experience: 9

Ashley Kelly (SAIC), Natural Resources Support

M.Phil., Human Ecology, Marine Mammal Ecology and Behavior

B.S., Marine Biology

Years of Experience: 6
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7.0 List of Preparers

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Table of Contents

Final 

Environmental Impact Statement/Overseas Environmental Impact Statement 

Atlantic Fleet Training and Testing

TABLE OF CONTENTS

8 PUBLIC INVOLVEMENT AND DISTRIBUTION __________________________________________8-1

8.1 Project Website .........................................................................................................8-1

8.2 Scoping Period...........................................................................................................8-1

8.2.1 Public Scoping Notification ....................................................................................8-1

8.2.1.1 Notification Letters................................................................................8-1

8.2.1.2 Postcard Mailers....................................................................................8-7

8.2.1.3 Newspaper Advertisements ................................................................8-14

8.2.2 Project Video........................................................................................................8-15

8.2.3 Public Scoping Comments....................................................................................8-15

8.2.3.1 A True No Action Alternative Analysis.................................................8-16

8.2.3.2 Time-Area Management and Mitigation Areas...................................8-16

8.2.3.3 Cumulative Impact Analysis.................................................................8-16

8.2.3.4 Range of Alternatives...........................................................................8-16

8.2.3.5 Impacts of Training and Testing to Marine Mammals.........................8-16

8.2.3.6 Impacts of Training and Testing to Marine Life...................................8-17

8.3 Notification of Availability of Draft Environmental Impact Statement/Overseas 

Environmental Impact Statement.............................................................................8-17

8.3.1 Notification of Draft Environmental Impact Statement/Overseas Environmental 

Impact Statement and Public Meetings...............................................................8-17

8.3.1.1 Notification Letters..............................................................................8-18

8.3.1.2 Subscribers Email.................................................................................8-35

8.3.1.3 Public Involvement Website................................................................8-35

8.3.1.4 Postcard Mailers..................................................................................8-37

8.3.1.5 Press Releases......................................................................................8-37

8.3.1.6 Newspaper Advertisements ................................................................8-37

8.3.2 Public Meetings....................................................................................................8-44

8.4 Distribution of the Draft and Final Environmental Impact Statement/Overseas 

Environmental Impact Statement.............................................................................8-44

8.4.1 Federal Agencies..................................................................................................8-44

8.4.2 State Elected Officials ..........................................................................................8-45

8.4.3 Repositories .........................................................................................................8-46

8.4.4 Federally-Recognized Tribes................................................................................8-49
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Table of Contents

8.5 Comments on the Draft EIS/OEIS..............................................................................8-53

8.6 Notification of National Marine Fisheries Service Proposed Rule...............................8-53

List of Figures 

Figure 8.2-1: Stakeholder Scoping Notification Letter...............................................................................8-8

Figure 8.2-2: Postcard Mailer for Scoping (front)....................................................................................8-12

Figure 8.2-3: Postcard Mailer for Scoping (back).....................................................................................8-13

Figure 8.2-4: Newspaper Announcement of Scoping ..............................................................................8-15

Figure 8.3-1: Stakeholder Letter for the Notification of the Draft Environmental Impact 

Statement/Overseas Environmental Impact Statement ....................................................8-30

Figure 8.3-2: Project Website Subscribers Email for the Notification of the Draft 

Environmental Impact Statement/Overseas Environmental Impact Statement................8-36

Figure 8.3-3: Postcard for the Notification of Availability of the Draft Environmental Impact 

Statement/ Overseas Environmental Impact Statement and Announcement of 

Public Meetings (front).......................................................................................................8-38

Figure 8.3-4: Postcard for the Notification of Availability of the Draft Environmental Impact 

Statement/ Overseas Environmental Impact Statement and Announcement of 

Public Meetings (back)........................................................................................................8-39

Figure 8.3-5: Press Release of Notification of Availability of the Draft Environmental Impact 

Statement/ Overseas Environmental Impact Statement and Announcement of 

Public Meetings ..................................................................................................................8-40

Figure 8.3-6: Newspaper Announcement of Notification of Availability of the Draft 

Environmental Impact Statement/Overseas Environmental Impact Statement 

and Announcement of Public Meetings.............................................................................8-43

List of Tables

Table 8.2-1: Entities that Received the Scoping Notification Letter..........................................................8-1

Table 8.2-2: Newspaper Announcements of Scoping Period ..................................................................8-14

Table 8.3-1: Entities that Received the Draft Environmental Impact Statement/Overseas 

Environmental Impact Notification Letter..........................................................................8-18

Table 8.3-2: Newspaper Announcements of Notification of Availability of the Draft 

Environmental Impact Statement/Overseas Environmental Impact Statement 

and Announcement of Public Meetings.............................................................................8-42

Table 8.4-1: Federal Agencies that Received the Draft and Final Environmental Impact 

Statement/ Overseas Environmental Impact Statement ...................................................8-44

Table 8.4-2: State Governors that Received the Draft and Final Environmental Impact 

Statement/Overseas Environmental Impact Statement ....................................................8-45

Table 8.4-3: Repositories that Received the Draft and Final Environmental Impact 

Statement/ Overseas Environmental Impact Statement ...................................................8-46
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Table 8.4-4: Federally-Recognized Tribes that Received the Draft and Final Environmental 

Impact Statement/Overseas Environmental Impact Statement ........................................8-49
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8.0 Public Involvement and Distribution

8 PUBLIC INVOLVEMENT AND DISTRIBUTION

This chapter describes the efforts to involve the public in preparing the Atlantic Fleet Training and 

Testing (AFTT) Environmental Impact Statement (EIS)/Overseas Environmental Impact Statement (OEIS), 

including distribution of the Draft EIS/OEIS.

8.1 PROJECT WEBSITE

A public website was established for this project: www.AFTTEIS.com. This website address was 

published in the Notice of Intent to Prepare an Environmental Impact Statement/Overseas 

Environmental Impact Statement (Appendix G, Federal Register Notices). It was subsequently reprinted 

in newspaper advertisements, agency letters, a subscribers email release, and postcards for the Notice 

of Intent. The scoping meeting fact sheets, public meeting fact sheets, technical reports, and various 

other materials are available on the project website and will be made available throughout the course of 

the project.

8.2 SCOPING PERIOD

The public scoping period began with issuance of the Notice of Intent in the Federal Register on 

November 12, 2015 (see Appendix G, Federal Register Notices). This notice included a project 

description, website address, and instructions on how to provide comments. A corrected Notice of 

Intent was issued on December 1, 2015 correcting an error in the comment deadline date and telephone 

number. The scoping period lasted 60 days, concluding on January 12, 2016. The public was provided a 

variety of methods to comment on the scope of the EIS/OEIS during the scoping period.

8.2.1 PUBLIC SCOPING NOTIFICATION

The U.S. Department of the Navy (Navy) made significant efforts to notify the public to ensure maximum 

public participation during the scoping process. A summary of these efforts follows.

8.2.1.1 Notification Letters

Notice of Intent and Scoping Notification letters were distributed at the beginning of the scoping period 

(November 12, 2015) to federally-recognized tribes; state elected officials; and federal, regional, and 

state agencies. Entities that received the Scoping Notification letter can be found in Table 8.2-1 and an 

example of the letter can be found in .

Table 8.2-1: Entities that Received the Scoping Notification Letter

Federally-Recognized Tribes

Alabama-Coushatta Tribes of Texas 

Aroostook Band of Micmac Indians of Maine 

Catawba Indian Nation 

Cayuga Nation of New York 

Chitimacha Tribe of Louisiana 

Coushatta Tribe of Louisiana 

Eastern Band of Cherokee Indians of North Carolina 

Jena Band of Choctaw Indians 

Kickapoo Traditional Tribe of Texas 

Mashantucket Pequot Tribe of Connecticut 

Mashpee Wampanoag Tribe, Massachusetts 

Miccosukee Tribe of Indians of Florida 

Mississippi Band of Choctaw Indians, Mississippi 

Mohegan Indian Tribe of Connecticut 

Narragansett Indian Tribe of Rhode Island 

Oneida Nation of New York 

Onondaga Nation of New York 

Passamaquoddy Tribe – Indian Township Reservation 

Penobscot Tribe of Maine 

Poarch Band of Creek Indians of Alabama 

Saint Regis Mohawk Tribe, New York 

Seminole Tribe of Florida 

Seneca Nation of New York 

Tonawanda Band of Seneca Indians of New York 

Tunica-Biloxi Indian Tribe of Louisiana 

Tuscarora Nation of New York 

Wampanoag Tribe of Gay Head of Massachusetts 

Ysleta del Sur Pueblo of Texas 
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Table 8.2-1: Entities that Received the Scoping Notification Letter (continued)

Alabama

State Elected Officials State Agencies Local

Office of the Governor 

Congressional Delegates 

Alabama Department of Agriculture and 

Industries 

Alabama Department of Conservation 

and Natural Resources 

Alabama Department of Economic and 

Community Affairs 

Alabama Department of Environmental 

Management 

Alabama Development Office 

Alabama Historical Commission

Baldwin County

City of Mobile

County of Mobile

Bay County

Brevard County

Connecticut

State Elected Officials State Agencies Local

Office of the Governor 

Congressional Delegates 

Connecticut Council on Environmental 

Quality 

Connecticut Department of Economic and 

Community Development 

Connecticut Department of Energy and 

Environmental Protection 

Connecticut Department of Public Health

City of New London

Town of Groton

Delaware

State Elected Officials State Agencies Local

Office of the Governor 

Congressional Delegates 

Delaware Division of Historical and 

Cultural Affairs 

Delaware Economic Development Office 

Delaware Heritage Commission 

Delaware River Basin Commission 

Delaware Office of Management and 

Budget: Budget Development, Planning, 

and Administration 

Department of Natural Resources and 

Environmental Control

Florida

State Elected Officials State Agencies Local

Office of the Governor 

Congressional Delegates 

Florida Department of Environmental 

Protection 

Florida Fish and Wildlife Conservation 

Commission 

Florida Fish and Wildlife Conservation 

Commission: Office of Environmental 

Services 

Florida State Clearinghouse

Bay County

Brevard County

Cape Canaveral Port Authority

City of Atlantic Beach

City of Cape Canaveral

City of Dania Beach

City of Jacksonville

City of Key West

City of Milton

City of Pensacola

County of Escambia

Jacksonville Port Authority

Monroe County

Panama City

Panama City Beach

Panama City Port Authority

Port Canaveral

Santa Rosa County
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8.0 Public Involvement and Distribution

Table 8.2-1: Entities that Received the Scoping Notification Letter (continued)

Georgia

State Elected Officials State Agencies Local

Office of the Governor 

Congressional Delegates 

Georgia Department of Economic 

Development 

Georgia Department of Natural Resources 

Georgia Environmental Facilities 

Authority 

Georgia Forestry Commission 

Georgia State Clearinghouse

City of Kingsland

City of St. Mary's

City of Woodbine

County of Camden

Louisiana

State Elected Officials State Agencies Local

Office of the Governor 

Congressional Delegates 

Louisiana Department of Culture, 

Recreation, and Tourism 

Louisiana Department of Economic 

Development 

Louisiana Department of Environmental 

Quality 

Louisiana Department of Natural 

Resources 

Louisiana State Military Department

City of New Orleans

Maine

State Elected Officials State Agencies Local

Office of the Governor 

Congressional Delegates 

Historic Preservation Commission 

Maine Department of Conservation 

Maine Department of Environmental 

Protection 

Maine Department of Inland Fisheries 

and Wildlife

Maine State Planning Office

City of Bath

City of Portland

Cumberland County

Town of Kittery

Maryland

State Elected Officials State Agencies Local

Office of the Governor 

Congressional Delegates 

Maryland Department of Environment 

Maryland Department of Natural 

Resources 

Maryland Department of Agriculture 

Maryland Department of Business and 

Economic Development 

Maryland Economic Development 

Corporation 

Maryland State Clearinghouse for 

Intergovernmental Assistance

Town of Ocean City

Somerset County

Wicomico County

Worcester County
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8.0 Public Involvement and Distribution

Table 8.2-1: Entities that Received the Scoping Notification Letter (continued)

Massachusetts

State Elected Officials State Agencies Local

Office of the Governor 

Congressional Delegates 

Cape Cod Commission 

Central Massachusetts Regional Planning 

Commission 

Franklin Regional Council of Governments 

Massachusetts Department of 

Conservation and Recreation 

Massachusetts Department of 

Environmental Protection 

Massachusetts Department of Public 

Health 

Massachusetts Executive Office of Health 

and Human Services 

Massachusetts Port Authority 

Massachusetts Regional Planning 

Commission 

Massachusetts Water Resources 

Authority 

Merrimack Valley Planning Commission

City of Boston

Town of Barnstable

Mississippi

State Elected Officials State Agencies Local

Office of the Governor 

Congressional Delegates 

Mississippi Department of Environmental 

Quality 

Mississippi Department of Finance and 

Administration 

Mississippi Department of Marine 

Resources, Coastal Management and 

Planning 

Mississippi Soil and Water Conservation 

Commission 

Mississippi State Port Authority

City of Meridian

City of Moss Point

City of Pascagoula

Harrison County

Jackson County

Port of Pascagoula

New Hampshire

State Elected Officials State Agencies Local

Office of the Governor 

Congressional Delegates 

New Hampshire Department of Cultural 

Resources 

New Hampshire Department of 

Environmental Services 

New Hampshire Department of 

Resources and Economic Development 

New Hampshire Department of Safety 

New Hampshire Division of Forests and 

Lands 

New Hampshire Fish and Game 

Department 

New Hampshire Office of Energy and 

Planning 

State of New Hampshire Economic 

Development

City of Portsmouth

Rockingham County
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8.0 Public Involvement and Distribution

Table 8.2-1: Entities that Received the Scoping Notification Letter (continued)

New Jersey

State Elected Officials State Agencies Local

Office of the Governor 

Congressional Delegates 

Garden State Preservation Trust 

New Jersey Department of Agriculture 

New Jersey Department of Environmental 

Protection 

New Jersey Department of Environmental 

Protection: Office of Permit Coordination 

and Environmental Review 

New Jersey Economic Development 

Authority 

New Jersey Historic Trust

Atlantic County

Ocean County

New York

State Elected Officials State Agencies Local

Office of the Governor 

Congressional Delegates 

New York State Department of 

Environmental Conservation 

Long Island, Nassau County

Long Island, Suffolk County

North Carolina

State Elected Officials State Agencies Local

Office of the Governor 

Congressional Delegates 

North Carolina Department of 

Administration 

North Carolina Department of 

Administration: State Environmental 

Review Clearinghouse 

North Carolina Department of Cultural 

Resources 

North Carolina Department of 

Environment and Natural Resources 

North Carolina Division of Parks and 

Recreation 

North Carolina Division of Water Quality 

North Carolina Economic Developers 

Association 

North Carolina State Ports Authority 

North Carolina Wildlife Resources 

Commission 

North Carolina's Southeast Economic 

Development Organization

City of Havelock

City of Jacksonville

City of Wilmington

County of Carteret

County of Craven

County of Jones

County of Pamlico

County Of Pender

Morehead City

Onslow County

Town of Nags Head

Rhode Island

State Elected Officials State Agencies Local

Office of the Governor 

Congressional Delegates 

Rhode Island Coastal Resources 

Management Council 

Rhode Island Department of 

Administration 

Rhode Island Department of 

Environmental Management 

Rhode Island Department of Health 

Rhode Island Division of Planning

City of Newport
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8.0 Public Involvement and Distribution

Table 8.2-1: Entities that Received the Scoping Notification Letter (continued)

South Carolina

State Elected Officials State Agencies Local

Office of the Governor 

Congressional Delegates 

Department of Natural Resources 

Office of State Budget 

South Carolina Department of Agriculture 

South Carolina Department of Health and 

Environmental Control 

South Carolina Department of Parks, 

Recreation, and Tourism 

South Carolina Sea Grant Consortium

City of Charleston

Texas

State Elected Officials State Agencies Local

Office of the Governor 

Congressional Delegates 

Texas Bureau of Economic Geology 

Texas Commission on Environmental 

Quality 

Texas General Land Office 

Texas Parks and Wildlife Department 

Texas State Grants Team

City of Corpus Christi

County of Kleberg

County of Nueces

County of San Patricio

Virginia

State Elected Officials State Agencies Local

Office of the Governor 

Congressional Delegates 

Chesapeake Bay Commission 

Virginia Department of Conservation and 

Recreation 

Virginia Department of Environmental 

Quality 

Virginia Department of Forestry 

Virginia Department of Game and Inland 

Fisheries 

Virginia Department of Historic Resources 

Virginia Department of Natural Resources 

Virginia Department of Planning and 

Budget

Virginia Department of Transportation 

Virginia Marine Resources Commission 

Virginia Port Authority 

Virginia Resources Authority

City of Newport News

City of Norfolk

City of Portsmouth

City of Virginia Beach

County of Accomack

Town of Chincoteague
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8.0 Public Involvement and Distribution

Table 8.2-1: Entities that Received the Scoping Notification Letter (continued)

Regional

Federal Agencies

Federal Aviation Administration, Eastern Region 

Federal Aviation Administration, Southern Region 

Federal Aviation Administration, Southwest Region 

Fishery Management Council, Caribbean 

Fishery Management Council, Gulf of Mexico 

Fishery Management Council, Mid-Atlantic 

Fishery Management Council, New England 

Fishery Management Council, South Atlantic 

Gulf State Marine Fisheries Commission 

National Marine Fisheries Service, West Palm Beach Field Office 

U.S. Army Corps of Engineers, Baltimore District 

U.S. Army Corps of Engineers, Galveston District 

U.S. Army Corps of Engineers, Jacksonville District 

U.S. Army Corps of Engineers, Jacksonville District, West Palm Beach Office 

U.S. Army Corps of Engineers, Mobile District 

U.S. Army Corps of Engineers, New England District 

U.S. Army Corps of Engineers, New Orleans District 

U.S. Army Corps of Engineers, New York District 

U.S. Army Corps of Engineers, Norfolk District 

U.S. Army Corps of Engineers, Philadelphia District 

U.S. Army Corps of Engineers, Wilmington District 

U.S. Coast Guard, District 1 

U.S. Coast Guard, District 5 

U.S. Coast Guard, District 7 

U.S. Coast Guard, District 8 

U.S. Coast Guard, District 9 

8.2.1.2 Postcard Mailers

On November 12, 2015, postcards were mailed to 647 recipients on the project mailing list, including 

individuals, nonprofit organizations, and for-profit organizations. The postcards provided information on 

the Proposed Action, methods for commenting, and the project website address to obtain more 

information. An example of the postcard is shown in Figure 8.2-2 and Figure 8.2-3
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8.0 Public Involvement and Distribution

Figure 8.2-1: Stakeholder Scoping Notification Letter
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8.0 Public Involvement and Distribution

Figure 8.2-1: Stakeholder Scoping Notification Letter (continued)
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8-10

8.0 Public Involvement and Distribution

Figure 8.2-1: Stakeholder Scoping Notification Letter (continued)
Atlantic Fleet

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8-11

8.0 Public Involvement and Distribution

Figure 8.2-1: Stakeholder Scoping Notification Letter (continued)
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8-12

8.0 Public Involvement and Distribution

Figure 8.2-2: Postcard Mailer for Scoping (front)
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8.0 Public Involvement and Distribution

Figure 8.2-3: Postcard Mailer for Scoping (back)
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8.0 Public Involvement and Distribution

8.2.1.3 Newspaper Advertisements

To announce the scoping period, advertisements were placed in the listed newspapers in the following 

cities on the dates indicated in Table 8.2-2. The advertisements included a description of the Proposed 

Action, the address of the project website, the duration of the comment period, and information on 

how to provide comments. An example of the advertisement is shown in Figure 8.2-4.

Table 8.2-2: Newspaper Announcements of Scoping Period

Portland, ME 

The Portland Press Herald 

November 13, 2015

November 14, 2015

November 15, 2015

Cumberland and Sagadahoc 

Counties, ME

The Times Record

November 13, 2015

November 16, 2015

November 17, 2015

New Bedford, MA

The Standard Times

November 13, 2015

November 14, 2015

November 15, 2015

Boston, MA 

The Boston Herald 

November 13, 2015

November 14, 2015

November 15, 2015

Providence, RI 

The Providence Journal

November 13, 2015

November 14, 2015

November 15, 2015

Newport, RI

The Newport Daily News

November 13, 2015

November 14-15, 2015

November 16, 2015

Salisbury, MD

The Daily Times

November 13, 2015

November 14, 2015

November 15, 2015

Norfolk, VA

The Virginia Pilot 

November 13, 2015

November 14, 2015

November 15, 2015

Newport News, VA

The Daily Press

November 13, 2015

November 14, 2015

November 15, 2015

Nags Head, NC

Outer Banks Sentinel 

November 13, 2015

Jacksonville, NC 

Jacksonville Daily News 

November 13, 2015

November 14, 2015

November 15, 2015

Wilmington, NC 

Wilmington Star News

November 13, 2015

November 14, 2015

November 15, 2015

Charleston, SC

Charleston Post and Courier

November 13, 2015

November 14, 2015

November 15, 2015

Savannah, GA 

Savannah Morning News 

November 13, 2015

November 14, 2015

November 15, 2015

Jacksonville, FL 

Florida Times Union

November 13, 2015

November 14, 2015

November 15, 2015

Fort Lauderdale, FL

Florida Sun Sentinel

November 13, 2015

November 14, 2015

November 15, 2015

Brevard, FL

Florida Today 

November 13, 2015

November 14, 2015

November 15, 2015

Panama City, Bay County, FL

The News Herald 

November 13, 2015

November 14, 2015

November 15, 2015

Pensacola, FL 

Pensacola News Journal

November 13, 2015

November 14, 2015

November 15, 2015

New Orleans, LA

Times-Picayune

November 13, 2015

November 15, 2015

November 18, 2015

Galveston, TX

Galveston Daily News 

November 13, 2015

November 14, 2015

November 15, 2015

Corpus Christi, TX 

Caller-Times

November 13, 2015

November 14, 2015

November 15, 2015

Pascagoula, MS 

The Mississippi Press

November 13, 2015

November 14, 2015

November 15, 2015
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Figure 8.2-4: Newspaper Announcement of Scoping

8.2.2 PROJECT VIDEO

A project video was developed to support the scoping phase and provide information to the public on 

the types of training and testing the Navy conducts and its importance. The project video was uploaded 

to the project website. Topics in the project video included:

 general project overview

 Navy’s mission

 importance of training and testing in the AFTT Study Area

 importance of training and testing with sonar and explosives

 existing marine mitigation measures

 environmental stewardship programs

8.2.3 PUBLIC SCOPING COMMENTS

The scoping comments could be submitted via the project website or by mail. The Navy received 

comments from federal agencies, state agencies, nongovernmental organizations, individuals and 

community groups. A total of 72 scoping comments were received and considered during preparation of 

the AFTT EIS/OEIS. The comments requested the Navy analyze environmental issues for physical and 

biological resources, such as sonar impacts on marine mammals, to human resources, such as public 

health and safety. A sampling of some of the specific concerns follows.
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8.2.3.1 A True No Action Alternative Analysis

Comments stated that the EIS/OEIS should have a true No Action Alternative in which Navy training and 

testing activities would cease to occur in the AFTT Study Area and include an analysis of these true No 

Action Alternative impacts on marine biota, air quality, water quality, socioeconomics, cultural 

resources, and human health and safety.

The AFTT EIS/OEIS analyzes a No Action Alternative where the Navy would not conduct the proposed 

training and testing activities in the AFTT Study Area. 

8.2.3.2 Time-Area Management and Mitigation Areas

Comments stated that the EIS/OEIS should have reasonable alternatives that incorporate mitigation 

measures such as time-area management, which would mitigate impacts of noise and other 

disturbances to marine mammals and sea turtles as activities would happen selectively to allow for 

areas to sometimes be closed for conservation. Areas of concern include areas identified by the National 

Marine Fisheries Service as important to marine species, including Cape Hatteras Special Research Area, 

Cul de Sac, Great Bahama Canyon, Mississippi Canyon, and Sperm Whale habitat west of the Florida 

Keys and Tortugas.

Chapter 5 (Mitigation), describes the mitigation measures that the Navy will implement to avoid or 

reduce potential impacts from the AFTT EIS/OEIS Proposed Action. 

8.2.3.3 Cumulative Impact Analysis

Comments expressed concern over cumulative impacts to marine biota in the AFTT Study Area and 

suggest that the Navy develop and implement a long-term monitoring program to assess potential 

cumulative impacts of AFTT activities on marine animals and their habitat.

All potential cumulative impacts on marine animals and their habitats are identified and addressed in 

Chapter 4 (Cumulative Impacts) of this EIS/OEIS. Chapter 5 (Mitigation) includes discussion of the Navy’s 

marine species monitoring programs.

8.2.3.4 Range of Alternatives

Comments expressed support for studying a wider range of alternatives and suggested the Navy develop 

alternatives that consider time and geographic restrictions, specifically during nesting and migration 

seasons.

The Navy analyzed two action Alternatives and a No Action Alternative which are detailed in Chapter 2 

(Description of Proposed Action and Alternatives). The practicability of time and geographic restrictions 

are discussed in Chapter 5 (Mitigation). 

8.2.3.5 Impacts of Training and Testing to Marine Mammals

Comments stated that impacts of training and testing on marine mammals are of great concern and 

need to be addressed in the EIS/OEIS. Ship strikes to fin whales and other species in the AFTT Study Area 

could be mitigated by a reduction in ship speed at times or in areas that have a high density of species 

present. The Navy Acoustic Effects Model is too general and should do more to reduce takes on local 

species. Impacts of dipping sonar should be more extensively studied and analyzed for marine 

mammals. Signal modification should be considered to reduce the takes of marine mammals. The 

Proposed Action should comply with the Marine Mammal Protection Act and the Endangered Species 

Act. Vessel noise should be added to acoustic impacts in the marine mammal analysis. Impacts from the 
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current and potential increase in use of Navy sonar on whales, especially endangered or threatened 

species such as the North Atlantic Right Whale, Bryde’s Whales, and Sperm Whale. Also, there were 

concerns expressed about the effect of sonar and explosives on marine mammals resulting in strandings 

and death.

The Navy does comply with the Marine Mammal Protection Act and the Endangered Species Act. All 

potential impacts to marine mammals from the Navy’s proposed training and testing activities are 

analyzed in the AFTT EIS/OEIS. Section 3.7 (Marine Mammals) details the potential impacts to marine 

mammals, including takes. Appendix E (Estimated Marine Mammals and Sea Turtle Impacts from 

Exposures to Acoustic and Explosive Stressors Under Navy Training and Testing Activities), provides the 

estimated number of marine mammal and sea turtle impacts resulting from the proposed activities. 

Specifically, estimated impacts are derived from the quantitative analysis for activities under 

Alternatives 1 and 2 that involve the use of acoustic or explosive stressors. The quantitative analysis 

takes into account Navy activities, marine species density layers, acoustic modeling and other 

environmental parameters.

8.2.3.6 Impacts of Training and Testing to Marine Life

Comments were critical of current Navy sonar and explosives testing and training and expressed concern 

over impacts to sea turtles, fish (Atlantic sturgeon), and birds. There was an overall concern about the 

impacts on marine habitat, ecosystems, and wildlife from training and testing activities as well as the

increased impacts on already sensitive marine and coastal species.

The impacts to marine life resulting from the proposed training and testing activities are detailed in the 

Chapter 3 resource sections. Chapter 4 (Cumulative Impacts), discusses the additional effects the 

Proposed Action may have on already sensitive species. 

8.3 NOTIFICATION OF AVAILABILITY OF DRAFT ENVIRONMENTAL IMPACT 

STATEMENT/OVERSEAS ENVIRONMENTAL IMPACT STATEMENT

The public comment period on the Draft AFTT 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 Federal 

Register notices included notification of the availability of the Draft EIS/OEIS and where it can be 

accessed; an overview of the Proposed Action and its purpose and need; public commenting 

information; and the locations, dates, and times of public meetings. The purpose of the public meetings 

was to inform the public about the Proposed Action and to solicit public comments on the 

environmental issues addressed and analyzed in the Draft EIS/OEIS. The Draft EIS/OEIS public review and 

comment period lasted 60 days, concluding on 29 August 2017. Comments were accepted by mail, 

through the EIS/OEIS website at: www.AFTTEIS.com, and at the public meetings.

8.3.1 NOTIFICATION OF DRAFT ENVIRONMENTAL IMPACT STATEMENT/OVERSEAS 

ENVIRONMENTAL IMPACT STATEMENT AND PUBLIC MEETINGS

The Navy made significant efforts to distribute information about the project and notify the public to 

ensure maximum public participation during the public comment period. A summary of these efforts 

follows.
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8.3.1.1 Notification Letters

Letters were sent to federally-recognized tribes; state elected officials; and federal, regional, and state 

agencies. The letters provided a description of the Proposed Action, address of the project website, 

duration of the comment period, and information on the public meetings. A stakeholder notification 

letter was distributed on the day of the release of the Draft EIS/OEIS to appropriate and interested 

federal, state, and local government agencies, nongovernmental organizations, and persons expressing 

an interest in the Proposed Action and Draft EIS/OEIS. A total of 1,340 stakeholder notification letters 

were mailed. Entities that received the notification letters are listed in Table 8.3-1. Figure 8.3-1 provides 

an example letter.

Table 8.3-1: Entities that Received the Draft Environmental Impact Statement/Overseas 

Environmental Impact Notification Letter

Federally-Recognized Tribes

Absentee Shawnee Tribe of Indians of Oklahoma 

Alabama-Coushatta Tribes of Texas 

Aroostook Band of Micmac Indians of Maine 

Catawba Indian Nation 

Cayuga Nation of New York 

Chitimacha Tribe of Louisiana 

Coushatta Tribe of Louisiana 

Delaware Nation

Delaware Tribe of Indians

Eastern Band of Cherokee Indians of North Carolina 

Houlton Band of Maliseet Indians

Jena Band of Choctaw Indians 

Kickapoo Traditional Tribe of Texas 

Mashantucket Pequot Tribe of Connecticut 

Mashpee Wampanoag Tribe, Massachusetts 

Miccosukee Tribe of Indians of Florida 

Mississippi Band of Choctaw Indians, Mississippi 

Mohegan Indian Tribe of Connecticut

Narragansett Indian Tribe of Rhode Island 

Oneida Nation of New York 

Onondaga Nation of New York 

Passamaquoddy Tribe – Indian Township Reservation 

Passamaquoddy Tribe at Pleasant Point Reservation

Penobscot Tribe of Maine 

Poarch Band of Creek Indians of Alabama 

Saint Regis Mohawk Tribe, New York 

Seminole Tribe of Florida 

Seneca Nation of Indians

Shawnee Tribe of Oklahoma

Shinnecock Indian Nation

Stockbridge-Munsee Band of the Mohicans

Tonawanda Band of Seneca Indians of New York 

Tunica-Biloxi Indian Tribe of Louisiana 

Tuscarora Nation of New York 

Wampanoag Tribe of Gay Head of Massachusetts 

Ysleta del Sur Pueblo of Texas 

State Elected Officials State Agencies Local

Office of the Governor 

Congressional Delegates 

Alabama Department of Agriculture and 

Industries 

Alabama Department of Conservation 

and Natural Resources 

Alabama Department of Economic and 

Community Affairs 

Alabama Department of Environmental 

Management 

Alabama Development Office 

Alabama Historical Commission

Alabama National Guard

Alabama Coastal Management Program

Alabama State Port Authority

State Oil and Gas Board of Alabama

Baldwin County

City of Mobile

County of Mobile
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Table 8.3-1: Entities that Received the Draft Environmental Impact Statement/Overseas 

Environmental Impact Notification Letter (continued)

Alabama

Connecticut

State Elected Officials State Agencies Local

Office of the Governor 

Congressional Delegates 

Connecticut Commission on Culture & 

Tourism, State Historic Preservation 

Office

Connecticut Council on Environmental 

Quality 

Connecticut Department of Economic 

and Community Development 

Connecticut Department of Energy and 

Environmental Protection 

Connecticut Department of Public Health

Connecticut Environmental and 

Occupational Health Assessment 

Program

Connecticut National Guard

Connecticut Office of Military Affairs

Connecticut Siting Council

City of New London

Town of Groton

Delaware

State Elected Officials State Agencies Local

Office of the Governor 

Congressional Delegates 

Delaware Division of Historical and 

Cultural Affairs 

Delaware Economic Development Office 

Delaware Heritage Commission 

Delaware River Basin Commission 

Delaware River and Bay Authority

Delaware National Guard

Delaware Office of Management and 

Budget: Budget Development, Planning, 

and Administration 

Department of Natural Resources and 

Environmental Control

Delaware State Historic Preservation 

Office
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Table 8.3-1: Entities that Received the Draft Environmental Impact Statement/Overseas 

Environmental Impact Notification Letter (continued)

Florida

State Elected Officials State Agencies Local

Office of the Governor 

Congressional Delegates 

Florida Department of Environmental 

Protection 

Florida Fish and Wildlife Conservation 

Commission 

Florida Fish and Wildlife Conservation 

Commission

Florida State Clearinghouse

Florida Department of Economic

Opportunity

Florida Department of Military Affairs

Florida Department of State

Florida Department of Transportation

Florida Division of Historical Resources

St. Johns River Water Management 

District

Workforce Florida

Bay County

Brevard County

Broward County

Cape Canaveral Port Authority

City of Atlantic Beach

City of Cape Canaveral

City of Dania Beach

City of Jacksonville

City of Key West

City of Milton

City of Pensacola

County of Escambia

Jacksonville Port Authority

Jacksonville Aviation Authority

Jacksonville Waterways Commission

Monroe County

Panama City

Panama City Beach

Panama City Port Authority

Pensacola Regional Airport

Port Canaveral

Port of Panama City

Port of Pensacola Santa Rosa County

Southeast Citizens Planning Advisory 

Committee

Georgia

State Elected Officials State Agencies Local

Office of the Governor 

Congressional Delegates 

Georgia Department of Defense

Georgia Department of Economic 

Development 

Georgia Department of Natural 

Resources 

Georgia Environmental Finance Authority 

Georgia Forestry Commission 

Georgia Historic Preservation Division

Georgia State Clearinghouse

Jekyll Island Authority

City of Kingsland

City of St. Mary's

City of Woodbine

County of Camden

Louisiana

State Elected Officials State Agencies Local

Office of the Governor 

Congressional Delegates 

Louisiana Department of Culture, 

Recreation and Tourism Louisiana 

Economic Development 

Louisiana Department of Environmental 

Quality 

Louisiana Department of Natural 

Resources 

Louisiana State Military Department / 

Louisiana National Guard

Port of New Orleans

City of New Orleans
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Table 8.3-1: Entities that Received the Draft Environmental Impact Statement/Overseas 

Environmental Impact Notification Letter (continued)

Maine

State Elected Officials State Agencies Local

Office of the Governor 

Congressional Delegates 

Historic Preservation Commission 

Maine Department of Agriculture, 

Conservation and Forestry

Maine Department of Environmental 

Protection 

Maine Department of Inland Fisheries 

and Wildlife

Maine Department of Marine Resources

Maine Military Authority

Maine State Planning Office

Maine National Guard and Maine 

Department of Defense, Veterans, and 

Emergency Management

City of Bath

City of Portland

Cumberland County

Town of Kittery

Maryland

State Elected Officials State Agencies Local

Office of the Governor 

Congressional Delegates 

Chesapeake Bay Commission

Maryland Department of Environment 

Maryland Department of Natural 

Resources 

Maryland Department of Agriculture 

Maryland Department of Business and 

Economic Development 

Maryland Department of Planning

Maryland Department of Transportation

Maryland Economic Development 

Corporation 

Maryland Environmental Service

Maryland Historical Trust

Maryland State Clearinghouse for 

Intergovernmental Assistance

Town of Ocean City

Somerset County

Wicomico County

Worcester County
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Table 8.3-1: Entities that Received the Draft Environmental Impact Statement/Overseas 

Environmental Impact Notification Letter (continued)

Massachusetts

State Elected Officials State Agencies Local

Office of the Governor 

Congressional Delegates 

Berkshire Regional Planning Commission

Cape Cod Commission 

Central Massachusetts Regional Planning 

Commission 

Franklin Regional Council of Governments 

Martha's Vineyard Commission

Massachusetts Department of 

Conservation and Recreation 

Massachusetts Department of 

Environmental Protection 

Massachusetts Department of Public 

Health 

Massachusetts Executive Office of Health 

and Human Services 

Massachusetts Historical Commission

Massachusetts National Guard

Massachusetts Port Authority 

Massachusetts Regional Planning 

Commission 

Massachusetts Water Resources 

Authority 

Merrimack Valley Planning Commission

Metropolitan Area Planning Council

Montachusett Regional Planning 

Commission

Nantucket Planning and Economic 

Development Commission

Pioneer Valley Planning Commission

Seaport Economic Council

Southeastern Regional Planning and 

Economic Development District

City of Boston

Town of Barnstable

Northern Middlesex Council of 

Government

Mississippi

State Elected Officials State Agencies Local

Office of the Governor 

Congressional Delegates 

Gulf of Mexico Program Office

Mississippi Department of Archives and 

History, Historic Preservation Division, 

Federal and State Project Review

Mississippi Department of Environmental 

Quality 

Mississippi Department of Marine 

Resources 

Mississippi Forestry Commission

Mississippi National Guard

Mississippi Soil and Water Conservation 

Commission 

Mississippi State Oil and Gas Board

Mississippi State Port Authority

City of Meridian

City of Moss Point

City of Pascagoula

Harrison County

Jackson County

Port of Pascagoula
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Table 8.3-1: Entities that Received the Draft Environmental Impact Statement/Overseas 

Environmental Impact Notification Letter (continued)

New Hampshire

State Elected Officials State Agencies Local

Office of the Governor 

Congressional Delegates 

New Hampshire Department of Cultural 

Resources 

New Hampshire Department of 

Environmental Services 

New Hampshire Department of 

Resources and Economic Development 

New Hampshire Department of Safety 

New Hampshire Division of Forests and 

Lands 

New Hampshire Division of Historical 

Resources

New Hampshire Fish and Game 

Department 

New Hampshire National Guard

New Hampshire Office of Energy and 

Planning 

State of New Hampshire Economic 

Development

City of Portsmouth

Rockingham County

New Jersey

State Elected Officials State Agencies Local

Office of the Governor 

Congressional Delegates 

Delaware River Basin Commission

Garden State Preservation Trust 

Jersey Pinelands Commission

New Jersey Department of Agriculture 

New Jersey Department of 

Environmental Protection 

New Jersey Department of 

Environmental Protection: Office of 

Permit Coordination and Environmental 

Review 

New Jersey Department of Military and 

Veterans Affairs

New Jersey Economic Development 

Authority 

New Jersey Historic Preservation Office

New Jersey Historic Trust

New Jersey Historical Commission

Pinelands Municipal Council

Atlantic County

Ocean County

New York

State Elected Officials State Agencies Local

Office of the Governor 

Congressional Delegates 

New York State Department of 

Environmental Conservation 

New York Department of State, Office of 

Communities and Waterfronts

New York Division of Military and Naval 

Affairs

New York Office of Parks, Recreation and 

Historic Preservation

Long Island, Nassau County

Long Island, Suffolk County
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Table 8.3-1: Entities that Received the Draft Environmental Impact Statement/Overseas 

Environmental Impact Notification Letter (continued)

North Carolina

State Elected Officials State Agencies Local

Office of the Governor 

Congressional Delegates 

NCEast Alliance

North Carolina Advisory Commission on 

Military Affairs

North Carolina Department of 

Administration 

North Carolina Department of Cultural 

Resources 

North Carolina Department of 

Environment and Natural Resources

North Carolina Department of Public 

Safety

North Carolina Department of 

Transportation North Carolina Division of 

Parks and Recreation 

North Carolina Economic Developers 

Association 

North Carolina National Guard

North Carolina State Historic Preservation 

Office

North Carolina State Ports Authority 

North Carolina Wildlife Resources 

Commission 

North Carolina's Southeast Economic 

Development Organization

Office of Conservation, Planning and 

Community Affairs

City of Havelock

City of Jacksonville

City of Wilmington

Coastal Carolina Regional Air Port 

Authority

County of Carteret

County of Craven

County of Jones

County of Pamlico

County Of Pender

Morehead City

Onslow County

Town of Nags Head

Port of Morehead City

Port of Wilmington

Rhode Island

State Elected Officials State Agencies Local

Office of the Governor 

Congressional Delegates 

Rhode Island Coastal Resources 

Management Council 

Rhode Island Department of 

Administration 

Rhode Island Department of 

Environmental Management 

Rhode Island Department of Health 

Rhode Island Historical Preservation & 

Heritage Commission

Rhode Island Division of Planning

Rhode Island National Guard

Rhode Island Water Resources Board

City of Newport
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Table 8.3-1: Entities that Received the Draft Environmental Impact Statement/Overseas 

Environmental Impact Notification Letter (continued)

South Carolina

State Elected Officials State Agencies Local

Office of the Governor 

Congressional Delegates 

South Carolina Department of Natural 

Resources 

South Carolina Office of State Budget 

South Carolina Department of Agriculture 

South Carolina Department of Health and 

Environmental Control 

South Carolina Department of Parks, 

Recreation, and Tourism 

South Carolina Forestry Commission

South Carolina Military Department

South Carolina Sea Grant Consortium

South Carolina State Historic Preservation 

Office

South Carolina State Ports Authority

City of Charleston

Texas

State Elected Officials State Agencies Local

Office of the Governor 

Congressional Delegates 

Brazos River Authority

Houston Port Authority

Lower Colorado River Authority

Texas Bureau of Economic Geology 

Texas Commission on Environmental 

Quality 

Texas General Land Office

Texas Historical Commission

Texas Military Forces

Texas Parks and Wildlife Department 

Texas Water Development Board

City of Corpus Christi

County of Kleberg

County of Nueces

County of San Patricio

Port of Corpus Christi

Virginia

State Elected Officials State Agencies Local

Office of the Governor 

Congressional Delegates 

Chesapeake Bay Commission 

Potomac River Fisheries Commission

Virginia Aquarium/Stranding Center

Virginia Department of Agriculture and 

Forestry

Virginia Department of Conservation and 

Recreation 

Virginia Department of Environmental 

Quality 

Virginia Department of Game and Inland 

Fisheries 

Virginia Department of Historic 

Resources 

Virginia Department of Natural Resources 

Virginia Department of Planning and 

Budget 

Virginia Department of Transportation 

Virginia Marine Resources Commission

Virginia Museum of Natural History

Virginia National Guard

Virginia Port Authority 

Virginia Resources Authority

City of Newport News

City of Norfolk

City of Portsmouth

City of Virginia Beach

County of Accomack

Hampton Roads Military and Federal 

Facilities Alliance

Hampton Roads Planning District 

Commission

Norfolk Environmental Commission

Town of Chincoteague

Virginia Beach Convention & Visitors 

Bureau Western Tidewater Community 

Services Board
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Table 8.3-1: Entities that Received the Draft Environmental Impact Statement/Overseas 

Environmental Impact Notification Letter (continued)

U.S. Virgin Islands

Elected Officials Agencies Local

Office of the Governor 

Congressional Delegates

Department of Planning & Natural 

Resources

Department of Planning & Natural 

Division of Environmental Protection

Historic Preservation Office

Regional

Federal Agencies

Advisory Council on Historic Preservation, Office of Federal Agency Programs

Assateague National Seashore

Bureau of Indian Affairs, Eastern Region

Bureau of Indian Affairs, Southern Plains Region

Bureau of Ocean Energy Management, Office of Renewable Energy Programs

Canaveral National Seashore

Cape Cod National Seashore

Council on Environmental Quality

Department of Commerce

Department of Interior, Atlanta Regional Office

Department of Interior, Boston Regional Office

Department of Interior, Bureau of Ocean Energy Management

Department of Interior, Bureau of Safety & Environmental Enforcement, Gulf of Mexico Region

Dry Tortugas National Park

Federal Aviation Administration

Federal Aviation Administration, Eastern Region 

Federal Aviation Administration, New England Region

Federal Aviation Administration, Southern Region 

Federal Aviation Administration, Southwest Region 

Fishery Management Council, Caribbean 

Fishery Management Council, Gulf of Mexico 

Fishery Management Council, Mid-Atlantic 

Fishery Management Council, New England 

Fishery Management Council, South Atlantic 

Gulf State Marine Fisheries Commission 

John F. Kennedy Space Center

Marine Mammal Commission

Mid-Atlantic Fishery Management Council

National Aeronautics and Space Administration, Goddard Space Flight Center, Wallops Environmental Office

National Marine Fisheries Service

National Marine Fisheries Service, West Palm Beach Field Office 

National Marine Fisheries Science Center, Northeast Region Fisheries Science Center

National Marine Fisheries Service, Southeast Fisheries Science Center

National Marine Fisheries Service, Beaufort Laboratory

National Marine Fisheries Service, Galveston Lab

National Marine Fisheries Service, Habitat Conservation Division

National Marine Fisheries Service, James J Howard Marine Science Lab

National Marine Fisheries Service, Lafayette Lab
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Table 8.3-1: Entities that Received the Draft Environmental Impact Statement/Overseas 

Environmental Impact Notification Letter (continued)

National Marine Fisheries Service, Miami Lab

National Marine Fisheries Service, Milford Lab

National Marine Fisheries Service, Narragansett Lab

National Marine Fisheries Service, National Systematics Laboratory

National Marine Fisheries Service, Northeast Regional Office

National Marine Fisheries Service, Office of Habitat Conservation, Program Planning & Integration Office

National Marine Fisheries Service, Office of Ocean Exploration and Research

National Marine Fisheries Service, Office of Protected Resources

National Marine Fisheries Service, Panama City Lab

National Marine Fisheries Service, Pascagoula Lab

National Marine Fisheries Service, Southeast Regional Office

National Marine Fisheries Service, Stennis Lab

National Marine Fisheries Service, West Palm Beach Field Office

National Oceanic & Atmospheric Administration

National Oceanic and Atmospheric Administration, Beaufort Field Office

National Oceanic and Atmospheric Administration, Chesapeake Bay Office

National Oceanic and Atmospheric Administration, Fisheries SERO, Right Whale Recovery Program

National Oceanic and Atmospheric Administration, Monitor National Marine Sanctuary

National Oceanic and Atmospheric Administration, Sapelo Island National Estuarine Research Reserve

National Office of Marine Sanctuaries, Flower Garden Banks National Marine Sanctuary

National Park Service

National Park Service, Cape Hatteras National Seashore

National Park Service, Cape Lookout National Seashore

National Park Service, Cumberland Island National Seashore

National Park Service, Gulf Islands National Seashore

National Park Service, Intermountain Region

National Park Service, Northeast Region

National Park Service, Padre Island National Seashore

National Park Service, Southeast Region

National Park Service, Timucuan Ecological and Historic Preserve

New England Fishery Management Council

National Oceanic and Atmospheric Administration Office of Marine Sanctuaries Florida Keys National Marine 

Sanctuary

National Oceanic and Atmospheric Administration Office of Marine Sanctuaries Gray's Reef National Marine 

Sanctuary 

National Oceanic and Atmospheric Administration Office of Marine Sanctuaries Monitor National Marine 

Sanctuary

National Oceanic and Atmospheric Administration Office of Marine Sanctuaries Stellwagen Bank National 

Marine Sanctuary

National Oceanic and Atmospheric Administration Office of Marine Sanctuaries Virginia Institute of Marine 

Science

South Atlantic Fishery Management Council

U.S. Army Corps of Engineers, Planning and Environmental Division

U.S. Army Corps of Engineers, Headquarters 

U.S. Army Corps of Engineers, Baltimore District 

U.S. Army Corps of Engineers, Galveston District 

U.S. Army Corps of Engineers, Jacksonville District 
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Table 8.3-1: Entities that Received the Draft Environmental Impact Statement/Overseas 

Environmental Impact Notification Letter (continued)

U.S. Army Corps of Engineers, New Orleans District 

U.S. Army Corps of Engineers, New York District

U.S. Army Corps of Engineers, Norfolk District 

U.S. Army Corps of Engineers, North Atlantic Division

U.S. Army Corps of Engineers, Philadelphia District 

U.S. Army Corps Of Engineers, Regulatory Division

U.S. Army Corps Of Engineers, Savannah District

U.S. Army Corps of Engineers, Washington Regulatory Field Office

U.S. Army Corps of Engineers, Wilmington District 

U.S. Coast Guard

U.S. Coast Guard Headquarters, Office of Environmental Management

U.S. Coast Guard, Atlantic Area

U.S. Coast Guard, District 1 

U.S. Coast Guard, District 5 

U.S. Coast Guard, District 7 

U.S. Coast Guard, District 8 

U.S. Coast Guard, District 9

U.S. Coast Guard, District Headquarters of Sector Jacksonville

U.S. Coast Guard, Sector North Carolina

U.S. Department of Agriculture

U.S. Department of Agriculture, Forest Service

U.S. Department of Agriculture, Forest Service, Eastern Region

U.S. Department of Agriculture, Forest Service, Ocala National Forest

U.S. Department of Agriculture, Forest Service, Southern Region

U.S. Department of Interior, Natural Resources Management Team

U.S. Department of Transportation, Maritime Administration, Office of Deepwater Ports and Offshore Activities

U.S. Department of Transportation, Maritime Administration, South Atlantic Region

U.S. Environmental Protection Agency

U.S. Environmental Protection Agency, Office of Enforcement and Compliance Assurance, Office of Federal 

Activities

U.S. Environmental Protection Agency, Office of Federal Activities, EIS Filing Section

U.S. Environmental Protection Agency, Region 1

U.S. Environmental Protection Agency, Region 2

U.S. Environmental Protection Agency, Region 3

U.S. Environmental Protection Agency, Region 4

U.S. Environmental Protection Agency, Region 6

U.S. Fish and Wildlife Service, Alligator River and Pea Island National Wildlife Refuges

U.S. Fish and Wildlife Service, Back Bay National Wildlife Refuge

U.S. Fish and Wildlife Service, Bears Bluff National Fish Hatchery

U.S. Fish and Wildlife Service, Cape Romain National Wildlife Refuge

U.S. Fish and Wildlife Service, Charleston Ecological Services Field Office

U.S. Fish and Wildlife Service, Chesapeake Bay Office

U.S. Fish and Wildlife Service, Chincoteague National Wildlife Refuge

U.S. Fish and Wildlife Service, Coastal Georgia Sub-Office (Townsend)

U.S. Fish and Wildlife Service, Ernest F. Hollings ACE Basin National Wildlife Refuge

U.S. Fish and Wildlife Service, Harris Neck National Wildlife Refuge

U.S. Fish and Wildlife Service, Headquarters

U.S. Fish and Wildlife Service, Mackay Island and Currituck National Wildlife Refuges

U.S. Fish and Wildlife Service, Mattamuskeet, Cedar Island and Swan Quarter
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Table 8.3-1: Entities that Received the Draft Environmental Impact Statement/Overseas 

Environmental Impact Notification Letter (continued)

U.S. Fish and Wildlife Service, Merritt Island National Wildlife Refuge

U.S. Fish and Wildlife Service, North Florida Ecological Services Office

U.S. Fish and Wildlife Service, Raleigh Field Office

U.S. Fish and Wildlife Service, Region 2

U.S. Fish and Wildlife Service, Region 4

U.S. Fish and Wildlife Service, Region 5

U.S. Fish and Wildlife Service, Savannah Coastal Refuges

U.S. Fish and Wildlife Service, Virginia Field Office

U.S. Fish and Wildlife Service, Waccamaw National Wildlife Refuge

U.S. Geological Survey

U.S. Geological Survey, Water Resources

U.S. Fish and Wildlife Service, Edenton National Fish Hatcheryv
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Figure 8.3-1: Stakeholder Letter for the Notification of the Draft Environmental Impact 

Statement/Overseas Environmental Impact Statement
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Figure 8.3-1: Stakeholder Letter for the Notification of the Draft Environmental Impact 

Statement/Overseas Environmental Impact Statement (continued)
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Figure 8.3-1: Stakeholder Letter for the Notification of the Draft Environmental Impact 

Statement/Overseas Environmental Impact Statement (continued)
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Figure 8.3-1: Stakeholder Letter for the Notification of the Draft Environmental Impact 

Statement/Overseas Environmental Impact Statement (continued)
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Figure 8.3-1: Stakeholder Letter for the Notification of the Draft Environmental Impact Statement/Overseas Environmental 

Impact Statement (continued)
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8.3.1.2 Subscribers Email

Project information was also distributed via the project web site subscribers email distribution list. A 

copy of the email sent to announce the availability of the Public Release Draft EIS/OEIS and provided 

information on ways to comment and public meeting times and locations in included as Figure 8.3-2.

8.3.1.3 Public Involvement Website

A public involvement website, www.AFTTEIS.com, housed a series of fact sheets and videos that 

explained specifics of the Proposed Action and described the overall planning process. Topics included: 

 National Environmental Policy Act Process and Timeline

 Importance of Navy Training and Testing 

 Study Area Map Proposed Action and Alternatives 

 Training and Testing Active Sonar and Explosives 

 Navy Acoustic Effects Model 

 Marine Resource Protection 

 Public Access and Safety

 Participating Navy Commands

The website provided additional in-depth informational videos that covered the following topics:

 The Importance of Navy Training and Testing 

 Proposed Action and Alternatives 

 Training and Testing Active Sonar and Explosives 

 Introduction to Navy Acoustic Effects Model 

 Marine Resource Protection 

 Public Access and Safety
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Figure 8.3-2: Project Website Subscribers Email for the Notification of the Draft Environmental 

Impact Statement/Overseas Environmental Impact Statement
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8.3.1.4 Postcard Mailers

More than 500 postcards were sent to individuals, agencies, and organizations. The postcards acted as 

formal notification of the Notice of Availability of the AFTT Draft EIS/OEIS and announcement of public 

meetings. An example of the Notice of Availability postcard is shown in Figure 8.3-3 and Figure 8.3-4.

8.3.1.5 Press Releases

Press releases to announce the public meetings for the Draft EIS/OEIS were released on 29 June 2017, 

14 July 2017, 21 July 2017, 24 July 2107, 27 July 2017, and 31 July 2017. These press releases provided a 

description of the Proposed Action, address of the project website, duration of the comment period, 

address of locations that the AFTT Draft EIS/OEIS could be viewed, and information on the public 

meetings. An example of one of these press releases can be found in Figure 8.3-5.

8.3.1.6 Newspaper Advertisements

To announce the Notification of Availability of the AFTT Draft EIS/OEIS and public meetings, 

advertisements were placed in the listed newspapers on the dates indicated in Table 8.3-2. The 

advertisements included a description of the Proposed Action, the project website, the duration of the 

comment period, and information on how to provide comments. An example of the advertisement is 

shown in Figure 8.3-6.
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Figure 8.3-3: Postcard for the Notification of Availability of the Draft Environmental Impact Statement/ Overseas Environmental Impact 

Statement and Announcement of Public Meetings (front)
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Figure 8.3-4: Postcard for the Notification of Availability of the Draft Environmental Impact Statement/ Overseas Environmental Impact 

Statement and Announcement of Public Meetings (back)
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Figure 8.3-5: Press Release of Notification of Availability of the Draft Environmental Impact 

Statement/ Overseas Environmental Impact Statement and Announcement of Public Meetings
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Figure 8.3-5: Press Release of Notification of Availability of the Draft Environmental Impact 

Statement/ Overseas Environmental Impact Statement and Announcement of Public 

Meetings (continued)
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Table 8.3-2: Newspaper Announcements of Notification of Availability of the Draft 

Environmental Impact Statement/Overseas Environmental Impact Statement and 

Announcement of Public Meetings

Portland, ME 

The Portland Press Herald 

July 2, 2017

Cumberland and Sagadahoc 

Counties, ME

The Times Record

June 30, 2017

New Bedford, MA

The Standard Times

July 2, 2017

Boston, MA 

The Boston Herald 

July 2, 2017

Providence, RI 

The Providence Journal

July 2, 2017

Newport, RI

The Newport Daily News

July 1, 2017

Salisbury, MD

The Daily Times

July 2, 2017

Norfolk, VA

The Virginia Pilot 

July 2, 2017

Newport News, VA

The Daily Press

July 2, 2017

Nags Head, NC

Outer Banks Sentinel 

July 5, 2017

Jacksonville, NC 

Jacksonville Daily News 

July 2, 2017

Wilmington, NC 

Wilmington Star News

July 2, 2017

Charleston, SC

Charleston Post and Courier

July 2, 2017

Savannah, GA 

Savannah Morning News 

July 2, 2017

Jacksonville, FL 

Florida Times Union

July 2, 2017

Fort Lauderdale, FL

Florida Sun Sentinel

July 2, 2017

Brevard, FL

Florida Today 

July 2, 2017

Panama City, Bay County, FL

The News Herald 

July 2, 2017

Pensacola, FL 

Pensacola News Journal

July 2, 2017

New Orleans, LA

Times-Picayune

July 2, 2017

Galveston, TX

Galveston Daily News 

July 2, 2017

Corpus Christi, TX 

Caller-Times

July 2, 2017

Pascagoula, MS 

The Mississippi Press

July 2, 2017
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Figure 8.3-6: Newspaper Announcement of Notification of Availability of the Draft Environmental 

Impact Statement/Overseas Environmental Impact Statement and Announcement of Public 

Meetings
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8.3.2 PUBLIC MEETINGS

Five public meetings were held on the following dates in the listed cities:

 19 July 2017 in Providence, Rhode Island

 25 July 2017 in Morehead City, North Carolina

 26 July 2017 in Norfolk, Virginia

 1 August 2017 in Jacksonville, Florida

 3 August 2017 in Panama City, Florida

The meetings were structured in an open-house format, presenting informational posters and written 

information, with Navy staff and project experts available to answer participants’ questions.

8.4 DISTRIBUTION OF THE DRAFT AND FINAL ENVIRONMENTAL IMPACT 

STATEMENT/OVERSEAS ENVIRONMENTAL IMPACT STATEMENT

The agencies, individuals, and organizations listed in the sections below could access the document 

electronically via the website, received an electronic/hard copy of the EIS/OEIS, or could access hard 

copies as available at the information repositories discussed in Section 8.4.3 (Repositories). Since release 

of the Draft EIS/OEIS, points of contact at some of the agencies and organizations changed; therefore, 

the distribution lists were updated to reflect those changes. Although the points of contact may have 

changed, the same agencies and organizations received a copy of both the Draft and Final EIS/OEIS. For 

states not having a clearinghouse, a copy of the EIS/OEIS was sent to the most relevant state agency.

8.4.1 FEDERAL AGENCIES

Electronic copies of the Draft and Final AFTT EIS/OEIS were delivered to the federal agencies listed in 

Table 8.4-1.

Table 8.4-1: Federal Agencies that Received the Draft and Final Environmental Impact 

Statement/ Overseas Environmental Impact Statement

Federal Agency

National Marine Fisheries Services (NMFS)

Ms. Cathryn Tortorici 

Chief, Endangered Species Act Interagency Cooperation Division Office of Protected Resources 

National Marine Fisheries Service

National Oceanic and Atmospheric Administration

1315 East-West Highway, SSMC3, Room 13821

Silver Springs, MD 20910-3282

U.S. Environmental Protection Agency (EPA)

Mr. Tim Timmermann

Office of Environmental Review

U.S. EPA Region 1

5 Post Office Square , Suite 100

Boston, MA 02109-3912

Mr. Chris Militscher

NEPA Program Office

U.S. EPA Region 4

61 Forsyth Street, SW

Atlanta, Ga 30303
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Table 8.4-1: Federal Agencies that Received the Draft and Final Environmental Impact 

Statement/ Overseas Environmental Impact Statement (continued)

Federal Agency

Mr. John Pomponio

Office of Environmental Programs Code 3EA30

U.S. EPA Region 3

1650 Arch Street

Philadelphia, PA 19106

Mr. Samuel Coleman

U.S. EPA Region 6

1445 Ross Avenue, Suite 1200

Dallas, TX 75202-2733

Ms. Catherine McCabe

Environmental Review Section

U.S. EPA Region 2

290 Broadway

New York, NY 10007-1866

8.4.2 STATE ELECTED OFFICIALS

Electronic copies of the Draft and Final AFTT EIS/OEIS were delivered to the state governors listed in 

Table 8.4-2.

Table 8.4-2: State Governors that Received the Draft and Final Environmental Impact 

Statement/Overseas Environmental Impact Statement

State Governors

Maine New Hampshire Massachusetts

The Honorable Paul LePage

Governor, State of Maine

Office of the Governor

1 State House Sta.

Augusta, ME 04333

The Honorable Chris Sununu 

Governor, State of New Hampshire 

Office of the Governor

107 North Main St.

Concord,NH 03301

The Honorable Charlie Baker 

Governor, Commonwealth of 

Massachusetts 

Office of the Governor

State House, Rm. 280

Boston, MA 02133

Rhode Island Connecticut New York

The Honorable Gina M. Raimondo 

Governor, State of Rhode Island 

Office of the Governor

82 Smith St.

Providence, RI 02903

The Honorable Dannel P. Malloy 

Governor, State of Connecticut 

Office of the Governor 

210 Capitol Ave.

Hartford, CT 06106

The Honorable Andrew M. Cuomo 

Governor State of New York 

Office of the Governor

NYS State Capitol Bldg.

Albany, NY 12224

New Jersey Delaware Maryland

The Honorable Phil Murphy

Governor, State of New Jersey 

Office of the Governor

P.O. Box 001

Trenton, NJ 08625

The Honorable John Carney 

Governor, State of Delaware

Office of the Governor

150 Martin Luther King Jr. Blvd. 

Dover, DE 19901

The Honorable Larry Hogan 

Governor, State of Maryland 

Office of the Governor

100 State Cir.

Annapolis, MD 21401
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Table 8.4-2: State Governors that Received the Draft and Final Environmental Impact 

Statement/Overseas Environmental Impact Statement (continued)

Virginia North Carolina South Carolina

The Honorable Terry McAuliffe 

Governor, Commonwealth of 

Virginia

Office of the Governor

P.O. Box 1475

Richmond, VA 23218

The Honorable Roy Cooper 

Governor, State of North Carolina 

Office of the Governor

20301 Mail Service Center

Raleigh, NC 27699-0301

The Honorable Henry McMaster

Governor, State of South Carolina 

Office of the Governor

1205 Pendleton St.

Columbia, SC 29201

Georgia Florida Alabama

The Honorable Nathan Deal 

Governor, State of Georgia

Office of the Governor

206 Washington St.,

111 State Capitol

Atlanta, GA 30334

The Honorable Richard Scott 

Governor, State of Florida

Office of the Governor

400 S. Monroe St.

Tallahassee, FL 32399

The Honorable Kay Ivey 

Governor, State of Alabama 

Office of the Governor

State Capitol, 600 Dexter Ave.

Montgomery, AL 36130

Mississippi Louisiana Texas

The Honorable Phil Bryant 

Governor, State of Mississippi 

Office of the Governor

P.O. Box 139

Jackson, MS 39205

The Honorable John Bel Edwards 

Governor, State of Louisiana 

Office of the Governor

P.O. Box 94004

Baton Rouge, LA 70804

The Honorable Greg Abbott 

Governor, State of Texas

Office of the Governor

P.O. Box 12428

Austin, TX 78711-2428

8.4.3 REPOSITORIES

Electronic copies of the Draft and Final AFTT EIS/OEIS were also delivered to the repositories listed in 

Table 8.4-3.

Table 8.4-3: Repositories that Received the Draft and Final Environmental Impact Statement/ 

Overseas Environmental Impact Statement

AFTT Information Repositories

Maine

Portland Public Library

5 Monument Sq.

Portland, ME 04101

Massachusetts

Boston Public Library, Central Library

700 Boylston St.

Boston, MA 02116

Hyannis Public Library

401 Main St.

Hyannis, MA 02601

Rhode Island

Providence Public Library

150 Empire St.

Providence, RI 02903
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Table 8.4-3: Repositories that Received the Draft and Final Environmental Impact Statement/ 

Overseas Environmental Impact Statement (continued)

Connecticut

Public Library of New London

63 Huntington St.

New London, CT 06320

Maryland

Anne Arundel County Public Library

5 Harry S. Truman Parkway

Annapolis, MD 21401

Virginia

Slover Memorial Main Library

235 E. Plume St.

Norfolk, VA 23510

North Carolina

Kill Devil Hills Branch Library

400 Mustian St.

Kill Devil Hills, NC 27948 

Dare County Library, Manteo

700 Highway 64/264

Manteo, NC 27954

Havelock-Craven County Public Library

301 Cunningham Blvd.

Havelock, NC 28532

Onslow County Library

58 Doris Avenue East

Jacksonville, NC 28540

Carteret County Public Library

1702 Live Oak St., Suite 100

Beaufort, NC 28516

AFTT Information Repositories

Webb Memorial Library Center

8112 Evans St.

Morehead City, NC 28557

New Hanover County Public Library

201 Chestnut Street

Wilmington, NC 28401

South Carolina

Charleston County Public Library

68 Calhoun St.

Charleston, SC 29401

Georgia

Camden County Public Library

1410 Highway 40 E.

Kingsland, GA 31548 
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Table 8.4-3: Repositories that Received the Draft and Final Environmental Impact 

Statement/ Overseas Environmental Impact Statement (continued)

Florida

Jacksonville Public Library

303 N. Laura St.

Jacksonville, FL 32202

West Palm Beach Library

411 Clematis St.

West Palm Beach, FL 33401

Monroe County Public Library

700 Fleming St.

Key West, FL 33040

Bay County Public Library

898 W. 11th St.

Panama City, FL 32401 

Walton County Library, Coastal Branch Library

437 Greenway Trail

Santa Rosa Beach, FL 32459

West Florida Public Library, Southwest Branch

122248 Gulf Branch Hwy

Pensacola, FL 32507

West Florida Public Library, Pensacola Library

239 North Spring St.

Pensacola, FL 32502

Alabama

Ben May Main Library

701 Government St.

Mobile, AL36602

Mississippi

Pascagoula Public Library

3214 Pascagoula St.

Pascagoula, MS 39567

Louisiana

East Bank Regional Library

4747 West Napoleon Ave.

Metairie, LA 70001

New Orleans Public Library, Main Library

219 Loyola Ave.

New Orleans, LA 70112

Texas

Houston Public Library

500 Mickinney St.

Houston, TX 77002

Corpus La Retema Central Library

805 Comanche

Corpus Christi, TX 78401
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8.4.4 FEDERALLY-RECOGNIZED TRIBES

Electronic copies of the AFTT Draft and Final EIS/OEIS were sent to the federally-recognized tribes listed 

in Table 8.4-4.

Table 8.4-4: Federally-Recognized Tribes that Received the Draft and Final Environmental 

Impact Statement/Overseas Environmental Impact Statement

Federally-Recognized Tribes

Maine

Edward Peter Paul

Tribal Chief

Aroostook Band of Micmacs

7 Northern Rd.

Presque Isle, ME 04769

Brenda Commander

Tribal Chief

Houlton Band of Maliseet Indians

88 Bell Rd.

Littleton, ME 04730

William J. Nicholas Sr.

Chief

Passamaquoddy Tribe - Indian Township Reservation

P.O. Box 301

Indian Township, ME 04668

Ralph E. Dana

Tribal Chief

Passamaquoddy Tribe at Pleasant Point Reservation

P.O. Box 343

Perry, ME 04667-0343

Kirk Francis

Tribal Chief

Penobscot Nation

12 Wabanaki Way

Indian Island, ME04468

Massachusetts

Cedric Cromwell

Chairperson

Cheryl Andrews-Maltais

Chairperson

Wampanoag Tribe of Gay Head of Massachusetts

20 Black Brook Rd.

Aquinnah, MA 02535

Rhode Island

Matthew Thomas

Chief Sachem

Narragansett Indian Tribe of Rhode Island

P.O. Box 268

Charlestown, RI 02813-0268
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Table 8.4-4. Federally-Recognized Tribes that Received the Draft and Final Environmental 

Impact Statement/Overseas Environmental Impact Statement (continued)

Connecticut

Rodney Butler

Chairperson

Mashantucket Pequot Indian Tribe

P.O. Box 3180

Mashantucket, CT 06338-3130

Kevin Brown

Chairperson

Mohegan Indian Tribe of Connecticut

13 Crow Hill Rd.

Uncasville, CT 06382

New York

Clint Halftown

Council of Chiefs Cayuga Nation of New York

2540 SR-89

Seneca Falls, NY 13148

Ray Halbritter

Nation Representative

Oneida Nation of New York

5218 Patrick Rd.

Verona, NY 13478

Council of Chiefs

Onondaga Nation of New York

3951 Route 11

Nedrow, NY 13120

Beverly Cook

Chief

Saint Regis Mohawk Tribe

412 State Route 37

Akwesasne, NY 13655

Ron Lafrance Jr.

Chief

Saint Regis Mohawk Tribe

412 State Route 37

Akwesasne, NY 13655

Eric Thompson

Chief

Saint Regis Mohawk Tribe

412 State Route 37

Akwesasne, NY 13655

Todd Gates

President

Seneca Nation of Indians

William Seneca Bldg.

Irving, NY 14081
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Table 8.4-4. Federally-Recognized Tribes that Received the Draft and Final Environmental 

Impact Statement/Overseas Environmental Impact Statement (continued)

Bryan Polite

Chairperson

Shinnecock Indian Nation

P.O. Box 5006

Southampton, NY 11969-5006

Roger Hill

Chief

Tonawanda Band of Seneca Indians of New York

7027 Meadville Rd.

Basom, NY 14013

Leo Henry

Chief

Tuscarora Nation of New York

5616 Walmore Rd.

Lewiston, NY 14092

North Carolina

Patrick H. Lambert

Principal Chief

Eastern Band of Cherokee Indians of North Carolina

P.O. Box 455

Cherokee, NC 28719-0460

South Carolina

Bill Harris

Chief

Catawba Indian Nation

996 Ave. of the Nations

Rock Hill, SC 29730

Florida

Billy Cypress

Chairperson

Miccosukee Tribe of Indians of Florida

Tamiami Station P.O. Box 440021

Miami, FL 33144

Marcellus Osceola Jr.

Chairperson

Seminole Tribe of Florida

6300 Stirling Rd.

Hollywood, FL 33024

Paul Backhouse

Tribal Historic Preservation Officer Seminole Tribe of Florida's Tribal Historic Preservation Officer

30290 Josie Billie Hwy. PMB-1003

Clewiston, FL 33440

Alabama

Stephanie A. Bryan

Tribal Chair

Poarch Band of Creek Indians of Alabama

5811 Jack Springs Rd.

Atmore, AL 36502
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Table 8.4-4. Federally-Recognized Tribes that Received the Draft and Final Environmental 

Impact Statement/Overseas Environmental Impact Statement (continued)

Mississippi

Phyllis J.Anderson

Tribal Chief

Mississippi Band of Choctaw Indians

101 Industrial Rd.

Choctaw, MS 39350

Louisiana

O'Neil J. Darden Jr.

Chairperson

Chitimacha Tribe of Louisiana

P.O. Box 661

Charenton, LA 70523-0661

Lovelin Poncho

Chair

Coushatta Tribe of Louisiana

P.O. Box 818

Elton, LA 70532-0818

Cheryl Smith

Chief

Jena Band of Choctaw Indians

P.O. Box 14

Jena, LA 71342-0014

Joey Barbry

Chairperson

Tunica-Biloxi Indian Tribe of Louisiana

151 Melacon Dr.

Marksville, LA 71351

Texas

Bryant J. Celestine

Historic Preservation Officer

Alabama-Coushatta Tribe of Texas Historic Preservation Office

Livingston, TX 77351

Clem Sylestine III

Principal Chief

Alabama-Coushatta Tribes of Texas

571 State Park Rd. 56

Livingston, TX 77351

Estavio Elizondo Menikapan

Tribal Council Chairman

Kickapoo Traditional Tribe of Texas

P.O. Box 972

Eagle Pass, TX 78853-0972

Carlos Hisa

Governor

Ysleta Del Sur Pueblo of Texas

P.O. Box 17579 

El Paso, TX 79917-7579
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Table 8.4-4. Federally-Recognized Tribes that Received the Draft and Final Environmental 

Impact Statement/Overseas Environmental Impact Statement (continued)

Oklahoma

Edwina Butler-Wolfe

Governor

Absentee Shawnee Tribe of Indians of Oklahoma 

2025 South Gordon Cooper

Shawnee, OK 74801

Kerry Holton

President

Delaware Nation

P.O. Box 825

Anadarko, OK 73005

Chester Brooks

Chief

Delaware Tribe of Indians 

5100 Tuxedo Blvd

Bartlesville, OK 74006

Jodi Hayes

Tribal Administrator

Shawnee Tribe of Oklahoma

P.O. Box 189

Miami, OK 74355

Wisconsin

Shannon Holsey

Tribal President

Stockbridge-Munsee Band of the Mohicans 

N8476 MoHeConNuck Road

Bowler, WI 54416

8.5 COMMENTS ON THE DRAFT EIS/OEIS

Comments on the Draft AFTT EIS/OEIS were received from 7 federal agencies, 31 state agencies, 7 

local/regional government agencies, 5 nongovernmental organizations, 2 tribal governments, 1 

commercial group, and 63 private individuals for a total of 116 comment submissions.

The 116 comment submissions were reviewed and categorized according to topic. Longer comments 

were broken down into multiple separate categories in order to properly and fully capture all of the 

different points within the letter (i.e., a comment may contain more than one theme within it). 

Comments were initially categorized into 21 categories based on their content As a result, the total 

number of comments the Navy responded to is much greater than the 116 comment submissions 

received. Appendix H (Public Comment Responses), contains a summary of the comments received on 

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

8.6 NOTIFICATION OF NATIONAL MARINE FISHERIES SERVICE PROPOSED RULE

National Marine Fisheries Service released its proposed rule; request for comment in the Federal 

Register on March 13, 2018. A correction to the proposed rule was listed in the Federal Register on April 

9, 2018. The correction replaced Table 4 from the preamble with a corrected table. Copies of both 

Federal Register notices are included in Appendix G, Federal Register Notices. 
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