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FEDERAL AVIATION ADMINISTRATION

WRITTEN RE-EVALUATION,

ADOPTION OF THE ENVIRONMENTAL ASSESSMENT

AND

FINDING OF NO SIGNIFICANT IMPACT AND RECORD OF DECISION

FOR

Mariana Islands Range Complex Airspace

1. INTRODUCTION

This document serves as the Federal Aviation Administration (FAA) adoption of the Mariana 

Islands Range Complex (MIRC) Airspace Environmental Assessment (EA)/Overseas 

Environmental Assessment (OEA) prepared by the Department of Navy (Navy). 

Pursuant to section 102 of the National Environmental Policy Act (NEPA) of 1969, as 

amended, the Council on Environmental Quality (CEQ) regulations (40 Code of Federal 

Regulations [C.F.R.] Parts 1500-1508) implementing the procedural provisions of NEPA, 

Executive Order (EO) 12114, Environmental Effects Abroad of Major Federal Actions, and 

Chief of Naval Operations Instruction 5090.1C CH-1, the United States (U.S.) Navy. The 

EA/OEA also complies with FAA Order 1050.1E, Appendix A (Analysis of Environmental 

Impact Categories). 

FAA Order 1050.1E was in effect when the Navy completed the EA/OEA. Per FAA Order 

1050.1 E, Paragraph 402a, since the FAA did not adopt the Navy’s EA within three years, the 

FAA must prepare a Written Re-Evaluation to determine whether the consideration of 

alternatives, impacts, existing environment, and mitigation measures set forth in the EA remain 

applicable. FAA Order 1050.1E was superseded on July 16, 2015 and replaced with FAA 

Order 1050.1F, which states the procedures in 1050.1F apply to the extent practicable to 

ongoing activities and environmental documents begun before the effective date. Therefore, 

this Written Re-Evaluation /Finding of No Significant Impact and Record of Decision have

been prepared in accordance with FAA Order 1050.1F. The FAA’s proposed rulemaking is 

subject to NEPA review per FAA Order 1050.1F, Paragraph 2-1.1.

2. BACKGROUND

The EA/OEA analyzes the potential environmental impacts associated with proposed changes 

to special use airspace (SUA), which includes establishment of new warning areas and the 

establishment of a new restricted area (RA). The new RA will encircle the existing R-7201

from three nautical miles (NM) to 12 NM around Farallon de Medinilla (FDM). The EA/OEA 

also focuses on the expansion of the Danger Zone (DZ) around FDM from 10 NM to 12 NM. 
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The proposed Warning Areas and the RA would provide a greater level of public health and 

safety by increasing the geographic extent of restrictions to all private and commercial aircraft 

during hazardous training and testing activities around FDM. The establishment of Warning 

Areas increases aviation safety by charting SUA, previously uncharted as Air Traffic Control

Assigned Airspace.

All military activities that are conducted in the MIRC are either scheduled or announced at 

least 72 hours prior to being conducted. Any potential conflicts with civilian routes and the 

proposed SUA have been minimized as a result of close coordination between the Navy and the 

FAA.

As the lead agency, the Navy published the EA/OEA in accordance with the National 

Environmental Policy Act (NEPA) and in accordance with the Memorandum of Understanding 

(MOU) between the FAA and Department of Defense (DoD), “Concerning Environmental 

Review of Special Use Airspace (SUA) Actions”, dated October 4, 2005.

The Navy invited the FAA to be a cooperating agency for this project because of its expertise 

and regulatory authority over the National Airspace System (JO 7400.2). By letter dated 

September 6, 2007, the Navy requested participation from the FAA as a cooperating agency (see

40 C.F.R. § 1501.6) in the preparation of an EIS to address the potential environmental impacts 

of proposed military training, research and development, and testing within the MIRC. By

letter dated October 9, 2007, the FAA, having responsibility for approving SUA under 49 U.S.C. 

section 40103(b)(3)(A), accepted the cooperating agency status.

The Navy released a Draft EIS/OEIS in January 2009 and a Final EIS/OEIS (FEIS) in May 

2010. The Navy issued their Record of Decision (ROD) on July 20, 2010. FAA received the 

Navy’s SUA Proposal after the completion of the FEIS in which the Navy requested 10 

changes to SUA. On August 17, 2011, FAA responded to the Navy that sufficient justification 

and requirements had not been identified to support the changes in the SUA proposal. FAA 

determined that two of the 10 proposals were infeasible, and another one did not have sufficient 

information to determine feasibility. Therefore, FAA could not issue a Letter of Adoption and 

Record of Decision for the FEIS due to these outstanding issues.

Subsequently, the Navy decided to split the Proposed Action as described in the FEIS into four 

separate Actions with four separate NEPA documents. The MIRC EA/OEA is one of the

Navy’s four separate Proposed Actions and includes the SUA subject to FAA’s approval. 

Although the Navy did not formally send another cooperating agency invitation request 

specific to the MIRC EA/OEA, the FAA acted as a Cooperating Agency and provided 

comments during the development of the EA/OEA to address issues raised by FAA on the 

2010 MIRC EIS/OEIS.

The Navy made no major changes to the SUA Proposal between the 2010 MIRC EIS/OEIS and 

the 2013 MIRC EA/OEA, but its justification for the changes was updated and accepted by 

FAA. As described in the EA/OEA, the level of training and testing activities that would occur 

within the airspace and sea space remains the same as those assessed and identified in the 

MIRC EIS/OEIS. The Navy’s Proposed Action in the EA/OEA does not include training 
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activities that differ in scope, nature, or location from those described in the Navy’s ROD for 

the MIRC FEIS/OEIS.

2.1 Navy Public Outreach on the EA/OEA

• On December 20, 2012, the MIRC Airspace Draft EA/OEA was posted on 

www.MIRCairspaceEA.com. The document was also made available at the following 

locations: Nieves M. Flores Memorial Public Library, University of Guam Robert F. 

Kennedy Memorial Library, Rota Public Library, Joeten-Kiyu Public Library, and Tinian 

Public Library.

• On January 15, 2013, a public open house regarding the Proposed Action was held on 

Guam at the University of Guam; on January 17, 2013, a public open house was held on 

Saipan at the Pedro P. Tenorio Center in Susupe. The open houses were attended by 

members of the public, elected officials or their representatives, and media.

• On February 4, 2013, the 45-day public comment period closed. The Navy received 11 

comments from individuals, elected officials, and government organizations in response 

to the Draft EA/OEA. Out of the 11 comments, a total of two were submitted during the 

open houses; the other comments were submitted using the online commenting form on 

the website or mailed via postal service.

o The Final EA/OEA was clarified to explain that the 12 NM Restricted Area would 

restrict all private and commercial (i.e. fishing) vessels from entering the area 

when, and only when, hazardous activities are scheduled.

o Other comments did not require any changes to the Final EA/OEA, such as noise 

at a commenter’s house and impacts to terrestrial endangered species, since they 

issue is outside the scope of the Proposed Action. 

The Navy issued their Finding of No Significant Impact (FONSI) and Finding of No Significant 

Harm for the MIRC EA/OEA on June 15, 2013.

2.2 FAA Aeronautical Process1

The aeronautical process typically takes place when the NEPA is well advanced. The actual 

timing depends on the complexity of the proposed action, its location, and how many FAA 

facilities are affected by the proposed action. For the Proposed MIRC SUA, the FAA determined 

the aeronautical study would be done after the Navy’s FONSI was issued.

The FAA had to delay the aeronautical study due to insufficient flight track data to complete the 

safety analyses. There was insufficient flight track data because radar coverage to collect flight 

track data for Guam and its surrounding airspace is limited due to terrain. To thoroughly assess 

the aeronautical impacts of the Proposed Action to air traffic operations, the FAA developed a 

flight track model to analyze flight path trajectories for arrivals and departures into A.B Won Pat 

International Airport on Guam. The modelled flight track data was developed as part of the 

preparation to complete the aeronautical study for the Proposed Action. The flight track 

modeling was not started until after the Navy issued their FONSI.

 1 FAA Joint Order 7400.2, Appendix 4. FAA Procedures for Processing SUA Actions describes how the steps of the 

FAA aeronautical and environmental processes overlap.
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Once the flight track data was modeled, as part of the FAA aeronautical process specific to the 

EA/OEA, the Guam Combined/Center Radar Approach Control (CERAP) completed an

aeronautical study of the proposal in February 2015. Per its assessment, changes to the proposed 

Warning Area 13 were made to reduce the impact to civilian traffic. The aeronautical study did 

not propose any changes to the boundaries of Warning Areas 11 and 12 and R-7201A.

During the processing for R-7201A, the FAA published a Notice of Proposed Rulemaking in the 

Federal Register (80 FR 51498) on August 25, 2015.The Docket number of the proposal is FAA2015-0739 and Airspace Docket No. 14-AWP-11. The comment period expired on October 9, 

2015, and no comments were received. On September 15, 2015, the FAA issued a circularization 

for public comment for Warning Areas 11, 12, and 13 with Docket No 15-AWP-4NR. No 

comments were received.

A Safety Risk Management Panel met on May 4, 2016 to assess the proposed change to the 

national airspace and associated hazards. Comments received as part of the NPRM and NFDD 

are typically considered during a SRM meeting, but since no comments were received, no 

comments had to be considered as part of the meeting. The members of the group agreed that the 

SUA expansion will enhance safety since charting increases SUA transparency and heightens 

communications and awareness for domestic and international airspace users. A Memorandum 

summarizing the Panel’s conclusions was issued June 10, 2016.

The FAA used the EA/OEA in its rulemaking for designation of restricted airspace and nonrulemaking processes for designations of warning areas to the airspace. FAA’s Airspace Policy 

Group is responsible for processing the special use airspace that overlies U.S. territories and 

possessions. Non-rulemaking airspaces are Military Operations Areas and warning areas.

The environmental review process by the FAA was sufficiently coordinated with the airspace 

analysis to have a consistency in the proposal and environmental impacts over the proposed 

areas.

2.3. Written Re-Evaluation (WR)

Since the Navy issued their FONSI on June 15, 2013, more than three years has elapsed, the 

FAA must prepare a WR of the relevant portion of the Navy’s EA/OEA in accordance with per 

FAA Order 1050.1F, paragraph 8-2.b. The purpose of a WR is to determine whether the MIRC 

EA/OEA remains valid or a new or supplemental environmental document is required.

As part of this WR, FAA found that the Navy’s Mariana Islands Training and Testing (MITT) 

EIS/OEIS, issued in May 2015, assumes the proposed SUA from the MIRC EA/OEA is 

established. The MITT EIS/OEIS proposes to increase training operations, add testing 

operations, and uses additional aircraft types that were not analyzed in the 2013 MIRC EA/OEA. 

The impacts resulting from this increase in operations are included in the Environmental Impacts 

of the Proposed Action section below.
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3. DESCRIPTION OF THE PROPOSED ACTION

The proposed FAA action for this WR/FONSI-ROD is solely the establishment of RA R7201A and the Warning Areas 11, 12, and 13. The Warning Areas will replace the existing Air 

Traffic Controlled Assigned Airspaces 1, 2, 3A, 3B, 3C, 5, and 6.

3.1 R-7201A Farallon De Medinilla Island, Mariana Islands.

The FAA is proposing an amendment to 14 C.F.R. Part 73 to establish R-7201A, which will 

encircle R-7201 from three NM to 12 NM. The new RA will be located in the vicinity of the

Farallon De Medinilla Island (FDM), Commonwealth of the Northern Mariana Islands. 

The boundary for R-7201A is described below:

Boundaries. That area from a 3-nautical mile radius outward to a 12-nautical mile radius of lat. 

16o01'04” N., long. 146o03’31” E.

Altitudes. Surface up to and including FL 600 

Times of use. As scheduled by Notice to Airmen (NOTAM) 12 hours in advance. 

Controlling agency. FAA, Guam Center/Radar Approach Control. 

Using agency. Commander, Joint Region Marianas.

The proposed addition of R–7201A would be to accommodate the minimum size required for 

containing stand-off weapons employment, naval gun fire training, and laser activities 

conducted there. The actual usage of the restricted area is estimated to be 4–5 days per week, 

3–6 hours per day with 1,680 sorties per year.

2

3.2 Warning Areas

FAA is also proposing to establish Warning Areas W-11A, W-11B, W-12, W-13A Low, W13B Low, W-13C Low, W-13A High, W-13B High, and W-13C High. The boundaries for the 

Warning Areas are described below:

3.2.1 W-11A Mariana Islands, Guam (GU).

Boundaries. Beginning at latitude 12o 50’ 00” N., longitude 145o 00’ 00” E.;

to latitude 12o 50’ 00” N., longitude 145o 10’ 00” E.;

to latitude 11o 32’ 00” N., longitude 146o 50’ 20” E.;

to latitude 11° 32’ 00” N., longitude 145° 11’ 00” E.;

to the point of beginning.

Altitudes. Surface up to and including FL 300 

Times of use. As scheduled by NOTAM 

Controlling agency. FAA, Guam Center/Radar Approach Control 

Using agency. Commander, Naval Forces, Marianas Naval Station, GU

 2 Department Of Transportation Federal Aviation Administration, 14 CFR Part 73, [Docket No. FAA–2015–0739; Airspace 

Docket No. 14–AWP–11], RIN 2120–AA66, Proposed Modification of Restricted, Area R–7201; Farallon De Medinilla Island; 

Mariana Islands, GU, AGENCY: Federal Aviation, Administration (FAA), DOT, ACTION: Notice of proposed rulemaking, 

(NPRM).
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3.2.2 W-11B Mariana Islands, GU.

Boundaries. Beginning at latitude 11o 32’ 00” N., longitude 146o 50’ 20” E.;

to latitude 11o 25’ 00” N., longitude 147o 00’ 00” E.;

to latitude 10o 30’ 00” N., longitude 147o 00’ 00” E.;

to latitude 10° 30’ 00” N., longitude 145° 20’ 00” E.;

to latitude 11° 32’ 00” N., longitude 145° 11’ 00” E.;

to the point of beginning.

Altitudes. Surface up to and including FL 300 

Times of use. As scheduled by NOTAM 

Controlling agency. FAA, Guam Center/Radar Approach Control 

Using agency. Commander, Naval Forces, Marianas Naval Station, GU

3.2.3 W-12 Mariana Islands, GU.

Boundaries. Beginning at latitude 11o00’00” N., longitude 143o00’00” E.;

to latitude 11o00’00” N., longitude 144o45’00” E.;

to latitude 10o30’00” N., longitude 144o45’00” E.;

to latitude 10°30’00” N., longitude 143°00’00” E.;

to the point of beginning.

Altitudes. Surface to unlimited 

Times of use. As scheduled by NOTAM 

Controlling agency. FAA, Guam Center/Radar Approach Control 

Using agency. Commander, Naval Forces, Marianas Naval Station, GU

4.2.4 W-13A Low Farallon De Medinilla Island, Mariana Islands.

Boundaries. Beginning at latitude 17°00’00” N., longitude 145°05’00 ” E.;

to latitude 17°00’00”N., longitude 146°27’40” E.,

to latitude 15°25’00” N., longitude 146°27’40” E.; 

to latitude 15°25’00” N., longitude 146°25’00” E.; 

to latitude 15°40’22” N., longitude 146°12’03” E.; 

to latitude 15°43’37” N., longitude 145°27’46” E.; 

to the point of beginning.

Altitudes. Surface up to and including FL 300 

Times of use. As scheduled by NOTAM

Controlling agency. FAA, Guam Center/Radar Approach Control 

Using agency. Commander, Naval Forces, Marianas Naval Station, GU

3.2.5 W-13B Low Farallon De Medinilla Island, Mariana Islands.

Boundaries. Beginning at latitude 17°00 00” N., longitude 146°27’40” E.; 

to latitude 17°00’00” N., longitude 147°00’00” E.; 

to latitude 16°09’28” N., longitude 148°09’46” E.; 
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to latitude 15°25’00” N., longitude 148°04’00” E.; 

to latitude 15°25’00” N., longitude 147°00’00” E.; 

to latitude 15°25’00” N., longitude 146°27’40” E.; 

to the point of beginning. 

Altitudes. Surface up to and including FL 300 

Times of use. As scheduled by NOTAM

Controlling agency. FAA, Guam Center/Radar Approach Control

Using agency. Commander, Naval Forces, Marianas Naval Station, GU

3.2.6 W-13C Low Farallon De Medinilla Island, Mariana Islands.

Boundaries. Beginning at latitude 15°25’00” N., longitude 148°04’00” E.; 

to latitude 15°25’00” N., longitude 146°25’00” E.; 

to latitude 14°16’00” N., longitude 146°25’00” E.; 

to latitude 14°45’00” N., longitude 148°00’00” E.; 

to the point of beginning.

Altitudes. Surface up to and including FL 300 

Times of use. As scheduled by NOTAM 

Controlling agency. FAA, Guam Center/Radar Approach Control 

Using agency. Commander, Naval Forces, Marianas Naval Station, GU

3.2.7 W-13A High Farallon De Medinilla Island, Mariana Islands.

Boundaries. Beginning at latitude 17°00’00” N., longitude 145°05’00” E.; 

to latitude 17°00’00” N., longitude 146°27’40” E.; 

to latitude 15°25’00” N., longitude 146°27’40” E.; 

to latitude 15°25’00” N., longitude 146°25’00” E.; 

to latitude 15°40’22” N., longitude 146°12’03” E.; 

to latitude 15°43’37” N., longitude 145°27’46” E.; 

to the point of beginning. 

Altitudes. FL 300 up to and including FL 600 

Times of use. As scheduled by NOTAM 

Controlling agency. FAA, Guam Center/Radar Approach Control 

Using agency. Commander, Naval Forces, Marianas Naval Station, GU

3.2.8 W-13B High Farallon De Medinilla Island, Mariana Islands.

Boundaries. Beginning at latitude 17°00’00” N., longitude 146°27’40” E.; 

to latitude 17°00’00” N., longitude 147°00’00” E.; 

to latitude 16°09’28” N., longitude 148°09’46” E.; 

to latitude 15°25’00” N., longitude 148°04’00” E.; 

to latitude 15°25’00” N., longitude 147°00’00” E.; 

to latitude 15°25’00” N., longitude 146°27’00” E.; 
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to the point of beginning. 

Altitudes. FL 300 up to and including FL 600 

Times of use. As scheduled by NOTAM 

Controlling agency. FAA, Guam Center/Radar Approach Control

Using agency. Commander, Naval Forces, Marianas Naval Station, GU

3.2.9 W-13C High Farallon De Medinilla Island, Mariana Islands.

Boundaries. Beginning at latitude 15°25’00” N, longitude 148°04’00” E; 

to latitude 15°25’00” N, longitude 146°25’00” E; 

to latitude 14°16’00” N, longitude 146°25’00” E; 

to latitude 14°45’00” N, longitude 148°00’00” E; 

to the point of beginning. 

Altitudes. FL 300 up to and including FL 600 

Times of use. As scheduled by NOTAM 

Controlling agency. FAA, Guam Center/Radar Approach Control 

Using agency. Commander, Naval Forces, Marianas Naval Station, GU

4. PURPOSE AND NEED

The purpose of the Proposed Action is to support the Navy’s requirements of maximizing 

public awareness of hazardous military training activities and to optimize safety and training 

efficiency. The Proposed Action is needed in order to support the Navy training activities that 

involve the use of advanced weapons systems.

5. ALTERNATIVES

5.1 The MIRC EA/OEA analyzed the potential environmental effects of three alternatives: 

Alternative 1, Alternative 2, and the No-Action Alternative. For each Alternative except the No 

Action Alternative, the proposed airspace changes are the same.

5.1.1 Alternative 1

Under Alternative 1, existing airspace within the MIRC would be modified to optimize public 

safety and training efficiency. Under Alternative 1, the Navy proposes to (1) extend the 

Restricted Area (R-7201) at FDM from 3 NM to 12 NM and designate the new RA as R-7201A 

and (2) create new Warning Areas (W), designated as W-11, W-12, and W-13, which, upon 

approval and implementation, would replace existing Air Traffic Control Assigned Airspace 1, 

2, and 3.
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5.1.2 Alternative 2 (Preferred Alternative)

Under Alternative 2, airspace within the MIRC would be modified as described under 

Alternative 1. In addition, the planned 10 NM DZ around FDM would be expanded to 12 NM

(congruent with proposed R-7201A). Alternative 2 is the preferred alternative because none of 

the other alternatives would be as effective in fulfilling the purpose of and need for the 

Proposed Action.

5.1.3 No Action Alternative

Under the No Action Alternative, training activities as defined by the 2010 MIRC EIS/OEIS 

and Navy ROD would continue as currently implemented or authorized, with no change to the 

existing three NM Restricted Area (R-7201) or the planned 10 NM surface DZ at FDM.

5.1.4 Alternatives Considered but Dismissed

As determined in the Test/Training Space Needs Statement developed by the 36th Air Base 

Wing at Andersen Air Force Base, Guam, there are no other feasible or reasonable airspace 

alternatives within the region. 

5.2 Preferred Alternatives from the 2010 MIRC and 2015 MITT EIS/OEIS

5.2.1 2010 MIRC EIS Proposed Alternative (Alternative 1)3

The Proposed Alternative 1 would include increased training as a result of upgrades and 

modernization of existing capabilities, and include establishment of a DZ and restricted area 

around FDM (a 10 NM zone around FDM to be established in accordance with C.F.R. Title 33 

§334.1; see Figure 2-3). Alternative 1 also includes training associated with ISR/Strike and other 

Andersen AFB initiatives. Training will also increase as a result of the development and 

deployment of new Portable Underwater Tracking Range (PUTR) capabilities. PUTR trains 

personnel in undersea warfare including conducting TRACKEX and TORPEX activities. 

Helicopter, ship, and submarine sonar systems will use this capability. Training activities will 

increase as a result of the development of a laser certified range area in W-517. This laser range 

capability will aid in the training of aircrews in the delivery of air-to-surface missiles against 

surface vessel targets. Primarily conducted in W-517, the weapon systems commonly used in 

this training activity are the laser guided HELLFIRE missile or an inert captive air training 

missile. The captive air training missile is a missile shape that contains electronics only, and it 

remains attached to the aircraft weapon mounting points. The MISSILEX involves in-flight laser 

designation and guidance, and arming and releasing of the air to surface weapon by aircraft, 

typically against a small stationary, towed, or maneuvering target; however a captive air training 

missile exercise (CATMEX) may be conducted against any laser reflective target mounted on or 

towed by a target support vessel.

5.2.2 MITT EIS Preferred Alternative4

The Navy proposes to conduct military readiness training and testing activities throughout the 

MITT Study Area. In order to achieve and maintain Fleet readiness, the Navy proposes to:

 3 The description of the 2010 MIRC EIS/OEIS only includes the elements relevant to the proposed SUA from the 

2013 MIRC EA. 

4 The description of the 2015 MITT EIS/OEIS only includes the elements relevant to the proposed SUA from the 

2013 MIRC EA.
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• Adjust baseline training and testing activities from current levels to the level needed to 

support military training and testing requirements beginning in 2015. As part of the 

adjustment, the Navy proposes to account for other activities and sound sources not 

addressed in the previous analyses.

• Analyze the potential environmental impacts of training and testing activities in 

additional at-sea areas (areas not covered in previous documents) where training and 

testing historically occurs, including Navy ports and the transit corridor serving these 

areas.

• Update the environmental impact analyses in the previous documents to account for force 

structure changes, including those resulting from the development, testing, and use of 

weapons, platforms, and systems that will be operational by 2020.

6. ENVIRONMENTAL IMPACTS OF THE PROPOSED ACTION

The FAA has completed an independent review and evaluation of the Navy’s EA/OEA in 

accordance with the CEQ regulations (see 40 C.F.R. § 1506.3(c)), FAA Order 1050.1F, and FAA

Order JO 7400.2K, “Procedures for Handling Airspace Matters.”

The following summarizes analyses in the EA/OEA and presents the results of the FAA’s 

independent review and evaluation regarding the potential environmental impacts of the FAA’s 

Proposed Action in each of the impact categories prescribed by FAA Order 1050.1F.

The Final EA/OEA examined potential impacts on public health and safety, transportation 

resources, regional economy, and recreation associated with each alternative. The Final EA/OEA 

did not analyze any resource areas that were adequately covered in the MIRC EIS/OEIS or that 

were not impacted by the Proposed Action, so information relevant to the impact category 

provided below is from both the 2013 MIRC EA/OEA and the 2010 MIRC EIS/OEIS. 

Additional information is also included from the 2015 MITT EIS/OEIS since it assumed the 

Proposed SUA is established, and the MITT increases training operations and includes additional 

aircraft types.

6.1 Environmental Impact Categories

6.1.1 Air Quality

6.1.1.1 MIRC EA/OEA

Proposed changes to the SUA and expansion of the DZ would not result in a change in total 

annual emissions because training activities would not differ in scope, nature, or location from 

those approved in the MIRC EIS/OEIS. 

6.1.1.2 MIRC 2010 EIS/OEIS Analysis

Evaluating aircraft emissions involves evaluating the type of training activities for each type of 

aircraft, the number of hours of operation for each aircraft type, the type of engine in each 

aircraft, and the mode of operation for each type of aircraft engine during training. Aircraft emit 

the following NAAQS criteria pollutants and precursors: Volatile Organic Compounds (VOCs), 

NOx, CO, SO2 and PM10. Emissions occurring above 3,000 feet AGL need not be addressed in 
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accordance with USEPA guidance (USEPA 1992). Aircraft flights, for the most part originate 

from an onshore air station (e.g., Andersen AFB), but some are from aircraft carriers offshore. It 

was assumed that all fixed wing aircraft would be traveling from Andersen AFB or an aircraft 

carrier to the ATCAAs, W-517 and R-7201 at elevations above 3,000 feet, and that transit to and 

from the airspaces would not affect local air quality. 

The MIRC EIS/OEIS determined that no significant impact on air quality would occur because 

all training events analyzed are within areas designated by the U.S. Environmental Protection 

Agency as being in attainment for all criteria pollutants, or in nonattainment areas for SO2 where 

the associated total annual emissions are less than the de minimis thresholds for General 

Conformity determination. 

6.1.1.3 MITT 2015 EIS/OEIS Analysis

Aircraft emissions were estimated assuming training and testing aircraft flights originated

offshore from aircraft carriers or other Navy vessels outfitted with flight decks and from North 

Field at Andersen Air Force Base. With the exception of helicopters, all aircraft are assumed to 

travel to and from training ranges at or above 3,000 feet above mean sea level and, therefore, 

their transits to and from the ranges do not affect surface air quality. Air combat maneuvers and 

air-to-air missile exercises are primarily conducted at altitudes well in excess of 3,000 feet above 

ground level and, therefore, are not included in the estimated emissions of criteria pollutants. 

Activities or portions of those training or testing activities occurring below 3,000 feet are 

included in emissions estimates. Examples of activities typically occurring below 3,000 feet 

include those involving helicopter platforms such as mine warfare, anti-surface warfare, and antisubmarine warfare training and testing activities.

Naval gunfire, missiles, bombs, and other types of munitions used in training and testing 

activities emit air pollutants. To estimate the amounts of air pollutants emitted by ordnance 

during use, the numbers and types of munitions used during training or testing activities are first 

totaled. Then, generally accepted emissions factors (AP-42, Compilation of Air Pollutant 

Emission Factors, Chapter 15: Ordnance Detonation [U.S. Environmental Protection Agency 

1995]) for criteria pollutants are applied to the total amounts. Finally, the total amounts of air 

pollutants emitted by each munition type are summed to produce total amounts of each criteria 

pollutant under each alternative.

Under the Proposed Action, the annual numbers of Navy training and testing activities in the 

Study Area would increase. Emissions of all criteria pollutants would increase. Criteria 

pollutants emitted in the Study Area within territorial waters could be transported ashore but 

would not affect the attainment status of the relevant air quality control regions. The amounts of 

air pollutants emitted in the Study Area and subsequently transported ashore would be minor 

because (1) the pollutants are emitted over large areas (i.e., the Study Area is an area source), (2) 

the distances the air pollutants would be transported are often large, and (3) the pollutants would 

be substantially dispersed during transport.
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Estimated Annual Criteria pollutant Emissions in the Study Area

Source Emissions by Air Pollutant (TPY)

CO NOx VOC SOx PM10 PM2.5 Total

Training Activities 1,052 1,436 210 677 459 412 4,246

Testing Activities 265 186 25 36 20 17 549

Total MITT Study 

Area

1,317 1,622 235 713 479 429 4,759

Emissions associated with the entire Study Area training and testing under the Proposed Action

primarily occur offshore. Fixed-wing aircraft emissions typically occur above the 3,000 feet 

mixing layer. Even though these stressors can co-occur in time and space, atmospheric 

dispersion would occur so that the impacts would be short term. Changes in criteria and 

hazardous air pollutant emissions are not expected to be detectable, so the air quality is expected 

to fully recover before a subsequent activity. For these reasons, impacts on air quality from 

combining these resource stressors are expected to be similar to the impacts on air quality for any 

of these stressors taken individually with no additive, synergistic, or antagonistic interactions. 

Emissions of most criteria pollutants and hazardous air pollutants are expected to increase under 

Alternative 1.

6.1.1.4 Conclusion

The FAA significant impact threshold for air quality would be met if the proposed Action would 

cause pollutant concentrations to exceed one or more of the National Ambient Air Quality 

Standards (NAAQS), as established by the Environmental Protection Agency under the Clean 

Air Act, for any of the time periods analyzed, or to increase the frequency or severity of any such 

existing violations. FAA verified that the area is still in attainment in October 2016. In addition, 

the majority of training activities (sorties) occur more than 12 NM from the shore and above 

3,000 ft. Because of the distances from land, these activities would have little to no impact on 

local air quality. Per the analysis in this Air Quality section above, the FAA has determined that 

the project will have less than significant impacts on air quality.

6.2 Biological Resources (including fish, wildlife, and plants)

6.2.1 MIRC EA/OEA

The Proposed Action would not change the manner of use or quality of land, water, or other 

coastal resources or limit the range of their uses as those analyzed in the MIRC EIS/OEIS. 

Proposed changes to the SUA and expansion of the sea space, or DZ, would not result in a 

change in the level of training activities and they would not differ in scope, nature, or location 

from those approved in the MIRC EIS/OEIS. 

6.2.2 MIRC 2010 EIS/OEIS Analysis

The MIRC EIS/OEIS determined that no significant impact on these species would occur 

because aircraft overflights would occur over marine environments at elevations in excess of 

3,000 feet above sea level and beyond three NM. Based on the analysis presented in the MIRC 

EIS/OEIS for aircraft overflights, marine mammals, sea turtles, seabirds and shorebirds, and 

terrestrial species would likely exhibit no response, or may change their behavior to avoid the 
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disturbance. Any behavioral avoidance reaction would be short-term and would not permanently 

displace animals or result in physical harm. Overflights would not be expected to result in 

chronic stress to these species, because it is extremely unlikely that individuals of each of these 

species would be repeatedly exposed to low-altitude overflights. Mitigation measures to avoid or 

minimize impacts would continue to be conducted in accordance with established policies and 

restrictions to conserve and protect resources. 

6.2.3 MITT 2015 EIS/OEIS Analysis

The proposed SUA includes R-7201A. Some of the Navy’s training and testing activities with 

live ordnance can only happen within the RA, therefore, impacts to wildlife within the ocean are 

considered below.

6.2.3.1 Wildlife

Whales

There are 15 whale species potentially found in the Study Area. Five of the 15 are listed under 

the Endangered Species Act (ESA) as endangered. The endangered species are: humpback whale 

(Megaptera novaeangliae), blue whale (Balaenoptera musculus), fin whale (Balaenoptera 

physalus), sei whale (Balenoptera ), and the sperm whale (Physeter microcephalus). The 

remaining 10 whales are Bryde’s whale (Balaenoptera brydei/edeni), Minke whale (Balaenoptera 

actorostrata), Omura’s whale (Balaenoptera omurai), pygmy sperm whale (Kogia breviceps), 

dwarf sperm whale (Kogia sima), killer whale (Orcinus orca), false killer whale (Pseudorca 

crassidens), pygmy killer whale (Feresa attenuata), short-finned pilot whale (Globicephala 

macrorhynchus), and the melon-headed whale (Peponocephala electra).

Dolphins

There are two dolphins potentially found in the Study Area. Neither are listed under ESA.

Sea Turtles

There are five sea turtle species potentially found in the Study Area are listed under ESA as 

endangered or threatened. The five species are: the green sea turtle (Chelonian mydas -

threatened), the hawksbill sea turtle (Eretmochelys imbricate - endangered), the loggerhead sea 

turtle (Caretta caretta - endangered), the olive ridley sea turtle (Lepidochelys olivacea -

threatened), and the leatherback sea turtle (Dermochelys coriacea - endangered).

Birds

Seabirds are birds whose normal habitat and food source is the sea, whether they utilize coastal 

waters (the nearshore), offshore waters, or pelagic waters (the open sea). Three seabirds that 

occur in the Study Area are listed under the ESA as threatened or endangered species. The shorttailed albatross (Phoebastria albatrus) and Hawaiian petrel (Pterodroma sandwichensis) are 

listed as endangered, and the Newell’s shearwater (Puffinus auricularis newelii) is listed as 

threatened. The Hawaiian petrel and Newell’s shearwater rarely occur within the Study Area.

6.2.3.1.1 Impacts from Aircraft Noise

The Proposed Action includes fixed- and rotary-wing aircraft overflights used for a variety of 

training and testing activities throughout the Study Area. More than 19,600 training activities 

involving some level of aircraft activity are proposed under the Proposed Action, as opposed to 
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5,300 in the No Action Alternative. Most fixed-wing military aircraft flights would occur above 

3,000 feet, and often at much higher altitudes (e.g., 20,000 feet) in the Study Area. Rotary wing 

aircraft typically fly at lower altitudes (less than 1,000 feet) and may hover at less than 100 feet 

during certain training and testing activities.

In most cases, exposure of animals to fixed-wing or rotary-wing aircraft presence and noise 

would last for only seconds 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. 

Takeoffs and landings occur at established airfields as well as on vessels at sea at unspecified 

locations across the Study Area. Takeoff and landings from Navy vessels could startle animals; 

however, these events only produce in-water noise at any given location for a brief period of 

time as the aircraft climbs to cruising altitude.

Helicopters

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. Underwater sounds from 

aircraft are strongest just below the surface and directly under the aircraft.

6.2.3.1.1.1 Training Activities

Marine Mammals

Whales and dolphins (marine mammals) 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. 

Marine mammals show little to no reaction from aircraft overflights above 2,000 feet. Some 

sonic booms from aircraft could startle marine mammals, but these events are transient and 

happen infrequently at any given location within the Study Area. Repeated exposure to most 

individuals over short periods (days) is extremely unlikely. No long-term consequences for 

individuals or populations would be expected. 

Low flight altitudes of helicopters during some anti-submarine warfare and mine warfare 

activities, often under 100 feet, may elicit a somewhat stronger behavioral response due to the 

proximity to marine mammals; the slower airspeed and therefore longer exposure duration; and 

the downdraft created by the helicopter's rotor. Marine mammals would likely avoid the area 

under the helicopter. It is unlikely that an individual would be exposed repeatedly for long 

periods of time as these aircraft typically transit open ocean areas within the Study Area. Marine 

mammals located at or near the surface when an aircraft flies overhead at low altitudes may 

startle, divert their attention to the aircraft, or avoid the immediate area by swimming away or 

diving.

The number of overflights, typical altitudes, and distribution throughout the year and over the 

Study Area would result in a low probability of exposing marine mammals to aircraft noise. No 

long-term consequences for individuals or populations would be expected. 
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Pursuant to the Marine Mammal Protection Act (MMPA), aircraft overflight noise during 

training activities under the Proposed Action is not expected to result in Level A or Level B 

harassment of marine mammals. Pursuant to the ESA, aircraft overflight noise during training 

activities as described under the No Action Alternative:

• May affect, but is not likely to adversely affect the blue whale, fin whale, humpback 

whale, sei whale, and sperm whale

Sea Turtles

Sea turtles may respond to both the physical presence and to the noise generated by aircraft, 

making causation by one or the other stimulus difficult to determine. In addition to noise, all 

low-flying aircraft create shadows, to which animals at the surface may 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 sea turtle to fixed-wing or rotary-wing aircraft would last for only 

seconds as the aircraft quickly passes overhead. Sea turtles would have to be at or near the 

surface at the time of an overflight to be exposed to appreciable noise levels. Take-offs and 

landings occur as on vessels at sea across the Study Area. Take-offs and landings from Navy 

vessels could startle sea turtles; however, these activities only produce in-water noise at any 

given location for a brief period as the aircraft climbs to cruising altitude. Some sonic booms 

from aircraft could startle sea turtles, but these activities are transient and happen infrequently at 

any given location within the Study Area. Repeated exposure to most individuals over short 

periods (days) is unlikely, except for animals that reside in nearshore areas around Navy ports, or 

on Navy fixed-ranges, or during major training exercises.

Low flight altitudes of helicopters during some activities, which often occur under 100 feet 

altitude, may elicit a somewhat stronger behavioral response due to the proximity to the water; 

the slower airspeed and therefore longer exposure duration; and the downdraft created by the 

helicopter’s rotor. Sea turtles would likely avoid the area under the helicopter. An individual 

likely would not be exposed repeatedly for long periods because these activities typically transit 

open ocean areas within the Study Area.

Significant behavioral reactions by sea turtles due to passing aircraft noise are not expected, even 

though the noise may cause short-term impacts, no long-term consequences for individuals or 

populations would be expected.

Pursuant to the ESA, noise from vessels and aircraft during training activities under the 

Proposed Action may affect, but is not likely to adversely affect, green, hawksbill, loggerhead, 

olive ridley, and leatherback sea turtles.

Birds 

Under the Proposed Action, seabirds and migratory birds may be exposed to more sonic booms 

infrequently while flying or foraging in the Study Area. Occasional startle or alert reactions to 

aircraft are not likely to disrupt major behavior patterns (such as migrating, breeding, feeding, 

and sheltering) or to result in serious injury to any seabirds. Helicopter overflights would be 

more likely to elicit responses than fixed-wing aircraft, but the general health of individual birds 
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would not be compromised. For these reasons, the impact of noise produced by Navy aircraft and 

vessels on seabirds under the Proposed Action would be minor and short-term. Short-term 

impacts on individual birds are not expected to impact seabird populations.

Pursuant to the ESA, aircraft and vessel noise generated during training activities under the 

Proposed Action would have no effect on the Hawaiian petrel, Newell’s shearwater, or shorttailed albatross. Under the MBTA regulations applicable to military readiness activities (50 

C.F.R. Part 21), aircraft and vessel noise generated during training activities under the 

Proposed Aciton would not result in a significant adverse effect on populations of the great 

frigatebird, masked booby, or other marine bird populations.

6.2.3.1.1.2 Testing Activities

Under Proposed Action, up to 390 aircraft-related testing activities would occur throughout the 

Study Area. The locations and flight profiles (altitude, airspeed, and duration) of testing activities 

involving aircraft would be similar to training activities involving aircraft. Even with an increase 

in the number of aircraft overflights, the majority of flight time would occur at altitudes greater 

than 3,000 feet above the water’s surface. 

Testing activities proposed under the Proposed Action would increase Navy aircraft overflights, 

increasing overall amounts of aircraft noise. Overall noise levels may increase in these 

environments.

Whales

Marine mammals are unlikely to be disturbed by high altitude overflights.

Pursuant to the MMPA, aircraft overflight noise during testing activities under Proposed Action

is not expected to result in Level A or Level B harassment of marine mammals. Pursuant to the 

ESA, aircraft overflight noise during testing activities as described under the Proposed Action:

• May affect, but is not likely to adversely affect the blue whale, fin whale, humpback 

whale, sei whale, and sperm whale

Sea Turtles

Although more sea turtle exposures to noise from aircraft could occur, sea turtles exposed to a 

passing Navy aircraft may not respond at all, or they may exhibit a short-term behavioral 

response such as avoidance or changing dive behavior. Short-term reactions to aircraft are not 

likely to disrupt major behavioral patterns or to result in serious injury to any sea turtles. 

Significant behavioral reactions by sea turtles due to passing vessel or aircraft noise are not 

expected. Even though the noise may cause short-term impacts, no long-term consequences for 

individuals or populations would be expected.

Pursuant to the ESA, noise from vessels and aircraft during testing activities under the Proposed 

Action may affect, but is not likely to adversely affect, green, hawksbill, loggerhead, olive ridley, 

and leatherback sea turtles.

Birds

The testing activities are specific to Navy vessels, and are not dependent on the proposed SUA.
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6.2.3.1.2 Impacts from Weapons Firing, Launch, and Impact Noise

Anti-surface warfare activities and anti-air warfare (surface-to-air) activities would involve the 

use of non-explosive and explosive ordnance such as small-, medium-, and large-caliber 

projectiles; missiles; rockets; and bombs. 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. These sounds would be transient and of short duration, lasting no more than a few 

seconds at any given location. Many missiles and targets are launched from aircraft, which 

would produce minimal noise in the water due to the altitude of the aircraft at launch. Missiles 

and targets launched by ships or near the water's surface may expose animals to levels of sound 

that could produce brief startle reactions, avoidance, or diving. Most activities would consist of 

single launches. Non-explosive bombs, missiles, and targets could impact the water with great 

force and produce a short duration impulse noise underwater that would depend on the size, 

weight, and speed of the object at impact. Due to the short-term, transient nature of launch noise, 

animals are unlikely to be exposed multiple times within a short period. Behavioral reactions 

would likely be short-term (minutes).

Training Activities

Marine Mammals

Marine mammals may be exposed to weapons firing and launch noise and sound from the impact 

of non-explosive ordnance on the water's surface. Reactions by marine mammals to these

specific stressors have not been recorded, however marine mammals would be expected to react 

to weapons firing, launch, and non-explosive impact noise as they would other transient sounds.

Pursuant to the MMPA, weapons firing, launch, and non-explosive impact noise during training 

activities under Proposed Action is not expected to result in Level A or Level B harassment of 

marine mammals. Pursuant to the ESA, weapons firing, launch, and non-explosive impact noise 

during training activities as described under the Proposed Action:

• May affect, but is not likely to adversely affect the blue whale, fin whale, humpback 

whale, sei whale, and sperm whale

Sea Turtles

Because model-predicted impacts are conservative and most impacts would be short-term, 

potential impacts are not expected to result in substantial changes to behavior, growth, survival, 

annual reproductive success, lifetime reproductive success (fitness), or species recruitment. 

Although a few individuals may experience long-term impacts and potential mortality, 

population-level impacts are not expected.

Pursuant to the ESA, noise from weapons firing, launch, and non-explosive impact during 

training activities under the Proposed Action may affect, but is not likely to adversely affect 

green, hawksbill, loggerhead, olive ridley, and leatherback sea turtles.

Birds

Impacts from weapons firing, launch and impact noise are covered under the Impacts from 

Aircraft Noise section above.
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Testing Activities

The Proposed Action adjusts to the location, type, and tempo of training and testing activities, 

which includes the addition of platforms and systems. Testing activities that produce in-water 

noise from weapons firing, launch, and non-explosive ordnance impact with the water's surface 

would occur under the Proposed Action. The majority of testing activities that would involve 

weapons firing and ordnance impacts with the water’s surface are Air-to-Surface Missile Test, 

Anti-Submarine Warfare Tracking Test – Maritime Patrol Aircraft (Sonobuoy), Anti-Surface 

Warfare Mission Package Testing, and Kinetic Energy Weapon Testing.

Marine Mammals

The testing activities would use both non-explosive and explosive medium-caliber rounds, largecaliber projectiles, and missiles. The locations, types, and severity of impacts would not be 

discernible from those described above in Training Activities above.

Pursuant to the MMPA, weapons firing, launch, and non-explosive impact noise during testing 

activities under the Proposed Action is not expected to result in Level A or Level B harassment of 

marine mammals. Pursuant to the ESA, weapons firing, launch, and non-explosive impact noise 

during testing activities as described under the Proposed Action:

• May affect, but is not likely to adversely affect the blue whale, fin whale, humpback 

whale, sei whale, and sperm whale

Sea Turtles

Any behavioral reactions would likely be short-term and consist of brief startle reactions, 

avoidance, or diving. Any significant behavioral reactions could lead to a sea turtle expending 

energy and missing opportunities to secure resources. However, because most activities would 

consist of a limited number of firings or launches and would not occur over long durations, there 

would be an opportunity to recover from an incurred energy cost. Although some individuals 

may be impacted by activities that include weapons firing, launch, and non-explosive impact, 

population-level impacts are not expected.

Pursuant to the ESA, noise from weapons firing, launch, and non-explosive impact during testing 

activities under Alternative 1 may affect, but is not likely to adversely affect green, hawksbill, 

loggerhead, olive ridley, and leatherback sea turtles.

Birds

Impacts from weapons firing, launch and impact noise are covered under the Impacts from 

Aircraft Noise section above.

6.2.3.1.3 Impacts from Military Expended Materials

A wide variety of expended materials are used during training and testing activities. Military 

expended materials used in the Study Area include all sizes of non-explosive practice munitions, 

fragments from explosive munitions, and expended materials other than ordnance, such as 

sonobuoys. The number of small-caliber projectiles that would be expended annually during 

gunnery exercises is much higher than the number of large-caliber projectiles. However, the total 

number of rounds expended is not a good indicator of strike probability during gunnery exercises 

because multiple rounds are fired at individual targets.
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There is a strike potential to animals from the following categories of military expended 

materials: (1) non-explosive practice munitions; (2) fragments from high-explosive munitions;

and (3) expended materials other than ordnance, such as sonobuoys, and expendable targets. 

While disturbance or strike from an item falling through the water column is possible, it is not 

very likely because the objects generally sink slowly through the water and can be avoided by 

most marine animals. 

While no strike from military expended materials has ever been reported or recorded, the 

possibility of a strike still exists. Animals that occur in the Study Area may be exposed to the 

risk of military expended material strike. The critical habitat would not be impacted by military 

expended materials as a physical disturbance and strike stressor. 

Training and Testing Activities

Marine Mammals

Under the Proposed Action, the strike potential to marine mammals ranges from zero (i.e., or a 

zero percent chance of a strike by a military expended material over the course of a year) to a 

high of approximately eight one-hundredths of one percent (0.08 percent) of a chance of being

struck by a military expended material. 

The increase in expended materials results in a corresponding increase of the risk of a strike, but 

it does not change the underlying conclusion that the use of military expended materials is not 

expected to result in the physical disturbance or a strike of marine mammals. Furthermore, Navy 

mitigation measures addressing the use of sonobuoys and other military expended materials 

require that the area is clear of marine mammals before deploying sonobuoys or other types of 

military expended materials.

Pursuant to the MMPA, the use of military expended materials during training or testing 

activities under the Proposed Action are not expected to result in Level A or Level B harassment 

of marine mammals. Pursuant to the ESA, the use of military expended materials during training 

or testing activities as described under the Proposed Action:

• May affect, but is not likely to adversely affect the blue whale, fin whale, humpback 

whale, sei whale, and sperm whale

Sea Turtles

While disturbance or strike from an item as it falls through the water column is possible, it is not 

very likely because the objects generally sink through the water slowly and can be avoided by 

most sea turtles. 

Training Activities

With the exception of those used at FDM, the majority of military expended materials (bombs, 

medium and large-caliber projectiles, and missiles) are all used in areas of the Study Area greater 

than 3 NM from shorelines, and the larger of these (bombs, missiles, large-caliber projectiles) are 

restricted to use in areas greater than 3 NM from shore. Small caliber projectiles would be used 

throughout the Study Area. The probabilities of a strike in the open ocean portion of the Study 
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Area, where the majority of materials are expended, is less than 0.00001 percent for all species 

of sea turtles.

Any of the 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. These species are 

distributed widely in all offshore portions of the Study Area. Under the Proposed Action,

exposures to military-expended materials used in training activities may cause short-term 

disturbance to an individual turtle, or, if struck, it could lead to injury or death. Potential impacts 

of exposure to military-expended materials 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 military-expended materials are not expected to 

result in population-level impacts.

There is a very low potential for aberrant ordnance to impact offshore waters near FDM on sea 

turtles for areas where ordnance is targeted (expected to fall), and probabilities of strike were 

calculated to be near zero percent. Based on this calculation, it is even more unlikely for a direct 

strike on a sea turtle or marine mammal from aberrant ordnance at FDM.

Pursuant to the ESA, the use military expended materials during training activities as described 

in the Proposed Action may affect, but is not likely to adversely affect, green, hawksbill, 

loggerhead, olive ridley, or leatherback sea turtles.

Testing Activities

Activities that could generate military expended materials would increase, and could take place 

throughout the Study Area. Similar to those for training activities, consequences of strikes or 

disturbances could include injury or mortality, particularly within the footprint of the object. The 

probabilities of a strike in the open ocean portion of the Study Area, where the majority of 

materials are expended, is less than 0.00001 percent for all species of sea turtles.

Under the Proposed Action, exposures to military expended materials used in testing activities 

may cause short-term disturbance to an individual turtle, or if struck, it could lead to injury or 

death. Potential impacts of exposure to military expended materials may result in changes to an 

individual’s behavior, growth, survival, annual reproductive success, lifetime reproductive 

success (fitness), or species recruitment. The fitness of individual organisms could be impacted 

directly or indirectly, but not to the extent that the viability of populations or species would be 

impacted, primarily because the possibility of strike is so low.

Pursuant to the ESA, the use military expended materials during testing activities as described in 

the No Action Alternative, Alternative 1, and Alternative 2 may affect, but is not likely to 

adversely affect, green, hawksbill, loggerhead, olive ridley, or leatherback sea turtles.

Birds

Exposure of birds to military expended materials during Navy training and testing activities 

could result in physical injury or behavioral disturbances to birds in air, at the surface, or 

underwater during foraging dives. Although a quantitative analysis is not possible due to the 

absence of bird density information in the Study Area, an assessment of the likelihood of 
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exposure to military expended materials was conducted based on general bird distributions in the 

Study Area.

The number of large-caliber projectiles and other large munitions (e.g., bombs, rockets, missiles) 

that would be expended in the Study Area annually at sea, coupled with the often patchy pelagic 

distribution of seabirds (Fauchald et al. 2002, Haney 1986), suggest that the likelihood of this 

type of strike for a seabird would be extremely low at sea.

Pursuant to the ESA, the use of military expended materials during testing activities under the 

Proposed Action would have no effect on the Hawaiian petrel, Newell’s shearwater, or shorttailed albatross. Under the MBTA regulations applicable to military readiness activities (50 

C.F.R. Part 21), the use of military expended materials during testing activities under the 

Proposed Action would not result in a significant adverse effect on populations of the great 

frigatebird, masked booby, or other marine bird populations.

6.2.3.1.4 Impacts from Explosive and Non-explosive Practice Munitions

Under the Proposed Action, approximately 97,000 explosive munitions and non-explosive 

practice munitions considered an ingestion risk would be used during training activities annually 

in the Study Area. Of that total, 86,000 are non-explosive, small-caliber projectiles, and the 

remaining are explosive munitions, including bombs, medium- and large-caliber projectiles, 

missiles, and rockets, that could introduce fragments potentially small enough to be ingested by a 

bottom feeding marine mammal. The number of explosive munitions and non-explosive practice

munitions proposed under the Proposed Action represents an increase of 57 percent over the 

number proposed under the No Action Alternative. All explosive bombs, missiles, rockets, and 

large-caliber projectiles would be used over deep, offshore waters greater than 12 NM (and in 

some cases greater than 50 NM) from shore. Approximately 45 percent of non-explosive, smallcaliber projectiles would be expended greater than 12 NM from shore, and 98 percent of 

explosive medium-caliber projectiles would be expended greater than 12 NM from shore.

Training Activities

Marine Mammals

The number of munitions and explosive munitions fragments that an individual animal could 

encounter would generally be low, based on the patchy distribution of both the munitions and an 

animal’s feeding habitat. In addition, an animal would not ingest every munitions or munitions 

fragment it encountered, and if a munition or munitions fragment were ingested, an animal may 

attempt to reject it when it realizes the item is not food. Wells et al. (2008) showed that even 

ingestion of certain items (e.g., hooks), if they do not become embedded in tissue, may not result 

in injury or mortality to the individual. Therefore, potential impacts of munitions ingestion 

would be limited to the unlikely event where a marine mammal might ingest an item that 

subsequently becomes embedded in tissue or is too large to be passed through the digestive 

system. 

Pursuant to the MMPA, ingestion of munitions used during training activities under the 

Proposed Action is not expected to result in Level A or Level B harassment of marine mammals.

Pursuant to the ESA, ingestion of munitions used during training activities as described under 

the Proposed Action:
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• May affect, but is not likely to adversely affect the blue whale, fin whale, humpback 

whale, sei whale, and sperm whale

Sea Turtles

Ingestion of expended materials by sea turtles could occur in all 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. Floating material could be eaten by turtles 

such as leatherbacks that feed at or near the water surface, while materials that sink to the 

seafloor pose a risk to bottom-feeding turtles such as loggerheads. Only small or medium caliber 

projectiles would be small enough for a sea turtle to ingest.

The expected impact on any exposed sea turtle due to ingestion of munitions used in training 

activities may cause short-term or long-term disturbance to an individual turtle. Potential impacts 

of exposure to munitions are not expected to result in population-level impacts.

Pursuant to the ESA, the use of munitions of ingestible size during training activities under the 

Proposed Action would have no effect on leatherback sea turtles. The use of munitions of 

ingestible size may affect, but is not likely to adversely affect green, hawksbill, loggerhead, and 

olive ridley sea turtles.

Birds

The majority impacts to birds from occur on land at their nesting sites, which are outside the 

proposed SUA.

Expending of military materials may coincide with transiting short-tailed albatrosses through 

training areas; however, the rarity of this species in general and the lack of frequent sightings, 

chances for its potential interactions with training exercises would be extremely low. The spatial 

and temporal variability of both the occurrence of a short-tailed albatross and the training 

activities conducted within offshore locations near foraging areas presents an improbable chance 

that a direct or indirect effect would occur to this species. The known ranges of Hawaiian petrels 

and Newell’s shearwaters may overlap with the transit corridor and do not overlap with land 

training areas or surrounding coastal areas.

Pursuant to the ESA, the use of military expended materials during training activities under the 

No Action Alternative would have no effect on the Hawaiian petrel, Newell’s shearwater, or 

short-tailed albatross. Under the MBTA regulations applicable to military readiness activities 

(50 C.F.R. Part 21), the use of military expended materials during training activities under the 

the Proposed Action would not result in a significant adverse effect on populations of the great 

frigatebird, masked booby, or other marine bird populations.

Testing Activities

Marine Mammals

Under the Proposed Action, approximately 11,000 explosive munitions and non-explosive 

practice munitions considered an ingestion risk would be used during testing activities annually 

in the Study Area. Of that total, approximately 4,000 are non-explosive, small-caliber or 

medium-caliber projectiles, and the remaining 7,000 are explosive munitions. Eighty-seven 
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percent of the explosive munitions are medium- and large-caliber projectiles, and the remaining 

13 percent are missiles, rockets, and torpedoes.

Explosive munitions could introduce fragments potentially small enough to be ingested by a 

bottom feeding marine mammal. The number of munitions and explosive munitions fragments 

that an individual animal could encounter would generally be low, based on the patchy 

distribution of both the munitions and an animal’s feeding habitat. In addition, an animal would 

not ingest every munitions or munitions fragment it encountered, and if a munition or munitions 

fragment were ingested, an animal may attempt to reject it when it realizes the item is not food. 

Therefore, potential impacts of munitions ingestion would be limited to the unlikely event where 

a marine mammal might ingest an item that subsequently becomes embedded in tissue or is too 

large to be passed through the digestive system. 

Pursuant to the MMPA, ingestion of munitions used during testing activities under the Proposed 

Action is not expected to result in Level A or Level B harassment of marine mammals. Pursuant 

to the ESA, ingestion of munitions used during testing activities as described under the Proposed 

Action:

• May affect, but is not likely to adversely affect the blue whale, fin whale, humpback 

whale, sei whale, and sperm whale

Sea Turtles

Sub-lethal effects due to ingestion of munitions used in testing activities may cause short-term or 

long-term disturbance to an individual. Potential impacts of exposure to munitions may result in 

changes to an individual’s behavior, growth, survival, annual reproductive success, lifetime 

reproductive success (fitness), or species recruitment. However, munitions used in testing 

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. Potential impacts of exposure to munitions are not 

expected to result in population-level impacts.

Pursuant to the ESA, the use of munitions of ingestible size during testing activities under 

Alternative 1 would have no effect on leatherback sea turtles. The use of munitions of ingestible 

size may affect, but is not likely to adversely affect green, hawksbill, loggerhead, and olive ridley 

sea turtles.

Birds

Impacts to birds from Explosive and Non-explosive Practice Munitions is covered under the 

Military Expended Materials section 7.2.3.1.3 of this FONSI-ROD.

6.2.3.1.5 Impacts from Military Expended Materials Other than Munitions

Training activities would release military expended materials other than munitions in the Study 

Area increase by approximately 300 percent. Target-related material, chaff, flares, and their 

subcomponents have the potential to be ingested by animals. Although most of these materials 

would quickly drop through the water column and settle on the seafloor, some Styrofoam, plastic 
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endcaps, and other small items may float for some time before sinking. Under the Proposed 

Action, approximately 63,000 military expended materials other than munitions would be used 

during training activities. Approximately 80 percent of these items are chaff and flares, all of 

which would be expended in deep waters beyond 12 NM from shore.

Chaff

Some animals 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 

animals would occasionally come in direct contact with chaff fibers while at the water’s surface 

and while submerged, but such contact would be inconsequential. Animals could occasionally 

ingest low concentrations of chaff incidentally from the surface, water column, or seafloor. 

While no studies were conducted to evaluate the effects of chaff ingestion on animals, the effects 

are expected to be negligible, based on the low concentrations that could reasonably be ingested, 

the small size of chaff fibers, and available data on the toxicity of chaff and aluminum.

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 animals. Chaff end caps and 

pistons sink in saltwater (Spargo 2007), which reduces the likelihood of ingestion by animals at 

the surface or in the water column.

Flares 

Flares are designed to burn completely. The only material that would enter the water would be a 

small, round, plastic end cap and piston (approximately 1.4 inch in diameter). Animals within the 

vicinity of flares could be exposed to light generated by the flares. Pistons and end caps from 

flares would have the same impact on animals as discussed under chaff cartridges. It is unlikely 

that animals 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.

Training Activities

Marine Mammals

The impacts of ingesting these forms of expended materials on marine mammals would be minor 

because of the limited geographic area where materials and other than ordnance 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 marine mammal might encounter and swallow 

these items on the sea floor, particularly given that many of these items would be expended over 

deep, offshore waters; and the ability of many marine mammals to reject and not swallow nonfood items incidentally ingested.

The impacts of ingesting military expended materials other than munitions would be limited to

cases where an individual marine mammal might eat an indigestible item too large to be passed 

through the gut. The marine mammals would not be preferentially attracted to these military 

expended materials. 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. Non-munition military expended materials that would remain floating on 
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the surface are too small to pose a risk of intestinal blockage to any marine mammal that 

happened to encounter it.

Pursuant to the MMPA, the use of military expended materials other than munitions during 

training activities under the Proposed Action is not expected to result in Level A or Level B 

harassment of marine mammals. Pursuant to the ESA, the use of military expended materials 

other than munitions during training activities as described under the Proposed Action:

• May affect, but is not likely to adversely affect the blue whale, fin whale, humpback 

whale, sei whale, and sperm whale

Sea Turtles

Because leatherbacks are more likely to feed at or near the surface, they are more likely to 

encounter materials at the surface than are other species of turtles that primarily feed along the 

seafloor. Furthermore, leatherbacks typically feed in the open ocean, while other species are 

more likely to feed in nearshore areas. Though they are bottom-feeding species that generally 

feed nearshore, green, hawksbill, olive ridley and loggerhead sea turtles may occur in the open 

ocean during migrations. The increase in training activities presented in the Proposed Action

increases the risk of sea turtles being exposed to chaff and flares; however, the expected impact 

on any exposed sea turtle remains the same. Sub-lethal effects due to ingestion of military 

expended materials other than munitions used in training activities may cause short-term or longterm disturbance to an individual turtle.

Pursuant to the ESA, the ingestion of military expended materials other than munitions during 

training activities under Alternative 1 may affect, but is not likely to adversely affect, green, 

hawksbill, loggerhead, olive ridley, or leatherback sea turtles.

Birds

Ingestion of chaff fibers is not expected to cause substantial damage to a bird’s digestive tract 

based on the fibers’ small size 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. 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).

If foraging in an area where military expended materials are present on the sea surface, the shorttailed albatross, Hawaiian petrel, and Newell’s shearwater could be impacted by ingestion of 

military expended material. Expended materials may be deposited in areas transited by shorttailed albatrosses; however, the rarity of this species in general and the lack of frequent sightings, 

chances for its potential interactions with military expended materials would be extremely low.

Pursuant to the ESA, potentially ingestible materials used during training activities under the 

Proposed Action would have no effect on the Hawaiian petrel, Newell’s shearwater, or shorttailed albatross. Under the MBTA regulations applicable to military readiness activities (50 

C.F.R. Part 21), potentially ingestible materials used during training activities under the 
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Proposed Action would not result in a significant adverse effect on populations of the great 

frigatebird, masked booby, or other marine bird populations.

Testing Activities

Under the Proposed Action, approximately 3,000 military expended materials other than 

munitions would be used during testing activities. Approximately 60 percent of these items are 

decelerators/parachutes and 30 percent are chaff and flares. The remaining 10 percent are targets.

Marine Mammals

Chaff, flares, and fragments from targets have the potential to be ingested by marine mammals. 

The impacts of ingesting these forms of expended materials on marine mammals would be minor 

because of the limited geographic area where materials and other than ordnance 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 marine mammal might encounter and swallow 

these items on the sea floor, particularly given that many of these items would be expended over 

deep, offshore waters; and the ability of many marine mammals to reject and not swallow nonfood items incidentally ingested.

The impacts of ingesting military expended materials other than munitions would be limited to 

cases where an individual marine mammal might eat an indigestible item too large to be passed 

through the gut. The marine mammals 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 species such as sperm whales and beaked whales. 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. Non-munition 

military expended materials that would remain floating on the surface are too small to pose a risk 

of intestinal blockage to any marine mammal that happened to encounter it.

Pursuant to the MMPA, the use of military expended materials other than munitions during 

testing activities under the Proposed Action is not expected to result in Level A or Level B 

harassment of marine mammals. Pursuant to the ESA, the use of military expended materials

other than munitions during testing activities as described under the Proposed Action:

• May affect, but is not likely to adversely affect the blue whale, fin whale, humpback 

whale, sei whale, and sperm whale

Sea Turtles

Activities that expend sonobuoys and air-launched torpedo decelerators/parachutes generally 

occur in water deeper than 183 m (600.4 ft.). Because the decelerators/parachutes sink, they are 

not expected to drift into another portion of the Study Area. Because of the low number of 

sonobuoys expended in the open ocean and the rapid sink rate of the decelerator/parachute, the 

likelihood of a leatherback encountering and ingesting a decelerator/parachute is extremely low. 

Because of the water depth over which these decelerators/parachutes are deployed, other sea 

turtle species are not likely to encounter a decelerator/parachute after it sinks through the water 

column.
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Pursuant to the ESA, the ingestion of military expended materials other than munitions during 

testing activities under Alternative 1 may affect, but is not likely to adversely affect, green, 

hawksbill, loggerhead, olive ridley, or leatherback sea turtles.

Birds

The likelihood of foraging seabirds encountering and ingesting expended materials is extremely 

low since the expended materials sink.

6.2.3.1.6 Explosions on Land and In-Air (Birds)

Explosives detonated at or just above the water surface, such as those used in anti-surface 

warfare, would create blast waves and acoustic waves that would propagate through both the 

water and air. 

Training Activities 

The pressure waves from explosives could injure or kill birds while either in flight or at the water 

surface. Detonations in air during anti-air warfare training and testing would typically occur at 

much higher altitudes (greater than 3,000 feet above sea level) where seabirds and migrating

birds are less likely to be present, although some activities target incoming missile threats at 

lower altitudes. At distances beyond those to injury, an explosive detonation would likely cause a 

startle reaction, as the exposure would be brief and any reactions are expected to be short-term. 

Birds have been observed taking interest in surface objects related to detonation activities and 

subsequently being killed by a detonation (Greene et al. 1985). Fleeing response to an initial 

explosion may reduce seabird exposure to any additional explosions that occur within a short 

timeframe. However, seabirds could also be attracted to an area to forage if an explosion resulted 

in a fish kill. This would only be a concern for activities that involved multiple explosions in the 

same area within a single activity, such as firing exercises, which involves firing multiple highexplosive five inch rounds at a target area; and bombing exercises, which could involve multiple 

bomb drops separated by several minutes.

Throughout the Study Area, use of explosives would increase from approximately 1,600 

explosions under the No Action Alternative to approximately 10,550 explosions. Most of these 

explosions are from medium-caliber explosive shells, which would occur in waters greater than 

12 NM from shore. In water, training activities using explosives would not typically occur within 

approximately 3 NM of shore.

Most of the impacts from explosions described in the EIS are on land and occur outside of the 

proposed SUA.

Pursuant to the ESA, the use of explosives during training activities under the Proposed Action

would have no effect on the Hawaiian petrel, Newell’s shearwater, or short-tailed albatross. 

Under the MBTA regulations applicable to military readiness activities (50 C.F.R. Part 21), the 

use of explosives during training activities under Alternative 1 would not result in a significant 

adverse effect on populations of the great frigatebird, masked booby, or other marine bird 

populations.
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Testing Activities

The Proposed Action would introduce activities within the SUA that use explosives as part of air 

to surface missile testing, mine countermeasure (MCM) mission package testing, and antisurface warfare mission package testing. All explosives used in testing activities occur at sea. 

While the impacts of explosions on seabirds under the Proposed Action cannot be quantified due 

to limited data on seabird density, lethal injury to some seabirds could occur. Detonations of 

torpedoes during testing activities may employ static targets that attract seabirds to the 

detonation site or fish kills from multiple detonations that attract seabirds to possible fish kills 

could be more likely to kill or injure seabirds. 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. Because testing activities that use explosives would consist of a 

limited number of detonations, exposures would not occur over long durations, and activities 

occur at varying locations, it is expected there would be an opportunity to recover from an 

incurred energetic cost and individual birds would not be repeatedly exposed to explosive 

detonations. Although a few individuals may experience long-term impacts and potential 

mortality, population-level impacts are not expected.

Testing activities that use explosives have the potential to intersect with transiting short-tailed 

albatrosses through testing areas; however, the rarity of this species in general and the lack of 

frequent sightings, chances for its potential interactions with testing activities would be 

extremely low. The spatial and temporal variability of both the occurrence of a short-tailed 

albatross and the testing activities conducted within offshore locations near foraging areas 

presents an improbable chance that a direct or indirect impact would occur to this species. 

Masked boobies, great frigatebirds, and other species that visit, roost, or breed within the Study 

Area would be exposed to explosions used during testing activities in the open ocean. Because of 

the availability of pelagic foraging grounds, a tendency for seabirds to use nearshore 

environments where large explosions are not used as part of testing activities, the widely 

dispersed locations of testing activities that use explosions, and the widely dispersed locations of 

seabirds within the Study Area, the chances of injury or harm to seabirds is extremely low. Any 

mortality or injury of individual seabirds would not represent a significant adverse impact on any 

population of seabird species.

Under the ESA, the use of explosives during testing activities under the Proposed Action would 

have no effect on the Hawaiian petrel, Newell’s shearwater, or short-tailed albatross. Under the 

MBTA regulations applicable to military readiness activities (50 C.F.R. Part 21), the use of 

explosives during testing activities under the Proposed Action would not result in a significant 

adverse effect on populations of the great frigatebird, masked booby, or other marine bird 

populations.

6.2.3.1.7 Impacts from Aircraft and Aerial Targets (Birds only)

Wildlife aircraft strikes are a serious concern for the Navy because these incidents can harm 

aircrews as well as damage equipment and injure or kill wildlife. Part of aviation safety during 

training and testing activities is the implementation of the Bird/Animal Aircraft Strike Hazard 

program. The Bird/Animal Aircraft Strike Hazard program manages risk by addressing specific 
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aviation safety hazards associated with wildlife near airfields through coordination among all the 

entities supporting the aviation mission (U.S. Department of Defense 2012). At Andersen Air 

Force Base, the only regular location of fixed wing take offs and landings, a sound cannon is 

deployed on the runway to discourage birds from accumulating on or near the runway. The plan 

is reviewed annually and updated as needed. Bird/Animal Aircraft Strike Hazard plans are not 

required around Northwest Field and Orote Air Field on Guam, and North Field on Tinian. As a 

standard operating procedure, aircraft avoid large flocks of birds to minimize the safety risk 

involved with a potential bird strike.

For the majority of fixed-wing activities, flight altitudes would be above 3,000 feet, 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 feet 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 of 

birds 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 a potential helicopter 

strike to a bird possible. 

In addition to manned aircraft, aerial targets such as unmanned drones and expendable rocket 

powered missiles, could also incur a bird strike but the probability is low. No data about bird 

strikes to drones or expendable rocket-powered missiles are available.

The potential for bird strikes to occur in offshore areas is relatively low because activities are 

widely dispersed and occur at relatively high altitudes (above 3,000 feet for fixed-wing aircraft) 

where seabird occurrences are generally low.

Training Activities

Training activities under the Proposed Action include an increase in aircraft flight. The number 

of sorties leaving Andersen Air Force Base and carriers at sea would increase less than 300 

percent relative to the No Action Alternative, as part of strike warfare (air to ground) training at 

FDM. 

Some bird and aircraft strikes and associated bird mortalities or injuries could occur in the Study 

Area under the Proposed Action; however, no long-term or population-level impacts are 

expected. Aircraft flight lines at sea may overlay transiting short-tailed albatrosses through 

training areas; however, due to the rarity of this species in general and the lack of frequent 

sightings, chances for its potential interactions with training exercises would be extremely low. 

Further, the altitude of aircraft at sea is likely much higher than a transiting or foraging albatross. 

Birds of this family follow wakes of ships, slightly increasing the potential for proximity to ships 

from which aircraft and aerial targets are launched. The spatial and temporal variability of both 

the occurrence of a short-tailed albatross and the training activities conducted within offshore 

locations near foraging areas presents an improbable chance that a direct or indirect impact 

would occur to this species. Because the highest risk for bird strike is during take offs and 
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landings, there would be no risk to short-tailed albatross because this species does not approach 

land areas in the Mariana Islands.

Pursuant to the ESA, the use of aircraft and aerial targets during training activities under the 

Proposed Action would have no effect on the Hawaiian petrel, Newell’s shearwater, or shorttailed albatross. Under the MBTA regulations applicable to military readiness activities (50 

C.F.R. Part 21), the use of aircraft and aerial targets during training activities under the 

Proposed Action would not result in a significant adverse effect on populations of the great 

frigatebird, masked booby, or other marine bird populations. 

Testing Activities

Testing activities under the Proposed Action would introduce rotary wing aircraft and fixed wing 

aircraft. Under the Proposed Action, 320 new activities involving aircraft movements are 

proposed. The types of activities, locations, and types of aircraft would not differ from training 

activities. 

For reasons stated in the training section above, disturbance or strike from aircraft or aerial 

targets are not expected to have lasting impacts on the survival, growth, recruitment, or 

reproduction of bird populations. Aircraft flight lines at sea under the Proposed Action may 

overlay transiting short-tailed albatrosses through training areas; however, the rarity of this 

species in general and the lack of frequent sightings, chances for its potential interactions with 

testing exercises would be extremely low. Further, the altitude of aircraft at sea is likely much 

higher than a transiting or foraging albatross. 

The spatial and temporal variability of both the occurrence of a short-tailed albatross and the 

testing activities conducted within offshore locations near foraging areas presents an improbable 

chance that a direct or indirect impact would occur to this species. Because the highest risk for 

bird strike is during take offs and landings, there would be no risk to short-tailed albatross 

because this species does not approach land areas in the Marianas.

Pursuant to the ESA, the use of aircraft and aerial targets during testing activities under the 

Proposed Action would have no effect on the Hawaiian petrel, Newell’s shearwater, or shorttailed albatross. Under the MBTA regulations applicable to military readiness activities (50 

C.F.R. Part 21), the use of aircraft and aerial targets during testing activities under the 

Proposed Action would not result in a significant adverse effect on populations of the great 

frigatebird, masked booby, or other marine bird populations.

6.2.4 PLANTS

Of the known major groups found in the Mariana Islands, there are approximately 26 species of 

blue green algae, 109 species of red algae, 31 species of brown algae, 71 species of green algae, 

10 species of seagrasses, 10 species of mangroves (Ellison 2008, Gilman et al. 2006, Lobban and 

Tsuda 2003), and an estimated 1,200 species of dinoflagellates (Castro and Huber 2000). The 

majority of military expended material would be used in open ocean areas, where marine 

vegetation would not be expected to occur.
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6.2.5 FISH

There are approximately 1,106 marine fish species in the coastal zone of the Study Area (Myers 

and Donaldson 2003). Migratory open-ocean fishes, such as the larger tunas, the billfishes, and 

some sharks, are able to move across the great distance that separates the Mariana Islands from 

other islands or continents in the Pacific. 

There is only one marine fish species, scalloped hammerhead shark (Sphyrna lewini), in the 

Study Area that is listed as threatened under the ESA. There are two fish species that are 

candidate species: the Humpheaded wrasse (Sheilinus undulates) and the Great hammerhead 

shark (Sphyrna mokarran). 2006).The scalloped hammerhead shark remains close to shore 

during the day and moves to deeper waters at night to feed (Bester 1999). A genetic marker study 

suggests that females typically remain close to coastal habitats, while males are more likely to 

disperse across larger open ocean areas

6.2.5.1 Aircraft Noise

Direct injury to fish is not likely to occur from exposure to non-impulse sources such as subsonic 

aircraft noise because non-impulse noise sources lack the strong shock wave associated with an 

explosion.

Training Activities

Training activities under the Proposed Action include an increase in the number of activities that 

involve aircraft as compared to the No Action Alternative; however, the training locations, types 

of aircraft, and types of activities would not differ. The number of individual predicted impacts 

associated with the Proposed Action aircraft overflight noise may increase. The primary 

exposure to aircraft noise may have the potential to expose scalloped hammerhead sharks to 

sound or general disturbance. However, any potential impacts would result in short-term 

behavioral or physiological responses; longterm impacts would be unlikely.

Pursuant to the ESA, the use of sonar and other non-impulse acoustic sources during training 

activities under the Proposed Action may affect, but is not likely to adversely affect ESA-listed 

scalloped hammerhead sharks.

Testing Activities

The number of annual testing activities that produce sound from aircraft analyzed under the 

Proposed Action would increase over what was analyzed for the No Action Alternative. These 

activities would happen in the same general locations as described under the Proposed Action

Training section. The primary exposure to aircraft noise would occur around ports and air bases. 

Aircraft overflight noise has the potential to expose fish to sound and general disturbance, 

potentially resulting in short-term behavioral responses. However, any short-term behavioral 

reactions, physiological stress, or auditory masking is unlikely to lead to long-term consequences 

for individuals. Therefore, long-term consequences for populations are not expected. The 

primary exposure to aircraft noise may have the potential to expose scalloped hammerhead 

sharks to sound or general disturbance. However, any potential impacts would result in shortterm behavioral or physiological responses; long-term impacts would be unlikely. The potential 

effects of testing activities under the Proposed Action on fish species would are expected to be 
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limited to short-term, minor behavioral reactions. Effects to fish populations would not occur as 

a result of non-impulse sounds associated with testing activities under the Proposed Action.

Pursuant to the ESA, the use of sonar and other non-impulse acoustic sources during testing 

activities under the Proposed Action may affect, but is not likely to adversely affect ESA-listed 

scalloped hammerhead sharks.

6.2.5.2 Weapons Firing, Launch, and Impact Noise

Activities are spread throughout the Study Area, and could take place within coastal or open 

ocean areas. Most activities involving large-caliber naval gunfire or the launching of targets, 

missiles, bombs, or other ordnance are conducted greater than 12 NM from shore.

Sound due to missile and target launches is typically at a maximum during initiation of the 

booster rocket and rapidly fades as the missile or target travels downrange. Many missiles and 

targets are launched from aircraft, which would produce minimal noise in the water due to the 

altitude of the aircraft at launch. Mines, non-explosive bombs, and intact missiles and targets 

could impact the water with great force and produce a large impulse and loud noise, but with 

very short pulse durations, depending on the size, weight, and speed of the object at impact 

(McLennan 1997). These sounds from weapons firing launch, and impact noise would be 

transient and of short duration, lasting no more than a few seconds at any given location.

Fish that are exposed to noise from weapons firing, launch, and non-explosive ordnance impact 

with the water's surface may exhibit brief behavioral reactions; however, due to the short term, 

transient nature of weapons firing, launch, and non-explosive impact noise, animals are unlikely 

to be exposed multiple times within a short period. Behavioral reactions would likely be short 

term (minutes) and substantive costs or long-term consequences for individuals or populations 

would not be expected.

Training

Under the Proposed Action, explosive bombs (212), missiles/rockets (239), large and mediumcaliber projectiles (9,450), and explosive sonobuoys (11) are proposed to be expended during 

training activities in the Study Area, which would be a 640 percent increase over the No Action 

Alternative. As described above, impacts from weapons firing, launch, and impact noise would 

likely be short term (minutes) and substantive costs or long-term consequences for individuals or 

populations would not be expected. Additionally, individuals are unlikely to be exposed multiple 

times within a short period. These activities would happen in the same general locations as

described by the No Action Alternative.

Potential impacts on fish from explosions and impulse sound sources can range from no effect, 

brief acoustic effects, tactile perception, and physical discomfort, to slight injury to internal 

organs and the auditory system, to death of the animal (Keevin and Hempen 1997). Occasional 

behavioral reactions to intermittent explosions and impulse sound sources are unlikely to cause 

long-term consequences for individual fish or populations. While serious injury and/or mortality 

to individual fish would be expected if they were present in the immediate vicinity of explosive

ordnance use, despite the increase in activities under the Proposed Action, the activities are 

infrequent and widely dispersed throughout the Study Area, and the distribution of potentially 
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affected fishes also varies, impacts from at-sea explosion from training activities would be 

temporary and localized, and are not expected to result in population level impacts. Scalloped 

hammerhead sharks have the potential to be exposed to explosive energy and sound associated 

with training activities under the Proposed Action. Training activities involving impulse acoustic

sources have the potential to affect the ESA-listed species present, potentially resulting in shortterm behavioral or physiological responses, hearing loss, injury, or mortality. However, given the 

infrequent nature of training activities involving impulse acoustic sources, the likelihood of these 

species encountering an explosive activity is remote.

Pursuant to the ESA, the use of explosives and other impulse sound sources during training 

activities under the Proposed Action may affect, and is likely to adversely affect, ESA-listed 

scalloped hammerhead sharks.

Testing

The testing described is within the water and is not dependent on the proposed SUA.

6.2.6 USFWS New 2015 ESA Listings 

On November 2, 2015, the USFWS listed 23 new species. Twenty-one are listed as endangered

(E), including 12 plants and 9 animals. Two plant species were listed as threatened (T). 

Plants Plants (continued)

Bulbophyllum guamense (cebello 

halumtano)

E Tabernaemontana rotensis (NCN) T

Dendrobium guamense (no common 

name (NCN))

E Animals

Eugenia bryanii (NCN) E Pacific sheath-tailed bat (Emballonura

semicaudata rotensis; liyang),

E

Hedyotis megalantha (paudedo) E Slevin’s skink (Emoia slevini; guali’ek

halomtano)

E

Heritiera longipetiolata (ufahalumtano)

E Mariana eight-spot butterfly (Hypolimnas 

octocula mariannensis; NCN)

E

Maesa walkeri (NCN) E Mariana wandering butterfly (Vagrans 

egistina; NCN)

E

Phyllanthus saffordii (NCN) E Rota blue damselfly (Ischnura luta; NCN) E

Psychotria malaspinae (aplokatingpalaoan)

E Fragile tree snail (Samoana fragilis; 

akaleha)

E

Solanum guamense (berenghenas 

halomtano)

E Guam tree snail (Partula radiolata; 

akaleha)

E

Nervilia jacksoniae (NCN) E Humped tree snail (Partula gibba; akaleha) E

Tinospora homosepala (NCN) E Langford’s tree snail (Partula langfordi; 

akaleha)

E

Tuberolabium guamense (NCN) E

Cycas micronesica (fadang) T
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All 23 species are based on land within the Commonwealth of Northern Mariana Islands, and are 

not present within the proposed SUA. Therefore FAA’s proposed action will have no effect on 

the 23 species.

6.2.7 Conclusion

The FAA’s significance threshold for ESA species would occur if the US Fish and Wildlife 

Service or the National Marine Fishery Service (NMFS) determines that the proposed action 

would be likely to jeopardize the continued existing of the species in question, or would result in 

the destruction or adverse modification of federally-designated critical habitat in the affected 

area. The FAA has not established a significance threshold for non-listed species.

The US Fish and Wildlife Service issued a Biological Opinion for the Navy’s MITT project on 

February 20, 2015. They also concurred with the determinations in the Biological Assessment 

that the proposed MITT program is not likely to adversely affect, the endangered nightingale 

reed-warbler, the endangered Mariana crow, the endangered Mariana swiftlet, and the 

endangered Mariana common moorhen. All of these birds are terrestrial, and outside of the 

proposed SUA. The 2015 Biological Opinion does not address Hawaiian petrel, Newell’s 

shearwater, or short-tailed albatross. Per FAA’s review of USFWS’s website, the Hawaiian 

petrel is known or believed to occur in Hawaii only. The Newell’s shearwater is known or 

believed to occur in Hawaii and American Samoa. The short-tailed albatross is known or 

believed to occur in Alaska, California, Hawaii, Oregon, and Washington. USFWS’s website 

does not show any of the three species to occur in CNMI.

NMFS issued a Biological Opinion for the Navy’s MITT project on June 12, 2015. The species 

under NMFS jurisdiction under the proposed SUA include the blue whale, the humpback whale, 

the fin whale, the sei whale, the sperm whale, the green sea turtle, the hawksbill turtle, the 

loggerhead turtle, the leatherback turtle, and the scalloped hammerhead sharks. The olive ridley 

turtle was not considered in the BO because NMFS considered olive ridley turtle occurrence 

would be rare and the potential for exposure to stressors from training and testing activities 

would be discountable. The BO established monitoring requirements for ESA-listed marine 

mammals, sea turtle species, and scalloped hammerhead sharks.

On July 31, 2015, NMFS issued a Letter of Authorization (80 FR 46111) for the take of 26 

species of marine mammals incidental to Navy training and testing activities including 

underwater detonations from August 3, 2015 through August 3, 2020. Mitigation requires 

monitoring (including lookouts), setting mitigation zones, and annual monitoring reports. 

Based on the discussion above, the FAA has determined that impacts to biological resources will 

be less than significant.

6.3 Climate

To estimate global warming potential, the United States quantifies greenhouse gas emissions 

using the 100-year timeframe values established in the Intergovernmental Panel on Climate 

Change Fourth Assessment Report (Intergovernmental Panel on Climate Change 2007), in 

accordance with United Nations Framework Convention on Climate Change (United Nations 
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Framework Convention on Climate Change 2004) reporting procedures. All global warming 

potentials are expressed relative to a reference gas, CO2, which is assigned a global warming 

potential equal to 1. The five other greenhouse gases have a greater global warming potential 

than CO2, ranging from 21 for CH4, 310 for N2O, 140 to 6,300 for hydrofluorocarbons, 6,500 to 

9,200 for perfluorocarbons, and up to 23,900 for SF6. To estimate the CO2 equivalency of a nonCO2 greenhouse gas, the appropriate global warming potential of that gas is multiplied by the 

amount of the gas emitted. All six greenhouse gases are multiplied by their global warming 

potential and the results are added to calculate the total equivalent emissions of CO2 (CO2e). The 

dominant greenhouse gas emitted is CO2, mostly from fossil fuel combustion (85.4 percent) 

(U.S. Environmental Protection Agency 2009b, c). Weighted by global warming potential, CH4

is the second largest component of emissions, followed by N2O. Global warming potentialweighted emissions are presented in terms of equivalent emissions of CO2, using units of 

teragrams (1 million metric tons or 1 billion kilograms [Tg]) of carbon dioxide equivalents (Tg 

CO2 Eq). The Proposed Action is anticipated to release greenhouse gases to the atmosphere. 

These emissions are quantified for the proposed Navy training and testing in the Study Area, and 

estimates are presented in Chapter 4 (Cumulative Impacts). 

The potential effects of proposed greenhouse gas emissions are by nature global; individual 

sources of greenhouse gas emissions are not large enough to have any noticeable effect on 

climate change but may have cumulative impacts. Therefore, the impact of proposed greenhouse 

gas emissions on climate change is discussed in the context of cumulative impacts in Chapter 4 

(Cumulative Impacts).

6.3.1 MIRC EA/OEA

This document addressed climate change and greenhouse gas emissions in the cumulative 

impacts section. It referred to the 2010 MIRC EIS/OES estimated annual emissions.

6.3.2 MIRC 2010 EIS/OEIS Analysis

The annual emission of carbon dioxide equivalent greenhouse gas from training and testing 

activities in the MIRC is estimated to be 127,729 metric tons per year (U.S. Department of the 

Navy 2010a). In comparison to the United States 2007 greenhouse gas emissions, the greenhouse 

gas emissions associated with the military activities amount to approximately 0.0017 percent, 

and the incremental contributions to cumulative impacts are negligible.

6.3.3 MITT 2015 EIS/OEIS Analysis

Greenhouse gas emissions were calculated for ships and aircraft, which contribute the majority 

of emissions associated with training and testing in the Study Area. Greenhouse gas emissions

from minor sources such as munitions, weapons platforms, and auxiliary equipment were

considered negligible and were not calculated. Ship greenhouse gas emissions were estimated by 

determining annual ship fuel (typically diesel) use based on proposed activities and multiplying 

total annual ship fuel consumption by the corresponding emission factors for CO2, CH4, and 

N2O. Aircraft greenhouse gas emissions were calculated by multiplying jet fuel use rates by the 

total operating hours, by the corresponding jet fuel emission factors for CO2, CH4, and N2O, and 

by the total annual sorties. Only the jet fuel emissions are relevant to the proposed SUA, but the 

Navy’s calculations do not separate them so all emissions are reported in the table below:
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Alternative Annual Emissions (Teregrams)

CO2 N2O CH4 CO2 Equivalent (Eq)

No Action Alternative 0.21 0.00 0.00 0.21

Proposed Alternative 0.74 0.00 0.00 0.75

Increase in emissions for Proposed 

Alternative compared to No Action 

Alternative

0.53 0.00 0.00 0.54

Ship and aircraft greenhouse gas emissions are compared to U.S. 2009 greenhouse gas 

emissions. The estimated CO2 Eq emissions from the No Action Alternative are 0.0032 percent

of the total CO2 Eq emissions generated by the United States in 2009. The estimated CO2 Eq 

emissions from the Proposed Alternative would increase because of increased training and 

testing activities to about 0.0113 and 0.0124 percent of the total CO2 Eq emissions, respectively, 

generated by the United States in 2009.

The changes in air quality would be measurable from the proposed increases in training and 

testing activities, but would still be below applicable standards and guidelines. Therefore, the 

Proposed Action would not be expected to appreciably contribute to greenhouse gas emissions.

6.3.4 Conclusion

The FAA has not established a significance threshold for Climate. Based on the analysis

presented in the Air Quality section, and the reasons summarized above, the changes in air 

quality would be measurable, but would still be below applicable standards and guidelines; 

therefore, the FAA has determined that the project will have less than significant impacts on 

climate. 

6.4 Coastal Resources 

The Proposed SUA would occur entirely over open ocean and above ground level. All coral reefs 

within the Study area are close to shore. R-7201A starts three NM from FDM. The three 

Warning areas are more than nine NM5 away from shore. Therefore, this impact category is not 

applicable.

6.5 Department of Transportation Act: Sec. 4(f) / Recreational Resources

Designation of airspace for military flight operations is exempt from section 4(f). The National 

Defense Authorization Act for Fiscal Year 1998 (Public Law 105-85) provided that "[n]o 

military flight operations (including a military training flight), or designation of airspace for such 

an operation, may be treated as a transportation program or project for purposes of section 303(c) 

of title 49, United States Code.

 5 Several distances were measured using Google Earth to determine the distance from shore, including between the 

shore of FDM to the edge of R-7201A, the shore of Guam to W-11, and from the shore of Saipan to W-13.
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Implementation of the proposed changes to SUA and expansion of the DZ from 10 NM to 12 

NM would not affect recreational fishing within the Study Area because most recreational 

fishing primarily occurs within three miles from shore at Guam and Saipan. The boating distance 

from Saipan (nearest island) to FDM is 45 NM, which is greater than the normal boating distance 

of three NM for most recreational fishing.

The proposed Action does not require the use of publically owned land of a public park, 

recreation area, or wildlife or waterfowl refuge or national, state, or local significance. The 

Proposed Action does not require the use of land from an historic site of national, state, or local 

significance. Therefore, there are negligible to no impacts to recreational resources from the 

proposed changes to the SUA.

6.6 Farmlands

The Proposed Action would occur in airspace entirely over open ocean and above ground level. 

Therefore, this impact category is not applicable.

6.7 Hazardous Materials, Solid Waste, and Pollution Prevention

6.7.1 MIRC EA/OEA

The Proposed Action would occur entirely over open ocean and above ground level. The 

Proposed Action would not result in a change in the level of training activities and they would 

not differ in scope, nature, or location from those analyzed in the MIRC EIS/OEIS.

6.7.2 MIRC 2010 EIS/OEIS Analysis

Some training materials, including gun ammunition, bombs, missiles, targets, chaff, and flares, 

are expended on the range and not recovered. Items expended on the water, and fragments that 

are not recognizable as expended material (e.g., flare residue or candle mix), typically are not 

recovered. A small percentage of training items containing military explosives fail to function 

properly, and, if not recovered, remain on the range as UXO. The EIS/OEIS describes potential 

activity effect from hazardous materials by range activity. The types of effects that could result 

from the changes to the SUA from aircraft overflights include: unintentional release of 

petroleum, oils and lubricants during aircraft mishap; release of hazardous materials from 

ordnance detonations; deposition of unexploded ordnance (UXO), and release of expended 

training materials.

There are specific requirements and restrictions categorized for air, maritime, and shore training 

as well as specific requirements and restrictions pertaining to air/air support training, naval ships 

training, land training, amphibious training, and underwater demolitions. The specific protective 

measures related to overflights in the SUA include the following:

• Do not use live cluster weapons, live scatterable munitions, fuel air explosives, 

incendiaries, or bombs greater than 2,000 lb (FDM – Live and Inert Bombing, Live Fire 

Guns, Naval Surface Fire Support).

• Emergency fuel release may only be conducted in designated aircraft emergency fuel 

release areas. If designated emergency fuel release areas are unavailable, fuel may be 

released as directed at locations at least 12 NM from any land, sea mound or island, in 

depths greater than or equal to 1,000 fathoms (6,000 feet) of water and at an altitude safe 

for flight or as directed to ensure complete evaporation of the fuel.
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• Ordnance may be jettisoned in designated emergency jettison areas only. If designated 

emergency jettison areas are unavailable, ordnance may be jettisoned at locations at least 

12 nm from any land, sea mound or island, in depths greater than or equal to 1,000 

fathoms (6,000 feet) of water and at an altitude safe for flight or as directed.

Expended training material can leak or leach small amounts of toxic substances as they degrade 

and decompose. The EIS/OEIS Table 3.2-2 lists the hazardous constituents of common training 

munitions. These items decompose very slowly, so the volume of expended material that 

decomposes within the training areas, and the amounts of toxic substances being released to the

environment, gradually increase over the period of military use. In ocean waters, sediment 

transport via currents can eventually disperse these contaminants outside training areas where 

they will be present at relatively lower concentrations compared to those in the training ranges 

and, thus, have no measurable effect on the open ocean environment.

Bombs that strike FDM would release a small percentage of munition constituents that are not 

consumed in the detonation and ensuing explosion. This amount would be further reduced by 

wind transporting some of the munition constituents to the southwest away from the island and 

rapidly mixing with the surrounding air before being deposited into the ocean. Munition 

constituents deposited on land are eventually carried out to the ocean by percolating surface 

water through the limestone formations. For this reason, the impact of hazardous materials in 

bombs on FDM would also be minimal.

Aerial targets are used for testing and training purposes. Most air targets contain jet fuels, oils, 

hydraulic fluid, batteries, and explosive cartridges as part of their operating systems. Fuel is shut 

off by an electronic signal, the engine stops, and the target begins to descend. A parachute is 

activated and the target descends to the ocean surface where range personnel retrieve it. Some 

targets are actually hit by missiles and fall into the range.

6.7.3 MITT 2015 EIS/OEIS Analysis

Training Activities

Under the Proposed Action, strike warfare training activities on FDM would include the use of 

explosive ordnance. The impacts of explosive byproducts on sediment and water quality would 

be indirect, short term, local, and negative. Chemical, physical, or biological changes in sediment 

or water quality would not be detectable because of the rapid mineralization and dissolution of 

explosive byproducts in marine environments.

The Proposed Action would increase the number of training activities and the amount of 

explosive ordnance used. The estimated amounts of associated residual explosive materials 

would increase to about 9,772 lb. per year. Approximately 1,687 lb. per year of residual 

explosives would remain from high-explosive ordnance used during training activities because of 

ordnance failure and low-order detonations. While the amount of residual explosive materials 

would increase by about 500 percent under the Proposed Action, impacts on water quality of 

explosive materials would be short term and localized due to rapid degradation in water. 

Residual explosive materials would be limited to a small area surrounding military expended 

materials. Based on previous studies and the low residence time of residual explosive materials 
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in marine sediments, residual explosive materials would have short-term, localized impacts on 

marine sediments under the Proposed Action.

Testing Activities

Residual explosive materials from harpoon and surface to surface missiles, sonobuoys, medium 

caliber explosive rounds and explosive torpedoes during testing are estimated at 1,075 lb. per 

year. A percent increase for residual explosive materials released from testing activities under the 

Proposed Action cannot be evaluated because these proposed testing activities are not currently 

conducted under the No Action Alternative. Based on the amount of residual explosive materials 

deposited in the Study Area, low leaching rates, and rapid degradation of explosive materials and 

the low residence time of residual explosive materials in marine sediments, impacts of residual 

explosive materials on sediments and water quality under the Proposed Action would be 

localized and short-term.

6.7.4 Conclusion

Because training activities are conducted in areas and facilities where access by the public is not 

allowed, human health risk from the increased storage, use, transportation, and disposal of 

hazardous substances associated with training activities will remain the same. However, risk of 

exposure of the environment to hazardous substances may increase. Compliance with applicable 

regulations and implementation of associated management plans should reduce the increased risk 

of environmental exposure.

Although the Proposed Action would have the potential to increase the use and disposal of 

hazardous materials as a result of increased training activities, training activities would continue 

to be conducted in accordance with applicable Federal, Guam and CNMI regulations, and 

applicable Service instructions. With adherence to established protective measures (specific to 

use of SUA) listed above in the MIRC 2010 EIS/OEIS Analysis section, impacts from hazardous 

materials from 2010 Proposed Action would not be considered significant.

The FAA has not established a specific significant impact threshold for hazardous materials, 

solid waste, and pollution prevention. Per the analysis above, the FAA has determined the 

establishment of the proposed SUA will have no significant impacts from hazardous materials, 

solid waste, and pollution prevention. 

6.8 Historical, Architectural, Archeological, and Cultural Resources

6.8.1 MIRC EA/OEA

There are also no land-based ground disturbing activities proposed in the SUA discussed in the 

EA/OEA. Thus, there will be no effect to historic properties/cultural resources, as none have 

been specifically identified in the project study area, and those issues related to this resource 

have been addressed in the MIRC 2009 Cultural Resources Programmatic Agreement and 

analyzed in the MIRC EIS/OEIS. 

The 2009 Programmatic Agreement was developed to satisfy the National Historic Preservation 

Act consultation requirements as part of the MIRC EIS/OEIS. The 2009 MIRC Programmatic 

Agreement covers all undertakings discussed within the MIRC EIS/OEIS and specifically noted 

the MIRC study area included “property and land under the jurisdiction of the DoD and other 
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entities, including 450,187 nautical miles of open ocean and littorals”, it focuses discussion on 

requirements for only those activities in certain locations where there is a potential to impact 

cultural resources. Cultural resources that may be present in the open ocean areas beneath W517, R-7201, or the seven Air Traffic Control Assigned Airspace (ATCAA) locations, will not 

be adversely impacted since activities analyzed in the MIRC EIS/OEIS will most likely occur on 

the surface, above the water or just below the surface water column and not on the ocean floor. 

Further, the designation of SUA and Danger Zone as analyzed in the MIRC Airspace EA/OEA 

will have no effect on any resources which may be present. (Personal Communication, John Van 

Name, Navy contractor, 11/2/16)

The 2009 Programmatic Agreement includes Training Constraint Maps that identify locations of 

off-limits or No Training (NT) areas and Limited Training (LT) areas. Field monitoring and 

reporting requirements are stipulated, and the reports are provided to the appropriate Historic 

Preservation Officer. The proposed SUA does not overlay any of the off-limit, NT and LT areas.

Both Guam and CNMI Historic Preservation Offices were provided copies of the Draft EA/OEA. 

In addition, public meetings on the Draft EA/OEA were conducted on Guam and Saipan on 

January 15 and 17, 2013, respectively. (Personal Communication, John Van Name, Navy 

contractor, 11/2/16)

The 2009 Programmatic Agreement for the MIRC is applicable for purposes of this EA/OEA. 

Therefore, the EA/OEA concluded that new/additional consultation with the State Historic 

Preservation Office is not required.

6.8.2 MIRC 2010 EIS/OEIS Analysis

Although no field surveys for cultural resources were conducted in deep water, an extensive 

literature review of all known submerged cultural resources in Micronesia was conducted by the 

Submerged Cultural Resources Unit of the National Park Service (NPS) (Carrell et al. 1991a). In 

addition, several shallow-waters areas in the Mariana Islands, including Guam, Saipan, and 

Tinian, were surveyed for cultural resources by the NPS and U.S. Navy divers. No cultural 

resources surveys were conducted in open waters, although several World War II (WWII)

submerged cultural resources are likely to occur in the open ocean areas beneath W-517, R-7201, 

or the seven Air Traffic Control Assigned Airspace (ATCAA) locations6.

The training activities that could potentially affect the submerged cultural resources include live 

fire and inert bombing. The training activities will most likely occur on the surface, above the 

water or just below the surface water column and not on the ocean floor. While submerged 

cultural resources could be exposed to direct ordnance strikes, the training exercises are 

intermittent and widely dispersed, which decreases the likelihood that a given area would be 

subjected to repeated exposure. Most ordnance firing occurs in areas greater than 12 NM

offshore. The velocity of ordnance would rapidly decrease upon contact with the water. As a 

result, expended ordnance would be moving at slow speeds by the time it travels through the 

water column and reaches the sea floor. Consequently, ordnance strikes would cause little or no 

physical damage to submerged cultural resources. The probability of ordnance striking a 

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shipwreck or other WWII submerged cultural resources is extremely low based on the widely 

dispersed nature of these resources and the training exercises. If ordnance were to strike these 

resources, little or no damage to the resources would be expected based on the slow speed the 

ordnance would be traveling upon contact. Although the increased training frequency will 

represent a slight increase in overall impacts to submerged cultural resources, non-explosive 

ordnance strikes offshore and in territorial waters would have no significant impact on 

submerged cultural resources under the Proposed Action.

6.8.3 MITT 2015 EIS/OEIS Analysis

Farallon de Medinilla (FDM)

A preliminary archaeological field survey of Farallon de Medinilla (FDM) was conducted in 

1996 (Welch 2010). No archaeological sites or isolated non-modern artifacts were observed. 

Only modern debris associated with the military use of the island was observed.

Mariana Islands Range Complex Programmatic Agreement

A Programmatic Agreement was negotiated for all military training activities proposed under the 

Preferred Alternative for the MIRC based on consultations with the Guam State Historic 

Preservation Office, CNMI Historic Preservation Office, Advisory Council on Historic 

Preservation, and the National Park Service. The training constraints map identifies 13 No 

Training areas (eight on Guam and five on Tinian) and 35 Limited Training areas (20 on Guam 

and 15 on Tinian), refined from the previous Military Operations Area constraints map 

boundaries (U.S. Department of Defense 2009). Limited Training areas are defined as pedestrian 

traffic areas with vehicular access limited to designated roadways and/or the use of rubber-tired 

vehicles. No pyrotechnics, demolition, or digging is allowed without prior consultation with the 

appropriate Historic Preservation Office. In addition to establishing No Training and Limited 

Training areas, stipulations for additional cultural resources investigations in un-surveyed areas; 

archaeological monitoring and conditions documentation of military use of ingress and egress 

paths and training areas; and preparation of field reports were also implemented.

Impacts from Military Expended Materials

Deposition of non-explosive practice munitions, sonobuoys, and military expended materials 

other than ordnance may affect submerged cultural resources through possible sudden impact of 

resources on the seafloor or the simple settling of military expended materials on top of 

submerged cultural resources. Most anticipated expended munitions would be small objects and 

fragments that would 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 

velocity, but their trajectory would be slower as they move through the water. If expended 

materials should sink in the vicinity of or on a submerged cultural resource, the expended

materials would not affect the archaeological or historic characteristics of the submerged historic

resource that contribute to its eligibility for the National Register of Historic Places or the World

Heritage List. However, the likelihood of expended materials either impacting or landing on 

submerged historic resources is very low because the Navy routinely avoids known submerged 

obstructions.
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6.8.4 Conclusion

The FAA has not established a specific significant impact threshold for historical, architectural, 

archeological, and cultural resources. Regulations at 36 CFR 800.8(a) state that an adverse effect 

finding does not automatically trigger a significant impact. 

In December 2016, FAA verified that no new cultural resources have been designated within the

Area of Potential Effect7. Per the analysis above, the FAA has determined that the 2009 

Programmatic Agreement from the 2010 MIRC EIS/OEIS is applicable to the 2013 MIRC 

EA/OEA and 2015 MITT EIS/OEIS, and no additional consultation with the Historic 

Preservation Officer was warranted for the Proposed Action, and the Proposed Action will have 

a no adverse effect on any resources under the Proposed SUA. 

6.9 Land Use

6.9.1 MIRC EA/OEA

FDM lies under R-7201. DoD live-fire training is the only land use permitted on FDM. The 

Navy has leased FDM from CNMI since 1971 and in 1983 negotiated a 50-year lease with an 

option to renew for another 50 years. Impact areas are restricted to the interior mesic flat 

ecosystem in the northern two thirds of the island and most of the southern peninsula, including 

the western cliffline ecosystem. No live-fire training is allowed in the coastal ecosystem. FDM is 

the only land under the existing SUA and close to the proposed SUA. Proposed changes to the 

SUA and expansion of the DZ would not result in a change in land use because training activities 

would not differ in scope, nature, or location from those approved in the MIRC EIS/OEIS around 

or on FDM. 

Warning Areas W-11, W-12, and W-13 are all over open ocean, so establishing them will not 

result in any land use changes.

The EA/OEA states the MIRC EIS/OEIS determined that no significant impact to land use would 

occur because the training activities analyzed occur more than 12 NM from the shore and above 

3,000 feet, and would have no impact on land use. 

6.9.2 MIRC 2010 EIS/OEIS Analysis

FDM is used for live-fire and inert ordnance training. No maneuver training is permitted on 

FDM and the nearshore waters are leased to the United States for military purposes specifically 

for use as a live fire naval gunfire and air warfare air strike training range. As such, FDM and its 

nearshore area have always been an off-limits area to all personnel both civilian and military due 

to unexploded ordnance concerns. This restriction will continue and FDM and nearshore areas, 

including the fringing reef remain a restricted area, which prohibits the entry of all personnel, 

civilian and military from the island without specific permission from Commander, Joint Region 

Marianas. Public access to FDM will remain strictly prohibited and there are no commercial or 

recreational activities on or near the island. 

 7

Verification was done using National Park Service data. https://www.nps.gov/maps/full.html?mapId=7ad17cc9-

b808-4ff8-a2f9-a99909164466
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NOTAMs will continue to be issued at least 72 hours in advance of potentially hazardous FDM 

range events and may advise restrictions for certain training events. No changes to existing real 

estate use or agreements are proposed as a result of the implementation of the EIS/OEIS 

Proposed Action. Therefore, the proposed activities associated with EIS/OEIS Proposed Action 

would have a less than significant impact on land use.

6.9.3 MITT 2015 EIS/OEIS Analysis

The EIS did not include a land use section in the EIS. Since the EIS increases the training and 

testing activities, but does not establish any new SUA, land use changes are not expected to 

result from the Proposed Action.

6.9.4 Conclusion

The FAA has not established a specific significant impact threshold for land use. The FAA has 

determined the establishment of the proposed SUA will have less than significant impacts on land 

use per the analysis above.

6.10 Natural Resources and Energy Supply

Military training involves consumption of nonrenewable resources, such as jet fuel, and materials 

for the manufacture of training materials such as chaff8 and flares9. Increased training operations 

would increase the consumption of nonrenewable resources and commitment of resources for 

munitions, chaff, and flares for the proposed action. See Table 2-8 in the 2010 EIS/OEIS for the 

changes to the annual training activities.

The FAA has not established a significance threshold for Natural Resources and Energy Supply, 

however a factor to consider in determining whether the action would have a significant impact is 

whether the proposed action would have a measureable effect on local supplies of energy or 

natural resources. FAA Order 1050.1E, Appendix A, Section 13. While the energy use of 

Proposed Action would increase due to the additional training activities, the amount and rate of 

consumption of resources would not significantly change, and would not result in significant 

environmental impacts, or the unnecessary, inefficient, or wasteful use of resources. 

The proposed action would not have the potential to cause demand to exceed the available or 

future supplies of these resources and therefore there would not be a significant impact to natural 

resources or energy supply. DoD policies and directives for operations at every level mandate 

minimization of the use of energy resources wherever possible without compromising safety of 

training activities. 

 8 Chaff is a self-protection device that permits an aircraft threatened by enemy radar-directed munitions to 

distract and/or avoid the threat. Although the chaff may be ejected from the aircraft using a small 

pyrotechnic charge, the chaff itself is not explosive. Depending on the chaff used, plastic or nylon pieces, 

a felt piece, or 2- by 3-inch square of parchment paper can fall to the ground with each released chaff 

bundle.

9 Flares are used in pilot training to develop the near instinctive reactions to a threat that are critical to 

combat survival. Flares ignite upon ejection from the aircraft and burn completely within approximately 

3.5 to 5 seconds, or approximately 400 to 500 feet from its release point. 
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The FAA has not established a specific significant impact threshold for natural resources and 

energy supply. Per the discussion above, the FAA has determined the establishment of the 

proposed SUA will have less than significant impacts on natural resources and energy supply. 

6.11 Noise and Noise-Compatible Land Use

6.11.1 MIRC EA/OEA

Proposed changes to SUA would not result in training activities that differ in scope, nature, or 

location from those approved in the MIRC EIS/OEIS. 

6.11.2 MIRC 2010 EIS/OEIS Analysis

In general, under the Proposed Action, the number of noise-generating training activities would 

increase. This increase in many of activities listed in Section 3.5.3.2 would not result in general 

increases in noise levels. Sound-generating events under the Proposed Action are intermittent, 

occur in remote or off-limit areas, and do not expose human receptors to high noise levels since 

the proposed SUA is uninhabited.

The primary sound sources of noise in the portions of the 2010 MIRC EIS analyzing the impacts 

to the proposed R7201-A and W-11, W-12, and W-13 are aircraft and training activities. The

only source of noise on the uninhabited Farallon de Medinilla (FDM) is periodic military 

bombardment and aircraft overflights. Land explosion noise in the MIRC typically involves 

active explosive demolition practice, explosive ordnance disposal (EOD), active bombing 

practice, offshore bombardment, artillery and small arms fire.

The type and quantity of ordnance expended depends highly on the training objectives and range 

utilized. By far the greatest amount of land explosion noise occurs in the FDM area Missile and 

target launch noise occurs in the MIRC in an infrequent manner, and only during scheduled

activities. Due to safety concerns associated with launch activities, a large buffer zone of several 

square miles is typically instituted. Noise due to missile and target launch activities is typically 

maximum at the point of initiation and rapidly fades as: a) the missile or target reaches optimal 

thrust conditions at which time thermal equilibrium of gasses surrounding the exhaust nozzle 

occur; and b) the missile or target reaches an adequate downrange distance.

The Offshore Operations are some of the training activities that contribute to noise in the 

proposed SUA areas. Under the Proposed Action, the number of activities occurring within W517 and FDM are expected to increase from 552 activities to 2,542 annually. Offshore major 

exercises are expected to increase as well, though not expected to contribute (outside of aircraft 

overflights over land and ordnance use) to community noise levels. The majority of these 

activities are expected to be associated with BOMBEX activities. The ordnance used in this 

training is expected to remain similar and include inert training munitions (e.g., MK-76, BDU45, BDU-48, BDU-56), and live MK-80-series bombs. The loudest sounds would be from live 

MK-80-series bombs, with SELs ranging between 110 dBA and 125 dBA, with peak sound 

levels being much higher. While the total number of annual activities is high, the average 

number of daily activities is less than ten and would still not contribute to equivalent noise 

levels. For example, assuming ten activities occur an hour, each involving the use of a live MK80 series bomb, and respective detonations occurring in the same location, this operation would 
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produce a hourly Leq of approximately 65 dBA at a distance of 180 feet. This increase in number 

of activities and detonations may affect non-human sensitive receptors on FDM from increased 

numbers of potentially disturbing impulse noises. However, current practices of targeting areas 

that are the least sensitive for nesting and roosting (eastern cliffs, northern portion of island) of 

sensitive species aim to reduce any direct effect from ordnance activities, though there may still 

be acoustic signatures that cause temporary disturbance. Impacts to human receptors would be 

minimal because the offshore areas are remote from populated areas, participants are all beyond 

safe distances, and there are no sensitive human receptors in the vicinity.

GUNEX. Surface-To-Surface GUNEX takes place in the open ocean offshore areas of MIRC to 

provide gunnery practice for Navy and Coast Guard ships utilizing shipboard gun systems and 

small craft crews utilizing small arms. GUNEX training activities conducted in W-517 involve 

only surface stationary targets such as a MK-42 Floating At Sea Target (FAST) or MK-58 

marker (smoke) buoys. The systems employed against surface targets include the 5-in,76-mm, 

25-mm chain gun, 20-mm Close In Weapon System (CIWS), .50 caliber machine gun, 7.62 mm 

machine gun, small arms, and 40-mm grenades. Air-to-Surface (A-S) GUNEX activities are

conducted by rotary-wing aircraft against stationary targets (FAST and smoke buoy). Rotarywing aircraft involved in this operation would use either 7.62-mm or .50-caliber door-mounted 

machine guns. Noise produced by GUNEX activities is varied in nature and typically consist of 

engine and boat noise or aircraft noise (A-S activities) with intermittent .50-cal machine gun and 

small arms firing. Of the ordnance types listed above, the loudest sounds would be from the 5-

inch and 76- mm guns, both of which are capable of producing SELs of 110 dBA at distances of 

50 feet from the source. The SH-60 helicopters that most typically participate in A-S GUNEX 

activities can produce single event overflight levels approaching 90 dBA SEL. Effects from these 

acoustic sources are minimal to non-existent to humans as the offshore areas are remote from 

populated areas, participants are all beyond safe distances, and there are no sensitive human 

sources in the vicinity.

BOMBEX. BOMBEX (Land) allows aircrews to train in the delivery of bombs and munitions 

against ground targets at FDM. BOMBEX exercises can involve a single aircraft or multiple 

aircraft which can include aircraft such as FA-18, B-1B, B-2, B-52, and H-60. F-22 and F-15 

aircraft will be part of the ISR/Task Force and may require use of this training range as well. 

Noise from aircraft is minimal, as long-range bombers typically operate at higher elevations 

(15,000 feet above ground level [AGL] or higher), and smaller tactical aircraft operate much 

lower, though usually above 3,000 feet AGL. At these elevations, SELs from direct overflights 

of F-18s and SH-60s would approach 95 dBA and 70 dBA, respectively. The ordnance 

commonly used in this training on FDM are inert training munitions (e.g. MK-76, BDU-45, 

BDU-48, BDU-56), and live MK-80-series bombs. Of these, the loudest sounds would be from 

live MK-80-series bombs, with SELs ranging between 110 dBA and 125 dBA, with peak sound

levels being much higher. However, the noise impacts to humans would be minimal because the 

offshore areas are remote from populated areas, participants are all beyond safe distances, and 

there are no sensitive human receptors in the vicinity.

MISSILEX (Air). The Air-to-air Missile Training Exercise provides live-fire opportunities for 

aircrews and supporting maintenance. Typically, these exercises are conducted by Air Force and 

Navy fighter aircraft, firing live missiles against unmanned, air-launched drones or flares. 
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Historically, these events have accompanied COCOM-level exercises and take place in Warning 

Areas at significant range (60 NM or greater) from inhabited areas, negating potential noise 

impacts on local populace.

The MIRC EIS/OEIS determined that airborne noise generated by training and testing activities 

would have no substantial environmental effects on human sensitive receptors because noise 

from training activities in the MIRC would be dispersed and intermittent, so it would not 

contribute to public long-term noise levels; and R-7201A, and W-11, W-12, and W-13 training 

areas are remote and isolated from the general public, so no sensitive receptors would be exposed 

to noise events occurring within R7201A. Therefore, the Proposed Action will have a less than 

significant noise impacts.

6.11.3 2015 MITT EIS EIS/OEIS Analysis

Aircraft Overflight Noise

Military aircraft originating from Guam would most often transit to one of the three warning 

areas located south of Guam (Figure 3.12-2). Warning Area (W)-517 overlays deep ocean waters 

and is located south-southwest of Guam. The northernmost boundary of W-517 is approximately 

8 NM from the southern tip of Guam (Figure 3.12-2). W-517 provides a large SUA area 

extending from surface to unlimited altitude (Table 3.12-1). W-517 is constrained by commercial 

air traffic lanes to the east and west. W-11A/B is located east of W-517 and also overlays deep 

ocean waters. The northernmost boundary of W-11 is approximately 30 NM south-southeast of 

the southern tip of Guam. W-12 is adjacent to the southern boundary of W-517 and extends SUA 

approximately 30 NM farther south. The northernmost boundary of W-12 is approximately 120 

NM from southern Guam. Aircraft are flying at an altitude of 5,000 ft. [1,500 m] and at a 

subsonic airspeed [400 knots]) (U.S. Department of the Navy 2009). Exposure to fixed-wing 

aircraft noise would be brief (seconds) as an aircraft quickly passes overhead.

Helicopters

Noise generated from helicopters is transient in nature and extremely variable in intensity. In 

general, helicopters produce lower-frequency sounds and vibration at a higher intensity than 

fixed-wing aircraft (Richardson et al. 1995). Helicopter sounds contain dominant tones from the 

rotors that are generally below 500 Hertz. Helicopters often radiate more sound forward than 

backward. The underwater noise produced is generally brief when compared with the duration of 

audibility in the air.

Helicopter unit level training typically entails a high volume of single-aircraft sorties over water 

that start and end at an air station, although flights may occur from ships at sea. Individual flights 

typically last about 2 to 4 hours. Some events require low-altitude flights over a defined area, 

such as mine countermeasure activities deploying towed systems. Most helicopter sorties 

associated with mine countermeasures would occur at altitudes as low as 75 to 100 feet. 

Likewise, in some anti-submarine warfare events, dipping sonar is deployed from a line 

suspended from a helicopter hovering at low altitudes over the water.

The military conducts training and testing activities in operating areas away from commercially 

used waterways and inside SUA. Most shipping lanes are located close to the coast but those that 

are trans-oceanic start and end to the northwest of Guam. The proposed SUA is over open water 
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and there are no human sensitive noise areas that will be exposed to additional noise within the 

proposed SUA as a result of the additional training and testing activities.

The EIS analyzes noise impacts to biological resources, and does not include a noise analysis for 

human noise sensitive area. Since the proposed SUA does not have any human noise sensitive 

areas, the Proposed Action will have less than significant noise impacts.

6.11.4 Conclusion

The FAA’s significance threshold for noise is whether the proposed action would increase noise 

by DNL 1.5 dB or more for a noise sensitive area that is exposed to noise at or above the DNL 65 

dB noise exposure level, or that will be exposed at or above the DNL 65 dB level due to a DNL 

1.5 dB increase, when compared to the no action alternative for the same timeframe. Per the 

discussion above, the FAA has determined the establishment of the proposed SUA will have less 

than significant noise impacts.

6.12 Socioeconomic Impacts, Environmental Justice, and Children’s Environmental 

Health, Safety Risks

6.12.1 Socioeconomic Impacts

In the western Pacific Ocean, four commercially used waterways link Guam and CNMI with 

major ports to both the east and west. These navigable waterways are utilized by commercial 

vessels. Figure 3.2-1 of the EA/OEA generally depicts the commercially used waterways and 

their relation within MIRC. Guam has one commercial port located within Apra Harbor (Port 

Authority of Guam 2011). There are three ports within CNMI: Rota, Tinian, and Saipan.

Commercial fishing occurs throughout the Study Area from nearshore waters adjacent to Guam 

and the CNMI, as well as offshore banks. Sport or recreational fishing also occurs at various 

times throughout the year when popular sport fish, including blue marlin, mahi-mahi, yellowfin, 

and skipjack tuna, are most abundant (Schultz 2000).

Commercial fishermen in Guam and the CNMI typically fish in waters that are less than 500 feet 

deep and target the red-gilled emperor (Western Fishery Management Council 2012). 

Commercial fishing peaks in summer when sea conditions are calm, but occurs year round in 

some locations (e.g., leeward side of the islands) where conditions are usually calmer. Some 

small-scale commercial fishing takes place in waters deeper than 500 feet and focuses on snapper 

and grouper species (Western Pacific Regional Fishery Management Council 2008).

Commercial and recreational fishing activities contribute to the overall economy and cultural 

heritage in the CNMI and on Guam. The military does not limit fishing activities from occurring 

in areas of the Study Area that are not being used by the Navy during training activities. The 

military has been conducting training activities within the Study Area for decades, and has taken 

and will continue to take measures to prevent interruption of commercial and recreational fishing 

activities. These measures include the following:

• Range control consists of scheduling SUA with operational units and notifying military 

and civilian stakeholders of SUA schedules via NOTAMs and Notice to Mariners 

(NOTMAR). NOTAMs and NOTMARs are issued at least 72 hours in advance to 
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minimize potential military/civilian interactions. This process is implemented to ensure 

that commercial and recreational users are aware of the military’s plans and allow users 

to plan their activities to avoid scheduled training activities and the frequency of fishing 

trips or in the availability of desirable fishing locations due to military activities is not 

expected to change.

• Notifying the public via NOTMARs of upcoming activities requiring a temporary 

exclusion zone. This provides mariners with advance notice of areas being used by the 

military for hazardous training activities, and allows mariners to plan accordingly by 

selecting an alternate destination without appreciable effect to their activities. 

The DZ around FDM would provide a greater level of public health and safety by increasing the 

geographic extent of restrictions to all private and commercial vessels during hazardous training 

and testing activities. As indicated above, the Navy’s safety policies and procedures would 

ensure that activities are conducted safely in the controlled training and testing areas. Areas that 

are not being used by the Navy and other Services for training purposes within the Study Area 

will continue to be accessible and available for fishing activities under EA/OEA Alternative 2. 

The military would maintain its measures to prevent interruption of commercial and recreational 

fishing activities, as described above. Thus, current measures and protocols would be used for 

the DZ expansion from 10 to 12 NM to allow commercial and recreational fishing boats to select 

an alternate destination without substantially affecting their activities.

Therefore, potential impacts on the regional economy (commercial and recreational fishing) from

implementation of Alternative 2 (MIRC EA/OEA) would not change as a result of the proposed 

airspace modification. 

The FAA has not established a significance threshold for socioeconomic impacts. There would 

be no significant shift in regional employment and spending or earning patterns as a result of 

implementation of the EA/OEA Alternative 2. No significant impacts on the regional economy 

would occur given the extensive size of the training area, the notification process via 

NOTMARs, and the limited number of commercial fishing vessels. Residential relocation is not 

required as part of the Proposed Action. Therefore, FAA has determined any socioeconomic 

impacts resulting from the Proposed Action are less than significant.

6.12.2 Environmental Justice 

No significant impact on air quality would occur because all training events analyzed are within 

areas designated by the U.S. Environmental Protection Agency as being in attainment for all 

criteria pollutants or in nonattainment areas for SO2 where the associated total annual emissions 

are less than the de minimis thresholds for General Conformity determination

The Navy has specific documented public health and safety procedures in place to ensure that 

non-participants, including children, are not endangered by Navy actions using SUA, including 

restricting public access to within 12 NM of FDM.

Impacts to subsistence fishermen are not expected. The military does not limit fishing activities 

from occurring in areas of the Study Area that are not being used by the Navy during training 

activities as discussed above. 
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Impacts on traditional cultural resources can be an environmental justice concern under EO 

12898. There are no traditional cultural resources identified in the Proposed SUA study areas in 

the 2010 EIS/OEIS. No significant unavoidable impacts on traditional cultural resources are 

anticipated to result from the changes that would occur as a result of the Proposed Action.

The MIRC EIS/OEIS determined that airborne noise generated by training and testing activities 

would have no substantial environmental effects on human sensitive receptors because noise 

from training activities in the MIRC would be dispersed and intermittent, and training areas on 

FDM are remote and isolated from the general public, so no sensitive receptors would be 

exposed to noise events occurring on FDM.

The Proposed Action would occur entirely over open ocean and above ground level. The 

Proposed Action would not impound, divert, drain, control, or otherwise modify the waters of 

any stream or other body of water. Therefore, the Proposed Action will not create a water 

resources impact. 

The FAA has not established a significance threshold for Environmental Justice. Based on the 

discussion above, the FAA has determined that the implementation the Proposed Action would 

not result in disproportionately high and adverse human health or environmental effects on 

minority and low-income populations. 

6.12.3 Children’s Environmental Health and Safety Risks

Impacts from air quality, biological resources, hazardous materials, historical/cultural resources, 

land use, public health and safety, and noise were analyzed to identify and assess environmental 

health risks and safety risks that may disproportionately affect children and to ensure that any 

activities address disproportionate risks to children that result from environmental health risks or 

safety risks as required in EO 13045, Protection of Children from Environmental Health Risks 

and Safety Risks and FAA Order 1050.1F, Exhibit 4-1. An assessment of the proposed actions 

identified no disproportionately high and adverse environmental or health effects on children. 

The FAA has not established a significance threshold for Children’s Environmental Health and 

Safety Risks. The Proposed Action would occur in airspace entirely over open ocean, above 

ground level, in an uninhabited area and there are no regular inhabitants that would see or hear 

aircraft overflights. Therefore, the Proposed Action will not have a noticeable impact on 

Children’s Environmental Health and Safety Risks

6.13 Visual Effects

The Proposed SUA is an uninhabited area and there are no regular inhabitants that would see 

aircraft overflights or would be impacted by lights on aircraft utilizing the warning areas and the 

RA. Therefore, the Proposed Action will not create an impact to light emissions or visual 

resources/visual character.

6.14 Water Resources

The Proposed Action would occur entirely over open ocean and above ground level. The 

Proposed Action would not impound, divert, drain, control, or otherwise modify the waters of 
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any stream or other body of water. Therefore, the Proposed Action will not create a water 

resources impact.

6.15 Cumulative Impacts

Cumulative impacts result from incremental impacts of an action when combined with other 

past, present, and reasonably foreseeable actions (40 CFR 1508.7). Cumulative impacts can 

result from individually minor but collectively significant actions over a period of time (CEQ, 

1997). Cumulative impacts would occur if incremental impacts of the Proposed Action, added to 

the environmental impacts of past, present, and reasonably foreseeable similar actions, would 

result in an adverse effect to resources in the region.

Past, present, and reasonably foreseeable actions are identified in Chapter 4 of the EA/OEA. Since 

the EA/OEA was published in 2013, some of the Actions analyzed in the Cumulative Impacts 

chapter are out of date. The FAA used the Navy’s 2015 Mariana Islands Training and Testing 

EIS/OEIS as a source of information to update the cumulative impact analysis below:

6.15.1 Military Actions:

6.15.1.1 Final Overseas Environmental Impact Statement and Environmental Impact 

Statement for Surveillance Towed Array Sensor System Low-Frequency Active Sonar

In August 2012, the Navy released a Record of Decision for employing the Surveillance Towed 

Array Sensor System Low Frequency Active Sonar. The Navy currently plans to operate up to 

four Surveillance Towed Array Sensor System Low Frequency Active Sonar systems for routine 

training, testing, and military operations. Based on current Navy national security and 

operational requirements, routine training, testing, and military operations using these sonar 

systems could occur in the Pacific Ocean (including the Study Area), Atlantic Ocean, Indian 

Ocean, and Mediterranean Sea. The underwater sound produced by this project may contribute to 

the cumulative impacts on marine mammals and sea turtles in the Study Area.

6.15.1.2 Terminal High-Altitude Area Defense (THAAD) Permanent Stationing in Guam 

Environmental Assessment

In June 2015, the Army released an Environmental Assessment to permanently place and operate 

a THAAD ballistic missile defense battery at Andersen Air Force Base (AFB) in Guam. The 

THAAD battery would be permanently located at the Northwest Field (NWF) of Andersen AFB. 

The EA also analyzes the potential impacts from the expansion of the NWF cargo drop zone 

training area that was encumbered by THAAD operations. The THAAD EA/OEA analyzed the 

environmental effects which might result from the implementation of the Navy’s Proposed 

Action. Resource areas analyzed included air quality, noise, water resources, biological 

resources, cultural resources, airspace management, hazardous materials and wastes, human 

health and safety, socioeconomics, and utilities and transportation infrastructure. The Army 

determined no significant impacts would occur as a result of the project, but the project may 

contribute incidentally to the cumulative impacts to these environmental resources in the Study 

Area.

Due to SUA conflicts with the Guam and Commonwealth of the Northern Mariana Islands 

Military Relocation project, changes will be made to the Proposed SUA analyzed in the 2015 

Final EA, and a re-evaluation of the EA is pending. 
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6.15.1.3 Mariana Islands Training and Testing Environmental Impact Statement/Overseas

Environmental Impact Statement

The Navy published the MITT EIS/OEIS in May 2015, and signed their ROD on July 23, 2015. 

The Proposed Action in the MITT EIS/OEIS is to conduct military training and testing activities 

in the MIRC, additional areas on the high seas, and a transit corridor where training and testing 

activities may occur. These areas are collectively referred to as the MITT Study Area. The 

Proposed Action includes activities such as an increase in air combat maneuvers which may 

occur outside of the 2010 and 2013 MIRC study areas, but within the MITT Study Area. Strike 

warfare and naval gunfire exercises at FDM would increase under the alternatives. 

The MITT EIS/OEIS analyzed the environmental effects which might result from the 

implementation of the Navy’s Proposed Action. Resource areas analyzed included sediments and 

water quality, air quality, marine habitats, marine mammals, sea turtles, seabirds and shorebirds, 

marine vegetation, marine invertebrates, fish, terrestrial species and habitats, cultural resources, 

socioeconomic resources, and public health and safety. In addition, cumulative impacts were

analyzed and to take into account potential cumulative impacts associated with increased training 

and testing activities (including increased sorties) as applicable to other reasonably foreseeable 

and ongoing actions. The impact findings of the EIS include:

• Past human activities have impacted these resources to the extent that several marine 

mammal species and terrestrial species, and all sea turtles species occurring in the Study 

Area are ESA-listed. Several marine mammal species and stocks are also classified as 

strategic stocks under MMPA.

• Several native forest-dwelling birds have been extirpated or suffered extinction in the 

Mariana Islands, primarily on Guam because of predation by introduced invasive species. 

These resources would be impacted by multiple ongoing and future actions.

• The use of sonar and other non-impulsive sound sources under the No Action Alternative, 

Alternative 1, and Alternative 2 has the potential to disturb or injure marine mammals 

and sea turtles.

• Explosive detonations under the No Action Alternative, Alternative 1, and Alternative 2 

have the potential to disturb, injure, or kill marine mammal, terrestrial and sea turtle 

species. 

• Explosive detonations and other military training activities on FDM under the No Action 

Alternative, Alternative 1, and Alternative 2 have the potential to disturb, injure, or kill 

the Mariana fruit bat, Micronesian megapode, and seabirds that nest or visit FDM.

• Under Alternative 1 and Alternative 2, proposed danger zones could potentially restrict 

access to fishing and recreational areas when ranges are in use.

The aggregate impacts of past, present, and other reasonably foreseeable future actions are 

expected to result in significant impacts on some marine mammal, terrestrial, all sea turtle 

species resources in the Study Area. The No Action Alternative, Alternative 1, or Alternative 2 

would contribute to cumulative impacts, but the relative contribution would be low compared to 

other actions. Marine mammal and sea turtle mortality and injury from bycatch, commercial 

vessel ship strikes, entanglement, ocean pollution, and other human causes are estimated to be 
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orders of magnitude greater (hundreds of thousands of animals versus tens of animals) than 

potential mortality, strandings, or injury resulting from military training and testing activities. 

(Culik 2004; International Council for the Exploration of the Sea 2005; Read et al. 2006).

6.15.1.4 Environmental Impact Statement for Divert Activities and Exercises, Guam and 

Commonwealth of the Northern Mariana Islands

The U.S. Air Force proposes improvements to an existing airfield or airfields on U.S. territory 

near the Philippine Sea in support of expanding mission requirements in the western Pacific. In 

addition, divert capabilities for current, emerging, and future training activities are proposed. A 

Draft EIS analyzing environmental impacts associated with the divert activities and exercises 

was published in June 2012. 

The Revised Draft EIS was the second public version of the EIS. It incorporated comments 

received on the 2012 Draft EIS and presented modified alternatives. The Revised Draft EIS 

public review period was initiated on October 16, 2015. The Final EIS presents three modified 

alternatives that are the same as those presented in the 2015 Revised Draft EIS and represent a 

reduced capability from that presented in the 2012 Draft EIS. The Final EIS was published in 

September 2016.

The EIS found that there could be major adverse effects from the construction phase of the 

project on cultural, resources, socioeconomics and environmental justice, and human health and 

safety within the project area that included Saipan and Tinian islands. The Modified Tinian 

Adverse effects could also occur on noise, and socioeconomic and environmental justice 

resources. Beneficial effects could also occur on socioeconomic resources at both Tinian and 

Saipan. Therefore, this project may contribute to the cumulative impacts on natural, noise, 

cultural and socioeconomic resources in the Study Area.

6.15.1.5 Guam and Commonwealth of the Northern Mariana Islands Military Relocation 

(2012 Roadmap Adjustments) Supplemental Environmental Impact Statement

In September 2010, the Navy signed a Record of Decision (ROD) regarding the 2010 Final EIS 

for the Guam and Commonwealth of the Northern Mariana Islands (CNMI) Military Relocation; 

Relocating Marines from Okinawa, Visiting Aircraft Carrier Berthing, and Army Air and Missile 

Defense Task Force. The ROD documented the Navy’s decision to implement the preferred 

alternatives identified in the 2010 Final EIS for the main base (cantonment), aviation, and 

waterfront operations to support relocation of approximately 8,600 Marines and approximately 

9,000 dependents from Okinawa to Guam. The ROD deferred a decision on the development of a 

live-fire training range complex along Route 15 in the northeastern part of Guam. 

The 2010 Final EIS concluded that activities on Guam could significantly impact noise, 

land/submerged land ownership and use, recreation, offbase roadways, socioeconomics, public 

health and safety, and environmental justice and protection of children. On Tinian, the project 

was found to potentially have significant impacts on land/submerged land, socioeconomics, and 

environmental justice and protection of children. Therefore, this project may contribute to the 

cumulative impacts on socioeconomic resources in the Study Area. 
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In February 2012, the Navy initiated a Supplemental EIS to evaluate the environmental 

consequences of establishing a live-fire training range complex on Guam in support of the 

relocation of Marine Corps forces to Guam. Scoping meetings for the Supplemental EIS were 

held in March 2012. On 27 April 2012, the U.S.-Japan Security Consultative Committee issued a 

joint statement announcing its decision to adjust the plans outlined in the May 2006 Realignment 

Roadmap document. In accordance with the adjustments (the “2012 Roadmap Adjustments”), 

the Department of Defense adopted a new force posture in the Pacific which provided a 

substantially smaller Marine Corps relocation to Guam. As a result of the 2012 Roadmap 

Adjustments, the Navy expanded the scope of the Supplemental EIS to also evaluate the 

potential environmental consequences from construction and operation of a main cantonment 

area, including family housing, and associated infrastructure to support the relocation of a 

substantially reduced number of Marines than previously analyzed. The Draft Supplemental EIS 

was released in April 2014 and supplements the 2010 Final EIS for the Guam and CNMI 

Military Relocation. The Final Supplemental EIS was released in July 2015 and the Navy signed 

the ROD on August 29, 2015. The project was found to have significant but mitigatable impacts 

on water resources (groundwater, wastewater, and nearshore waters), biological resources 

(vegetation/plants and some ESA species), cultural resources, and socioeconomic resources, and 

environmental justice communities. Therefore, this project may contribute to the cumulative 

impacts to these environmental resources in the Study Area.

Due to SUA conflicts with the Army’s THAAD project, changes will be made to the Proposed 

SUA analyzed in the 2015 Final Supplement EIS, and a re-evaluation of the EIS is pending.

6.15.1.6 Commonwealth of the Northern Mariana Islands Joint Military Training 

Environmental Impact Statement/Overseas Environmental Impact Statement 

The CNMI Joint Military Training Draft EIS/OEIS was published April 2015, and it evaluated

the potential impacts associated with alternatives for meeting U.S. Pacific Command Service 

Components’ unfilled unit level training and combined level of military training requirements in 

the Western Pacific. The proposed action would establish a series of live-fire and maneuver

ranges and training areas within the CNMI and include amphibious operations on Tinian. The 

proposed action is to expand existing ranges and training areas (RTAs) and construct new RTAs 

within the CNMI for 20 weeks of live-fire training on Tinian. Therefore, this project may 

contribute to the cumulative impacts on natural resources, biological resources, noise, cultural,

socioeconomic resources and possibly others in the Study Area.

6.15.2 Other Environmental Considerations

6.15.2.1 Commercial Fishing

Commercial fishing can adversely affect fish populations, other species, and habitats. Potential 

impacts include overfishing of targeted species and bycatch, both of which negatively affect fish 

stocks (Barnette 2001; National Research Council 2002). Commercial fishing in the CNMI 

generally occurs within 30 nm of shore. 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). The MIRC EIS/OEIS concluded that the transient nature of 

training and testing exercises and the minor, localized potential ecosystem effects are negligible. 

The CNMI Fishery Management Plan (Western Pacific Regional Fishery Management Council 
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2005) provides regulatory procedures and processes to prevent overfishing and overfished 

stocks. The same conditions would apply for the MIRC EA/OEA.

67.15.2.2 Maritime Traffic

Section 3.2, Transportation, discusses ocean traffic as the transit of commercial, private, or 

military vessels at sea, including submarines. Three navigable waterways are used by 

commercial vessels to link Guam and the CNMI with major ports to the east and west. Primary 

concerns for cumulative impacts include vessel strikes and underwater sound. Navy vessel traffic 

is a small fraction (approximately 2 percent) of the overall commercial vessel traffic (Jensen and 

Silber 2004). The MIRC EA/OEA analysis determined no significant impact on and no 

significant harm to maritime traffic would occur.

6.15.2.3 Ocean Pollution and Marine Debris

Ocean pollution and marine debris may originate from land-based runoff and discharges, spills, 

dumping, vessels, and atmospheric deposition (U.S. Department of the Navy 2010a). Plastic 

debris is a major concern for ocean pollution; floating debris has been discovered accumulating 

in oceanic gyres (Law et al. 2010). However, Navy training and testing activities are 

implemented in accordance with environmental compliance policies and procedures applicable to 

shipboard training afloat and pollution prevention as defined in Navy and DoD Instruction 

5000.2-R, EO 12856, and EO 13101. The same environmental compliance policies and 

procedures would apply for the MIRC EA/OEA; preventive measures to protect water quality 

would continue to be implemented.

6.15.3 Conclusion

Under the Proposed Action, the number and types of training and testing activities and the 

geographical locations in which they are conducted are described in the 2010 MIRC EIS/OEIS

and additional training and testing activities are analyzed in the 2015 MITT EIS/OEIS. No 

significant contribution of military training and testing activities to cumulative impacts when 

added to other past, present, and reasonably foreseeable future actions were identified in the 

2010 MIRC EIS/OEIS and the 2015 MITT EIS/OEIS. The discussions presented in Chapter 3 

of the EA/OEA indicated that the Proposed Action would not significantly impact the resources 

that have been evaluated (public health and safety, transportation, regional economy, and 

recreation). The evaluation of other actions that are reasonably foreseeable in the Study Area 

and other environmental considerations indicated that procedures and processes are 

implemented to minimize or avoid cumulative impacts. 

Based on the FAA’s independent review and evaluation, the FAA concludes that the Proposed

Action, when considered with other past, present, and reasonably foreseeable future actions, is 

not likely to result in significant cumulative impacts when the mitigation measures described in 

the 2013 MIRC EA/OEA, the 2010 MIRC EIS/OEIS, the 2015 MITT EIS/OEIS, the 2009 

Programmatic Agreement enacted to comply with the National Historic Preservation Act, and 

NMFS’s June 12, 2015 Biological Opinion and July 31, 2015 Marine Mammal Protection Act 

Letter of Authorization are considered.
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7 INCORPORATED BY REFERENCE

The FAA has reviewed the following information: 

1. Mariana Islands Range Complex Airspace Environmental Assessment/Overseas 

Environmental Assessment, June 2013

2. Mariana Islands Range Complex Environmental Impact Statement/Overseas 

Environmental Impact Statement, May 2010

3. The Mariana Islands Training and Testing Environmental Impact Statement/Overseas 

Environmental Impact Statement, May 2015

8 DECISIONS AND ORDERS

8.1 Written Reevaluation

As a result of this written reevaluation, FAA determined that the following warranted 

consideration due to changes since the 2013 MIRC EA/OEA was issued. 

• The Navy’s Mariana Islands Training and Testing (MITT) EIS/OEIS, issued in May 

2015, assumes the proposed SUA from the 2013 MIRC EA/OEA is established.

• New species were listed under the Endangered Species Act as threatened or endangered 

within the Proposed Action area after consultation for the 2010 MIRC EIS/OES was 

concluded.

• Confirmation that no new historic and cultural resources were designated within the 

project study area since 2013.

FAA independently evaluated the information in the 2015 MITT EIS/OEIS to determine if the 

activities proposed in the EIS would create any new environmental impacts within the Proposed 

SUA that were not considered in the 2013 EA/OEA. The MITT EIS/OEIS proposes to increase 

training operations, add testing operations, and use additional aircraft types in the Proposed SUA

that were not analyzed in the 2013 MIRC EA/OEA. Per the analysis provided above in Section 6 

Environmental Impacts of the Proposed Action, the FAA finds no significant impacts result from

an increase in those operations and additional aircraft types within the proposed SUA. 

As part of FAA’s evaluation of the 2015 MITT EIS/OEIS, FAA verified the Navy consulted with 

USFWS and NMFS to comply with ESA. This consultation resulted in a February 20, 2015 

USFWS Biological Opinion, and a January 12, 2015 NMFS Biological opinion. These two 

documents conclude that the Navy’s proposed actions in its 2015 MITT EIS/OEIS would not 

likely jeopardize the continued existence of various addressed species in accordance with the 

Terms and Conditions and Reasonable and Prudent Measures identified that prescribe limits on 

training and testing activities to avoid and minimize impacts to the listed species. 

As part of FAA’s reevaluation, FAA found that an additional 23 species were listed under ESA 

after the Navy completed consultation for the 2015 MITT EIS/OEIS. All 23 species are based on 

land within the Commonwealth of Northern Mariana Islands, and are not present within the 

proposed SUA. Therefore FAA’s proposed action will have no effect on the 23 species. 
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FAA has also verified that no new historic and cultural resources have been designated within

the project study area for the Proposed Action, and FAA has found that the 2009 Programmatic 

Agreement from the 2010 MIRC EIS/OEIS is applicable to the 2013 MIRC EA/OEA and 2015 

MITT EIS/OEIS. The Proposed SUA falls outside of the PA’s stipulated training restriction 

areas, so FAA finds the Navy is in compliance with the PA’s stipulations.

Per the reasons cited above in this section, the FAA has concluded that the 2015 MITT 

EIS/OEIS adequately analyzed the Navy’s proposed training and testing activities, which were 

addressed in the 2013 MIRC EA/OEA. In addition, FAA has verified that there are no new 

activities or new information that warrants supplemental analysis for any of the environmental 

impact categories described above in Section 6 Environmental Impacts of the Proposed Action.

Therefore, pursuant to FAA Order 1050.1F, paragraph 9-2, FAA has determined that no new 

supplemental EA or EIS is required because this WR indicates:

1. The Proposed Action conforms to plans or projects for which the prior 2013 MIRC 

EA/OEA and Navy FONSI have been issued and for the prior 2015 MITT EIS/OEIS and 

Navy ROD has been filed and there are no substantial changes in the action that are 

relevant to environmental concerns. 

2. Data and analyses contained in the 2013 MIRC EA/OEA and FONSI and 2015 MITT 

EIS/OEIS are still substantially valid and there are no significant new circumstances or 

information relevant to environmental concerns and bearing on the proposed action or its 

impacts.

3. Pertinent conditions and requirements of the prior approval have been, or will be, met in 

the current action.

8.2 Adoption

In accordance with FAA Order 1050.1F, paragraph 8-2, the FAA has conducted an independent 

evaluation and prepared this Record of Decision for the Navy’s Mariana Islands Range Complex 

Airspace EA/OEA. The FAA has determined that the EA/OEA and its supporting 

documentation, as incorporated by reference, adequately assess and disclose the environmental 

impacts of the Proposed Action. As a cooperating agency, the FAA provided subject matter

expertise and closely coordinated with the Navy during the environmental review process, 

including the preparation of the EA/OEA. Based on its independent review and evaluation as 

described in Section 6 Environmental Impacts of the Proposed Action and Section 8.1 Written 

Reevaluation of this document, the FAA has determined that the EA/OEA and its supporting 

documentation, as incorporated, adequately assess and disclose the environmental impacts of the 

FAA’s proposed action. 

Based on this evaluation, the FAA, as the Cooperating Agency, concludes that adoption of the

Mariana Islands Range Complex Airspace EA/OEA, with incorporation of its supporting 

documentation, is authorized in accordance with 40 CFR section 1506.3.

In addition, the FAA has determined that while the Navy’s MITT project increased training 

operations and introduced new aircraft into the proposed SUA, the impacts from the MITT 

project does not result in any significant new circumstances in the sections of the MITT EIS that 
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are relevant to SUA, or new information relevant to environmental concerns and bearing on the 

Proposed Action and to the adoption of the MIRC EA/OEA.

8.3 Finding Of No Significant Impact

After careful and thorough consideration of the facts contained herein, the undersigned finds that 

the Proposed federal Action is consistent with existing national environmental policies and 

objectives as set forth in Section 101(a) of the NEPA, as amended, and other applicable 

environmental requirements and will not significantly affect the quality of the human 

environment or otherwise include any condition requiring consultation pursuant to Section 

102(2)(C) of NEPA.

The review included the purpose and need to be served by this project, the alternative means of 

achieving them, the environmental impacts of these alternatives, the mitigation necessary to 

preserve and enhance the human environment, and the response to public concerns. There will 

not be any disproportionately high and adverse human health or environmental effects from the 

implementation of the Proposed Action on minority and low-income populations. Nor will there 

be any impacts associated with the protection of children from environmental health and safety 

risks.

This decision signifies that applicable Federal environmental requirements relating to the

Proposed Action have been met. The decision enables the FAA to complete its Rulemaking

actions to establish R-7201A and non-rulemaking actions to establish W-11, W-12, and W-13 as 

described in the Proposed Action.