Joint Informational briefing on the 2019 MITT Draft Supplemental EIS

Senator Therese Terlaje and Senator Sabina Perez were concerned after hearing several government agencies’ comments on the Mariana Islands Training and Testing (MITT) draft Supplemental Environmental Impact Statement (SEIS) and are encouraging all to have a say in the health and well-being of our livelihood and environment as impacted by military testing and training in our region.  The April 17th deadline has been extended to April 27th for the public to submit comments to the Department of the Navy on the proposed actions in the draft Supplemental Environmental Impact Statement (SEIS). 

The draft SEIS is an update to the 2015 Final MITT Environmental Impact Statement/Overseas Environmental Impact Statement (EIS/OEIS) and is intended to assess potential environmental impacts that would be caused by the Navy’s training and testing activities that include the use of active sonar and explosives.  This study area encompasses 984,601 square nautical miles of the entire ocean across and beyond the Mariana Islands, which is larger than the states of Washington, Oregon, California, Idaho, Nevada, Arizona, Montana and New Mexico combined.

Currently, the Navy’s permit allows 12,580 detonations of various magnitudes per year for 5 years, and 81,962 takings (or killings) of 26 different marine mammal species per year for 5 years. 

On August 15, 2019, Senator Therese Terlaje and Senator Sabina Perez conducted a joint informational briefing on the 2019 MITT Draft Supplemental EIS and invited Bureau of Statistics and Plans, Guam Environmental Protection Agency, Department of Agriculture, Guam State Historic Preservation Officer, Guam Preservation Trust, Guam Historic Preservation Review Board, Guam Waterworks Authority, and Guam Solid Waste Authority to share their expertise and comments on the potential impacts of the MITT on Guam’s environment, resources, cultural sites, and health.

Agencies highlighted various concerns:

Brent Tibbets, Biologist with Fisheries Section of Guam Department of Agriculture

He states, “reviewing the EIS, there are several portions of it that are comment worthy. I guess I would say one, of course, is the potential to interact with marine mammals with the activities that we see being proposed. Sonar, vessel interactions, explosive detonation in the water, all of these have the potential to impact marine mammals. One of the concerns from the EIS is that for all of the marine mammals that are mentioned, I don’t think there’s a single one that has the most current information available listed with it. We have information on strandings, on sightings, on whales sighted giving birth that were not mentioned in the EIS anywhere. And I’m not certain where that information was gotten from, but all of this information that was provided to our federal partners as well as that we have available, was not mentioned in the EIS.”  He continues to state, “We do have additional stranding records. We have additional records of marine mammals identified giving birth in the region. One of particular concern is the mention of the Agat offshore mine detonation site. That’s almost precisely where we have photographic evidence of sperm whales giving birth which are both marine mammal and endangered species listed organisms. Though it’s not listed anywhere in the EIS that incidents like that. Another area of concern is vessel strikes. Vessel strikes with marine mammals are addressed in the EIS but we have a greater incidence of vessel strikes with sea turtles on Guam. We’ve had at least five sea turtles killed by vessel strike in the last seven years on Guam that we’ve been able to identify. It’s difficult to identify the vessel that did strike the turtle. Nearly all of these occurred in inner Apra Harbor which is pretty much closed to all activity except military vessel activities. So the implication is that it could be military vessel strikes that are causing the sea turtle mortality. Another area in the EIS is mentioned… a large area to southeast of Guam Whiskey 517 is an area it was mentioned. It was very closely related to some offshore fishing banks where we documented a fair amount of fishing activity. In the last two years those banks have been off-limits about a 120 days, an average for the last two years which is about a third of the year for activity and primarily for fishing activity. Now they do fall just outside the range that is delineated but we’ve had fishermen report that when they get down to the banks there are military vessels that are telling them to not enter while activities are going on even though they’re outside the area.”

Edwin Reyes, Administrator, Guam Coastal Management Program, Bureau of Statistics and Plans

He states during his slide presentation regarding the MITT process, “it’s going to be a discussion on mitigation or project adjustments.  So this is an engagement process where we can understand the project fully but then also work to ensure that the resources of the territory are protected.”  He further states, “so the initial concepts that we’ll be looking at just by reading the executive summary (of the SEIS) one of them is marine habitat. So we want to ensure that military expended material will not pose contamination threats as material breaks down. This is not only a direct impact as the detonation occurs but any particles that may be consumed by organisms that can affect the food chain.  We’re not looking at just the moment but what could happen after the activity takes place.  We are concerned about any kind of seafloor detonations within our coastal zone and this doesn’t matter if there’s no corals on hard bottom or substrates.  With or without the presence of coral we know that the hard bottom substrate is an important area where coral polyps can settle and we want to be sure that that habitat is protected.”

Jesse Cruz, Administrator, Guam EPA’s Environmental Monitoring and Analytical Services

He mentions 12 different issues with the draft SEIS.  Two of the 12 issues are the following: “At minimum, a yearly report should be produced summarizing all activities identified in the MITT.  There is no current mechanism to evaluate if the activities and quantities identified in the MITT are met or exceeded.  Report should also address any impacts to stressor types.”  Additionally, he states, “Neither the 2015 MITT nor the 2019 Supplemental MITT have a discussion on the rational for an increase from a 10 lbs. underwater mine charge to the new standard of a 20 lbs. charge for the listed mine detonation activities.  What is the justification for the increase?  This needs to be further explained and justified.” 

Joe Quinata, Chief Program Officer, Guam Preservation Trust and

Dave Lotz, Member of Guam Historic Preservation Review Board

Regarding the Cultural Resources section of the draft SEIS, the State Historic Preservation Officer was not present at the informational briefing but did relay to her oversight chair that her concern was that the list of cultural resources referenced in the SEIS does not fully incorporate all the cultural resources that may be impacted.  Representatives from the Guam Preservation Trust and the Guam Historic Preservation Review Board echoed the SHPO’s sentiments.

The draft SEIS for the MITT is available at https://mitt-eis.com/.  The public is encouraged to submit their comments at https://mitt-eis.com/ by April 27, 2019.

Terlaje and Perez both reiterate, “Guam does not have a seat at the table to say yes or no to the detonations or use of sonar in our lands and waters.  But we can, for the sake of our children, make it very clear on the record that we individuals and agencies object to the cumulative harm.  We are looking to our government agencies and all of our leaders to do whatever it takes to protect our resources and health.”

See copies of all of the written comments from the agencies present at the informational briefing below: