We
appreciate the opportunity to provide input to the
Environmental Assessment process for this onerous
proposal. We emphatically oppose the proposed bombing
activity. Furthermore, we insist that the Navy prepare a
complete Environmental Impact Statement in order to
evaluate the truly complex array of potential direct and
cumulative impacts that may accrue from the Navy's
proposed actions. This EIS should consider the potential
impacts of not only the proposed training practice when
all is going well and according to schedule, but also the
potential impacts associated with the array of events
that can go wrong, including intentional, as well as
unintentional errors in flight trajectories.
This ill-conceived proposal has targeted the nucleus
of ecosystem integrity for our entire region, including
affected areas on both coastal and interior sides of the
Coast Ranges, as well as our precious marine environment
in the Monterey Bay National Marine Sanctuary. Among our
concerns that should be addressed in an EIS are the
following potential direct and cumulative impacts of
sonic effects from the over-flights and bombing on:
• Population and metapopulation dynamics of the
federal and state listed endangered San Joaquin kit fox.
We are concerned that these sonic effects could
negatively impact this species' reproductive behavior and
dispersal patterns.
• Population and metapopulation dynamics of Tule
elk, including reproductive behavior and migration
patterns. Since tule elk are already protected by
specific legislation, they have not been listed as an
endangered species.
"In 1971, the debate surrounding tule elk moved from
the Fish and Game Commission to the California State
Legislature, which passed the Behr Bill. This bill
amended Section 332 and added Section 3951 to the
California Fish and Game Code. This law prohibited the
take of tule elk until a minimum population size of 2000
animals was attained. In 1976, the United States
Congress passed Public Law 94-389, which concurredwith
the state law and directed federal agencies to make land
available for elk reintroduction. In 1977 the Tule Elk
Interagency Task Force was formed to coordinate the
efforts of the many state and federal agencies
responsible for tule elk reintroduction. By 1987 the
tule elk population exceeded 2000 animals, and so the
legislature amended the Behr Bill. " (Rigney 2000)
Tule elk at FHL have been documented interbreeding
with the Fort Roberts herd, indicating incipient
metapopulation structure. Also, there is anecdotal
evidence that Tule elk may have migrate as far as to the
coast near Big Sur.
• Recovery (where applicable) and general
population dynamics, including migratory, foraging and
reproductive behavior, of an array of avian species (with
various regulatory protection) occurring within range of
the likely sonic impacts, including: California condor,
bald eagle, golden eagle, prairie falcon, peregrin
falcon, Cooper's hawk, sharp-shinned hawk, Bell's vireo,
yellow-breasted chat, purple martin, and the highest
concentration of oak savanna specialists in the nation,
including yellow-billed magpie, acorn woodpecker,
Nuttall's woodpecker, white-breasted nuthatch and western
bluebird, according to an annual Breeding Bird Survey
conducted by the US Fish and Wildlife Service. This
concentration of prime oak savanna habitats is of
national significance (D. Roberson and J. Banks pers.
com.)
• Reproductive biology and behavior patterns, as
well as other behavioral issues for a number or amphibian
and reptile species (with various regulatory protection),
including California red-legged frog, arroyo toad,
southwestern pond turtle, western spade foot toad and
California tiger salamander. We are concerned that sonic
effects reverberating through permanent and seasonal
aquatic habitats may impact the integrity of the
typically delicate egg masses of these species, among
other potential impacts.
• Reproductive biology of vernal pool fairy
shrimp &endash; again the concern regarding sound impacts
on aquatic habitats.
• Substrate stratification and embeddedness of
spawning gravels used by steelhead populations within
range of the sonic effects of overflights and
bombing.
• Reproductive behavior and metapopulation
structure of endangered Smith's blue butterfly along the
Big Sur coast.
• Behavior of pollinator species critical to the
life history of various sensitive plant species, as well
as those associated with local agricultural
production.
• Stability of landslide-prone areas associated
with Highway 1 along the Big Sur coast. We are concerned
that sonic effects of the proposal could destabilize
slopes already made tenuous by Highway 1 roadcuts,
leading to landslides that can bury critical marine rock
fish habitats.
• Reproductive and other behavior patterns of
marine mammals potentially effected by acoustic
reverberations in their marine environments, including
sea otters, grey whales and dolphins.
In addition to these sonic effects, we are concerned
about the potential for crashes, fuel spills and other
mishaps ,and their associated impacts on all of the above
species, as well as many others too numerous to name.
Furthermore, our own personal experiences include
witnessing military aircraft engaged in presumably
unauthorized "buzzing" of off-limit areas. One case in
point was the experience of the ground-shaking sonic
booms associated with military aircraft flying low over
the Tuolumne Meadows vicinity of Yosemite National
Park.
Presumably this was an unauthorized flight pattern.
Such joy-riding events may be unauthorized, but they
clearly do occur and the potential impacts of such
activities should be evaluated in the EIS.
Another vivid experience in one of our memories
occurred while working, as a consultant, on the Resource
Management Plan for Aliso and Wood Canyons Regional Park
for the Orange County Environmental Management Agency in
southern California. Our project team was on a field
trip in the park when a couple F-18s flew over from
nearby El Toro Marine Base. All the coyotes in the park
began to wail simultaneously. This did not sound like
the typical social howling they often seem to do around
sunset, but rather bloodcurdling screams.
It seemed clear the noise was piercing their eardrums
and all they could do was cry. This is but one of the
images that comes to mind when we think about the
prospect of such flights over the precious natural areas
of Fort Hunter Liggett, the Ventana and Silver Peak
Wilderness areas, the Cone Peak Research Natural Area and
the Big Sur coast in general. Not only coyotes, but kit
fox, raptors,and humans, among others, will presumably
suffer from such jarring impacts.
To reiterate, a complete Environmental Impact
Statement evaluating the above potential impacts, among
many others not mentioned here, is well-warranted.
Verna Jigour
and
Joe Rigney
Coast Ranges Ecosystem Alliance/Ventana Wildlands
Project
Citations:
Roberson, Don and Jim Banks. 1998. Personal
communications. *In* Fort Hunter Liggett Natural
Resources Group. Fort Hunter Liggett Natural Resources
Conservation Report. March 1998.
Rigney, Joe. 2001. Tule Elk Reintroduction
Opportunities. *In* Ventana Wildlands Project. 2001
(In press). Wildlands Network Assessment for
Central-West Ecoregion of California. Coast Ranges
Ecosystem Alliance, California Wilderness Coalition and
University of California, Santa Cruz Environmental
Studies Department and Geographic Information Systems
Lab.