Coast Ranges Ecosystem Alliance/Ventana Wildlands Project

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

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.

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