COMMENTS OF LANNY SINKIN ON DRAFT OVERSEAS ENVIRONMENTAL IMPACT STATEMENT AND ENVIRONMENTAL IMPACT STATEMENT FOR SURVEILLANCE TOWED ARRAY SENSOR SYSTEM LOW FREQUENCY ACTIVE (SURTASS LFA) SONAR

PREFACE

1. THERE IS AMPLE EVIDENCE THAT THE DRAFT IS NOT AN OBJECTIVE EVALUATION OF THE SURTASS LFA SYSTEM AND ITS ENVIRONMENTAL EFFECTS

1.1. Illegal Development of SURTASS LFA

1.2. Illegal Expenditure of Funds on Development of SURTASS LFA

1.3 Response to Getting Caught

1.4. Lack of Scientific Rigor in the OEIS/EIS process

1.4.1 The tests conducted off the Island of Hawai`i lacked a baseline of whale locations prior to the initiation of testing and lacked adequate monitoring of whale locations during testing

1.4.2. The Phase III testing did not include monitoring of dolphin behavior

1.4.3. During Phase III, the scientists made no effort to follow up on reported adverse impacts of SURTASS LFA

1.4.4. The LFS SRP observations of individual whales was inadequate

1.4.5 The determination of no significant impacts on turtles appears to rely solely on a personal communication, not data or studies

1.5. Lack of an "Open Process" in the Development of the OEIS/EIS

1.6. Deliberate failure to consider relevant evidence

1.7. Premature Issuance of the Draft

1.8. Conclusion of Section 1

2. THE PRESENTATION OF ALTERNATIVE 1 AS THE PREFERRED ALTERNATIVE IS CONFUSING AND CONTRADICTORY BECAUSE TWO DIFFERENT ALTERNATIVES ARE PRESENTED AS ONE

3. THE CONCLUSIONS REACHED IN THE DRAFT REGARDING ENVIRONMENTAL IMPACTS EITHER LACK SUFFICIENT SCIENTIFIC BASIS OR ARE CONTRARY TO EXISTING SCIENTIFIC INFORMATION

3.1. The Scientific Research Program Does Not Support Deployment

3.1.1. Critical data gaps were not filled

3.1.1.1 The data gaps are critical

3.1.1.2. Prior illegal development of SURTASS LFA limited time available for research to fill data gaps

3.1.1.3. The Draft relies heavily on the most recent research

3.1.1.4. The research does not fill the gaps

3.2. The Draft Calculation of Risk is Inadequate

4. Miscellaneous Concerns

5. Conclusion

6. A Personal Note

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