"The Navy and the NMFS have changed the modelling they use to predict the effects of sonar on the behaviour of marine mammals," explains Steve Mashuda, an attorney with the San Diego office of conservation group Earthjustice. "For years they assumed the onset of temporary hearing loss occurred at 198 decibels [dB]. They've now lowered that to 178dB.
"So the amount and the extent of harm jumps dramatically." Mashuda says 31 million instances does not mean 31 million animals. Instead, it is likely the same animal will be impacted more than once.
This is bad news for whales and other marine mammals, which are heavily dependent on their hearing ability to survive. Permanent deafness would leave victims "essentially dead in the water," says Good Stefani.
Low-frequency noise from the Surveillance Towed Array Sensor System measures 230dB, louder than a fighter jet at take-off, and registers 140dB [which the NRDC says is "a hundred times more intense than the level known to alter the behaviour of large whales"] at 640km.
The NMFS estimates the take would include 60,000 instances of temporary hearing loss among grey whales off the California coast. "Yet there are less than 20,000 grey whales left," says Good Stefani. "So you're talking about temporary hearing loss to some whales several times a year or to every single grey whale left."
Naval exercises, involving US and Nato warships using active sonar, have "definitively caused or been associated with multiple stranding events of whales and other marine mammals around the world," dating to 1996, according to Earthjustice.
After 17 whales beached during a US Navy exercise off the Bahamas in 2000, marine autopsies found they had haemorrhaged in and around the ears. Sound conducting tissue was also damaged. The NMFS and Navy found the injuries were caused by "acoustic or impulse trauma, most likely" from MFA sonar.
Inevitably, the threat to whales is driven by US national security. Active sonar is used to hunt diesel-electric submarines, which can run very quietly and are favoured by many Asian nations [Indian ships using active sonar in the Andaman Sea may have killed 40 whales in January].
The NRDC and its allies would like the Navy to avoid sensitive habitats at specific times, use passive sonar to detect marine animals before exercises, and employ computer models to determine how salinity, ocean topography and temperature affect sonar impulses. Otherwise the Navy risked pushing whales and other endangered species towards extinction.