letter of request mmc

8/12/2019 Letter of Request MMC

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May 20, 2014

Dr. Rebecca Lent,Executive Director

The Marine Mammal Commission4340 East-West Highway, Suite 700Bethesda, Maryland 20814

Letter of Request:For the Protection and Conservation of the Okinawa Dugongi

Dear Dr. Lent,

We are writing with urgency to you and other members of the Marine MammalCommission (MMC) regarding the construction of a new US military base undertaken by

both the US Department of Defense and the Japanese government in the area of Henokoand Oura Bay in northern Okinawa Island, Japan. We are concerned that possibleimpacts of the construction and operation of the new base on the endangered Okinawadugong have not been examined thoroughly. Should construction be carried out, theOkinawa dugong would be gravely impacted, probably to the extent of extinction. Weurgently request that the MMC takes action in its capacity for the protection of theOkinawa dugong.

The fate of the Okinawa dugong is at a critical juncture. Despite continual opposition fromthe people of Okinawa, the U.S. and Japanese governments have been pushing their plan

forward to construct a military air base in the area of Henoko and Oura Bay. This is toreplace the U.S. Marine Corps Futenma Air Station in Ginowan City, Okinawa.

The area of Henoko and Oura Bay is considered as one of the most biodiversity rich areasin Okinawa and in Japan. It has been designated by the Okinawa Prefectural Governmentas an Assessment Rank I area, which requires strict protection and conservation of theenvironment.ii The area is also a critical habitat for the Okinawa dugong. Moreover, thearea of Henoko and Oura Bay is just 20 kilometers away from the northern part ofOkinawa Island (the Yanbaru area). The Japanese Ministry of the Environment, inDecember 2013, nominated the Yanbaru area as one of its candidate sites for theUNSECOs World Natural Heritage. iii These facts alone should have declared the

construction plan infeasible long ago.

In December 2012, the Okinawa Defense Bureau in its Final Environmental ImpactStatement (Final EIS) concluded that the base construction would have no impact on theenvironment, this includes the Okinawa dugong. In December 2013, Okinawa GovernorHirokazu Nakaima, under pressure from the Japanese government, accepted thatconclusion and gave permission to the Okinawa Defense Bureau to reclaim 160 hectares ofthe public water in that area. In March 2014, the Okinawa Defense Bureau began its


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bidding process for land reclamation including drilling survey work. It is reported, drillingsurveys could start as early as June 2014 and actual reclamation work could start in thefall of 2014.ivReclamation work will require twenty-one million cubic meters of soil androck to be poured into the waters of Henoko and Oura Bay (thats over 3 million 10-ton

truck loads of soil and rock) and 17 million cubic meters of it will be transported fromseveral different sites in mainland Japan.v

As members of environmental NGOs who have been closely following and opposing thebase construction plan, we are extremely concerned by the Okinawa Defense BureausEIA process and its no impact conclusion in the Final EIS. We argue that in the FinalEIS, the potential impacts of the construction and operation of the base on theenvironment are purposefully underestimated while the effects of proposed mitigationmeasures are overestimated. vi As indicated in the Appendix, we have found manyproblems with the Final EIS in regard to the Okinawa dugong. For example, the value ofthe area of Henoko and Oura Bay as habitat for the Okinawa dugongs is underestimated;

the mitigation measures proposed for conservation of dugongs are not consistent with thefindings of scientific studies; the lack of transparency is acute in terms of providing thenames of experts and releasing all the information obtained in and in relation to the EIA.In fact, some of these problems were pointed out in the Governors Statements submittedin February 2012 on the Okinawa Defense Bureaus Environment Impact Statement (EIS).This means that the Okinawa Defense Bureau were not able to present substantivesolutions for these problems in the Final EIA.

We are also concerned that the U.S. Department of Defense (DoD) has not provided itsown analysis of the impacts of the construction and operation of the base on the Okinawa

dugong as required under Section 402 of the National Historical Preservation Act (NHPA)according to the January 2008 ruling of the U.S. District Court for the District of NorthernCalifornia. Although this case has been held in abeyance by the Court for the uncertaintyof the base construction plan at the time of February 2012,vii we believe that the DoDshould follow the Courts order. We also believe that the DoD should not take any actionwhich constitutes the Undertaking of the base construction unless it has complied withthe NHPA 402. The undertaking of the planned base construction includes the DoDsissuing permits to the Japanese government to use the area of Camp Schwab to carry outconstruction work.

We also remain concerned that if the DoD relies heavily upon the Okinawa Defense

Bureaus Final EIS, its analysis of the impacts of the construction and operation of thebase on the Okinawa dugong would be problematic for the reasons stated above and in our

Appendix. We insist that the DoD should at least take into consideration critical views putforth by NGOs and the Governors Statements in using the Okinawa Defense BureausEIA in its analysis of the impacts.

With the urgency of this situation, particularly as construction is about to begin combinedwith our concerns on the Final EIS, we believe that in its capacity the MMC could take


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action for the protection and conservation of the Okinawa dugong. We welcome and areencouraged by the fact that the MMC has shown its concern for the issue of the baseconstruction since 2000. In particular we welcome and are encouraged by the MMCsstatement in its 2009 Annual Report to Congress:

If, after the review of the relocation plan, the proposal remainsunchanged, the Commission intends to review and comment on theDepartment of Defenses analysis of impacts on dugongs under theNational Historic Preservation Act when it becomes available. (The MMC2009 Annual Report to Congress pp. 36)

At this critical juncture we would like to make the following requests of the MMC.

First, we would like to request that the MMC thoroughly review and comment on theDoDs analysis of the impacts of the base construction on the dugong when such analysis

becomes available as indicated in the MMC 2009 Annual Report to Congress. We wouldalso like the MMC to take into consideration, when reviewing and commenting on theDoDs analysis, the information provided by the Japanese government, includingtranslations of EIA documents prepared for the DoD.

Second, we would like to request that the MMC issue a recommendation that the DoDshould not take any action constituting the Undertaking of the base construction,including issuing permits to the Japanese government to use the area of Camp Schwab forthe construction work before the MMC reviews and comments on the DoDs analysis.

We appreciate the time you took to read this letter of request. We intend to provide ourown analysis of the DoDs analysis of the possible impacts of the construction andoperation of the base on the Okinawa dugong when they become available. We await yourresponse. Should you need further information, we would readily provide it for you.

Sincerely yours,

Hideki Yoshikawa (Contact Person)

Citizens Network for Biodiversity in OkinawaSave the Dugong Campaign [email protected]


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The organizations listed below endorse this letter.

Association to Promote Ryukyu Islands as World Natural Heritage (Okinawa, Japan)Association to Protect Northernmost Dugong (Japan)

Citizens Network for Biodiversity in Okinawa (Okinawa, Japan)Dugong Network Okinawa (Okinawa, Japan)Dugong no Sato (Okinawa, JapanHeri kichi iranai jyukkuno kai (No Heliport Base Association of 10 Districts North ofFutamai) (Okinawa, Japan)Okinawa Citizens Network for PeaceOkinawa Environmental Network (Okinawa, Japan)Okinawa Reef Check and Research Group (Okinawa, Japan)Save the Dugong Campaign Center (Japan)Save the Dugong Foundation (Okinawa, Japan)The Conference Opposing Heliport Construction (Okinawa, Japan)

The Nature Conservation Society of Japan (Japan)

i The term The Okinawa dugong does not imply that there is a sub-spices of the Dugongspecific to Okinawa. The term is used as a matter of convenience and it denotes dugongsliving around the waters of Okinawa.ii The coastal area of Henoko and Oura Bay is designated as Assessment Rank I in theOkinawa Prefectural Governments Guidelines on the Conservation of the NaturalEnvironment.Assessment Rank I is the highest ranking designation for coastal areas

and strict protection and conservation of the natural environment is required for thedesignated areas.iii See the Japanese Ministry of the Environments press release (in Japanese) on thelisting of Amami and Ryukyu (Okinawa) islands on its Tentative List for UNESCO WorldNatural Heritage available at http://www.env.go.jp/press/press.php?serial=16268.See also the article Okinawa Island in the IUCN CEM EcosystemNews available athttp://iucn.org/about/union/commissions/cem/cem_resources/ecosystem_news_4_2013/.iv See the Ryukyu Shimpo article (in Japanese) on the Okinawa Defense Bureaus plan toconduct drilling surveys available athttp://ryukyushimpo.jp/news/storyid-225173-storytopic-3.htmlv The Documents regarding the sites and the amount of soil and rock collected for land

reclamation in the Okinawa Defense Bureaus Revised Application for Land Reclamationfor the Futenma Replacement Facilities Construction Project(in Japanese) (May 31,2013).vi See the comments (in Japanese) by the Nature Conservation Society-Japan available athttp://www.nacsj.or.jp/katsudo/henoko/2013/02/post-59.htmlSee also the comments (in Japanese) by the Citizens Network for Biodiversity in Okinawaavailable at http://okinawabd.ti-da.net/e4399901.htmlvii Center for Biological Diversity, et al., Plaintiff(s), vs. Leon Panetta, Secretary of


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Defense, et el., Defendant(s). Case3:03-cv-04350-MHP Document147.