ENVIRONMENTAL ASSESSMENT for the Japan-Guam-Australia (JGA) South Telecommunications Cable Landing within the Marianas Trench Marine National Monument

Prepared for:

United States Department of the Interior U.S. Fish and Wildlife Service

and

RTI Solutions Inc. 268 Bush Street #77 San Francisco, CA 94104

Prepared by:

Duenas, Camacho & Associates, Inc. 238 E. Marine Corps Drive Suite 201 Diamond Plaza Hagatna, Guam 96910

August 2019

JGA South Cable Landing in the MTMNM EA Cover Sheet

Environmental Assessment for the Japan-Guam-Australia South (JGA South) Telecommunications Cable Landing within the Marianas Trench Marine National Monument

Responsible Agency: U.S. Department of the Interior, U.S. Fish and Wildlife Service

Point of Contact: Ms. Danielle Zarlengo, USFWS

Summary: RTI Solutions, Inc. (RTI) is proposing to land a portion of the Japan-Guam- Australia South (JGA South) telecommunications cable within the Marianas Trench Marine National Monument (MTMNM). This Environmental Assessment (EA), in accordance with the National Environmental Policy Act (NEPA), examines the potential impacts of the No Action Alternative, and Proposed Action Alternative, including the preferred alternative.

Under the No Action Alternative, RTI would not land the cable through the MTMNM, and the cable would be routed several hundred miles around the MTMNM. The No Action Alternative would impact the economic feasibility of the project by increasing the total linear distance of cable needed.

The Proposed Action Alternative would land the cable through the MTMNM, which is a marine national monument managed under the U.S. Fish and Wildlife Service Refuge System. The JGA South cable is needed to provide connectivity between Guam and Australia within the greater Japan-Guam-Australia network. The JGA cable system will further enhance and contribute to the much-needed expansion of communications networks from Japan and Australia, to Asia and the United States, thereby improving network redundancy, ensuring highly reliable communications, and expanding onward connectivity options in Guam. This alternative would not result in significant impacts to environmental resources, and was determined to be the preferred alternative, since it meets the purpose and need of the project.

JGA-South Cable Landing in MTMNM EA Table of Contents

TABLE OF CONTENTS

PAGE LIST OF APPENDICES ...... iv LIST OF TABLES ...... v ACRONYMS AND ABBREVIATIONS ...... vi 1 PURPOSE OF AND NEED FOR PROPOSED ACTION ...... 1-1 1.1 Summary of Proposed Action ...... 1-2 1.2 Purpose of and Need for Action ...... 1-2 2 ALTERNATIVES INCLUDING THE PROPOSED ACTION ...... 2-1 2.1 No Action Alternative ...... 2-1 2.2 Cable Route Determination ...... 2-1 2.3 Alternatives Considered and Rejected ...... 2-4 2.3.1 JGA South CRE Alternative ...... 2-4 2.3.2 Dr. Fryer Alternative ...... 2-4 2.4 Proposed Action Alternative ...... 2-5 2.5 Environmental Effects of the Proposed Action and No Action Alternatives ...... 2-7 3 AFFECTED ENVIRONMENT ...... 3-1 3.1 Hydrology ...... 3-1 3.2 Geology and Topography ...... 3-2 3.3 Biological Resources ...... 3-2 3.3.1 Marine Flora ...... 3-2 3.3.2 Fauna ...... 3-3 3.3.3 Threatened and Endangered Species, and Critical Habitat ...... 3-5 3.3.4 Essential Fish Habitat ...... 3-9 3.4 Cultural Resources ...... 3-12 3.5 Public Health and Safety ...... 3-12 3.6 Land and Water Use ...... 3-13 3.7 Noise ...... 3-13 3.8 Air Quality ...... 3-13 3.9 Aesthetics ...... 3-14 3.10 Socioeconomic Characteristics ...... 3-14 4 ENVIRONMENTAL CONSEQUENCES ...... 4-1 4.1 Hydrology ...... 4-1 4.2 Geology and Topography ...... 4-1 4.3 Biological Resources ...... 4-1 4.4 Threatened and Endangered Species ...... 4-3 4.5 Cultural Resources ...... 4-4 4.6 Hazardous Materials ...... 4-4 4.7 Unexploded Ordnance ...... 4-5 4.8 Military Training ...... 4-5 4.9 Land and Water Use ...... 4-5 4.10 Noise ...... 4-6 4.11 Air Quality ...... 4-6 4.12 Aesthetics ...... 4-6 4.13 Socioeconomic Characteristics ...... 4-6 4.14 Cumulative Effects ...... 4-7

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JGA-South Cable Landing in MTMNM EA Table of Contents

TABLE OF CONTENTS

PAGE 4.15 Relationship Between Short-Term Use of the Environment and Maintenance and Enhancement of Long-Term Productivity ...... 4-9 4.16 Probable Irretrievable and Irreversible Commitments of Resources ...... 4-9 4.17 Environmental Compliance ...... 4-9 4.17.1 National Environmental Policy Act (NEPA) of 1969 ...... 4-9 4.17.2 Presidential Proclamation 8335 ...... 4-9 4.17.3 Military Coordination ...... 4-9 4.17.4 Federal Water Pollution Control Act (Clean Water Act), 33 U.S.C. 1251 ...... 4-10 4.17.5 Coastal Zone Management Act (CZMA) ...... 4-10 4.17.6 Magnuson-Stevens Fisheries Conservation & Management Act ...... 4-10 4.17.7 Marine Mammal Protection Act ...... 4-11 4.17.8 National Historic Preservation Act (NHPA) ...... 4-11 4.17.9 Clean Air Act (CAA), 42 U.S.C. 7401 et seq...... 4-11 4.17.10 Endangered Species Act of 1973 (ESA), 16 U.S.C 1531 et seq...... 4-12 4.17.11 Migratory Bird Treaty Act, 16 U.S.C. 703 and Executive Order 13186, Responsibilities of Federal Agencies to Migratory Bird Treaty Act ...... 4-12 4.17.12 Executive Order 13112, Invasive Species ...... 4-13 4.17.13 Executive Order 12898, Environmental Justice in Minority Populations and Low Income Populations ...... 4-13 4.17.14 Executive Order 13045, Protection of Children from Environmental Health Risks and Safety Risks ...... 4-13 4.17.15 Executive Order 11988, Floodplain Management ...... 4-14 4.17.16 Executive Order 11990, Protection of Wetlands ...... 4-14 4.17.17 Executive Order 13089, Protection of Coral Reefs ...... 4-14 4.17.18 Executive Order 13101, Greening the Government Through Waste Prevention, Recycling, and Federal Acquisition ...... 4-15 4.17.19 Executive Order 13123, Greening the Government Through Efficient Energy Management ...... 4-15 4.17.20 Executive Order 13148, Greening the Government Through Leadership in Environmental Management ...... 4-15 4.18 Separate But Related Compliance Actions ...... 4-16 4.18.1 United States Army Corps of Engineers ...... 4-16 4.18.2 National Marine Fisheries Service ...... 4-16 4.18.3 Guam Department of Agriculture, Division of Aquatic and Wildlife Resources ...... 4-16 4.18.4 Guam Environmental Protection Agency ...... 4-16 4.18.5 Guam Coastal Management Program ...... 4-17 5 REFERENCES ...... 5-1 6 PREPARERS ...... 6-1

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JGA-South Cable Landing in MTMNM EA Table of Contents

LIST OF APPENDICES

APPENDIX A. Project Figures Figure 1. JGA South Cable Route Figure 2. Site Location Map for the Marianas Trench Marine National Monument Units and the JGA South Cable Figure 3a. Okeanos Expedition 1605 Legs 1 and 3 Dive Sites Figure 3b. Detail View of Okeanos Expedition 1605 Legs 1 and 3 Dives 1, 2, 4, 5 and 7 Figure 4. Site Location Map and Approximate Locations of Existing Cables Figure 5. Bathymetric Survey Data from the 2018 Survey – Contours Figure 6. Bathymetric Survey Data from the 2018 Survey – Backscatter Figure 7. Individual Sightings of the Marine Mammals and Reptiles within the Marianas Trench Marine National Monument

APPENDIX B. Compatibility Determination

APPENDIX C. JGA South Submarine Fiber-Optic Cable System Cable Routing Mariana Trench (ASN 2019)

APPENDIX D. Summary of EFH and HACP Designations

APPENDIX E. Photograph Photo 1. Typical Cable Repeater

APPENDIX F. Responses to Comments

LIST OF TABLES

PAGE Table 2-1. Summary of Cable Dimensions within the MTMNM ...... 2-6 Table 2-2. Summary of Environmental Effects of the Proposed Action and No Action Alternatives ...... 2-8 Table 3-1. List of Cetaceans that May Occur Within the Project Area ...... 3-4 Table 3-2. Threatened and Endangered Species in the Mariana Islands Region ...... 3-5 Table 4-1. Submarine Communication Cables within the MTMNM ...... 4-7

JGA-South Cable Landing in MTMNM EA Table of Contents

ACRONYMS AND ABBREVIATIONS

BMP Best Management Practice CEQ Council on Environmental Quality CFR Code of Federal Regulations CNMI Commonwealth of the Northern Mariana Islands CRE Cable Route Estimate CRS Cable Route Study DC direct current DCA Duenas, Camacho & Associates, Inc. DOI Department of Interior EA Environmental Assessment EEZ Exclusive Economic Zone EFH Essential Fish Habitat EIS Environmental Impact Statement EO Executive Order FONSI Finding of No Significant Impact ft feet FUD formerly used defense site GIS Geographic Information System ICPC International Cable Protection Committee in inch JGA South Japan-Guam-Australia South km kilometer LW Lightweight Cable Type LWP Lightweight Protected Cable Type m meter mi mile MUS Management Unit Species MTMNM Marianas Trench Marine National Monument NEPA National Environmental Policy Act NHPA National Historic Preservation Act NM nautical mile NOAA National Oceanic and Atmospheric Administration NSCPO U.S. Naval Seafloor Cable Protection Office Pac-SLOPES Standard Local Operating Procedures for Endangered Species in the central and western Pacific region PFE power feed equipment sq. ft square feet sq. m square meter SHPO State Historic Preservation Office Tbps terabits per second USACE United States Army Corps of Engineers USFWS United States Fish and Wildlife Service UXO unexploded ordnance WD water depth

JGA South Cable Landing in MTMNM EA Chapter 1

1 PURPOSE OF AND NEED FOR PROPOSED ACTION

This Environmental Assessment (EA) was prepared in compliance with National Environmental Policy Act (NEPA), as implemented by Council of Environmental Quality (CEQ) regulations as provided by Code of Federal Regulations (CFR) title 40, Parts 1500 to 1508 (40 CFR 1500, et seq.). This EA analyzes the potential impacts of the Proposed Action and Alternatives, and it is intended to provide sufficient evidence and analysis for determining whether to prepare an environmental impact statement or a Finding of No Significant Impact (FONSI).

This EA will address impacts associated with the proposed action on only the submerged lands within the “Trench Unit” of the Marianas Trench Marine National Monument (MTMNM). As defined in Presidential Proclamation 8335 – Establishment of the Marianas Trench Marine National Monument, the Trench Unit includes only the submerged lands as delineated by its boundaries within the United States of America Exclusive Economic Zone (EEZ). No waters are included in the Trench Unit (NOAA 2012).

The Marianas Trench Marine National Monument (MTMNM) was established by Presidential Proclamation 8335 issued on January 6, 2009, and consists of three units: (1) the Islands Unit, (2) the Volcanic Unit, and (3) the Trench Unit (Appendix A, Figure 2). The telecommunications cable is proposed to cross the Trench Unit which is managed as a component of the National Wildlife Refuge System and includes only subsurface lands, not the overlying waters.

Pursuant to the Proclamation, the Secretaries of the Interior and Commerce “shall not allow or permit any appropriation, injury, destruction or removal of any feature of this monument except as provided for by this proclamation or as otherwise provided by law.” The Proclamation also requires the Secretaries to provide: “monitoring and enforcement necessary to ensure that scientific exploration and research, tourism, and recreational and commercial activities do not degrade the monument‟s coral reef ecosystem or related marine resources or species or diminish the monument‟s natural character”.

The freedom to lay undersea cables has long been recognized as a lawful use of the sea. The United States recognizes this right under the Convention on the High Seas (1958), Article 2: the Convention on the Continental Shelf (1958), Article 4; and the United Nations Convention on the Law of the Sea (UNCLOS) which provides that within the Exclusive Economic Zone (EEZ) (200 nautical miles (NM)), all states enjoy the “freedoms referred to in Article 87 of navigation and overflight and of the laying of submarine cables and pipelines.” (Article 58).

Thus, in order for the Secretaries to meet their resource protection obligations under the Proclamation and the National Wildlife Refuge System Administration Act, and for the U.S. to uphold its marine conservation obligations under international conventions, the Service is evaluating this telecommunications cable application in consultation with NOAA and the Department of Defense and if appropriate, the Service will issue a Compatibility Determination and Right-of-Way Permit (Appendix B).

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JGA South Cable Landing in MTMNM EA Chapter 1

1.1 Summary of Proposed Action RTI Solutions, Inc. (RTI) is seeking a Right-of-Way Permit from the United States Department of the Interior (DOI), U.S. Fish and Wildlife Service (USFWS) to land a portion of the Japan- Guam-Australia South (JGA South) telecommunications cable within the Marianas Trench Marine National Monument (MTMNM). RTI is preparing an EA under NEPA for this proposed action through its consultant, Duenas, Camacho & Associates, Inc. (DCA).

The proposed action would land a length of approximately 83.5 miles (mi) (134.3 kilometers (km)) of submarine cable within the southern sector of the MTMNM Trench Unit, located to the south of the U.S. Territory of Guam. The proposed JGA South cable would provide telecommunications interconnectivity between Guam and Australia, and is an integral part of the larger Japan-Guam-Australia cable system.

1.2 Purpose of and Need for Action The purpose of this EA is to evaluate whether the issuance of a Right-of-Way Permit to allow the installation of a new fiber-optic submarine cable in the MTMNM is in compliance with applicable laws and regulations with respect to potential impacts on the natural and human environment. The action is needed in order for the proposed cable to efficiently link Guam with Australia and to provide improved interconnectivity within the western Pacific region.

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JGA South Cable Landing in MTMNM EA Chapter 2

2 ALTERNATIVES INCLUDING THE PROPOSED ACTION

This EA document covers the proposed action to issue a Right-of-Way Permit to allow installation of a fiber-optic communications submarine cable within a portion of the MTMNM Trench Unit. Under NEPA, an analysis of the potential effects of the Proposed Action, including a No Action Alternative, is required. This EA evaluates the No Action and the Proposed Action Alternatives.

2.1 No Action Alternative Under the No Action Alternative, a Right-of-Way Permit would not be issued and RTI would not land the JGA South cable through the MTMNM. In the absence of a Permit, longer, less feasible route alternatives would need to be considered. The JGA South cable route would need to be re- designed and re-routed several hundred miles around the MTMNM, which would impact the economic feasibility of the project by increasing the total linear distance of submarine cable. If such a route could not be identified, the cable would not be installed, and improved communications interconnectivity in this region of the western Pacific would not be realized.

2.2 Cable Route Determination The process of defining the JGN South cable route involved three distinct phases, as described in the Alcatel Submarine Networks (ASN) cable routing report (Appendix C). The bid phase produced an initial Cable Route Estimate (CRE) route, which is the base route that serves as a starting point to connect two destinations (Australia and Guam). This desktop CRE route is primarily used for early cost estimates during the bidding process; therefore, it does not include critical data usually obtained after the contract is awarded, and the route is anticipated to be further developed and changed as information is made available (e.g., research and results from the cable route study).

In the second phase, a Cable Route Study (CRS) was commissioned from ASN to define a route for survey. The CRS phase worked off the CRE route and considered all available information that have the potential to affect the cable during installation and operation, including the end points to be connected, seabed characteristics, risks of cable damage, water depths, and the routes and characteristics of cables already in place (ICPC 2015a and 2015b). During the CRS, the alignment was changed where necessary to avoid off-shore hazards and third-party cables and assets. Upon completion of the CRS, the CRS route was surveyed to acquire bathymetry data along a corridor, with the CRS route serving as the centerline.

During the final phase of the process, the CRS route was refined and a post-survey route (PSR) was developed based on actual survey data, which was used to select the most practical route within the survey corridor. Repeaters were added in accordance with system design, and positioned to avoid conflict with existing cables. The PSR forms the basis of the Proposed Action Alternative.

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JGA South Cable Landing in MTMNM EA Chapter 2

Recommendations published by the International Cable Protection Committee (ICPC) are considered and followed to the maximum extent practicable during this process to ensure minimal confliction with existing cables (e.g., minimum cable separation distances, minimum repeater separation distances, and appropriate crossing angles), known biological resources, and geologic, commercial, or oceanographic features and activities that have the potential to adversely affect the cable.

CRS considerations, as outlined by the ICPC‟s Recommendation No. 9, Issue: 5 (ICPC 2015a), generally include but are not limited to: 1. Geology a. The tectonic setting b. Seafloor morphology and lithology, c. Volcanic activity, including sub-sea volcanoes and hydrothermal venting, with location and dates of eruption d. Seismicity (including locations, dates and magnitude of earthquakes), e. Tsunamis f. Surface faulting, g. Turbidity currents, h. Sediment transport, i. Sand waves, j. Beach and near shore seabed stability k. Offshore geology and burial assessment l. Other geohazards, not covered in above sections. 2. Climatology a. Seasonal variations in climate and weather on a regional basis for the area adjacent to and along the proposed cable route. b. Examination of the major climatological controls, such as monsoons, convergence zones and the like, temperatures, rainfall, winds and the seasonality and frequency of gales, storms, hurricanes and the like c. Proximity to flood prone areas. 3. Oceanography a. Typical sea states experienced in the region of interest b. Surface, midwater and bottom currents including tidal streams and currents (in order to determine the optimum direction of installation) c. Bottom water temperatures d. Wind and wave data (including wave height and dominant wind directions) e. Other environmental anomalies that may affect survey and installation (e.g., sea fog and sea ice if applicable) f. Tidal levels and variations at the landings and at pertinent areas along the planned route g. Local and seasonal variations should be investigated for the above parameters 4. Commercial Operations, Hazards and Restricted Areas a. Shipping i. Shipping patterns ii. Designated shipping channels iii. Anchorages

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JGA South Cable Landing in MTMNM EA Chapter 2

iv. Informal anchoring practices v. Cable protection zones and other no-anchoring areas b. Restricted areas (full-time or part-time) such as; i. Mined areas, ii. Military exercise areas, iii. Dumping grounds (chemical/industrial wastes, explosives, radioactive materials) either in use, abandoned or planned, iv. Culturally significant sites v. Tourist attractions. c. Commercial and research activities such as; i. Artisanal and commercial fishing activities (current and future), including information on fish aggregation devices, ii. Offshore petroleum leases (current and future) that may require the construction of in-field or platform to shore transmission pipelines or umbilicals, iii. Offshore renewable energy installations (current and future) iv. Pipelines (current and future), v. Other submarine cables (out-of-service and in-service, both current and planned in the vicinity of the proposed route) and their fault history, with tabulated information on the crossed systems name, cable type, position, water depth and angle at the crossing point and, where possible, distance to the crossed systems underwater plant, (i.e. Repeaters and equalisers), vi. Plans to remove existing out-of-service submarine cables, vii. Oceanographic and weather buoys, viii. Dredging activities, ix. Submarine resource development (including deep sea mining) and offshore renewable energy developments, x. Coastal construction projects such as new port facilities, outfalls and intake structures d. Other obstructions such as shipwrecks, artificial reefs etc, e. Known security threats and piracy, or political groups that may pose security risks (including „non friendly‟ countries or unstable governments). 5. Biological Factors a. Marine Protected Areas (MPAs) or similar marine conservation zones for example coral reefs (including cold water corals), marine sanctuaries and national parks b. flora and fauna (particularly endangered and protected species) located at the proposed landings c. seabed communities including shellfish, crustaceans and coral d. fish and crustacean spawning grounds and nursery areas e. local and migratory bird populations f. marine mammals

Where in-service cables lay parallel to each other, the ICPC recommends a minimum cable distance between them of three times the water depth (3 × WD) where possible (ICPC, 2015b).

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JGA South Cable Landing in MTMNM EA Chapter 2

Cable separation can be decreased to 2 × WD on one side of the cable if a separation of 3 × WD remains on the opposite side.

Whenever feasible, the routes of new cables should be selected so as to avoid crossings of other cables, in particular existing in-service cables. When crossings are unavoidable, the ICPC recommends that they shall be made as near to a right angle (90 degrees) as possible. If a 90- degree angle is not technically feasible, then angles down to 45 degrees may be considered depending on the particular circumstances (ICPC, 2015b).

2.3 Alternatives Considered and Rejected

2.3.1 JGA South CRE Alternative As depicted in Figure 3 of Appendix A, the JGA South CRE route passes near the HANTRU-1 cable, and crosses the PPC-1 cable. This route was studied and determined to be unsuitable due to inadequate separation distances from the existing cables and insufficient cable-crossing angles (ASN 2019). The CRE route was developed into the CRS route, which was used as the basis for the marine geophysical survey. The CRS route was adjusted in order to be deconflicted with existing cables and comply with ICPC recommendations wherever possible, while still avoiding wherever possible any seabed features (ASN 2019). The CRS route was refined and developed into the PSR, which is the Proposed Action Alternative cable route.

2.3.2 Dr. Fryer Alternative An alternative cable route was proposed by Patricia Fryer, Ph.D., Hawai'i Institute of Geophysics & Planetology, University of Hawai'i (Appendix A, Figure 3). The route considered certain features, including an area of unusually high metabolic activity in the sediment that was discovered through a core sample collected in 2016 by Dr. Jeff Drazen approximately five miles west of the JGA South route (see Figure 3). A high volume of nutrients moves from north to south in the Mariana backarc region at the west side of Guam, where the microbial rates have been measured to be very high. According to Dr. Fryer, the subsurface biome here is extremely active and has the highest consumption of oxygen measured anywhere in the world. Dr. Fryer noted that the currents in the backarc region are very strong and move nutrients and materials through to the first possible exit route located east of the Santa Rosa Bank, which is a highly valued area for research and learning about plate tectonics, the development of hydrothermal vents, mud volcanoes, and species development and survival through chemosynthesis. According to Dr. Fryer, there is a very large caldera in the vicinity of the cable route, and a submarine volcano fired-off near the cable route in 2002. Dr. Fryer was concerned that further investigation of this area could be precluded by scientists using remotely operated vehicles (ROVs), since ROVs are generally not permitted to operate near known sea floor cables.

In order to provide more separation from a potentially unique area of the MTMNM, Dr. Fryer proposed a route that was slightly east of the Proposed Action Alternative, and closer to the desktop CRE route generated by ASN (ASN 2019). The alternative proposed by Dr. Fryer was evaluated, but was determined to be unsuitable for similar reasons as the CRE route. Therefore, this alternative route was not considered for further analysis in this EA.

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JGA South Cable Landing in MTMNM EA Chapter 2

The concerns raised by Dr. Fryer with respect to the Proposed Action Alternative were evaluated. Operation of ROVs would be allowed in proximity of the cable in accordance with the conditions of the right-of-way agreement for the Proposed Action Alternative. The information on strong currents was also reviewed and it was determined this would not be a concern since the cable would be adequately protected from abrasion, and would be laid parallel to and not against the currents, making it less likely to shift its position. The 2002 eruption of a subsea volcano in the vicinity was not considered a significant risk factor for the cable. The location of this feature is not available; however, there are no volcanoes present within the CRS route survey corridor in the MTMNM, which is approximately 4 miles (7 km) wide on either side of the cable centerline.

2.4 Proposed Action Alternative Under the Proposed Action Alternative, a Right-of-Way Permit would be issued by USFWS to RTI Solutions to allow the landing of the JGA South fiber-optic communications submarine cable through a portion of the MTMNM (Appendix A, Figures 1 and 2). As it is laid flush on the seafloor by a cable-laying ship, the cable would cross over the Mariana Trench and through the MTMNM for a total linear distance of approximately 83.5 miles (134 km). The proposed cable route is the shortest feasible cable route across the MTMNM. This alternative was determined to be the preferred alternative, since it meets the purpose and need of the project.

Subsea Fiber-Optic Cable. The cable will comprise two types of armored cable within the MTMNM: Lightweight Protected (LWP) and Lightweight (LW) cable types. The LWP cable type is 2.4 centimeters (cm) in diameter (0.94 inch (in)), while the LW cable type is 1.7 cm in diameter (0.67 in). The LWP cable type is needed to ensure the cable is sufficiently protected in the deeper portions of the Mariana Trench from stressors such as abrasion. Water depths along the proposed cable route within the MTMNM range from approximately 5,600 to 10,000 m, spanning the abyssal (4,000 to 6,000 m) and hadal (6,000 to 11,000 m) zones, based on a non- intrusive bathymetric survey in 2018 (EGS Survey Group, 2018). The total cable footprint within the MTMNM is approximately 0.7 acres (30,768.53 square feet (sq. ft)), with a total linear distance of 83.48 mi (72.54 NM) or 134.34 km). A summary of cable dimensions within the MTMNM is presented in Table 2-1.

Cable Repeaters. Light pulses can be transmitted only approximately 37 to 50 miles (60 to 80 kilometers) along the cable before they need to be regenerated. This regeneration would be done by regenerator equipment, known as repeaters, attached to the cable at the appropriate intervals. The proposed repeaters are typically 18 inches (45.7 cm) in diameter and 72 inches (6 ft. or 1.8 m) in length (Appendix E, Photo 1) with an approximate maximum footprint of 36 sq. ft. (3.34 sq. m.). Two (2) such repeaters will be needed in the MTMNM. They will be arranged so that they can be placed at the shallowest depth possible (i.e., neither will be placed near the bottom of the trench) (Appendix A, Figures 3 and 4).

The repeaters would operate from 48 volts of direct current (DC) electricity. The marine cable would contain a copper conductor to transmit the DC electrical power to the repeaters. The DC power system for the repeaters would be housed at the power feed equipment (PFE) facility and contain protective equipment that can detect either a sharp decrease or sharp increase in electrical

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JGA South Cable Landing in MTMNM EA Chapter 2 current flow. Upon detection of abnormal current flow, the DC power system would be shut down. The DC generates a magnetic field on the order of 5 milligauss at a distance of 3.28 feet (1 meter) from the cable. The field diminishes with distance from the cable (such that at 33 feet [10 meters] it would be approximately 0.5 milligauss).

Table 2-1. Summary of Cable Dimensions within the MTMNM Cable Type m km ft mi NM Cable LWP 82,101.12 82.10 269,360.61 51.02 44.33 Length LW 52,239.15 52.24 171,388.29 32.46 28.21 Total 134,340.27 134.34 440,748.90 83.48 72.54

Cable Type mm cm m in ft Cable LWP 24.00 2.40 0.024 0.94 0.079 Width LW 17.00 1.70 0.017 0.67 0.056

Cable Type sq. m sq. km sq. ft sq. mi acre Cable LWP 1,970.43 0.00197 21,209.48 0.00076 0.48690 Area LW 888.07 0.00089 9,559.05 0.00034 0.21945 Total 2,858.49 0.00286 30,768.53 0.00110 0.70635

Cable Installation. The fiber-optic cable would be laid directly on the seabed. The cable laying ship can proceed at approximately 3.7 kilometers per hour (2 knots). Slack would be continuously applied at various rates throughout the installation to allow the cable to conform to the contour of the seabed as much as feasible.

The Proposed Action Alternative would implement BMPs and follow the Standard Local Operating Procedures for Endangered Species in the central and western Pacific region (Pac- SLOPES), which are conditions of the JGA South Cable Department of the Army Permit. While no biological monitors are proposed to be onboard the cable ship, since it will not make port weekly, the cable ship operators will be briefed on the potential presence of marine mammals and sea turtles by qualified biologists. The training will occur either in port on Guam, or by video communication if the cable ship will not come into port on Guam. The awareness training would include descriptions of any marine mammal or sea turtle species that have the potential to occur in areas where the cable ship will be operating, and suggested procedures if they are observed within the vicinity of the vessel.

Cable Operations and Maintenance. There is no routine monitoring or maintenance associated with the submerged segments of the cable within the MTMNM. However, it is possible that emergency repair activities could occur if there is a cable fault. The typical triggers for emergency repair are such things as ship anchors being dragged across the cable route during active anchoring, fishing gear entanglement during active fishing (neither of which would be a concern in the MTMNM due to the great depths), and equipment failure.

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JGA South Cable Landing in MTMNM EA Chapter 2

ROV Operation. The right-of-way agreement will include conditions governing the ability to continue to conduct scientific research using ROVs in proximity to the cable. Emergency Repair. If the cable needs to be repaired in the MTMNM, it would need to be recovered to the cable ship for repair. Because of the depth of the cable, the operation would take place in several steps. First a flatfish grapnel fitted with a cutting blade would be pulled until it snags and cuts the cable. Then a Gifford grapnel would be used to retrieve one end of the cable to the cable ship. After the cable is recovered, the end would be prepared and the fibers tested using a conventional optical time-domain reflectometer (OTDR). After conducting the necessary tests onboard the cable ship, this end of the cable would be sealed and buoyed off for easy recovery later.

Next, the other cable end would be recovered and similarly tested to locate the fault more precisely. The cable ship would retrieve this end of cable until the fault is aboard. After the fault site (either a cable or repeater section) is removed from the system, the repaired cable would be joined to the fault-free cable end and paid out as the vessel returns to the buoyed end. When the buoy is recovered aboard the ship, the two cable ends would be joined. After final testing, the cable would then be paid out through the stern of the ship to settle on the ocean floor.

Retirement, Abandonment, or Removal of the Cable Systems. The project would have a life of approximately 25 years. After the cable is decommissioned, it is typically abandoned in place.

Landing Schedule. This single submarine fiber-optic cable would be installed in the third quarter of 2019 and will connect Guam and Australia as part of the larger Japan-Guam-Australia cable system. The JGA South cable will provide approximately 36 terabits per second (Tbps) of data capacity (approximately 4,500 gigabytes per second) and will further enhance and contribute to the much-needed expansion of communications networks from Japan and Australia, to Asia and the United States, thereby improving network redundancy, ensuring highly reliable communications, and expanding onward connectivity options in Guam.

2.5 Environmental Effects of the Proposed Action and No Action Alternatives A summary of the environmental effects of the No Action and Proposed Action Alternatives is presented in Table 2-2.

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JGA South Cable Landing in MTMNM EA Chapter 2

Table 2-2. Summary of Environmental Effects of the Proposed Action and No Action Alternatives

Resource Proposed Action Alternative No Action Alternative

No significant impact. The cable size and footprint is small and thus, will not have any significant effect on hydrology. The cable would be a light-weight protected (LWP) type in much of the 1 Hydrology No impact. MTMNM, and would be resistant to abrasion from strong currents. The cable would be laid parallel to, not against, the currents to minimize the potential for it to shift its position. No significant impact. The cable will be laid directly on the seabed. No cable burial is proposed. No volcanoes or Geology and hydrothermal vents were discovered within the approximately 8- 2 No impact. Topography mile (14 km) wide survey corridor centered on the cable. The ROW agreement would will include conditions governing the ability to conduct research in proximity to the cable. No significant impact. The cable will be laid directly on the seabed and has the potential to impact any sessile or slow-moving mobile organisms in its path. Deep sea coral and sponge 3 Biological Resources No impact. communities have been documented within the MTMNM; the closest mapped community is approximately 36.5 miles (58.7 km) southwest of the cable; therefore, it would be avoided by the cable. No significant impact. No critical habitat has been designated within the vicinity of the cable route. ESA-listed marine species (e.g., whales and sea turtles) have been documented within the Threatened and vicinity of the cable route. Cable ship movement is very slow (less 4 No impact. Endangered Species than 6 knots), minimizing the likelihood of vessel strikes. RTI will comply with Pac-SLOPES conditions as part of Department of the Army permit requirements, and the cable ship operator will be trained in protocols for avoidance of these species.

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Resource Proposed Action Alternative No Action Alternative

No impact. No known cultural resources are within the vicinity of 5 Cultural Resources No impact. the cable route. No impact. The cable is benign and not a source of hazardous 6 Hazardous Materials materials. The cable ship would have proper spill response No impact. materials and follow protocols for fuel spills or leaks. Unexploded Ordnance No impact. The cable ship would not involve the use of UXOs. 7 The cable would not be buried but laid directly on the seafloor, No impact. (UXO) although UXOs are not known to exist in the project area. No impact. Advance notice would be issued prior to military 8 Military Training training activities within the MIRC warning areas that are in No impact. proximity to the cable route. No impact. Existing regulated land uses in the MTMNM would continue following the laying of the cable. The ROW agreement 9 Land Use No impact. would will include conditions governing the ability to conduct research in proximity to the cable. No significant impact. The low speed of the cable ship during cable-installation would produce low noise levels in comparison to 10 Noise similar vessels, such as freight ships, that navigate through the No impact. MTMNM. No noise would be generated by the cable during normal operation. No significant impact. The cable ship would be an insignificant 11 Air Quality mobile source of emissions. No emissions would be generated by No impact. the cable after installation. No significant impact. The cable size and footprint is small (1.7 12 Aesthetics to 2.4 cm diameter) and likely to be naturally buried in sediments No impact. over time; thus, it will not have any significant effect on aesthetics. Socioeconomic No adverse impact. The JGA South cable will increase internet 13 No impact. Characteristics bandwidth and connectivity for the region.

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3 AFFECTED ENVIRONMENT

This chapter describes the affected environment of the proposed action within the Trench Unit of the MTMNM, which is located in the abyssal (4,000 to 6,000 m) and hadal zones (6,000 to 11,000 m) of the western Pacific Ocean. The hadal zone comprises the deepest areas of the world's oceans, and hadal trenches in this zone are one of the least understood habitats on Earth (Jamieson et al., 2009).

The MTNMN was established by a Presidential Proclamation of George W. Bush on January 6, 2009 under the authority of the Antiquities Act of 1906. According to Presidential Proclamation 8335, the MTMNM includes the waters and submerged lands of the three northernmost Mariana Islands (i.e., Farallon de Pajaros (Uracas), Maug, and Asuncion) (collectively, the „„Islands Unit‟‟) and only the submerged lands of designated volcanic sites (the „„Volcanic Unit‟‟) and the Mariana Trench (the „„Trench Unit‟‟). The boundary of the Trench Unit extends from the northern limit of the U.S. EEZ in the Commonwealth of the Northern Mariana Islands (CNMI) to the southern limit of the U.S. EEZ in Guam (Appendix A, Figure 1).

The Mariana Trench is a crescent-shaped hadal trench that averages 2,550 km in length and 69 km in width. In the portion within the U.S. EEZ, the Mariana Trench is approximately 940 NM (1,740 km) long and 38 NM (70 km) wide. The deepest known point on the Earth's seafloor, Challenger Deep, is located at the southern extent of the Mariana Trench and lies beyond the western boundary of the MTMNM. While the depth has been estimated at approximately 10,984 ± 25 m based on multi-beam echosounder mapping (Gardner et al. 2014), the deepest depth reached by a manned submersible is 10,928 m (Five Deeps 2019). Sirena Deep (estimated at 10,732 m) (Fryer et al. 2003) is located within the MTMNM approximately 145 km south of Guam. The proposed cable route is located to the east of these deepest known points.

USFWS was delegated to manage the MTMNM through the DOI Secretary‟s Order No. 3284, which directed that the Volcanic Unit and the Trench Unit be managed as part of the National Wildlife Refuge System. The Secretary of the Department of Commerce (DOC), through the National Oceanic and Atmospheric Administration (NOAA), has primary management responsibility for fishery related activities in the waters of the MTMNM.

3.1 Hydrology The cable route lies in a fault-controlled valley east of Santa Rosa Bank; the valley is an outlet for a major southerly current that moves material from the Mariana Trough (west of the islands) southward toward the trench. These currents sweeping south from the Mariana Trough towards the Mariana Trench have been observed to be in the range of 1 to 1.5 knots at a depth of 1,600 m (Personal communication, Patricia Fryer, Ph.D.). The bottom currents in the Mariana Trench near the Challenger Deep, at depths between 6,000 and 10,890 m, are less than 1.5 cm per second (0.029 knots) for 22.9–63.8% of the time (Taira 2004). The typical bottom currents along the proposed JGA South cable landing corridor are anticipated to be similar.

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3.2 Geology and Topography The underlying geology along the proposed cable route has not been extensively surveyed or studied. A bathymetric survey was conducted for RTI in August 2018 in order to determine and study topological features, substrate hardness, and slope (Appendix A, Figures 4 and 5); however, no intrusive activities, such as sediment sampling, were conducted. The proposed cable route would cross over the Mariana Trench and through the MTMNM for a total linear distance of approximately 83.5 miles. Along the proposed cable route, slopes range from 6º to 24º (10.5% to 44.5%), and water depths range from 5,600 to 10,030 m (Appendix A, Figure 4).

A north-south fault, the East Santa Rosa Banks Fault, runs between the escarpment immediately west of Guam and the Mariana Trench (Reagan et al. 2000). The cable lies close to the fault along its approach to the MTMNM, then diverges as it enters the MTMNM. The route lies in a region of high metabolism within the sediment column, possibly as a consequence of nutrients swept down the fault-controlled submarine valley east of Santa Rosa Bank.

The area east of the fault (known as the southeast Mariana fore arc) is considered stable, while the region on the west side of the fault is dominated by back-arc basin extension, active magmatism, and rapid deformation (Reagan et al. 2000). There is significant seismicity in the southern Mariana forearc region.

Hadal zone researchers Alan Jamieson and Heather Stewart studied areas in close proximity to the proposed cable route, with four survey points within 2 to 5 km of the proposed JGA South cable alignment, both in the hadal and adjacent abyssal slope zones of the MTMNM (Stewart and Jamieson 2018). They classified the basic geologic structure by depth zones. Their study involved taking images of the seafloor using two free-fall lander vehicles: the Hadal-lander and the Abyssal-lander. Substrate types were categorized through the analysis of photographic data since the landers were not capable of returning physical samples. Within the water depth range of 4,506 m to 5,641 m, the dominant seabed sediment observed comprised muddy gravel, with one observation each of bedrock, bedrock and fine-grained sediment, and gravelly fine-grained sediment across all fifteen sampling stations (Stewart and Jamieson 2018). Within the water depth range of 6,008 to 7,941 m, gravelly fine-grained sediment was the dominating sediment type; fine-grained sediment, bedrock, slightly gravelly fine-grained sediment, and muddy gravel were also observed within this depth range (Stewart and Jamieson 2018). Within the final and deepest water depth range of 8,000 and 10,890 m, the researchers observed fine-grained sediment, slightly gravelly fine-grained sediment, gravelly fine-grained sediment, bedrock, and bedrock with gravelly mud (Stewart and Jamieson 2018).

3.3 Biological Resources Since project-specific biological surveys were not performed in the MTMNM portion of the proposed cable corridor, this EA draws from past surveys, in addition to other available desktop resources, such as peer-reviewed scientific journal articles and publications.

3.3.1 Marine Flora Photosynthetic marine plants are not expected to occur along the proposed cable route due to the complete absence of light in the abyssal and hadal zone depths of the MTMNM.

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3.3.2 Fauna

3.3.2.1 Invertebrate Macrofauna Hadal communities are generally dominated by actinians (sea anemones), polychaetes (bristle worms), isopods, amphipods, echiurids (spoon worms), and holothurians (sea cucumbers) (Wolff 1970), with the deepest epibenthic community comprising holuthurians, amphipods, and xenophyophores in the Challenger Deep (Gallo et al. 2015). These organisms would be expected in the MTMNM portion of the proposed cable corridor, although their densities are unknown.

3.3.2.2 Fish Elongate, scavenging fish are more common in the abyssal plain, though members of these families are able to extend their range into the abyssal-hadal transition zone of the Mariana Trench between 4,506 to 6,198 m (Lindley et al. 2017). These include Macrouridae (Coryphaenoides yaquinae), Ophidiidae (Barathrites iris, Bassozetus spp. and Bassozetus cf. compressus), and Zoarcidae (Lindley et al. 2017). Zoarcids, also known as eelpouts, are eels in the order of Perciformes (Nelson 1994). An undescribed species of eelpout (Zoarcidae) was observed at a depth of 6,142 m within the Mariana Trench, the maximum observed depth for these fish (Linley et al. 2017). Macrourids, also known as grenadier, are dominant scavengers within abyssal plains (Jamieson 2012). Their deepest observed depth (7,012 m) is in the Mariana Trench (Linley et al. 2017). Ophidiids (cusk-eels) are a group of bony fishes in the order Ophidiiformes (Nelson 1994). They have been observed between 4,506 m and 6,198 m in the Mariana Trench (Linley et al. 2016).

The hadal zones of the trench (6,000 m to 8,200 m deep) are dominated by the predatory hadal snailfish (Liparidae), possibly because of adaptations allowing them to exploit the abundant amphipods at these depths (Jamieson 2011; Gerringer et al. 2019). Snailfish occupy the widest range of depths of any fish family, from intertidal to hadal waters (Gerringer et al. 2017). Hadal snailfish are small (less than 30 cm in length) and are found in greater densities and at deeper depths than other hadal fishes (Linley et al. 2017). Among these is the ethereal snailfish, an undescribed species which has only been observed in the Mariana Trench (8,007 m to 8,143 m depths) (Linley et al. 2017). The deepest snailfish is the Mariana snailfish (Pseudoliparis swirei), described from 37 individuals collected from 6,898 m to 7,966 m in the Mariana Trench, where it is likely endemic (Gerringer et al. 2017). It has been observed in the trench at a depth of 8,178 m (Oguri and Noguchi 2017). Physiological evidence suggests that bony fish cannot survive at depths greater than approximately 8,200 m because of an inability to regulate osmotic pressure beyond this depth (Yancey et al. 2014; Linley et al. 2016).

3.3.2.3 Reptiles The endangered leatherback sea turtle (Dermochelys coriacea) was observed diving to depths of 1,280 m in the North Atlantic, and is recognized as the deepest diving sea turtle and reptile (Byrne 2007; Fossette 2010). Ocean Biogeographic Information System (OBIS) data compiled from surveys and incidental sightings indicates that sea turtles have been documented within the vicinity of the project location (Appendix A, Figure 6). These observations include leatherback sea turtles in 2006 and unspecified sea turtles in 2007.

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3.3.2.4 Mammals All marine mammals are protected under the Marine Mammal Protection Act (MMPA). According to the International Union for the Conservation of Nature (IUCN) Red List GIS data on marine mammal distribution, compiled data, and 2007 surveys of the Mariana Archipelago, 30 cetaceans have the potential to occur within the marine waters of the project area (Table 3-1).

Table 3-1. List of Cetaceans that May Occur Within the Project Area Common Name Scientific Name Common Name Scientific Name Balaenoptera Hubb‟s beaked Mesoplodon Minke whale* acutorostrata whale*** carlhubbsi Blainville‟s beaked Mesoplodon Sei whale***† Balaenoptera borealis whale* densirostris Ginkgo-toothed beaked Mesoplodon Bryde‟s whale*† Balaenoptera edeni whale** ginkgodens Deraniyagala‟s beaked Blue whale** Balaenoptera musculus Mesoplodon hotaula whale** Fin whale** Baleanoptera physalus Killer whale* Orcinus orca Short-beaked common Delphinus delphinus Melon-headed whale*† Peponocephala electra dolphin** North Pacific right Physeter Euhalaena japonica Sperm whale*† whale** macrocephalus Pygmy killer whale*† Feresa attenuata False killer whale*† Pseudorca crassidens Short-finned pilot Globicephala Pantropical spotted Stenella attenuata whale*† macrorhynchus dolphin*† Longman‟s beaked Indopacetus pacificus Striped dolphin*† Stenella coeruleoalba whale* Risso‟s dolphin* Grampus griseus Spinner dolphin*† Stenella longirostris Rough-toothed Pygmy sperm whale* Kogia breviceps Steno bredanensis dolphin*† Indo-Pacific bottlenose Dwarf sperm whale* Kogia sima Tursiops aduncus dolphin*** Common bottlenose Fraser‟s dolphin* Lagenodelphis hosei Tursiops truncatus dolphin*† Cuvier‟s beaked Humpback whale*† Megaptera novaeangliae Ziphius cavirostris whale* Sources: IUCN Red List, 2019; Fulling et al. 2011. Key: * = Regular (occurs as usual part of fauna of the area, regardless of its abundance); ** = Rare (occurs only sporadically); *** = Extralimital (occurs outside of its usual range); † = observed in Mariana Archipelago during 2007 surveys.

Surveys in 2007 detected 13 species in the Marianas (Table 3-1) (Fulling et al. 2011). OBIS data compiled over the years from surveys and incidental sightings, including the 2007 surveys, indicates that five cetacean species have been documented within the vicinity of the project location in the MTMNM (Figure 7). These include a sperm whale in 1913, and a Cuvier's beaked whale, a pygmy killer whale, a sei whale, and a rough-toothed dolphin in 2007. Cuvier‟s beaked whale (Ziphius cavirostris) is currently recognized to be the deepest diving mammal, with a record depth of 2,992 m (Schorr,‟ 2014). These toothed whales are widely distributed, although little information exists on their ecology, behavior, and population structure (Santos,‟ 2001).

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3.3.3 Threatened and Endangered Species, and Critical Habitat NOAA Fisheries or National Marine Fisheries Service (NMFS) lists 17 marine species in the Mariana Islands region as protected under the U.S. Endangered Species Act (Table 3-2).

Table 3-2. Threatened and Endangered Species in the Mariana Islands Region Common Name Scientific Name ESA Listing Marine Mammals Blue Whale Balaenoptera musculus Endangered Fin Whale Balaenoptera physalus Endangered Humpback Whale Megaptera novaeangliae Endangered Sei Whale Balaenoptera borealis Endangered Sperm Whale Physeter macrocephalus Endangered Dugong Dugong dugon Endangered Sea Turtles Green Turtle Chelonia mydas Endangered Hawksbill Turtle Eretmochelys imbricata Endangered Leatherback Turtle Dermochelys coriacea Endangered Loggerhead Turtle Caretta caretta Endangered Olive Ridley Turtle Lepidochelys olivacea Threatened Fish Scalloped Hammerhead Shark Sphyrna lewini Threatened Giant Manta Ray Manta birostris Threatened Oceanic Whitetip Shark Carcharhinus longimanus Threatened Corals None Seriatopora aculeata Threatened None Acropora globiceps Threatened None Acropora retusa Threatened Source: NOAA Marine Protected Species of the Mariana Islands, January 2018.

According to NMFS, there is no critical habitat designated in the Mariana Islands. The only designated critical habitat for ESA-listed species in the Pacific Islands region is for the Hawaiian monk seal (Neomonachus schauinslandi) in the Northwestern Hawaiian Islands and the main Hawaiian Islands insular false killer whale (Pseudorca crassidens).

3.3.3.1 Corals In 2014, NMFS listed three coral species in the Mariana Archipelago as threatened under the ESA: Seriatopora aculeata, Acropora globiceps, and Acropora retusa. These reef-building corals occur at a maximum depth of less than 30 m; therefore, they would not be present within the hadal and abyssal zones of the MTMNM.

3.3.3.2 Fish NMFS lists three fish species in the Mariana Archipelago as threatened: scalloped hammerhead shark, giant manta ray, and oceanic whitetip shark (Table 3-2).

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Scalloped hammerhead shark. The Indo-West Pacific distinct population segment (DPS) of the scalloped hammerhead shark (Sphyrna lewini) was listed as threatened in 2014. The biology, habitat, and conservation status of this species is described in a species status review by Miller et al. (2014). Scalloped hammerheads feed opportunistically on a varied diet of teleosts, cephalopods, crustaceans and rays (Miller et al. 2014). The main threats to the Indo-West Pacific DPS are overutilization by industrial/commercial and artisanal fisheries, as well as illegal, unregulated and unreported (IUU) fishing and high at-vessel mortality; habitat degradation, inadequacy of current regulatory mechanisms, and schooling behavior were considered moderate risks (Miller et al. 2014). The scalloped hammerhead shark was known to visit depths up to 450 m (Klimley 1993); however, data from a tagged female in the tropical eastern Pacific indicates activity ranged from the surface to a depth of 980 m in the mesopelagic zone (200 to 1,000 m) (Jorgensen et al. 2009).

Giant manta ray. The giant manta ray (Manta birostris) was listed as threatened in 2018. The biology, habitat, and conservation status of this species is described in a species status review by Miller and Klimovich (2016). The giant manta ray is a pelagic, migratory and solitary species that commonly occurs on offshore reefs, sea mounts, pinnacles and oceanic islands, and locations in close proximity to deep water, such as outer atoll edges near drop-offs (Kashiwagi et al. 2011). Data from the tropical eastern Pacific indicate that giant manta ray activity gradually shifts from surface waters to 100 m to 150 m during the year, as it targets surface zooplankton, then shifts to vertical migrators (Steward et al. 2016).

Oceanic whitetip shark. The oceanic whitetip shark (Carcharhinus longimanus) was listed as threatened in 2018. The biology, habitat, and conservation status of this species is described in a species status review by Young et al. (2016). The oceanic whitetip shark is a pelagic species, generally remaining offshore in the open ocean, or around oceanic islands in water depths greater than 600 ft (183 m) (NOAA 2018b). The oceanic whitetip shark will make short dives to the mesopelagic and bathypelagic zones (maximum observed depth 1,082 m); however, over 99% of the time is spent shallower than 200 m (Howey-Jordan et al., 2013).

Since the maximum depths for these fish species are around 1,000 m or shallower, they may be present in the water column, but are not likely to be present within the abyssal and hadal zones of the MTMNM.

3.3.3.3 Reptiles Five turtle species listed as occurring in the Marianas are protected under the ESA: green sea turtle, hawksbill turtle, leatherback turtle, loggerhead turtle, and olive ridley turtle (Table 3-2).

Green sea turtle. In 1978, breeding colony populations of the green sea turtle in Florida and on the Pacific coast of Mexico were listed as endangered, while remaining populations were listed as threatened. NMFS and USFWS issued a final rule in 2016 that listed three DPSs of green sea turtle as endangered and eight DPSs as threatened species. The Central West Pacific DPS of turtles (including Guam) are endangered. The biology, habitat, and conservation status of the green sea turtle is described in status reviews (NMFS-USFWS 2007a, Seminoff et al. 2015). The threats to green sea turtles include coastal development, beachfront lighting, and erosion

3-6 JGA South Cable Landing in MTMNM EA Chapter 3 resulting from sand mining; illegal take of turtles and eggs; nest and hatchling non-human predation; and fishing practices, marine pollution, and climate change (Seminoff et al. 2015). Occasional vessel strikes have been documented on Guam, although this threat to green sea turtles is not known to be of great consequence for the Central West Pacific DPS (Seminoff et al. 2015).

Hawksbill sea turtle. The hawksbill sea turtle was listed as endangered in 1973. The biology, habitat, and conservation status of this species is described in status reviews (NMFS-USFWS 2007b, NMFS-USFWS 2013). Hawksbill turtles are considered specialist sponge carnivores, although neonates are thought to be pelagic herbivores before transitioning to a benthic sponge diet as they mature (NMFS-USFWS 1998b). Guam supports a small foraging population of hawksbill sea turtles; nesting activities, although apparently rare, have also been reported, with the first one documented in 1991 (NMFS-USFWS 1998b). On Guam, the primary hawksbill sea turtle threats are directed take and coastal construction (NMFS-USFWS 1998b).

Leatherback sea turtle. The leatherback sea turtle was listed as endangered in 1973 throughout its range. The biology, habitat, and conservation status of this species is described in status reviews (NMFS-USFWS 2007c, NMFS-USFWS 2013). This species is uncommon in the insular Pacific, and nesting is not known in Guam or the CNMI, but individuals are sometimes encountered in deep water near prominent archipelagoes (NMFS and USFWS 1998c). Adults are highly migratory and forage widely in the pelagic marine habitat, with documented movement over 10,000 km in a single year (WPRFMC 2009b). To a large extent, the oceanic distribution of leatherbacks may reflect the distribution and abundance of macroplanktonic prey (NMFS- USFWS 1998c). In the western Pacific, turtles nesting in Indonesia were found to migrate to several areas, including eastern Indonesia, the central North Pacific, South China Sea, southeastern Australia, and the west coast of the U.S. (Bailey et al. 2012). Hatchlings are thought to become entrained by oceanic currents into the North Pacific, South Pacific or Indian Oceans, and drift passively for one to two years into temperate regions, then as juveniles, swim actively toward warmer latitudes before winter, and higher latitudes during spring (NMFS-UFWS 2013). The threats to leatherback sea turtles include natural and anthropogenic impacts to their foraging habitats, by-catch in fisheries, boat strikes, ingestion of marine debris, and exposure to heavy metals and other contaminants (NMFS-USFWS 2013).

Loggerhead sea turtle. The loggerhead sea turtle was listed as threatened in 1978 throughout its worldwide range. In 2011, the USFWS and NMFS determined that the loggerhead sea turtle is composed of nine DPS, and listed four DPSs as threatened and five DPSs as endangered under the ESA. The biology, habitat, and conservation status of this species is described in status reviews (NMFS-USFWS 2007d). For the endangered North Pacific DPS (including Guam), loggerheads are present throughout tropical to temperate waters; however, nesting occurs only in Japan, and possibly in areas surrounding the South China Sea (USFWS-NMFS 2011). Sightings of loggerheads have not been reported in Guam or the CNMI (NMFS-USFWS 1998d); therefore, this species is unlikely to occur within the vicinity of the Proposed Action Alternative.

Olive ridley sea turtle. The olive ridley sea turtle was listed in 1978 as endangered for breeding colony populations along the Mexican coast, and listed as threatened elsewhere. The biology, habitat, and conservation status of this species is described in status reviews (NMFS-USFWS

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2007e). Nesting is not known to occur in Guam or the CNMI. The olive ridley is rare in the central Pacific, both at sea and around islands; the only at sea occurrences in waters under U.S. jurisdiction are limited to Hawaii and the west coast of the continental U.S. (NMFS-USFWS 2007e). Therefore, this species is unlikely to occur within the vicinity of the Proposed Action Alternative.

All of these listed turtles occupy shallow depths above the abyssal and hadal zones, with the deepest recorded dive among these species made by the leatherback turtle to 1,280 m in the North Atlantic (Byrne 2007; Fossette 2010). Leatherback sea turtles have been observed in the vicinity of the project area in 2006, based on OBIS data compiled from surveys and incidental sightings (Appendix A, Figure 6).

3.3.3.4 Mammals Six mammals listed as occurring within the Mariana Archipelago are protected under the ESA: blue whale, fin (or finback) whale, humpback whale, sei whale, sperm whale, and dugong. All five whales have been classified as endangered under the ESA since the Act was passed in 1973.

Dugong. The dugong is listed as endangered under the jurisdiction of the USFWS. This shallow- water species is extralimital in Guam, with only anecdotal sightings at Cocos Island in 1975 and 1985 (Eldredge 2003); therefore, this species is not expected to occur in the MTMNM.

Blue whale. In the North Pacific, the blue whale (Balaenoptera musculus) ranges from Kamchatka to southern Japan in the west, and from the Gulf of Alaska and California to at least Costa Rica in the east; whales have been sporadically reported within several hundred km of the Hawaiian Islands (NMFS 1998a). The blue whale is considered rare in the waters of Guam and the CNMI; no whales were observed during extensive surveys in these waters in 2007 (Fulling et al. 2011). Seasonal migrations governed by food requirements lead to movement of whales toward the polar waters in the spring, and movement toward the subtropics in the fall (NMFS 1998a). There are three subspecies of blue whale, including B. m. brevicauda, or pygmy blue whale, which had a maximum confirmed dive depth of 506 m near Australia, the deepest record for the blue whale (Owen et al. 2016). The potential threats to the blue whale include collisions with vessels, entanglement in fishing gear, reduced zooplankton production from habitat degradation, and disturbance from low-frequency noise (NMFS 1998a). The risk of ship strike is greatest for blue whale calves or feeding animals that are thought to spend the greatest amount of time at the surface (Owen et al. 2016).

Fin whale. The fin whale is a cosmopolitan species that has a generally anti-tropical distribution centered in the temperate zones (NMFS 2010a). This species is considered rare in the Mariana Archipelago; no fin whales were observed during extensive surveys in these waters in 2007 (Fulling et al. 2011).

Sei whale. The sei whale is a highly mobile and cosmopolitan species, but tends to avoid polar and tropical waters, preferring temperate and subtropical zones (NMFS 2011). A total of 16 sei whale sightings were documented during extensive surveys between 10o-18o N around the Mariana Islands in 2007 (Fulling et al. 2011). The sei whale is considered extralimital and unique in the waters around Guam and the CNMI because the species was not previously

3-8 JGA South Cable Landing in MTMNM EA Chapter 3 confirmed to occur south of 20oN. Winter distribution of sei whales in the North Pacific is not well understood, and no breeding or calving grounds have been found, although the 2007 Marianas survey reported several cow-calf sightings of this species (Fulling et al. 2011). It is unclear if the 2007 sightings were an unusual occurrence, or whether the sei whale is indeed a regular component of the cetacean community in the Marianas region (Fulling et al. 2011).

Humpback whale. Humpback whales are found in temperate and tropical waters (10o-23o latitude) of both hemispheres during the winter months, when mate and calve, although reproductive events may also occur during migration (NMFS 1998a). In the North Pacific, three distinct wintering grounds are identified: 1) the coastal and insular waters along Baja California; 2) main islands of Hawaii; and 3) the islands south of Japan, including the Ryuku, Bonin, and Northern Mariana Islands (NMFS 1998a). Humpbacks were acoustically and visually detected during extensive surveys between 10o-18o N around the Mariana Islands in January-April 2007, although no cow-calf pairs were observed (Fulling et al. 2011). Surveys around Saipan and Tinian in February-March 2015 yielded 12 whales, including four cow-calf pairs, with multiple sightings of two of the pairs, suggesting that the waters off western Saipan and adjacent areas may be a breeding ground for humpback whales (Hill et al. 2015). This was confirmed by similar cow-calf sightings and observations of competitive groups (a common breeding behavior) in February-March 2016, February 2017, and February 2018 (NOAA 2018a).

Humpbacks migrate long distances to high latitude (35o-65o latitude) summering areas in waters over continental shelves, where they feed intensively; shorter, within-season migration occurs through a portion of the summer range to locate or follow prey concentrations (NMFS 1998a). These summering grounds are 1) the coast of Central California; 2) Southeastern Alaska; and 3) Southcentral Alaska (NMFS 1998a). Humpbacks have been observed to dive as deep as 240 m (Hamilton et al. 1997). The most frequently identified source of human-caused injury or mortality to humpbacks is from entrapment and entanglement in active fishing gear, particularly around northeastern continental shelf waters during summer months (NMFS 1998a).

Sperm whale. The sperm whale is a cosmopolitan species found in all oceans. With a total of 23 sperm whale sightings, this was the most frequently sighted species during extensive surveys between 10o-18o N around the Mariana Islands in January-April 2007 (Fulling et al. 2011). The observations ranged from individuals, to a mixed sighting of 25 sperm whales (including calves) logging on the surface near the Challenger Deep and bottlenose dolphins (Fulling et al. 2011). Sperm whales are the second deepest diving mammal at 2,250 m (7,382 ft), after Cuvier‟s beaked whale (Ponganis 2011). The current potential threats to this species are vessel strikes, entanglement in fishing gear, reduced prey due to overfishing, habitat degradation, disturbance from anthropogenic noise, and possible illegal whaling (NMFS 2010b).

3.3.4 Essential Fish Habitat

3.3.4.1 EFH and HAPC Designations Essential Fish Habitat (EFH) are those waters and substrates necessary for a fish species‟ full life cycle, including aquatic areas and their associated physical, chemical, and biological properties. On Guam, EFH is defined as the marine water column from the surface to the 1,000 m depth, from the shoreline to the outer boundary of the EEZ (5,150 km/200 nm/230 miles), and the seafloor from the shoreline out to a depth of 700 m around the island. This EFH designation

3-9 JGA South Cable Landing in MTMNM EA Chapter 3 includes the water column and seafloor where the cable project is proposed within the MTMNM, and its surrounding waters and submerged lands that support various life stages for the Management Unit Species (MUS) identified under the Western Pacific Regional Fishery Management Council's (WPRFMC) Pelagic and Mariana Archipelago Fishery Ecosystem Plans (FEP) (2009a, 2009b). In addition to EFH, the WPRFMC identified Habitat Areas of Particular Concern (HAPC) within EFH for all Fishery Management Plans (2009a, 2009b). HAPCs are specific areas within EFH that are essential to the life cycle of important coral reef species. A summary of EFH and HACP designations is presented in Appendix D.

Bottomfish MUS. The bottomfish fishery in Guam is distinguished by species and depth, and comprises a shallow-water fishery from 0-100 m, and a deep-water fishery from 100-400 m. The water column extending from the shoreline to the outer boundary of the EEZ to a depth of 400 m is EFH for bottomfish eggs and larvae. EFH for adult and juvenile bottomfish is designated as the water column and all bottom habitat extending from the shoreline to a depth of 400 m, encompassing the steep drop-offs and high-relief habitats that are important for bottomfish. All escarpments/slopes between 40-280 m depths are designated as HAPC for adult bottomfish. These limits extend into the MTMNM; however, they do not encompass any of the submerged lands within the vicinity of the Proposed Action Alternative.

Crustaceans MUS. Rather than use individual species and life stages, the WPRFMC designated EFH for crustacean species assemblages of spiny and slipper lobsters, and Kona crab. EFH is designated as the water column from the shoreline to the outer limit of the EEZ down to a depth of 150 m for eggs and larvae, and all of the bottom habitat from the shoreline to a depth of 100 m for juvenile/adult life stages. EFH for deepwater shrimp (Heterocarpus spp.) is the water column and associated outer reef slopes between 550-700 m for eggs and larvae, and the outer reef slopes at depth between 300-700 m for juvenile/adult life stages. HAPC for the spiny and slipper lobster complex is designated as all banks with summits less than or equal to 30 m (15 fm) from the surface. These limits extend into the MTMNM, however, they do not encompass any of the submerged lands within the vicinity of the Proposed Action Alternative. No HAPC is designated for deepwater shrimp.

Precious Coral MUS. Precious coral MUS may be divided into deep- and shallow-water species. Deep-water precious corals are generally found between 350 and 1,500 meters and include pink coral (Corallium secundum), gold coral (Gerardia sp. and Parazoanthus sp.), and bamboo coral (Lepidistis olapa) (WPRMFC 2009b). Shallow-water species occur between 30 and 100 meters and consist primarily of three species of black coral: Antipathes dichotoma, Antipathes grandis, and Antipathes ulex (WPRMFC 2009b). Until the Okeanos Explorer expedition in 2016, no precious coral beds had been identified in the Marianas (Glickson et al. 2017). Previous surveys in the CNMI in the 1970s for pink and red corals (Corallium sp.) and black coral (Antipathes spp.) yielded very few results, and there have been no reports of precious coral harvests around Guam (WPFMC 2009b).

EFH for precious coral was based on assemblages to reduce the complexity and the number of EFH identifications required for individual species and life stages. The species complex designations are based on the ecological relationships among the individual species and their preferred habitat. The WPRFMC considered using the known depth range of individual precious

3 -10 JGA South Cable Landing in MTMNM EA Chapter 3 coral MUS to designate EFH, but rejected this alternative because of the rarity of the occurrence of suitable habitat conditions. Instead, the WPRFMC designated the six known beds of precious corals as EFH, which are all found in the Hawaiian Islands. There are no EFH or HAPC designated for precious corals in the Mariana Archipelago.

Coral Reef Ecosystems MUS. The WPRFMC designated EFH Coral Reef Ecosystem MUS (CRE-MUS) by linking MUS to specific habitat “composites” (e.g., sand, live coral, seagrass beds, mangrove and open ocean) for each life history stage, consistent with the depth of the ecosystem to 50 fathoms (fm) (152 m) and to the limit of the EEZ. These limits extend into the MTMNM, however, they do not encompass any of the submerged lands within the vicinity of the Proposed Action Alternative. CRE-MUS HAPC are designated at five coastal locations for Guam: Cocos Lagoon, Orote Point Ecological Reserve Area, Haputo Point Ecological Reserve Area, Ritidian Point, and Jade Shoals. These HAPCs are all located outside the MTMNM.

Pelagic MUS. Pelagic MUS (PMUS) include temperate and tropical species complexes, sharks and squids (Appendix D). The water column down to a depth of 1,000 m from the shoreline to the outer limit of the EEZ is EFH for juvenile and adult life stages of PMUS. The eggs and larvae of all teleost PMUS are pelagic. They are slightly buoyant when first spawned, are spread throughout the mixed layer and are subject to advection by the prevailing ocean currents. Because the eggs and larvae of the PMUS are found distributed throughout the tropical (and in summer, subtropical) epipelagic zone, EFH for these life stages has been designated as the epipelagic zone (0-200 m depth) from the shoreline to the outer limit of the EEZ. The water column down to 1,000 m that lie above all seamounts and banks within the EEZ shallower than 2,000 m (1,000 fm) is designated as HAPC for PMUS.

3.3.4.2 Description of Habitats in Action Area

The following habitat is available in the JGA South project area to provide EFH for MUS in the Mariana Archipelago, as summarized in Appendix D. The project area does not encompass any designated seafloor EFH for MUS, nor is located within any designated HAPC for MUS.

Water Column: bottomfish eggs and larvae; adult/juvenile bottomfish; spiny and slipper lobster complex and Kona crab complex eggs and larvae; CRE-MUS complexes; temperate and tropical species complex PMUS eggs and larvae and juveniles/adults; shark eggs and larvae and juveniles/adults; and squid eggs and larvae and juveniles/adults.

3.3.4.3 Corals The NOAA 2016 Okeanos Explorer Expedition Leg 1 (EX 1605L1) conducted seven ROV dives (Dives 1 through 7) south of Guam (Appendix A, Figure 3). The expedition documented six high-density coral communities and two medium-density coral communities, as well as several sponge communities. Among the corals found on these dives were primnoids, isidids, chrysogorgiids, paragorgiids, stylasterids, desmophyllids, plexaurids (Glickson et al. 2017). The corals and sponges provided habitat and shelter for many other animals. The nearest coral and sponge community was found at Dive 3, located outside the MTMNM approximately 10.4 km from the Proposed Action Alternative. Within the MTMNM, coral and sponge communities were

3 -11 JGA South Cable Landing in MTMNM EA Chapter 3 found during Dive 4, approximately 58.7 km to the southwest of the proposed JGA South cable route (Appendix A, Figure 4).

The ROV surveys also confirmed the presence of precious corals – documenting pink, gold, black and bamboo corals – however, fewer were documented than expected (Glickson et al. 2017). Gold, bamboo, and black corals were documented in five of the ROV dives south of Guam (Appendix A, Figures 3 and 7). Of these five dives, only Dive 4 was conducted in the MTMNM. The most common precious corals were bamboo corals, which were observed on Dives 1, 2, 5 and 7. Gold corals were observed on Dives 1, 2, and 4, while black coral was rare and only seen at one location on Dive 2. The corals were found within depths of approximately 468 m to 3,714 m. The deepest of these were the gold corals observed on Dive 4, which were all found at over 3,000 m depths.

Precious corals are non–reef-building species that inhabit the dark depths below the euphotic zone (WPRFMC 2009b). Pink, bamboo, and gold corals all have planktonic larval stages and sessile adult stages; their larvae settle on solid substrate where they form colonial branching colonies. Little is known about the larval stage of black corals (Wagner et al. 2012). Precious corals are found in areas with moderate-to-strong (>25 cm/sec or 0.49 knots) bottom currents, which help prevent the accumulation of sediments that would smother young coral colonies and interfere with the settlement of new larvae (WPRFMC 2009b).

3.3.4.4 Fish Six EX 1605L1 expedition ROV dives (Dives 1, 2, 12, 17, 18 and 19) focused on collecting data on deep-water bottom fishery habitats where species of deep-water snapper, grouper, roughy, tuna, pomfret, and jack were documented. The ROV observations revealed that while there was little overlap observed between bottomfish and precious coral habitats, there was overlap between bottomfish and non-precious coral habitat (Glickson et al. 2017). These dive locations are not within the MTMNM (Appendix A, Figure 3).

3.4 Cultural Resources No known cultural resources have been documented along the proposed cable route. The 2018 bathymetric survey of the proposed cable corridor did not indicate the presence of any potential cultural resources, such as shipwrecks (EGS Survey Group 2018).

3.5 Public Health and Safety

3.5.1.1 Hazardous Waste The proposed action and alternative sites are not located over any existing documented U.S. military formerly used defense (FUD) site (U.S. Army Corps of Engineers 2008).

3.5.1.2 Unexploded Ordnance The proposed cable route does not contain any areas of known unexploded ordnance (UXO). The potential for UXOs is considered low.

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3.5.1.3 Military Training The U.S. military has established a Mariana Islands Range Complex (MIRC) in the Mariana Archipelago that includes land training areas, ocean surface and subsurface areas, and special use airspace (Department of the Navy (DON) 2019). The MIRC encompasses the sea and undersea space from the ocean surface to the ocean floor, and includes designated sea and undersea space training areas, such as designated drop zones, underwater demolition, and floating mine exclusion zones. Portions of the MTMNM lie within the MIRC and under all MIRC warning areas; the prohibitions required by the Presidential Proclamation establishing the MTMNM do not apply to exercises and activities of the Armed Forces (DON 2019). Two warning areas located south of Guam are in the vicinity of the Proposed Action Alternative. W-517 encompasses 14,000 sq. NM, and W-11 (A/B) occupies approximately 10,500 sq. NM (DON 2019) (Appendix A, Figure 4). These warning areas are designated as special use airspace where the sea space underneath may be restricted from public access during hazardous training events. Scheduled training and testing activities are published in Notices to Mariners issued by the U.S. Coast Guard (DON 2019).

3.6 Land and Water Use Vessels, such as fishing or commercial freight, navigating through the waters of the MTMNM are the only regular human use in this area. Waters depths along the proposed cable route range from 5,527 to 10,060 m, therefore, anchoring would not be feasible. The Mariana Trench is not considered a tourist attraction, but it continues to be an area of great scientific interest to international researchers. Exploration and research, such as the 2016 Okeanos Explorer expedition (Glickson et al. 2017), is conducted infrequently in the Trench Unit with the oversight and permits from the USFWS.

3.7 Noise There are no permanent noise generators in the vicinity of the project site. Temporary sources of noise comprise mobile sources, such as fishing boats or commercial freight ships that may pass through the area. The project area is within the range of sensitive noise receptors such as marine mammals.

3.8 Air Quality The National Ambient Air Quality Standards (NAAQS) are pollutant concentration limits established by U.S. Environmental Protection Agency (USEPA) under the Clean Air Act (CAA) to protect human health and welfare, including sensitive populations, such as children and the elderly. The NAAQS encompass the following criteria air pollutants: carbon monoxide (CO), nitrogen dioxide (NO2), sulfur dioxide (SO2), particulate matter less than 10 and 2.5 microns (PM10, PM2.5), lead (Pb) and ozone (O3). Since the cable would be laid in the open ocean, there are no permanent stationary emission sources of air pollutants in the project area. Temporary emission sources of air pollutants comprise mobile sources, such as fishing boats or commercial freight ships that may pass through the area.

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3.9 Aesthetics The benthic environment of the MTMNM may be considered a scenic area to some people, although it is not easily accessible. The majority of the public experiences the MTMNM benthic environment indirectly via images and videos captured by researchers.

3.10 Socioeconomic Characteristics The MTMNM Trench Unit comprises only the submerged lands extending from the northern limit of the EEZ of the United States in the CNMI to the southern limit of the EEZ in the U.S. territory of Guam (USFWS 2017). No households or permanent populations exist in the Trench Unit of the MTMNM, or within the vicinity of the project location, which is approximately 57.5 miles south of Guam, the nearest inhabited island.

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4 ENVIRONMENTAL CONSEQUENCES This section discusses the potential effects of the No Action and Proposed Action Alternatives on environmental resources.

4.1 Hydrology No Action Alternative The No Action Alternative would not involve laying the cable within the MTMNM; hence, it would have no effect on hydrology.

Proposed Action Alternative Two cable types, a light-weight protected (LWP) and a light-weight (LW) type, would traverse the MTMNM within the cable corridor, with two repeaters. Given the small diameters (2.4 cm and 1.7 cm, respectively) of these cable types, and moderate profile of the repeaters (45.7 cm), the proposed cable and repeaters would not impede natural water movement or create significant obstructions. The cable size and footprint is small and thus, will not have any significant effect on hydrology. The cable would be a LWP type in much of the MTMNM, and would be resistant to abrasion from strong currents. The cable would be laid perpendicular to bottom currents, as they generally flow along the trench axis from south to north (Kawabe, et al. 2003). No significant post-construction impacts to marine waters are anticipated from the Proposed Action Alternative.

4.2 Geology and Topography No Action Alternative The No Action Alternative would not involve laying the cable within the MTMNM; hence, it would have no effect on geology, substrate and topography.

Proposed Action and Alternatives The proposed cable would be laid on the surface of the seabed and is not proposed to be trenched or otherwise buried. Minor disturbances to surface sediments would occur, temporarily increasing suspended particles and turbidity. These disturbances would settle shortly after the cable is laid, or would be dispersed by natural water movement. Trenches are generally considered areas of high sedimentation (Beliaev 1989), therefore, in areas of softbottom substrate the cable will likely become buried over time. The cable will be laid directly on the seabed. No cable burial is proposed. No volcanoes or hydrothermal vents were discovered within the approximately 8-mile (14 km) wide survey corridor centered on the cable. The ROW agreement will include conditions governing the ability to conduct research in proximity to the cable.

4.3 Biological Resources No Action Alternative The No Action Alternative would not involve laying the cable within the MTMNM; hence, it would have no effect on biological resources.

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Proposed Action Alternative Deep sea coral and sponge communities have been documented within the MTMNM. The closest mapped community is approximately 36.5 miles (58.7 km) southwest of the cable; therefore, it would be avoided by the cable. There is a low potential for adverse impacts on biological resources within the cable‟s relatively narrow footprint, and within the footprint of the two repeaters. Potential impacts from the cable-laying process include laying the cable directly on or abrading sessile or slow-moving organisms, although given the 2.4 cm and 1.7 cm diameters of the cable, the likelihood of direct adverse impacts is low. Organisms in the vicinity of the cable route could also be adversely affected by the temporary disturbance of surface sediments and the associated increase in turbidity. Increases in turbidity and suspended sediments would be temporary and eventually dispersed by the benthic currents.

Potential adverse impacts to biological resources during the cable landing are usually limited to contaminants from the ship (e.g., oil or fuel spills) and vessel strikes. The cable ship will be equipped with appropriate spill response kits to immediately address any releases of oil or fuel while the vessel is operating within the MTMNM.

Once the cable is laid, it will have a maximum depth of 10,036.9 m (32,929.46 ft) and a minimum depth of 5,527.3 m (18,134.18 ft) within the MTMNM. The five listed whale species that may occur within the MTMNM are not likely to be present within the abyssal and hadal zones of the cable route; however, these species may occupy the shallower epipelagic to bathypelagic zones.

Studies show that the probability of a lethal injury (mortality or severely injured) to whales increases with vessel speed, while there is a substantial decrease in lethality as vessel speed falls below 15 knots (Vanderlaan and Taggart 2007). The cable installation activities take place at such a slow rate that the probability of impact to any marine mammal is extremely remote. During the cable landing, the cable ship will travel at speeds ranging from 1 to 6 knots (1.2 to 7 mph), which greatly reduced the likelihood of the vessel striking marine mammals or sea turtles. During other operational tasks not including cable laying, the vessel will reduce speed to 10 knots (11.5 mph) or less when in the proximity of marine mammals, and 5 knots (5.7 mph) when in areas of known or suspected turtle activity. The cable ship will alter course to remain at least 100 yds (300 ft or 274 m) away from any observed whales, and 50 yds (150 ft or 45 m) away from other marine mammals and sea turtles.

No biological monitors or “whale watchers” are proposed to be onboard the cable ship since it will not make port weekly. Once the cable ship starts to lay the cable, it usually will not stop until it reaches the next shore landing site (i.e., Australia). The cable ship operators will be briefed on the potential presence of marine mammals and sea turtles by qualified biologists either in port on Guam, or by video communication if the cable ship will not come into port on Guam. The awareness training would include descriptions of any marine mammal or sea turtle species that have the potential to occur in areas where the cable ship will be operating, and suggested procedures if they are observed within the vicinity of the vessel.

Hydrothermal vent communities are known to have low biodiversity but an extremely high biomass relative to the surrounding deep sea (Ramirez-Llodra 2015), while seamounts can be

4-2 JGA South Cable Landing in MTMNM EA Chapter 4 biodiversity hotspots (Clark 2010). These vent and seamount features will be avoided by the cable-laying activity since they pose risks to the security of the cable; this avoidance would reduce the possibility of directly impacting the organisms found in these habitats. Deep-sea coral and sponge communities were mapped during the 2016 Okeanos expedition; the closest of these communities are located 28 km or more from the cable route and would be avoided by the Proposed Action Alternative.

The earth produces a static magnetic field of approximately 250 to 650 milligauss (Finlay, 2010). The effects of the submarine fiber-optic cable's magnetic field are expected to be minimal since the proposed cable produces a low-level magnetic field of 5 milligauss at 1 m (3.3 ft.) to 0.5 milligauss at 10 m (33 ft.), significantly lower than the earth's natural magnetic field.

4.4 Threatened and Endangered Species No Action Alternative The No Action Alternative would not affect any threatened or endangered species listed by the federal government.

Proposed Action Alternative This alternative would have no effect on critical habitat, since no such habitat has been designated or proposed within the vicinity of the Proposed Action Alternative. There are no proposed, candidate, or threatened or endangered species known to visit or occupy the depth ranges of the benthic abyssal and hadal environment within the Trench Unit of the MTMNM. Therefore, the cable-laying activities would not affect any listed species on the seafloor of the MTMNM.

While eleven of the ESA-listed species in the Marianas (Table 3-2) are not likely to be present within the abyssal and hadal zones of the MTMNM, they may occupy the shallower epipelagic to bathypelagic zones overlying the seafloor of the MTMN. These include three threatened fish (scalloped hammerhead shark, giant manta ray, and oceanic whitetip shark); three threatened turtles (green sea turtle, hawksbill sea turtle, and leatherback sea turtle); and five whales (blue whale, fin whale, sei whale, humpback whale, and sperm whale). The blue whale and fin whale are rare in the Marianas, and are considered the least likely of the five whale species to occur within the vicinity of the cable route, while the sperm whale and humpback whale are considered the most likely to occur. Sperm whales are the most frequently sighted among these species in the Marianas (Fulling et al. 2011), and the Mariana Islands have been confirmed as a seasonal breeding ground for a small population of humpbacks (NOAA 2018a). There is a potential for these species to be encountered during cable-laying activities if they transit within the path of the cable ship. The cable-laying ship would be moving at a very slow rate (less than 6 knots) in order to carefully place the cable in its assigned corridor. Hence, any ESA-listed species traversing the shallower depths of the corridor would be able to anticipate and avoid interactions with the ship, minimizing the likelihood of vessel strikes. RTI will implement BMPs and comply with Pac-SLOPES conditions as part of Department of the Army permit requirements. In addition, the cable ship operator will be trained in protocols for avoidance of these species. These include altering course to remain at least 100 yards from whales, and at least 50 yards from other marine mammals and sea turtles, and reducing vessel speed to 10 knots or less when

4-3 JGA South Cable Landing in MTMNM EA Chapter 4 piloting vessels in the proximity of marine mammals, and to 5 knots or less when piloting vessels in areas of known or suspected turtle activity.

Since the cable ship would be traveling very slowly and would not be burying the cable, the noise levels generated would be low compared with similar vessels (such as freighters) that would be navigating through the MTMNM. These low noise levels are not anticipated to have an adverse effect on listed species.

As with any motorized vessel at sea, there is a potential for accidental oil or fuel releases to occur during operations, which could introduce pollutants into marine waters that may affect listed species. Spill response materials will be available on board the cable ship and would be immediately deployed in the event of a release. Once it is laid on the seabed, normal operation of the cable is considered benign, and would not produce any noise or emissions that would affect ESA-listed species.

Given the measures that would be implemented to safeguard ESA-listed species, the potential for vessel strikes, noise effects and pollutants would be minimized to less than significant levels. Therefore, the Proposed Action Alternative may affect, but would not adversely affect any threatened or endangered species listed by the federal government.

4.5 Cultural Resources No Action Alternative The No Action Alternative would not involve laying the cable within the MTMNM; hence, it would have no effect on cultural or historic resources.

Proposed Action Alternative No known cultural or historic resources have been documented along the proposed cable route or detected by the 2018 benthic survey of the cable corridor. Therefore, no impacts to cultural or historic resources are anticipated from the Proposed Action Alternative.

4.6 Hazardous Materials No Action Alternative The No Action Alternative would not involve laying the cable within the MTMNM; hence, it would have no effect on hazardous materials.

Proposed Action Alternative The only source of hazardous materials would be petroleum-based fuel and oil used in the operation of the cable ship during cable-laying activities. Should a fuel or oil spill occur, it would be cleaned immediately using onboard spill kits, and the spill would not impact the seabed. There are no hazardous materials associated with the laying of the fiber-optic cable; hence, there would be an insignificant effect from the Proposed Action Alternative.

4-4 JGA South Cable Landing in MTMNM EA Chapter 4

4.7 Unexploded Ordnance No Action Alternative The No Action Alternative would not involve laying the cable within the MTMNM; hence, it would have no effect on unexploded ordnance.

Proposed Action Alternative There are no documented or known UXOs within the vicinity of the proposed cable route, therefore, there would be no impacts from this hazard.

4.8 Military Training No Action Alternative There are no documented or known UXOs within the vicinity of the proposed cable route. It is possible that previously unknown UXOs are present at the bottom of the MTMNM, although impacts from UXOs are highly improbable and not likely to occur.

Proposed Action Alternative Under the Proposed Action Alternative, the cable route would traverse MIRC Warning Area 11, and pass within 2 km of Warning Area W-517 (Appendix A, Figure 4). These warning areas are designated as special use airspace where the sea space underneath may be restricted from public access during hazardous training events. There would be Notices to Mariners issued by the U.S. Coast Guard prior to any scheduled training and testing activities in these warning areas (DON 2019). The cable ship would avoid these areas during these activities. Upon completion of the cable installation, there would be no effect on the Proposed Action Alternative from military training in the MIRC.

4.9 Land and Water Use No Action Alternative The No Action Alternative would not involve laying the cable within the MTMNM; hence, it would have no effect on land use.

Proposed Action Alternative The proposed cable would be laid directly on the seabed; therefore, no significant changes to land use are expected. The cable passes the Sirena Deep with a separation distance of approximately 20.5 miles (33 km) at the closest point. This separation distance is sufficient enough to allow for unimpeded access to and exploration of this important bottom feature. The right-of-way agreement between the cable owners and USFWS will include conditions governing the ability for researchers and ROV operators and managers to conduct research and dives in proximity to the cable.

The existing regulated uses within the Trench Unit of the MTMNM would continue after the laying of the cable. These include research and exploration of the Mariana Trench with the proper federal permits, and commercial fishing in compliance with federal regulations.

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4.10 Noise No Action Alternative The No Action Alternative would not involve laying the cable within the MTMNM; hence, it would have no effect on ambient noise levels.

Proposed Action and Alternatives The cable ship and on-board machinery and equipment are the only noise sources associated with the proposed action and alternatives. Noise levels originating from the cable ship are similar to other vessels, such as commercial fishing boats or freight ships that could navigate these waters. The cable ship, while actively laying cable, will proceed at speeds of less than 6 knots (6.9 mph). Due to the low speed of travel, the cable ship‟s engines are not operating at maximum power and therefore, the noise generated will be relatively low when compared to other commercial vessels of similar size. These impacts are considered insignificant.

Once it is laid on the seabed, normal operation of the cable would not produce any noise and, therefore, would have no effect on existing noise levels.

4.11 Air Quality No Action Alternative The No Action Alternative would have no effect on ambient air quality.

Proposed Action Alternative The proposed action alternative would have no effect on ambient air quality on the submerged lands of the MTMNM Trench Unit. The cable-laying ship would be a mobile source of emissions; however, these would not present a significant effect on air quality. No emissions would be generated by the cable after installation.

4.12 Aesthetics No Action Alternative The No Action Alternative would have no effect on aesthetics.

Proposed Action Alternative The proposed cable would be laid directly on the seabed in submerged lands, and would not be visually detectable from the surface of the MTMNM. In soft-bottom benthic areas, the cable will likely become naturally buried as a result of natural water and sediment movement. Therefore, it would not have a significant effect on aesthetics.

4.13 Socioeconomic Characteristics No Action Alternative The No Action Alternative would not involve the laying of the JGA South cable within the MTMNM. The increased bandwidth and interconnectivity that the cable would provide would not be realized. Guam is becoming an increasingly integral part of the Western Pacific‟s internet

4-6 JGA South Cable Landing in MTMNM EA Chapter 4 infrastructure needs as it provides a hub for Asia and South Pacific cable systems, and the ability to connect these systems to the Hawaii and the mainland U.S. Guam‟s internet and data capacity demands will continue to expand as its population grows and U.S. military presence increases.

Proposed Action Alternative The proposed action would lay the JGA South cable through the MTMNM and complete the Japan-Guam-Australia cable system. This cable will provide approximately 36 Tbps of data capacity (approximately 4,500 gigabytes per second). The JGA cable system will further enhance and contribute to the much-needed expansion of communications networks from Japan and Australia, to Asia and the United States, thereby improving network redundancy, ensuring highly reliable communications, and expanding onward connectivity options in Guam.

4.14 Cumulative Effects Cumulative effects are the combined, incremental effects of development on the environment. The effects of even minor actions may accumulate over time and result in significant impacts on the environment. The cumulative impacts from the proposed action alternative were evaluated in conjunction with effects from other past, present and reasonably foreseeable future projects. Table 4-1 presents those known projects that may potentially contribute cumulative effects on the MTMNM.

Table 4-1. Submarine Communication Cables within the MTMNM

Cable Name Status Date in Description Service Commercial 1903- First telegraph cable across Pacific Ocean, connected Guam Inactive Pacific Cable 1951 with Midway Atoll, Manila, Honolulu and California. Coaxial cable that connected U.S. mainland, Hawaii, Midway Trans-Pacific 1964- Inactive Atoll, Wake Island, Guam and Japan. Sections of the cable Cable-1 (TPC-1) 1990 were repurposed for scientific use in 1990. South East Asia 1967- Coaxial telephone cable that connected Guam with Hong Commonwealth Inactive 1986 Kong and Australia. (SEACOM-B) Coaxial cable that connected Guam, Taiwan, Korea, Hong Trans-Pacific 1976- Inactive Kong and Singapore. Sections of the cable were repurposed Cable-2 (TPC-2) 1994 for scientific use in 1996. Trans-Pacific 1989- First fiber-optic cable across the Pacific Ocean, connecting Inactive Cable-3 (TPC-3) 2003 California, Hawaii, Japan, Guam. Replaced TPC-1 and TPC-2. Fiber-optic cable that connected Guam with Australia. 1995- PacRimWest Inactive Sections of the cable outside of the MTMNM were cut and 2005 repurposed in 2006. Trans-Pacific Fiber-optic cable ring that previously linked Japan, Guam, Cable-5 Cable 1996- Hawaii and the U.S. mainland. Portions of the cable have Inactive Network 2013 been recovered and relaid for the GOKI (Guam, Okinawa, (TPC-5 CN) Kyushu, Incheon) cable.

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Cable Name Status Date in Description Service China-US Cable Fiber-optic cable that previously connected several 2000- Cable Network Inactive countries in Asia to the mainland U.S, with a landing point 2016 (CUCN) on Guam. Australia-Japan 2001- Cable (AJC) Active Fiber-optic cables linking Australia, Japan, and Guam. present (Segment 4) Australia-Japan 2001- Fiber-optic cable connecting parts of Japan and Australia Cable (AJC) Active present with Guam. (Segment 6) PIPE Pacific 2009- Fiber-optic cable connecting Australia with Guam, with a Active Cable-1 (PPC-1) present landing point in Papua New Guinea.

Asia-America 2009- Fiber-optic cable connecting Southeast Asia to the mainland Active Gateway present U.S, with landing points on Guam and Hawaii.

2010- Fiber-optic cable connecting Kwajalein to Guam, with HANTRU-1 Cable Active present landing points in Majuro and Pohnpei. Fiber-optic cable system connecting Indonesia, the Southeast Asia- 2017- Active Philippines and Republic of Palau with the mainland U.S. via U.S. (SEA-US) present landings on Guam and Hawaii.

The potential impacts from the Proposed Action Alternative, as discussed in the preceding sections, form a basis for identifying resources or resource areas that may be affected. Cable- laying activities would result in short-term cumulative impacts produced by turbidity increases and direct cable impacts to slow-moving or sessile organisms on the seabed surface. Turbidity is anticipated to be insignificant, and would dissipate with the currents in the water column. No burial of the cable is proposed; hence, intrusive disturbance of the seabed would be avoided. The Proposed Action Alternative would avoid known areas of deep-sea sponge and coral communities.

No long-term adverse cumulative impacts are anticipated on land use and benthic habitat. Regulated uses within the MTMNM would continue after the cable is laid, with no adverse effect. The cable and repeaters would add an approximately 2,865 sq. m area to the previously laid cables in the MTMNM (Table 4-1) that occupy similarly small footprints on the sea floor, and have likely become buried in the sediments of the Trench Unit over time. The proposed action alternatives, when considered with past, present and reasonably foreseeable actions, would not have a significant cumulative effect on the environment.

The region of influence for cumulative impacts on these resource areas is within the MTMNM Trench Unit. The No Action Alternative would have no long-term negative cumulative impacts on the existing environment.

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4.15 Relationship Between Short-Term Use of the Environment and Maintenance and Enhancement of Long-Term Productivity The proposed action would occupy a small footprint on the seafloor to accommodate the proposed cable. The proposed action would enhance long-term productivity through the efficient transmission of telecommunication information over the approximately 25-year expected life span of the cable.

4.16 Probable Irretrievable and Irreversible Commitments of Resources Labor and energy resources in the form of fossil fuels would be consumed during the laying of the JGA South cable. This would be an irretrievable commitment of resources. As has been done with other cables (Table 4-1), the JGA South cable could be removed and repurposed at the end of its life span; therefore, the area of seafloor occupied by the cable would not constitute an irreversible commitment of resources.

4.17 Environmental Compliance This section describes the compliance of the Proposed Action with the following Presidential Executive Orders, federal acts and regulations. The Proposed Action Alternative is entirely within the submerged lands of the MTMNM Trench Unit.

4.17.1 National Environmental Policy Act (NEPA) of 1969 This document was prepared in accordance with NEPA (42 United States Code §4231, et seq.), as implemented by the Council on Environmental Quality regulations (40 CFR 1500-1508), and as required by Secretarial Order 3355 and the August 18, 2018 Memorandum.

4.17.2 Presidential Proclamation 8335 According to the 2009 Presidential Proclamation establishing the MTMNM, the Secretaries of the Interior and Commerce shall not allow or permit any appropriation, injury, destruction, or removal of any feature of this monument except as provided for by this proclamation or as otherwise provided for by law. The USFWS was delegated to manage the MTMNM Trench Unit as part of the National Wildlife Refuge System, through the DOI Secretary‟s Order No. 3284. The proposed action would be implemented under a Right-of-Way Permit to allow for the laying of the JGA South cable within the MTMNM, and would comply with the conditions of this permit.

4.17.3 Military Coordination RTI has coordinated with Catherine Creese, Assistant Director, U.S. Naval Seafloor Cable Protection Office (NSCPO), in Washington, D.C. for the Proposed Action Alternative. NSCPO is the official point of contact for all Navy cables, with a mission to protect all Department of Defense interests with respect to seafloor cables by providing internal coordination and external representation of those interests to the U.S. government and the industry. Aside from protecting

4-9 JGA South Cable Landing in MTMNM EA Chapter 4 the Navy‟s existing systems, NSCPO works with the cable industry to ensure the protection of existing commercial cables in the event that the Navy builds a new cable or range.

4.17.4 Federal Water Pollution Control Act (Clean Water Act), 33 U.S.C. 1251 Section 402 of the Clean Water Act established the National Pollutant Discharge Elimination System (NPDES) program that initially controlled the discharge of pollutants from point sources such as wastewater outfalls. The program has expanded to include the control of stormwater discharges. Under current regulations a NPDES permit would be required for construction activities that disturb more than one acre. The proposed action would be in compliance with this Act, since it would not involve the burial of the cable on the seafloor, or result in the point source discharge of pollutants or stormwater.

4.17.5 Coastal Zone Management Act (CZMA) Federal activities and development projects which directly affect the coastal zone must be conducted or supported in a manner which is, to the maximum extent practicable, consistent with the Coastal Resource Management (CRM) Program. The implementation of these federal consistency provisions will be carried out in accordance with Section 307 of the CZMA and Federal Regulations at 15 CFR, Part 930. The proposed action would be consistent with the Guam Coastal Management Program, which is the CRM Program on Guam. The proposed cable system would be constructed and operated in conformance with these standards and policies.

4.17.6 Magnuson-Stevens Fisheries Conservation & Management Act The 1996 Sustainable Fisheries Act (P.L. 104-267) amendments to the Magnuson-Stevens Fishery Management and Conservation Act is the primary law governing marine fisheries management in U.S. federal waters and promotes long-term biological and economic sustainability within waters of the U.S. out to 200 nautical miles (230.2 miles) from shore. Key objectives of this act are: prevent overfishing, rebuild overfished stocks, increase long-term economic and social benefits, use reliable data and sound science, conserve essential fish habitat (EFH), and ensure a safe and sustainable supply of seafood. EFH for the proposed action was defined in Section 3.3.4.1. and Appendix D.

The Mariana Islands EFH extents relative to the Proposed Action Alternative are shallow for both the seafloor (from the shoreline to 700 m depth) and water column (surface to 1,000 m water depth); therefore, they do not encompass the abyssal (3,000-6,000 m) and hadal zones (6,000-11,000 m) of the MTMNM. There is no precious coral fishery for Guam; however, precious corals (gold, bamboo and black corals) were found during the 2016 Okeanos Explorer expedition (Glickson et al. 2017). The nearest corals within the MTMNM are gold corals located approximately 58.7 km or more from the cable route; these are also the deepest of the corals and were found in the MTMNM at around 3,700 m depths (Appendix A, Figure 3). The proposed cable route would traverse depths between 5,527-10,036 m within the MTMNM and would avoid these corals.

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Since the action of laying the cable would be performed by a slow-moving cable ship and no burial is proposed, this activity would generate only minor turbidity as the cable settles on the seafloor, and it would not create significant turbidity in the water column within the EFH depths. Therefore, the proposed action may affect, but would not adversely affect EFH for these MUS in the water column above the submerged lands of the MTMNM.

4.17.7 Marine Mammal Protection Act The U.S. Marine Mammal Protection Act of 1972 provides protection for all marine mammals, including cetaceans (whales, dolphins, and porpoises), pinnipeds (seals and sea lions), sirenians (manatees and dugongs), sea otters and polar bears within the waters of the U.S. Under the Act, it is illegal to take (harass, hunt, capture, collect, or kill) any marine mammal or part of a marine mammal without a permit from the NMFS or USFWS, who are responsible for management of these species.

The Proposed Action Alternative would implement BMPs and follow the Standard Local Operating Procedures for Endangered Species in the central and western Pacific region (Pac- SLOPES), which are conditions of the JGA South Cable Department of the Army Permit. Additionally, the cable ship operators will undergo awareness training that would include descriptions of any marine mammal or sea turtle species that have the potential to occur in areas where the cable ship will be operating, and suggested procedures if they are observed within the vicinity of the vessel. These measures would collectively serve to minimize the likelihood of any take of marine mammals during the cable-laying activities. Upon completion of the cable installation, the risk of the cable to marine mammals is remote. Previous entanglements with cetaceans, mainly sperm whales, occurred at shallow depths down to approximately 620 fm (3,720 ft or 1,133 m) between the 1850s-1950s, primarily because of excessive cable slack (Heezen 1957); however, with advances in cable design, laying and maintenance techniques, no further entanglements have been reported (Carter et al. 2009).

4.17.8 National Historic Preservation Act (NHPA) Section 106 of the NHPA requires federal agencies to take into account the effects of their proposed actions on historic properties, and to preference those that avoid or mitigate those effects. No known historic resources have been documented within the vicinity of the Proposed Action Alternative, and no potential cultural resources (e.g., shipwrecks) were detected during the 2018 survey of the cable corridor (EGS Survey Group 2018).

4.17.9 Clean Air Act (CAA), 42 U.S.C. 7401 et seq. The Clean Air Act (CAA) includes provisions that ensure Federal Actions do not obstruct local efforts to control air pollution. Section 176(c) of the CAA prohibits Federal agencies, departments or instrumentalities from engaging in, supporting, licensing, of approving any action that does not conform to an approved state or Federal implementation plan. Conformity to an implementation plan is defined as:

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Conformity to an implementation plan's purpose of eliminating or reducing the severity and number of violations of the national ambient air quality standards and achieving expeditious attainment of such standards; and that such activities will not  cause or contribute to any new violation of any standard in any area;  increase the frequency or severity of any existing violation of any standard in any area; or  delay timely attainment of any standard or any required interim emission reductions or other milestones in any area. The proposed action would be in conformity with the CAA since there would be no significant emission sources from the cable-laying activity or following the laying of the cable.

4.17.10 Endangered Species Act of 1973 (ESA), 16 U.S.C 1531 et seq. Under the ESA, Federal agencies are required to conduct their actions as to not jeopardize the continued existence of any threatened or endangered species, or result in the destruction or adverse modification of critical habitat. Federal agencies are required to consult with the U.S. Fish and Wildlife Service and/or the National Marine Fisheries Service for actions that would adversely affect listed species or habitat.

Once the cable is laid, it will have a maximum depth of 10,036.9 m (32,929.46 ft) and a minimum depth of 5,527.3 m (18,134.18 ft) within the MTMNM. There are no proposed, candidate, or threatened or endangered species known to occupy the depth ranges of the benthic abyssal and hadal environment within the Trench Unit of the MTMNM (see Section 3.3.3). Listed turtles, fish and mammals may occupy the shallower epipelagic to bathypelagic zones. There is a potential for these species to be encountered during the cable-laying operation. During these activities, the cable-laying ship would be moving at a slow rate in order to carefully place the cable in its assigned corridor. Therefore, any ESA-listed species traversing the shallower depths of the corridor would be able to anticipate and avoid interactions with the ship. While no biological monitors or “whale watchers” are proposed to be onboard the cable ship, since it will not make port weekly, the cable ship operators will be briefed on the potential presence of marine mammals and sea turtles by qualified biologists. The training will occur either in port on Guam, or by video communication if the cable ship will not come into port on Guam. The awareness training would include descriptions of any marine mammal or sea turtle species that have the potential to occur in areas where the cable ship will be operating, and suggested procedures if they are observed within the vicinity of the vessel.

The Proposed Action Alternative would implement BMPs and follow the Standard Local Operating Procedures for Endangered Species in the central and western Pacific region (Pac- SLOPES), which are conditions of the JGA South Cable Department of the Army Permit.

4.17.11 Migratory Bird Treaty Act, 16 U.S.C. 703 and Executive Order 13186, Responsibilities of Federal Agencies to Migratory Bird Treaty Act The Migratory Bird Treaty Act prohibits the taking or harming of migratory birds. Under the executive order a Federal agency taking actions that have, or are likely to have, a measurable negative effect on migratory bird populations is directed to develop and implement, within two

4 -12 JGA South Cable Landing in MTMNM EA Chapter 4 years, a Memorandum of Understanding (MOU) with the Fish and Wildlife Service (Service) that shall promote the conservation of migratory bird populations.

The Proposed Action Alternative would not involve the taking or harming of migratory birds.

4.17.12 Executive Order 13112, Invasive Species This executive order directs all federal agencies whose actions may affect the status of invasive species shall, to the extent practicable and permitted by law:  identify such actions;  subject to the availability of appropriations, and within Administration budgetary limits, use relevant programs and authorities to: (i) prevent the introduction of invasive species, and (ii) not authorize, fund, or carry out actions that it believes are likely to cause or promote the introduction or spread of invasive species in the United States or elsewhere unless, pursuant to guidelines that it has prescribed, the agency has determined and made public its determination that the benefits of such actions clearly outweigh the potential harm caused by invasive species; and that all feasible and prudent measures to minimize risk of harm will be taken in conjunction with the actions.

The Proposed Action Alternative would not involve activities that increase the potential for introduction of invasive species.

4.17.13 Executive Order 12898, Environmental Justice in Minority Populations and Low Income Populations Executive Order 12898 requires federal agencies to undertake efforts to achieve environmental justice in minority and low-income populations by “identifying and addressing, as appropriate, disproportionately high and adverse human health or environmental effects of its programs, policies, and activities.”

The Proposed Action Alternative would not affect minority of low-income populations. The cable-laying activity would only involve submerged lands of the Trench Unit in the MTMNM, and is considered to be benign.

4.17.14 Executive Order 13045, Protection of Children from Environmental Health Risks and Safety Risks Executive Order 13045 entitled “Protection of Children from Environmental Health Risk and Safety Risks” acknowledges that children may suffer disproportionately relative to adults from environmental and safety risks attributable to the development of their neurological, immunological, digestive and other bodily systems. The executive order requires federal agencies to place a high priority on the identification of and assessment of environmental health and safety risks of its policies, programs, activities and standards that may disproportionately affect children.

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The Proposed Action would have no environmental or safety risks that would disproportionately affect children. The cable-laying activity is considered to be benign.

4.17.15 Executive Order 11988, Floodplain Management Executive Order 11988 requires federal agencies to avoid to the extent possible the long and short-term adverse impacts associated with the occupancy and modification of flood plains and to avoid direct and indirect support of floodplain development wherever there is a practicable alternative. In accomplishing this objective, "each agency shall provide leadership and shall take action to reduce the risk of flood loss, to minimize the impact of floods on human safety, health, and welfare, and to restore and preserve the natural and beneficial values served by flood plains in carrying out its responsibilities" for the following actions:  acquiring, managing, and disposing of federal lands and facilities;  providing federally-undertaken, financed, or assisted construction and improvements;  conducting federal activities and programs affecting land use, including but not limited to water and related land resources planning, regulation, and licensing activities.

The Proposed Action would not be located in any base floodplains identified by the Federal Emergency Management Agency (FEMA), and would not encourage direct or indirect support of floodplain development. The cable-laying activity would only involve submerged lands of the Trench Unit in the MTMNM, and is considered to be benign.

4.17.16 Executive Order 11990, Protection of Wetlands Executive Order 11990 requires federal agencies to provide leadership and take action to minimize the destruction, loss or degradation of wetlands, and to preserve and enhance the natural and beneficial values of wetlands. Each agency, to the extent permitted by law, must avoid undertaking or providing assistance for new construction located in wetlands unless the head of the agency finds: there is no practical alternative to such construction; the proposed action includes all practical measures to minimize harm to wetlands that may result from such use. In making this finding the head of the agency may take into account economic, environmental and other pertinent factors. Each agency must also provide opportunity for early public review of any plans or proposals for new construction in wetlands.

The Proposed Action would not be located in wetlands nor would it have direct or indirect effects upon wetlands.

4.17.17 Executive Order 13089, Protection of Coral Reefs Executive Order 13089 was signed in 1998 to preserve and protect the biodiversity, health, heritage, and social and economic value of U.S. coral reef ecosystems and the marine environment. As such, all Federal agencies whose actions may affect U.S. coral reef ecosystems shall: (a) identify their actions that may affect U.S. coral reef ecosystems; (b) utilize their programs and authorities to protect and enhance the conditions of such ecosystems; and (c) to the

4 -14 JGA South Cable Landing in MTMNM EA Chapter 4 extent permitted by law, ensure that any actions they authorize, fund, or carry out will not degrade the conditions of such ecosystems.

The Proposed Action Alternative would not directly or indirectly impact any coral reef ecosystems, since these habitats are not found within the deep abyssal and hadal zones of the cable corridor. The known deep-sea coral and sponge communities mapped by the 2016 Okeanos Explorer expedition are located 28 km or more from the proposed cable route, and would be avoided by the Proposed Action Alternative.

4.17.18 Executive Order 13101, Greening the Government Through Waste Prevention, Recycling, and Federal Acquisition Executive Order 13101 aims to improve the Federal Government‟s use of recycled products and environmentally preferable products. Under the Order, pollution should be prevented, whenever feasible, or else recycled. If prevention or recycling is not feasible, then pollution should be treated in an environmentally safe manner; disposal should be used only as a final option.

The proposed cable would not be a source of any pollutants or contaminants. The cable-laying ship would comply with this Executive Order in its waste management operations.

4.17.19 Executive Order 13123, Greening the Government Through Efficient Energy Management Under E.O. 13123, the Federal Government must implement effective energy management in order to save taxpayer dollars and reduce emissions that contribute to air pollution and global climate change. Federal agencies must reduce greenhouse gas emissions; improve energy efficiency; reduce energy consumption in industrial and laboratory facilities; strive for expanded use of renewable energy; reduce the use of petroleum; reduce total energy use at the source; and reduce water consumption and associated energy use.

Once it is laid in place, the proposed cable would be a benign use, and would not generate emissions that contribute to air pollution and global climate change.

4.17.20 Executive Order 13148, Greening the Government Through Leadership in Environmental Management E.O. 13148 requires heads of Federal agencies to integrate environmental accountability into their decision-making and long-term planning processes. The E.O. includes the following agency goals: develop and implement environmental management systems and environmental compliance audit programs and policies; reduce pollution and inform the public of possible pollution sources from facilities; reduce toxic chemical releases; reduce the use of toxic chemicals, hazardous substances, and pollutants; reduce the generation of hazardous and radioactive waste; reduce the use of ozone-depleting substances; and promote environmentally and economically beneficial landscaping.

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The Proposed Action would not be a source of any pollutants, toxic chemicals, or any hazardous materials of any kind. The cable would be laid using industry-standard techniques and equipment that are compliant with all applicable laws regarding pollutant discharge.

4.18 Separate But Related Compliance Actions The following permits and compliance certifications were applied for as part of the JGA South cable landing in Piti, Guam.

4.18.1 United States Army Corps of Engineers The United States Army Corps of Engineers (USACE) is the lead federal agency for projects within waters of the U.S. under the Rivers and Harbors Act of 1899, the Clean Water Act, and the Marine Protection Research and Sanctuaries Act of 1972. A USACE Nationwide Permit (NWP) Application for the JGA South cable landing on Guam was submitted to the USACE field office on July 31, 2018. The USACE issued a NWP 12 for Utility Line Activities to authorize this project on April 22, 2019 (USACE File No. POH-2018-191). The proposed action will comply with all Pac-SLOPES conditions.

4.18.2 National Marine Fisheries Service Essential Fish Habitat (EFH) and Endangered Species Act (ESA) consultations with the National Marine Fisheries Service (NMFS) were completed on June 25, 2019 and June 26, 2019 respectively. The NMFS concurred that the proposed action is not likely to adversely affect ESA-Listed species and Essential Fish Habitat.

4.18.3 Guam Department of Agriculture, Division of Aquatic and Wildlife Resources A Marine Protected Area (MPA) Permit Application was submitted to the Guam Department of Agriculture, Division of Aquatic and Wildlife Resources (DAWR) on October 1, 2018. DAWR is the lead Government of Guam agency overseeing terrestrial and marine resources, including marine protected areas and threatened and endangered species. It is also a key reviewer for activities in the Guam Seashore Reserve and Federal Consistency under Coastal Zone Management Act.

4.18.4 Guam Environmental Protection Agency A 401 Water Quality Certification Application was submitted to the Guam Environmental Protection Agency (GEPA) on August 1, 2018. Guam EPA issued a 401 Water Quality Certification for the project on April 2, 2019. Guam EPA is the lead agency overseeing effects on resources under U.S. and Guam Clean Water Acts, including Section 401 Water Quality Certification. It is also a key reviewer for activities in the Guam Seashore Reserve and Federal Consistency under Coastal Zone Management Act.

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4.18.5 Guam Coastal Management Program A Guam Coastal Management Program Federal Consistency Application for the JGA South cable landing on Guam was submitted to the Guam Bureau of Statistics and Plans (BSP) on August 1, 2018. BSP is the lead agency for Federal Consistency under Coastal Zone Management Act and a key reviewer for activities in the Guam Seashore Reserve. BSP issued a Federal Consistency Review and Concurrence letter for this project on November 20, 2018.

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5 REFERENCES

Bailey H., S. R. Benson, G. L. Shillinger, S. J. Bograd, P. H. Dutton, S. A. Eckert, S. J. Morreale, F. V. Paladino, T. Eguchi, D. G. Foley, B. A. Block, R. Piedra, C. Hitipeuw, R. F. Tapilatu, and J. R. Spotila. 2012. Identification of distinct movement patterns in Pacific leatherback populations influenced by ocean conditions. Ecol. App., 22(3): 735-747.

Beliaev, G.M. 1989. Deep-Sea Ocean Trenches and Their Fauna. Nauka Publishing House, Moscow.

Byrne, R., Fish, J., Doyle, T., Houghton, J. 2007. Leatherback turtles satellite-tagged in European waters. Endangered Species research, Vol. 3. 9 pp.

Carter L., D. Burnett, S. Drew, G. Marle, L. Hagadorn, D. Bartlett-McNeil, and N. Irvine. 2009. Submarine Cables and the Oceans – Connecting the World. UNEP-WCMC Biodiversity Series No. 31. ICPC/UNEP/UNEP-WCMC. 68 pp.

Clark, Malcolm R., Rowden, Ashley A., Schlacher, Thomas, Williams, Alan, Consalvey, Mireille, Stocks, Karen I., Rogers, Alex D., O'Hara, Timothy D., White, Martin, Shank, Timothy M., Hall-Spencer, Jason M.. 2010. The ecology of seamounts: structure, function, and human impacts. Annual Review of Marine Science, Vol. 2: 253–278.

Department of the Navy (DON). 2019. Mariana Islands Training and Testing Activities Draft Supplemental Environmental Impact Statement/Overseas Environmental Impact Statement. Vols. 1 and 2. January 2019.

EGS Survey Group. 2018. Bathymetric survey of Japan-Guam-Australia (JGN) South Cable Route. Prepared for Alcatel Submarine Networks (ASN).

Eldredge, L.G. 2003. The marine reptiles and mammals of Guam. Micronesica 35-36: 653-660.

Finlay, C.C., S. Maus, C.D. Beggan, T.N. Bondar, A. Chambodut, T.A. Chernova, A. Chulliat, V.P. Golokov, B. Hamilton, M. Hamoudi, R. Holme, G. Hulot, W. Kuang, B. Langlais, V. Lesur, F.J. Lowes, H. Luhr, S. Macmillan, M. Mandea, S. McLean, C. Majoj, M. Menvielle, I Michaelis, N. Olsen, J. Rauberg, M. Rother, T.J. Sabaka, A. Tangborn, L. Toffner-Clausen, E. Theabault, W.W.P. Thomson, I Wardinski, Z. Wei, and T.I. Zvereva. 2010. International Geomagnetic Reference Field: the eleventh generation. Geophys. Jour. Intl..183(3): 1216– 1230.

Five Deeps. 2019. Deepest Submarine Dive in History, Five Deeps Expedition Conquers Challenger Deep. Five Deeps Press Release. May 13, 2019. 7 pp.

Fossette, Sabrina. 2010. Behavior and Buoyancy Regulation in the Deepest-Diving Reptile: The Leatherback Turtle. The Journal of Experimental Biology. Volume 213. Pages 4074-4083

5-1 JGA South Cable Landing in MTMNM EA Chapter 5

Fryer, P., N. Becker, B. Appelgate, F. Martinez, M. Edwards, and G. Fryer. 2003. Why is the Challenger Deep so deep? Earth and Planetary Science Letters, 211 (3-4): 259-269.

Fulling, G.L., P.H. Thorson, and J. Rivers. 2011. Distribution and abundance estimates for cetaceans in the waters off Guam and the Commonwealth of the Northern Mariana Islands. Pacific Science, 65(3): 321-343.

Gallo, N., Cameron, J., Hardy, K., Fryer, P., Bartlett, D., A. Levin, L. 2015. Submersible- and lander-observed community patterns in the Mariana and New Britain trenches: Influence of Productivity and depth on epibenthic and scavenging communities. Deep-Sea Research I, Vol. 99: 119–133.

Gardner, J. V., A. A. Armstrong, B. R. Calder and J. Beaudoin. 2014. So, how deep is the Mariana Trench? Marine Geodesy, 37: 1-13.

Gerringer, M.E. 2019. On the success of the hadal snailfishes. 2019. Integrative Organismal Biology. pp. 1-18.

Gerringer, M.E., T.D. Linley, A.J. Jamieson, E. Goetze, and J.C. Drazen. 2017. A newly- discovered hadal snailfish (Scorpaeniformes: Liparidae) from the Mariana Trench. Zootaxa, 4358 (1): 161–177.

Glickson, D. A., D. Amon, L.A. McKenna, and K. Elliott. 2017. 2016 deepwater exploration of the Marianas, EX-16-05 Leg 1 cruise report: Guam and the Commonwealth of the Northern Mariana Islands Guam to Saipan, Northern Mariana Islands. NOAA Office of Ocean Exploration and Research, Silver Spring, MD. 31 pp.

Grigg RW.1993. Precious coral fisheries of Hawaii and the US Pacific Islands. Mar Fish Rev 55(2):50B60.

Hamilton, P.K., G.S. Stone, and S.M. Martin. 1997. Note on a deep humpback whale Megaptera novaeanglieae dive near Burmuda. Bull. Mar. Sci., 61(2): 491-494.

Hill, M., A. Ligon, A. Ü, and A. Bradford. 2015. Humpback whales in the Marianas. NOAA Pacific Islands Fisheries Science Center Blog. Posed March 23, 2015. https://pifscblog.wordpress.com/2015/03/23/humpback-whales-in-the-marianas/

Heezen, Bruce C. 1957. Whales entangled in deep sea cables. Deep Sea Research, 4: 105-115.

Howey-Jordan L.A., E.J. Brooks, D.L. Abercrombie, L.K.B. Jordan, and A. Brooks. 2013. Complex Movements, Philopatry and Expanded Depth Range of a Severely Threatened Pelagic Shark, the Oceanic Whitetip (Carcharhinus longimanus) in the Western North Atlantic. PLOS ONE 8(2): e56588. https://doi.org/10.1371/journal.pone.0056588

International Cable Protection Committee. 2015a. ICPC Recommendation: Recommendation No. 9, Minimum Technical Requirements for a Desktop Study (also known as a Cable Route Study). ICPC Recommendation No. 9, Issue: 5. November 2, 2015. 16 pp.

5-2 JGA South Cable Landing in MTMNM EA Chapter 5

International Cable Protection Committee. 2015b. ICPC Recommendation: Recommendation No. 2, Recommended Routing and Reporting Criteria for Cables in Proximity to Others. ICPC Recommendation No. 2, Issue: 11. November 3, 2015. 17 pp.

IUCN 2019. The IUCN Red List of Threatened Species. Version 2019-1. http://www.iucnredlist.org. Downloaded on 20 March 2019.

Jamieson, A., T. Fujii, D.J. Mayor, M. Solan, and I.G. Priede. 2010. Hadal Trenches: The Ecology of the Deepest Places on Earth. Trends in Ecology and Evolution. 8 pp.

Jamieson, A. 2011. Ecology of deep oceans: hadal trenches. In: eLS. John Wiley & Sons, Ltd, Chichester.

Jamieson, A., I.G. Priede, and J. Craig. 2012. Distinguishing between the abyssal macrourids Coryphaenoides yaquinae and C. armatus from in situ photography. 2012. Deep Sea Research Part I: Oceanographic Research Papers. Volume 64, June 2012, Pages 78-85

Jorgensen, S.J., A.P. Klimley, and A.F. Muhlia-Melo. 2009. Scalloped hammerhead shark Sphyrna lewini, utilizes deep-water, hypoxic zone in the Gulf of California. Journal of Fish Biology, 74: 1682-1687.

Kashiwagi, T., A.D. Marshall, M.B. Bennett and J.R. Ovenden. 2011. Habitat segregation and mosaic sympatry of the two species of manta ray in the Indian and Pacific Oceans: Manta alfredi and M. birostris. Marine Biodiversity Records, 4: 1-8. Published online by Marine Biological Association of the United Kingdom.

Kawabe, M., S. Fujino, and D. Yanagimoto. 2003. Deep-water circulation at low latitudes in the western North Pacific. Deep Sea Research Part I Oceanographic Research Papers, 50(5): 631-656

Klimley, A.P. 1993. Highly directional swimming by scalloped hammerhead sharks, Sphyrna lewini, and subsurface irradiance, temperature, bathymetry, and geomagnetic field. Marine Biology 117: 1.

Linley, T.D., M.E. Gerringer, P.H. Yancey, J.C. Drazen, C.L. Weinstock, and A.J. Jamieson. 2016. Fishes of the hadal zone including new species, in situ observations and depth records of Liparidae. Deep-Sea Research Part I, Volume 114, pp. 99-110.

Linley, T. D., A.L. Stewart, P.J. McMillan, M.R. Clark, J.C. Drazen, T. Fujii, and A.J. Jamieson. 2017. Bait attending fishes of the abyssal zone and hadal boundary: community structure, functional groups and species distribution in the Kermadec, New Hebrides and Mariana Trenches. Deep Sea Research Part I: Oceanographic Research Papers (2016). 58 pp.

Mestre V.J. and D. Wooten. 1979. Noise Impact Analysis. In J.G. Rau and D.C. Wooten (eds.), Environmental Impact Analysis Handbook. McGraw-Hill, New York, U.S.A. 642 pp.

5-3 JGA South Cable Landing in MTMNM EA Chapter 5

Miller, M.H., Carlson, J., Cooper, P., Kobayashi, D., Nammack, M., and J. Wilson. 2014. Status review report: scalloped hammerhead shark (Sphyrna lewini). Final Report to National Marine Fisheries Service, Office of Protected Resources. March 2014.133 pp.

Miller, M.H. and C. Klimovich. 2016. Endangered Species Act Status Review Report: Giant Manta Ray (Manta birostris) and Reef Manta Ray (Manta alfredi). Draft Report to National Marine Fisheries Service, Office of Protected Resources, Silver Spring, MD. December 2016. 127 pp.

National Marine Fisheries Service (NMFS). 1998a. Recovery plan for the blue whale (Balaenoptera musculus). Prepared by Reeves R.R., P.J. Clapham, R.L. Brownell, Jr., and G.K. Silber for the National Marine Fisheries Service, Silver Spring, MD. 42 pp.

National Marine Fisheries Service. 1998b. Recovery plan for the humpback whale (Megaptera novaengliae). Prepared by Reeves R.R., P.J. Clapham, R.L. Brownell, Jr., and G.K. Silber for the National Marine Fisheries Service, Silver Spring, MD. 42 pp.

National Marine Fisheries Service. 2010a. Recovery plan for the fin whale (Balaenoptera physalus). National Marine Fisheries Service, Silver Spring, MD. 121 pp.

National Marine Fisheries Service. 2010b. Recovery plan for the sperm whale (Physeter macrocephalus). National Marine Fisheries Service, Silver Spring, MD. 165pp.

National Marine Fisheries Service. 2011. Final Recovery Plan for the Sei Whale (Balaenoptera borealis). National Marine Fisheries Service, Office of Protected Resources, Silver Spring, MD. 108 pp.

National Marine Fisheries Service and U.S. Fish and Wildlife Service. 1998a. Recovery Plan for U.S. Pacific Populations of the Green Turtle (Chelonia mydas). National Marine Fisheries Service, Silver Spring, MD. 97 pp.

National Marine Fisheries Service and U.S. Fish and Wildlife Service. 1998b. Recovery Plan for U.S. Pacific Populations of the Hawksbill Turtle (Eretmochelys imbricata). National Marine Fisheries Service, Silver Spring, MD. 95 pp.

National Marine Fisheries Service and U.S. Fish and Wildlife Service. 1998c. Recovery Plan for U.S. Pacific Populations of the Leatherback Turtle (Dermochelys coriacea). National Marine Fisheries Service, Silver Spring, MD.

National Marine Fisheries Service and U.S. Fish and Wildlife Service. 1998d. Recovery Plan for U.S. Pacific Populations of the Loggerhead Turtle (Caretta caretta). National Marine Fisheries Service, Silver Spring, MD.

National Marine Fisheries Service and U.S. Fish and Wildlife Service. 1998e. Recovery Plan for U.S. Pacific Populations of the Olive Ridley Turtle (Lepidochelys olivacea). National Marine Fisheries Service, Silver Spring, MD.

National Marine Fisheries Service and U.S. Fish and Wildlife Service. 2007a. Green Sea Turtle (Chelonia mydas). 5-Year Review: Summary and Evaluation. 105 pp.

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National Marine Fisheries Service and U.S. Fish and Wildlife Service. 2007b. Hawskbill Sea Turtle (Eretmochelys imbricata). 5-Year Review: Summary and Evaluation. 93 pp.

National Marine Fisheries Service and U.S. Fish and Wildlife Service. 2007c. Loggerhead Sea Turtle (Caretta caretta). 5-Year Review: Summary and Evaluation. 67 pp.

National Marine Fisheries Service and U.S. Fish and Wildlife Service. 2013. Hawskbill Sea Turtle (Eretmochelys imbricata). 5-Year Review: Summary and Evaluation. 92 pp.

Nelson, J.S., 1994. Fishes of the world. 3rd edition. John Wiley & Sons, Inc., New York. 600 pp.

NOAA. 2018a. #MIhumpbacks: Humpback whales of the Mariana Islands. NOAA Fisheries News. April 9, 2018. https://www.fisheries.noaa.gov/feature-story/mihumpbacks- humpback-whales-mariana-islands

NOAA. 2018b. Oceanic Whitetip Shark, Overview, Conservation and Management Resources. https://www.fisheries.noaa.gov/species/oceanic-whitetip-shark

Oguri, K. and T. Noguchi. 2017. Deepest fish ever recorded, documented at depths of 8,178 m in Mariana Trench. JAMSTEC Press Release.

Ponganis, Paul J. 2011. Diving mammals. Comprehensive Physiology, 1: 517-535.

Ramirez-Llodra, E., T.M. Shank, and C.R. German. 2007. Biodiversity and biogeography of hydrothermal vent species: Thirty years of discovery and investigations. Oceanography, 20 (1): 30–41.

Reagan, M. K., O. Ishizuka, R. J. Stern, K. A. Kelley, Y. Ohara, J. Blichert-Toft, S. H. Bloomer, J. Cash, P. Fryer, B. B. Hanan, R. Hickey-Vargas, T. Ishii, J. Kimura, D. W. Peate, R. C. Rowe, M. Woods. 2010. Fore-arc Basalts and Subduction Initiation in the Izu-Bonin- Mariana System. Geochemistry, Geophysics, Geosystems (G3), Vol. 11, No. 3. 17 pp.

Santos, M.B., G.J. Pierce, J. Herman, O, A. Lopez, P, A. Guerra, P, E. Mente and M.R. Clarke. 2001. Feeding Ecology of Cuvier's Beaked Whale (Ziphius Cavirostris): a Review with New Information on the Diet of this Species. Journal of the Marine Biological Association of the United Kingdom, 81: 687-694.

Schorr G.S., E.A. Falcone, D.J. Moretti, R.D. Andrews. 2014. First Long-Term Behavioral Records from Cuvier‟s Beaked Whales (Ziphius cavirostris) Reveal Record-Breaking Dives. PLoS ONE 9(3): e92633. https://doi.org/10.1371/journal.pone.0092633

Seminoff, J.A., C.D. Allen, G.H. Balazs, P.H. Dutton, T. Eguchi, H.L. Haas, S.A. Hargrove, M.P. Jensen, D.L. Klemm, A.M. Lauritsen, S.L. MacPherson, P. Opay, E.E. Possardt, S.L. Pultz, E.E. Seney, K.S. Van Houtan, R.S. Waples. 2015. Status Review of the Green Turtle (Chelonia mydas) Under the U.S. Endangered Species Act. NOAA Technical Memorandum, NOAANMFS-SWFSC-539. 571 pp.

5-5 JGA South Cable Landing in MTMNM EA Chapter 5

Steward, J.D., E.M. Hoyos-Padilla, K.R. Kumli, and R.D. Rubin. Deep-water feeding and behavioral plasticity in Manta birostris revealed by archival tags and submersible observations. Zoology 119 (5): 406-413.

Stewart, H. and A. Jamieson. 2018. Habitat Heterogeneity of Hadal Trenches: Considerations and Implications for Future Studies. Progress in Oceanography. Volume 161: 47-65.

Taira, K., Kitagawa, S., Yamashiro, T., Yanagimoto, D., 2004. Deep and bottom currents in the Challenger Deep, Mariana Trench, measured with super-deep current meters. J. Oceanogr. Vol. 60. Pages 919–926.

Vanderlaan, A. S., and Taggart, C. T. 2007. Vessel collisions with whales: the probability of lethal injury based on vessel speed. Marine mammal science, 23(1), 144-156.

Wagner, D., D.G. Luck, and R.J. Toonen. 2012. The biology and ecology of black corals (Cnidaria: Anthozoa: Hexacorallia: Antipatharia). In Advances in marine biology, Vol. 63, pp. 67-132. Academic Press.

Western Pacific Regional Fishery Management Council. 2009a. Fishery Ecosystem Plan for Pacific Pelagic Fisheries of the Western Pacific Region. Western Pacific Regional Fishery Management Council, Honolulu, HI. 251 pp.

Western Pacific Regional Fishery Management Council. 2009b. Fishery Ecosystem Plan for the Mariana Archipelago. Western Pacific Regional Fishery Management Council, Honolulu, HI. 251 pp.

Wolff, T., 1970. The concept of the hadal or ultra-abyssal fauna. Deep-Sea Res 17(6): 983–1003.

Yancey, P.H., Gerringera, M.E., Drazen, J.C., Rowdenc, A.A., and Jamieson, A. (2014). Marine fish may be biochemically constrained from inhabiting the deepest ocean depths. Proc. Nat. Aca. Sci., 111: 4461–4465.

Young, C.N., Carlson, J., Hutchinson, M., Hutt, C., Kobayashi, D., McCandless, C.T., Wraith, J. 2016. Status review report: oceanic whitetip shark (Carcharhinius longimanus). Final Report to the National Marine Fisheries Service, Office of Protected Resources. November 2016. 162 pp.

5-6 JGA South Cable Landing in MTMNM EA Chapter 6

6 PREPARERS

A. This EA was prepared by the following entities:

Dueñas, Camacho & Associates, Inc. Claudine Camacho, Biologist Devin Keogh, Biologist William Concepcion, Geographic Information System Manager/Planner

B. Information in this EA was contributed by the following entities:

RTI Solutions, Inc. Chris Brungardt, Senior Vice-President, Regulatory Compliance

Alcatel Submarine Networks

6-1 JGA South Cable Landing in MTMNM EA

APPENDIX A. Figures

Figure 1. JGA South Cable Route Figure 2. Site Location Map for the Marianas Trench Marine National Monument Units and the JGA South Cable Figure 3a. Okeanos Expedition 1605 Legs 1 and 3 Dive Sites Figure 3b. Detail View of Okeanos Expedition 1605 Legs 1 and 3 Dives 1, 2, 4, 5 and 7 Figure 4. Site Location Map and Approximate Locations of Existing Cables Figure 5. Bathymetric Survey Data from the 2018 Survey – Contours Figure 6. Bathymetric Survey Data from the 2018 Survey – Backscatter Figure 7. Individual Sightings of the Marine Mammals and Reptiles within the Marianas Trench Marine National Monument

JGA South Cable Landing in MTMNM EA

APPENDIX B. Compatibility Determination

Compatibility Determination

Right of Way (landing, operating and maintaining a submarine telecommunications cable), Mariana Trench National Wildlife Refuge

Use: Rights-of-way (utility). The right to use and possibly alter the landscape through installation, maintenance, and operation of submarine telecommunications cable on lands under control by the U.S. Fish and Wildlife Service (Service).

Refuge Name: Mariana Trench National Wildlife Refuge

City/County and State: U.S. Minor Outlying Islands (Guam, Commonwealth of the Northern Mariana Islands)

Establishing and Acquisition Authorities:

Presidential Proclamation 8335 (6 Jan 2009) established the Marianas Trench Marine National Monument in an area of 95,216 sq. miles, under the authority of the Antiquities Act of 1906. The Secretary of the Interior has management responsibility, except that the Secretary of Commerce has primary responsibility for the fishery related activities. Secretary‘s Order 3284 (16 Jan 2009) directed that the Director of the Fish and Wildlife Service to manage the Trench Unit (Mariana Trench NWR) as a unit of the National Wildlife Refuge System.

Refuge Purpose(s):

―... for the development, advancement, management, conservation, and protection of fish and wildlife resources ...‖ 16 U.S.C. § 742f(a)(4) ―... for the benefit of the United States Fish and Wildlife Service, in performing its activities and services. Such acceptance may be subject to the terms of any restrictive or affirmative covenant, or condition of servitude ...‖ 16 U.S.C. § 742f(b)(1) (Fish and Wildlife Act of 1956). ―... conservation, management, and ... restoration of the fish, wildlife, and plant resources and their habitats ... for the benefit of present and future generations of Americans...‖ 16 U.S.C. § 668dd(a)(2) (National Wildlife Refuge System Administration Act) ―... suitable for— (1) incidental fish and wildlife-oriented recreational development, (2) the protection of natural resources, (3) the conservation of endangered species or threatened species ...‖ 16 U.S.C. § 460k-1 ―... the Secretary ... may accept and use ... real ... property. Such acceptance may be accomplished under the terms and conditions of restrictive covenants imposed by donors ...‖16 U.S.C. § 460k-2 (Refuge Recreation Act (16 U.S.C. § 460k-460k-4), as amended).

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National Wildlife Refuge System Mission:

"The mission of the [National Wildlife Refuge] System is to administer a national network of lands and waters for the conservation, management, and where appropriate, restoration of the fish, Wildlife, and plant resources and their habitats within the United States for the benefit of present and future generations of Americans" (National Wildlife Refuge System Administration Act of 1966, as amended [16 U.S.C. 668dd-668ee]).

Description of Use:

The use is issuance of a Right-of-Way Permit, defined as the ―right to use and possibly alter the landscape through construction, maintenance, and operation of… powerline, telecommunications line …‖ on lands under control by the U.S. Fish and Wildlife Service (Service.) The Secretary of the Interior, through his/her authorized representative, the Regional Director, United States Fish and Wildlife Service (Service), in accordance with applicable authorities, and regulations published in 50 CFR 29.21 et. seq., will grant a Right-of- Way Permit to RTI Solutions, Inc., herein referred to as the Permittee. The permit will grant the Permittee the right to use certain submerged lands within the Mariana Trench National Wildlife Refuge (Refuge) for up to 50 years solely for the purpose of landing, operating, and maintaining a submarine telecommunications cable. The permit includes those activities required to install and maintain a telecommunications cable on submerged Refuge lands, including, but not limited to, cable installation (laying), pre- and post-lay surveys, cable operations, and maintenance and repairs.

NEPA compliance for the landing, operation, and maintenance of the telecommunications cable is covered under the Environmental Assessment (EA) for the Japan-Guam-Australia (JGA) South Telecommunications Cable Landing within the Marianas Trench Marine National Monument (USFWS 2019). A Right-of-Way Permit will be issued by USFWS to RTI Solutions to allow the landing of the Japan-Guam-Australia (JGA) South fiber-optic communications submarine cable through a portion of the MTMNM. This will complete the Japan-Guam- Australia cable system. This cable will provide approximately 36 Tbps of data capacity (approximately 4,500 gigabytes per second). The JGA cable system will enhance and contribute to the expansion of communications networks from Japan and Australia, to Asia and the United States, thereby improving network redundancy, ensuring highly reliable communications, and expanding onward connectivity options in Guam.

The cable route will cross over the Mariana Trench and through the MTMNM for a total linear distance of approximately 83.5 miles (134 km). The cable route is the shortest feasible route across the MTMNM.

The cable will be laid flush on the seafloor by a cable-laying ship. Along the proposed cable route, slopes range from 6º to 24º (10.5% to 44.5%), and water depths range from 5,600 to 10,030 m, covering both abyssal (4,000 to 6,000 m) and hadal zones (6,000 to 11,000 m). (EA, Appendix A, Figure 5).

Subsea Fiber-Optic Cable. The cable will comprise two types of armored cable within the

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MTMNM: Lightweight Protected (LWP) and Lightweight (LW) cable types. The LWP cable type is 2.4 centimeters (cm) in diameter (0.94 inch (in)), while the LW cable type is 1.7 cm in diameter (0.67 in). The LWP cable type is needed to ensure the cable is sufficiently protected in the deeper portions of the Mariana Trench. Water depths along the cable route within abyssal (4,000 to 6,000 m) and hadal (6,000 to 11,000 m) zones, based on a non-intrusive bathymetric survey in 2018 (EGS Survey Group, 2018). The total cable footprint within the MTMNM is approximately 0.7 acres (30,768.53 square feet (sq. ft)), with a total linear distance of 83.48 mi (72.54 nautical miles (NM) or 134.34 km).

Cable Installation. The fiber-optic cable will be laid directly on the seabed. The cable laying ship will proceed at approximately 3.7 kilometers per hour (2 knots). Slack will be continuously applied at various rates throughout the installation to allow the cable to conform to the contour of the seabed as much as feasible.

Cable Operations and Maintenance. There is no routine monitoring or maintenance associated with the submerged segments of the cable. However, it is possible that emergency repair activities could occur. The typical triggers for emergency repair are such things as ship anchors being dragged across the cable route during active anchoring, fishing gear entanglement during active fishing (neither of which would be a concern in the MTMNM due to the great depths), and equipment failure. The Right-of-Way permit will include conditions governing the ability to continue to conduct scientific research using ROVs in proximity to the cable. ROVs are generally not permitted to operate near known sea floor cables. However, the applicant, RTI, has agreed to conditions in the right-of-way permit that allow the operation of ROVs in proximity of the cable.

Emergency Repair. If the cable needs to be repaired in the MTMNM, it would need to be recovered to the cable ship for repair. Because of the depth of the cable, the operation would take place in several steps. First a flatfish grapnel fitted with a cutting blade would be pulled until it snags and cuts the cable. Then a Gifford grapnel would be used to retrieve one end of the cable to the cable ship. After the cable is recovered, the end would be prepared and the fibers tested using a conventional optical time-domain reflectometer (OTDR). After conducting the necessary tests onboard the cable ship, this end of the cable would be sealed and buoyed off for easy recovery later.

Next, the other cable end would be recovered and similarly tested to locate the fault more precisely. The cable ship would retrieve this end of cable until the fault is aboard. After the fault site (either a cable or repeater section) is removed from the system, the repaired cable would be joined to the fault-free cable end and paid out as the vessel returns to the buoyed end. When the buoy is recovered aboard the ship, the two cable ends would be joined. After final testing, the cable would then be paid out through the stern of the ship to settle on the ocean floor.

Retirement, Abandonment, or Removal of the Cable Systems. The project would have a life of approximately 25 years. After a cable is decommissioned, it is typically abandoned in place. Abandonment in place would cause fewer environmental impacts than recovering the cable from the seafloor.

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Availability of Resources In general, the Refuge will incur no expense except administrative costs for review of applications, issuance of a ROW Permit, and staff time to conduct a literature review and complete a finding of appropriateness (FOA) and compatibility determination (CD).

Administrative Costs Review request, coordination, and process ROW Permit: 4 staff: 58 hours: $2,227.70 Conduct literature review, process FOA and CD: 1 staff: 20 hours: $1,136.60 Total $3,364.30 RTI Solutions Inc. will oversee the landing of the submarine cable and will be responsible for maintenance of the cable (EA, Appendix A, Figure 1).

Anticipated Impacts of the Use(s):

Impacts to wildlife and habitat: Impacts of laying and maintaining the submarine cable were analyzed in the Environmental Assessment for the Japan-Guam-Australia (JGA) South Telecommunications Cable Landing within the Marianas Trench Marine National Monument (USFWS 2019). The location of the proposed right of way was surveyed to ensure safety and to minimize impacts to habitat. Cables in deep water environments are generally laid on the surface of the ocean floor, as is being proposed for the JGA South Cable. Environmental impacts associated with submarine cables can generally be attributed to either installation, maintenance and repair work, and removal; or the operational phase.

The Refuge consists only of submerged lands. The National Marine Fisheries Service oversees activities that have the potential to affect fish and marine mammals living in the waters above the refuge. Therefore, only effects to the benthic environment are analyzed here. Effects to fish (other than benthic species) and marine mammals from multibeam sonar used during cable route surveys, noise associated with the vessel and any laying machinery, visual disturbance from the vessel, and potential collisions between the vessel and marine mammals, are not analyzed. Candidate actions potentially responsible for interactions with the benthic environment include laying down the cable on the seafloor, short and long-term interactions of the cable and its environment, and cable retrieval in the event of a fault or at the end of the cable‘s lifespan.

When placed in waters more than 2,000 meters in depth, cables are generally not buried. They are simply laid across the ocean floor. This is because, at such depths, cables are significantly less susceptible to potentially harmful interactions with living marine resources. The degree of benthic disturbance caused by laying submarine cables depends on the habitat and its associated ecosystem. Although the underlying geology of the proposed cable route has not been extensively studied or surveyed, studies carried out by researchers Heather Stewart and Alan Jamieson within hadal and abyssal areas near the proposed cable route classified basic geologic structure by depth zone. Within the water depth range of 4,506 m to 5,641 m, the dominant seabed sediment observed comprised muddy gravel, with one observation each of bedrock, bedrock and fine-grained sediment, and gravelly fine-grained sediment across all fifteen sampling stations (Stewart and Jamieson 2017). Within the water depth range of 6,008 to 7,941 m, gravelly fine-grained sediment was the dominating sediment type; fine-grained sediment,

4 bedrock, slightly gravelly fine-grained sediment, and muddy gravel were also observed within this depth range (Stewart and Jamieson 2017). Within the final and deepest water depth range of 8,000 and 10,890 m, the researchers observed fine-grained sediment, slightly gravelly fine- grained sediment, gravelly fine-grained sediment, bedrock, and bedrock with gravelly mud (Stewart and Jamieson 2017). There are no deep sea corals or sponge communities mapped along the cable route. The closest mapped deep sea coral or sponge community in the MTMNM is located approximately 58 km to the south-southwest of the cable route.

Laying submarine cable, though a relatively short-lived activity, can be disruptive to the area and ecosystem in which it is carried out. Disturbance of bottom sediments and suspension of sediment in the water column would be expected, but would be localized and temporary. Disturbance and mortality of benthic organisms may occur but the effect would be minor, given the small footprint of the cable.

A collaborative study conducted by the Monterey Bay Aquarium Research Institute (MBARI) and the National Oceanic and Atmospheric Administration division of Oceanographic and Atmospheric Research (NOAA-OAR) investigated the potential interactive effects between a fiber-optic submarine cable and its environment (Kogan et al. 2006). Results from this study indicated that the cable had few detectable effects on marine life. Although this was generally the case, in areas with soft sediments, the cable provided an artificial solid substrate that a number of different species sought out. This is known as the ‗reef-effect‘ and results in species inhabiting an area that they typically would not (OSPAR 2009). The ‗reef-effect‘ has been studied extensively and has been found in many cases to lead to the introduction of non-local biota and the alteration of the natural benthic community. The introduction on non-local biota is highly unlikely given the depth of the cable. Localized changes in the benthic community are possible, but would likely be temporary as the cable becomes buried in the sediments over time (Kerchhof et al. 2007, Tyrell and Byers 2007, OSPAR 2009).

Fiber-optic cables primarily transmit light; however, they also use a small amount of electricity to power the repeaters and boost the telecommunications signal, and therefore transmit small amounts of electromagnetic radiation and heat to the surrounding environment. During normal operation, the cable is powered by direct current (DC). DC currents produce the same type of magnetic field as the earth. The magnetic field generated by the cable is hundreds of times smaller than the Earth‘s magnetic field and thus would not be detectible or distinguishable against the Earth‘s field. A small amount of electromagnetic radiation may be produced by submarine fiber-optic cables during the rare events when the cable suffers an outage and AC electroding is used to find faulted cables. These would be exceedingly rare, short-term events and would generate very low levels of radiation comparable to background levels naturally produced by the earth. Therefore, it is expected that the weak magnetic fields produced by the JGA South cable would have a negligible potential effect on marine organisms. Likewise, while the two repeaters located within the trench will produce small amounts of heat, the low heat output the large quantity of water surrounding the repeaters, and movement of water due to currents and tides will likely result in negligible environmental effects.

The submarine cable system is designed and manufactured to be electrically isolated from the environment and in the event of an incident resulting in an insulation cable fault, the cable will

5 be automatically grounded to zero as it comes into contact with water. Consequently, there will likely be negligible effects resulting from electricity associated with the cable.

Once in place—if correctly laid—submarine cables have thus far not been shown to have a significant adverse effect on the surrounding marine environment since they are generally immobile once placed and coated with a layer of polyethylene, which is inert in seawater. Leaching from cables and their repeaters and is believed to pose very little risk to the surrounding environment –especially in extremely deep environments (Collins 2007; Andrady 2000). Chemical breakdown processes, such as oxidation, hydrolysis, and mineralization, are extremely slow – largely as a result of low UV penetration at those depths. In a study conducted by Andrady (2000), it was predicted that total conversion of cable-grade polyethylene to carbon dioxide and water would take centuries.

After the cable is laid, RTI Solutions Inc. would be expected to enter the ROW to conduct repairs and/or upgrades to the telecommunications cable. All use, maintenance, and upgrades would occur within the ROW. Impacts to habitat and wildlife caused by RTI Solutions Inc.‘s use of the ROW are expected to be short term and minor.

Impacts to the Public:

The existing regulated uses within the Mariana Trench NWR would continue after the laying of the cable. These include research and exploration of the Mariana Trench with the proper federal permits, and commercial fishing in compliance with federal regulations.

SUMMARY: The issuance of the ROW Permit to install, operate and maintain the telecommunications cable would result in minor, short term negative impacts to the benthic habitat and marine life, and no impacts to the public.

Public Review and Comment: The following methods were used to solicit public review and comment: This compatibility determination was prepared concurrently with an Environmental Assessment (EA), which addressed environmental effects associated with the proposed ROW for the subject submarine telecommunications cable. The EA and Compatibility Determination were available for public review and comment for a period of 30 days, from June 12 to July 12, 2019. The public was be notified of the opportunity to review and comment on the CD and EA through media releases, and posting of the EA and CD on the Refuge‘s webpage. The EA and CD were available at the Guam National Wildlife Refuge Headquarters in Dededo, Guam, and the Pacific Island Refuges and Monuments Office in Honolulu, Hawaii. The Permittee conducted extensive outreach through correspondence with Ms. Catherine Creese, Assistant Director of the U.S. Naval Seafloor Cable Protection Office (NSCPO).

Determinations: (check one below) ___ Use is Not Compatible _X_Use is Compatible with the Following Stipulations:

Stipulations Necessary to Ensure Compatibility:

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To ensure compatibility with the National Wildlife Refuge System and the refuge goals and objectives, installation and maintenance of the aforementioned submarine fiber optic cable can only occur under the following conditions:

(1) The Service reserves the right to authorize other activities, including research involving remote operated vehicles (ROVs), in the vicinity of the cable. Before permitting activities within 500 meters of the final as-built location of the cable, the Service will consult with RTI Solutions, Inc. to establish protocols for communications and operations to minimize the potential for impacts to the cable. RTI Solutions, Inc. will ensure that the final coordinates identifying the location of the cable are fully communicated and has agreed to conditions in the right-of-way permit that allow the operation of ROVs in proximity of the cable.

(2) The Applicant will produce and share the ―as built‖ legal description describing the accurate location of the cable to the Service, within 180 days after it has been laid on the seafloor.

(3) To minimize the risk of introducing contaminants into the marine environment, all instruments and equipment (including small boats) should be checked prior to deployment to ensure that there are no contaminant leaks (oil, fuel, hydraulic fluid, etc.) which could affect marine resources in the project area. If any instruments or equipment is found to not be in good working order, it should be removed from service until all necessary repairs have been made which would prevent a release of contaminants. Also, the crew of the vessel used to lay the cable should try to minimize the amount of detergents and other noxious substances that might be washed overboard as part of an effort to clean instruments or equipment used during the cruise or in day-to-day operation of the vessel.

(4) To prevent the spread of disease or invasive species, all equipment used in the cable laying operation should be rinsed with fresh water when practical.

(5) Birds at sea have the potential to be attracted to or confused by lights on the vessel. At night the ship shall use the minimum amount of light necessary for legal and safe transit when underway. Through coordination with the USFWS, the cable ship operators will be briefed on the potential for bird encounters and will follow these protocols: a. The operators will pick up any downed birds and place them in a clean box to prevent soiling of their feathers. b. The birds will be kept in a cool, safe place until daylight. c. The birds will then be placed in an open area near the stern of the cable ship where they can take off when ready. d. Photographs of any downed birds will be taken to document distribution of species at sea and the USFWS will be notified and provided with these photographs.

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(6) The Applicant shall notify the Refuge Manager or his/her designee a minimum of 2 weeks prior to commencing with installation of the submarine cable to avoid conflicts with Refuge programs.

(7) Any operations to conduct emergency repairs or maintenance of the cable must be coordinated with the Refuge Manager prior to scheduling said repair or maintenance.

(8) The Applicant shall notify the Refuge Manager 30 day prior to the cable decommission date.  Consistent with regulations at 50 CFR 25.21 (h), the Service reserves the right to modify terms and conditions of the ROW permit in the future, as necessary to ensure the continued compatibility with the use and occupancy of the land.

Justification:

It is anticipated that wildlife populations will find sufficient food resources and resting places such that their abundance and use of the Refuge will not be measurably lessened during the submarine cable installation, operation and maintenance activities facilitated by the proposed use. The relatively limited number of wildlife individuals expected to be adversely affected during the operation and maintenance of the submarine cable will not cause wildlife populations to materially decline, the physiological condition and production of wildlife species present will not be impaired, alterations to the behavior and normal activity patterns will be minor or nonexistent, and their overall welfare will not be negatively impacted.

The right of way as described is determined to be compatible because potential impacts from the\ permittee‘s use of this right of way on wildlife that use this Refuge unit would be minimal and not materially interfere with or detract from achievement of the NWRS mission or from the Service‘s ability to achieve Refuge wildlife, habitat, or other public-use-related purposes and goals.

Mandatory 10- or 15- Year Re-evaluation Date: (provide month and year for ―allowed‖ uses only)

______Mandatory 15-year reevaluation date (for wildlife-dependent public used __NA__ Mandatory 10-year reevaluation date (for all uses other than wildlife-dependent public uses)

NEPA Compliance for Refuge Use Decision: (check one below)

___Categorical Exclusion without Environmental Action Statement ___Categorical Exclusion and Environmental Action Statement _X Environmental Assessment and Finding of No Significant Impact ___Environmental Impact Statement and Record of Decision

References:

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Andrady, A.L., 2000. Plastics and their impacts in the marine environment. Proceedings International Marine Debris Conference on Derelict Fishing Gear and the Marine Environment, Hawaii, August.

Collins, K., 2007. Isle of Man cable study – Preliminary material environmental impact studies. Preliminary report, University of Southampton.

Kerchhof, F., B. Rumes, T. Jaques, S. Degraer, and A. Norro. 2010. Early development of the subtidal marine biofouling on a concrete offshore windmill foundation on the Thornton Bank (southern North Sea): first monitoring results. Underwater Technology 29: 137-149.

Kogan, I., C. Paull, L. Kuhnz, E. Burton, S. Von Thun, H. G. Greene, J. Barry. 2006. ATOC/Pioneer Seamount cable after 8 years on the seafloor: Observations, environmental impact. Continental Shelf Research 26: 771-787.

NOAA. 2017. Submarine cables: domestic regulation. URL: https://www.gc.noaa.gov/gcil_submarine_cables_domestic.html Accessed September 21, 2018.

OSPAR. 2008. Background Document on potential problems associated with power cables other than those for oil and gas activities. – Publication Number: 370/2008, 50 pp.

Stewart, H. and A. Jamieson. 2017. Habitat Heterogeneity of Hadal Trenches: Considerations And Implications For Future Studies. Progress in Oceanography. 161: 47-65.

Tyrell, M. C. and J. E. Byers. 2007. Do artificial substrates favour non indigenous fouling species over native species? Journal of Experimental Marine Biology and Ecology. 342: 54-60.

USFWS. 2019. Environmental Assessment (EA) for the Japan-Guam-Australia (JGA) South Telecommunications Cable Landing within the Marianas Trench Marine National Monument.

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Compatibility Determination for Right of Way (landing, operating and maintaining a submarine telecommunications cable), Mariana Trench National Wildlife Refuge. Use is compatible with stipulations.

Refuge Manager/ Project Leader Approval:______(Signature) (Date)

Concurrence

Regional Chief, National Wildlife Refuge System: ______(Signature) (Date)

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JGA South Cable Landing in MTMNM EA

APPENDIX C. JGA South Submarine Fiber Optic Cable System Cable Routing Mariana Trench (ASN 2019)

JGA SOUTH

Submarine Fibre Optic Cable System Cable Routing Mariana Trench

ISSUE DATE DOC. REF.

02 23-May-2019 INST. 13414

AUTHORISATION

Signatory Name Date

Originator M Boyce 23-May-2019

Survey and Engineering Manager M Jonkergouw 23-May-2019

Project Marine Manager A Poulain 23-May-2019

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Telegraph House, 10 Telcon Way, Greenwich, London, SE10 0AG, United Kingdom

Registered in England No. 1750343

ALCATEL SUBMARINE NETWORKS JGA SOUTH – MARIANA TRENCH

Contact Details:

Name: Max Boyce

ALCATEL SUBMARINE NETWORKS UK LTD, Telegraph House, 10 Telcon Way, Address: Greenwich, London, SE10 0AG, United Kingdom

Telephone: +44 (0)208 465 1719

Email: [email protected]

DOCUMENT CONTROL SHEET

Issue No. Date Description Created By Checked By Approved By

1 26-March-19 Initial Issue MB MB AP

2 23-May-19 Final Issue MB MB AP

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ALCATEL SUBMARINE NETWORKS JGA SOUTH – MARIANA TRENCH

1 INTRODUCTION ...... 4 2 GENERAL ROUTING GUIDELINES ...... 4

3.1 BATHYMETRY ...... 4 3.2 SLOPES AND ROUTING ...... 5 3.3 ALTER COURSES (ACS) ...... 6 3.4 CROSSINGS AND PARALLEL CABLES ...... 6 3.5 REPEATERS ...... 7

3 JGA SOUTH & MARIANA TRENCH ...... 7

3.1 CABLE ROUTE ESTIMATE (CRE) ...... 8 3.2 CABLE ROUTE STUDY (CRS) ...... 8 3.3 POST SURVEY ROUTE (PSR) ...... 9

4 CONCLUSION ...... 11 5 BIBLIOGRAPHY ...... 11

FIGURES

FIGURE 1 ENGINEERED ROUTE TO AVOID SEABED FEATURES ...... 5 FIGURE 2 SEABED PROFILES BEFORE AND AFTER ENGINEERING ...... 6 FIGURE 3 CRE ROUTE THROUGH MARIANA TRENCH...... 8 FIGURE 4 CRS ROUTE THROUGH MARIANA TRENCH...... 9 FIGURE 5 PSR ROUTE THROUGH MARIANA TRENCH ...... 10 FIGURE 6 PSR ROUTE THROUGH MARIANA TRENCH (WITH SURVEY DATA) ...... 10

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ALCATEL SUBMARINE NETWORKS JGA SOUTH – MARIANA TRENCH

1 INTRODUCTION

The JGA Consortium have commissioned Alcatel Submarine Networks (ASN) to define a Cable Route for the JGA South Cable System. The system has been designed to connect Guam to Sydney Australia). This document has been prepared to assist the NEPA process to appreciate the constraints when planning cable routes for Submarine Cable Systems. The document addresses most of the scenarios a cable route may encounter when linking two or more destinations by sea. Other technology alternatives for linking two destinations are satellite or terrestrial based communications systems. However, neither of these viable due to several factors, transmission speeds, security, weather, and ease of maintenance. As such submarine cable systems are the preferred method for modern data communications. To link two destinations using the oceans, the most direct route is taken. However, a multitude of constraints must be taken in to consideration. Rarely in the submarine cable industry are there alternative submarine routes between two destinations, the final route is actually defined by geological, geophysical, other seabed user’s infrastructure, and other third- party activities.

2 GENERAL ROUTING GUIDELINES

Cable Route Engineering is performed to ensure that the installed cable is best able to withstand the rigours of the marine environment for the design life of the system. To achieve this a series of different aspects, are to be considered.

2.1 Bathymetry

Bathymetry is the depth information and is displayed as depth contours and slope gradients of the seabed to assist with the route decision making progress. The Engineer will select the most benign route possible for the cable whilst also accounting for the additional factors such as existing infrastructure. Other restrictions such as cable crossings and Ammunition Dumps that may prevent this from being possible. These are dealt with on a case by case basis with the final route selection optimised taking account all routing constraints. In deep water such as the Mariana Trench bathymetry is the only survey data acquired on site as the cable will be surface laid directly on the seabed negating the requirement for full geophysical survey. The image below shows an engineered route modified away from the survey centreline to avoid significant slopes.

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ALCATEL SUBMARINE NETWORKS JGA SOUTH – MARIANA TRENCH

Figure 1 Engineered route to avoid seabed features (ASN REH, 2019)

2.2 Slopes and Routing

In all water depths, the cable will be routed with the lowest slope angles possible, by changing the route. Where steep seabed slopes are unavoidable, the route will be planned so that it runs as close to perpendicular up/down the slope. This minimises cable damage from risk of suspensions, abrasion and sediment slumps.

Seabed depressions, ridges, canyons, seamounts are also avoided, wherever possible. The figure below shows an example of a seabed profile before and after the Route Engineering has taken place. The most significant slopes have been removed post engineering.

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Before Engineering. Note Steep Slopes

After Engineering. Slopes minimal

Figure 2 Seabed Profiles Before and after Engineering (ASN REH, 2019)

Despite these guidelines it is not always possible to avoid areas of steep slopes. In such situations, the route engineer uses judgement and expertise to minimise the risk to the cable by selecting the most benign route possible and maintain wherever possible as close to perpendicular to steep contours.

2.3 Alter Courses (ACs)

Alter Courses are placed along the route as waypoints as the route develops based on information collated during the Cable Route Study and data acquired during the Cable Route Survey. To enable a realistic route ACs should be kept to below 30-degree course alteration. ACs are limited by water depth and should be separated by twice the water depth at the AC location. This stipulation is to ensure that the cable touches down on the seabed at the planned location before the AC is initiated by the installation vessel. This can create a challenge for route engineers as when water depths increase so does the separation of ACs. This can greatly impact the flexibility of the route in deep waters. For example the Mariana Trench is a very deep part of the world’s oceans reaching depths greater than 10000m. In these water depths it is only possible to alter the cable course by a maximum of 30ᵒ every 20 km.

2.4 Crossings and Parallel Cables

With the ever-increasing number of Submarine Cables and other seabed infrastructure, inevitably there will be a requirement to cross or route close to existing cables. The International Cable Protection Committee

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(ICPC) provides recommendations for routing in the proximity and crossing In Service Cables (ICPC Recommendations No2 & No3). The recommendations are applied wherever possible and are designed to enable future maintenance of cable systems should they sustain a fault or damage. Briefly the ICPC recommends that cables are crossed as close to 90ᵒ as possible and not less than 45ᵒ. Parallel cables should be separated preferably by 3 x Water Depth on either side. This can be reduced to 2 x Water Depth if 3 times water depth remains on the opposite side. This is not always possible in congested areas and compliance should be achieved at the earliest opportunity.

2.5 Repeaters

Wet plant such as repeaters are an intrinsic part of a cable system and form part of an as laid cable system. The distance they are separated varies with the system design and capacity. Third party repeater positions are to be considered when planning a new system to ensure they are not ‘trapped’ by a newly installed cable. To ensure this any cable crossings should be planned to a minimum of 3 x Water Depth which enables recovery of a repeater should a fault occur. This can be reduced to 2 x Water Depth if 3 x Water Depth is present on the opposite side.

3 JGA SOUTH & MARIANA TRENCH

The JGA South Route selection has followed ASN Industry standards. The route evolves as information is gathered. Prior to installation there are three distinct phases that develop the route. Firstly, the bid stage which has a less defined route as a starting point to connect the two destinations. Following this a Cable Route Study is commissioned. The Cable Route Study collates all available information that may impact the route. The route is developed accordingly and on completion of the Cable Route Study the route is considered ready for Survey. The Cable Route Study route then becomes the base line for the Cable Route Survey acting as the centreline and using Multibeam Echo Sounders (MBES) to acquire data. Post Survey the route is again ‘fine-tuned’ to select the most practical route within the surveyed corridor. Should the survey bathymetry shows evidence that the selected route could be improved if the cable was to be routed outside the survey corridor then additional survey data is acquired to see if this is viable and if so the route is developed accordingly. A typical Deep Water Survey Corridor is a minimum of 3 x Water depth up to 10km wide.

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Cable Route Estimate (CRE)

The Cable Route Estimate is the base route used for initial costing of the system. Whilst quite comprehensive critical detail that is obtained after contract award is not present. The CRE route is considered basic and is anticipated to be developed as information is gathered. The image below shows the CRE route for JGA South through the Mariana Trench.

Figure 3 CRE Route through Mariana Trench (Google Earth, 2019)

3.1 Cable Route Study (CRS)

The Cable Route Study develops the route further for survey and considers third party cables and wet plant and other offshore hazards. The image below shows the Cable Route Study route that differs from the CRE route after these adjustments. This is the route that became the baseline for the survey. The CRS route shown in yellow has been deconflicted with existing cables and complies with ICPC recommendations wherever possible with good separation from existing repeaters and crossing angles between 45ᵒ and 90ᵒ whilst still avoiding wherever possible any seabed features.

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REPEATERS AMMO DUMP

Figure 4 CRS Route through Mariana Trench (Google Earth, 2019)

3.2 Post Survey Route (PSR)

The post survey route is a more detailed route of the CRS route. The route is developed further based on actual survey data acquired by the survey vessel and is the most detailed route prior to installation. Repeaters are added in accordance with system design and positioned to avoid conflict with existing cables. This route is regarded by ASN as the most optimised route possible for both economic viability and cable integrity.

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REPEATERS

AMMO DUMP

REPEATERS

Figure 5 PSR Route through Mariana Trench (Google Earth, 2019)

Figure 6 PSR Route through Mariana Trench (with Survey Data)

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4 CONCLUSION

It is ASN viewpoint that the current cable route for JGA South S2A has been optimised with due diligence with respect to ICPC recommendations and Industry Routing Guidelines.

5 BIBLIOGRAPHY

ASN REH. (2019). ASN ROUTE ENGINEERING GUIDELINES.

Google Earth. (2019). Google.

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JGA South Cable Landing in MTMNM EA

APPENDIX D. Summary of EFH and HACP Designations

JGA South Cable Landing in MTMNM EA

Table 1. Essential Fish Habitat and Habitat Areas of Particular Concern for the Mariana Archipelago Applicable to Guam

Management Species Complex EFH HAPC Unit Shallow-water species (0-50 fm): uku (Aprion Eggs and larvae: the water column All slopes and viriscens), thicklip trevally (Pseudocarancx extending from the shoreline to the escarpments dentex), lunartail grouper (Variola louti), blacktip outer limit of the EEZ down to a depth between 40-280 m grouper (Epinephelus fasciatus), ambon emperor of 400 m (200 fm) (20 and 140 fm) (Lethrinus amboinensis), redgill emperor (Lethrinus rubrioperculatus), giant trevally Juvenile/Adult: the water column and (Caranx ignoblis), black trevally (Caranx all bottom habitat extending from the lugubris), amberjack (Seriola dumerili), taape shoreline to a depth of 400 m (200 fm) (Lutjanus kamsira) Deep-water species (50-200 fm): ehu (Etilis Eggs and larvae: the water column All slopes and carbunculus) onaga (Etelis coruscans), extending from the shoreline to the escarpments opakapaka (Pristipomoides filamentosus), outer limit of the EEZ down to a depth between 40-280 m Bottomfish and yellowtail kalekale (P. auricilla), yelloweye of 400 m (200 fm) (20 and 140 fm) Seamount opakapaka (P. flavipinnis), kalekale (P. sieboldii), Groundfish gindai (P. zonatus), hapuupuu (Epinephelus Juvenile/Adult: the water column and quernus), lehi (Aphareus rutilans) all bottom habitat extending from the shoreline to a depth of 400 m (200 fm) Seamount groundfish species (50-200 fm): Eggs and larvae: the (epipelagic No HAPC designated amorhead (Pseudopentaceros richardsoni), zone) water column down to a depth of for seamount ratfish/butterfish (Hyperglyphe japonica), alfonsi 200 m (100 fm) of all EEZ waters groundfish (Beryx splendens) bounded by latitude 29⁰ - 35⁰ N

Juvenile/adults: all EEZ waters and bottom habitat bounded by latitude 29⁰ - 35⁰ N and longitude 171⁰ E - 179⁰ W between 200 and 600 m (100 and 300 fm)

JGA South Cable Landing in MTMNM EA

Management Species Complex EFH HAPC Unit Spiny and slipper lobster: Spiny lobster (P. Eggs and larvae: the water column All banks with penicillatus, P. spp.), ridgeback slipper lobster from the shoreline to the outer limit of summits less than or (Scyllarides haanii), Chinese slipper lobster the EEZ down to a depth of 150 m equal to 30 m (15 fm) (Parribacus antarcticus) from the surface

Kona crab: Kona crab (Ranina ranina) Juvenile/adults: all of the bottom habitat from the shoreline to a depth of Crustaceans 100 m Deepwater shrimp (Heterocarpus spp.) Eggs and larvae: the water column No HAPC designated and associated outer reef slopes for deepwater shrimp between 550 and 700 m

Juvenile/adults: the outer reef slopes at depths between 300 and 700 m

Precious Corals Deep-water precious corals (150-750 fm) No EFH for precious corals on Guam. No HAPC for precious corals on Guam Shallow-water precious corals (10-50 fm) Coral Reef All Currently Harvested Coral Reef Taxa EFH for CRE-MUS includes the water Cocos Lagoon, Orote Ecosystems (CHCRT) column and all benthic substrate to a Point Ecological (CRE) depth of 100 m from the shoreline to Reserve Area, Haputo All Potentially Harvested Coral Reef Taxa the outer limit of the EEZ. Point Ecological (PHCRT) Reserve Area, Ritidian Point, and Jade Shoals Pelagic Temperate species: striped marlin (Tetrapurus Eggs and larvae: the (epipelagic The water column audax), bluefin tuna (Thunnus thynnus), zone) water column down to a depth of from the surface down swordfish (Xiphias gladius), albacore (Thunnus 200 m (100 fm) from the shoreline to to a depth of 1,000 m alalonga), mackerel (Scomber spp.) bigeye the outer limit of the EEZ. (500 fm) above all (Thunnus obesus), pomfret (family Bramidae). seamounts and banks Tropical species: yellowfin (Thunnus Juvenile/adults: the water column with summits albacares), kawakawa (Euthynnnus affinis), down to a depth of 1,000 m (500 fm) shallower than 2,000 skipjack (Kastuwonus pelamis), frigate and bullet from the shoreline to the outer limit of m (1,000 fm0 within tunas (Allothunnus fallai), black marlin (Makaira the EEZ

JGA South Cable Landing in MTMNM EA

Management Species Complex EFH HAPC Unit indica), dogtooth tuna (Gymnosarda unicolor), the EEZ spearfish (Tetrapturus spp.), sailfish (Istiophorus platypterus), mahimahi (Coryphaena hippurus, C. equiselas), ono (Acanthocybium solandri), opah (Lampris spp.). Sharks: pelagic thresher shark (Alapias pelagicus), bigeye thresher shark (Alopias), common thresher shark (Alopias vulpinus), silky shark (Carcharhinus falciformis), oceanic whitetip shark (Carcharhinus longimanus), blue shark (Prioace glacuca), shortfin mako shark (Isurus oxyrinchus), longfin mako shark (Isurus paucus), salmon shark (Lamna ditropis); Squid: neon flying squid (Ommastrephes bartamii), diamondback squid (Thysanoteuthis rhombus), purple flying squid (Sthenoteuthis oualaniensis)

JGA South Cable Landing in MTMNM EA

APPENDIX E. Photograph

Photo 1. Typical Cable Repeater

APPENDIX F. Comment Response Matrix.

The U.S. Fish and Wildlife Service provided the public with a 30-day comment and review period for the Japan-Guam-Australia South Telecommunications Cable Landing within the Marianas Trench Marine National Monument Project Draft Environmental Assessment (EA). The public comment period began on June 12, 2019 and concluded on July 12, 2019. A total of three (3) comment letters were received during the public review period. The following Comment Response Matrix provides responses to these public comments.

Where appropriate, comments are paraphrased, or the comment subject line is included. In the remaining instances, sections from comment letters are included in entirety and enclosed in quotation marks. All comment letters can be found in their entirety in Appendix F-2.

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JGA South Cable Landing in MTMNM Draft EA Comments Response Matrix

Relevant Draft # Commenter Comment Summary or Quote USFWS Response EA Section 1-A Dr. Patricia Regarding these [International Cable Protection Chapter 2, Comment noted. Cable deconfliction was a high-priority Fryer, Univ. Committee (ICPC)] criteria it is surprising that Page 2-2 consideration and a major determining factor during cable route Hawai’i at the decision to place the cable through the selection and design. The ICPC is a non-governmental committee Manoa fault-controlled canyon between Guam and the made up of cable companies and other seabed users. Their Mariana Trench axis as shown in the permit protocols and standards assist cable engineers in selecting the request was selected as the least adverse most appropriate cable alignments by considering numerous environment for laying the cable. It appears factors that have the potential to affect the proposed cable, that the primary reason for the choice of cable existing cable systems, and the existing environment and route by Duenas, Camacho & Associates, Inc. biological resources. The ICPC and cable designers put a high was to avoid potential for “confliction with priority on deconfliction with other cable systems in order to existing cables.” However, there are geological ensure successful long-term cable operation and to facilitate ease- reasons why the route chosen does have of-repair if needed. potential for damage to the cable for the following reasons:

1-B Dr. Patricia “1. The cable is to be laid through a well known Chapter 2, Comment noted. The presence of a fault and significant seismicity Fryer, Univ. fault zone (see Figure 1, below) in an area that Page 2-2 are recognized in the EA. Since ICPC protocols and standards were Hawai’i at has had magnitude 6 to 8 earthquakes within used, tectonic activity was a consideration in the cable route Manoa the geologically very recent past (see - design. Therefore, cable route adjustments, if available, would not https://en.wikipedia.org/wiki/List_of_ significantly improve cable conditions. The Applicant accepts the earthquakes_in_Guam). The route chosen risks to the cable system by crossing the trench and any passes directly through a left lateral strike-slip tectonically active or fault-controlled areas. The risks associated fault zone.” with the proposed cable route would not be dissimilar to the routes of other cable systems in the area (e.g., HANTRU-1, a U.S. Government data cable approximately 15 miles east-northeast of the proposed JGA South cable route). These cable systems have a good “no cable fault” history.

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JGA South Cable Landing in MTMNM Draft EA Comments Response Matrix

Relevant Draft # Commenter Comment Summary or Quote USFWS Response EA Section 1-C Dr. Patricia “2. A submersible dive (Shinkai 6500 dive 1093 - Section 2.2 Comment noted. Because this comment addresses potential Fryer, Univ. see location on above map) on the seafloor, Cable Route impacts to the subsea cable, no change to the EA is needed. The Hawai’i at along the fault-controlled canyon that the cable Determination Applicant has acknowledged this possible impact and accepts the Manoa will traverse, permitted observation and potential risks to their cable system. sampling of the eastern wall of the canyon where there were exposed large, sparsely- sedimented pillow lavas, as well as talus debris (landslide deposits). These observations suggest either removal of sediments from the pillow lava via strong current action or relatively recent volcanism as well as landslide activity, which could bury a cable or potentially damage it.”

1-D Dr. Patricia “3. Volcanic activity has been suggested to be Section 2.2 Comment noted. Because this comment addresses potential Fryer, Univ. associated with the western slope of the fault Cable Route impacts to the subsea cable, no change to the EA is needed. The Hawai’i at bounding the west side of Santa Rosa Ban. In Determination Applicant has acknowledged this possible impact and accepts the Manoa 1992 two submersible dives ((Shinkai 6500 dives potential risks to their cable system. 158 &159) near 12°19’N, 144°9’E (starting depth = 5650 m) revealed unsedimented pillow lavas protruding from talus. This locality is only 45 km from the trench axis. Because the sea floor region has still only been examined at a few spots during submersible dives, it is not known how prevalent recent eruptions in the forearc along these fault-controlled canyons may be. The presence of fresh-looking pillow lavas found within 45 km of the trench suggests that pressure-release melting of the forearc mantle (magmagenesis) in response to movement on

3

JGA South Cable Landing in MTMNM Draft EA Comments Response Matrix

Relevant Draft # Commenter Comment Summary or Quote USFWS Response EA Section either of the faults flanking Santa Rosa Banks can result in eruptions within the fault canyons.”

2 Dr. Patricia “In section 4.1 “Hydrology” the second to last Section 4.1 Comment noted. The Final EA has been edited to indicate that Fryer, Univ. sentence of the “Proposed Action and Hydrology deep sea currents flow perpendicular to the cable in the trench. Hawai’i at Alternatives” paragraph, the text “parallel to, The Applicant and cable engineers have confirmed that the Manoa not against” should be changed, because, as the image on the next page shows, in the NW Pacific magnitude of the currents pose no threat to the cable. The article, the deep-water currents flow along the trench Deep and Bottom Currents in the Challenger Deep, Mariana Trench, Measured with Super-Deep Current Meters (Taira et.al, axis from south to north. In the southern extension of the Izu-Bonin-Mariana trench 2004) shows minimal seabed currents, with 37% of measurements system they do the same (Kawabe, et al., reading 0 cm/s, mean flows of 0.7 cm/s at 7,009 m and 0.5 cm/s at 6,615 m, and a maximum recorded current measurement of 8.1 2003*). Deep currents (Lower Circumpolar Deep Water) that would affect the cable in the cm/s at 10,890 m. These currents are not of a magnitude that will Monument actually flow perpendicular (against) impact the cable even if they flow perpendicular to (against) the cable. the cable”

3 Dr. Patricia “In section 4.2 “Geology and Topography” the Section 4.2 The Final EA has been edited accordingly. Fryer, Univ. last sentence of the “Proposed Action and Geology and Hawai’i at Alternatives” paragraph, the text should use one Topography Manoa or the other of the words “would” or “will,” not both, in the highlighted sentence below:

“The ROW agreement would will include conditions governing the ability to conduct research in proximity to the cable.”

4 Dr. Patricia “On p. 4-3 In the first three lines of the first Section 4.2 Based on best available data, all known vents will be avoided by Fryer, Univ. paragraph, at the top of the page, the first full Geology and the proposed cable route. However, due to limited data

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JGA South Cable Landing in MTMNM Draft EA Comments Response Matrix

Relevant Draft # Commenter Comment Summary or Quote USFWS Response EA Section Hawai’i at sentence assumes there are no vents on the Topography availability, especially pertaining to the proposed project location Manoa seafloor in the area to be traversed. However, within the MTMNM, absolute avoidance cannot be guaranteed. In so little observation of the sea floor has been the unlikely event that the cable is laid across a hydrothermal done in this area that it is impossible to say that vent, the resulting impacts to the vent feature are expected to be “these features will be avoided.” Lack of minimal. evidence is not evidence of a lack of these features. For instance, lander studies during James Cameron’s expedition in 2012 (Hand et al., submitted) and a submersible dive by Victor Vescovo in 2019 show the presence of microbial communities on the seafloor, near the area proposed for laying the cable, are associated with effluent near the sea floor that has major differences in the chemistry from that of normal sea water.”

5 Ignacio “At present, the Friends of the Mariana Trench Comment noted. Cabrera, (FOMT) recommend that the no action Friends of alternative be selected. Under the No Action the Mariana Alternative, a Right-of-Way Permit would not be Trench issued and RTI would not land the JGA South cable through the MTMNM and impacts to MTMNM resources would be avoided.”

6 Ignacio “The EA lacks discussion concerning heat The fiber optic cable type being used for this project does not Cabrera, emission and electromagnetic fields generated generate any measureable heat. The repeaters, of which there are Friends of by the fiber optic cable and potential impacts of two within the MTMNM, will generate small amounts of heat as the Mariana heat and electromagnetic fields to unique part of their normal operation. Each repeater has a thermal load Trench microorganisms and other biological resources of approximately 20 watts. The repeater-seawater interface is on the seabed. Although these potential sources expected to heat up by approximately 0.5°C. At the water 5

JGA South Cable Landing in MTMNM Draft EA Comments Response Matrix

Relevant Draft # Commenter Comment Summary or Quote USFWS Response EA Section of impacts are mentioned in the draft temperatures and ocean currents at the project location (i.e., the compatibility determination, specific impacts seafloor of the MTMNM), the heat will be quickly dissipated and is anticipated and references from scientific considered negligible. literature is lacking.” Concern about magnetic fields comes from fields generated by alternating current (AC) not direct current (DC). The cable repeaters will be powered by DC transmitted along the fiber optic cable. Magnetic fields generated from a very low amperage DC cable are hundreds of times weaker than the earth’s natural magnetic field and would be undetectable.

7 Ignacio “The FOMT are concerned that there was a lack Previous cables and installations are beyond the scope of this EA Cabrera, of public review of cable lines landed in the and project. Friends of MTMNM after its designation. These cables may the Mariana include PIPE Pacific Cable-1 (PPC-1) America Trench Gateway, HANTRU-1. Southeast Asia U.S. (SEA- US). Are the owners of these cables in compliance with Refuge regulations? If not, what is being done to require owners to come into compliance for cables installed after the MTNMN designation if a permit was not issued?”

8 Ignacio “Is there a plan to remove/repurpose cables Previous cables and installations are beyond the scope of this EA Cabrera, that are no longer active and that are located and project. Friends of within the boundaries of the MTMNM? How the Mariana does the USFWS plan to manage abandoned Trench equipment or property within the MTMNM?”

9 Ignacio “What is the status of NOAA concurrence on Concurrences from the National Marine Fisheries Service (NOAA

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JGA South Cable Landing in MTMNM Draft EA Comments Response Matrix

Relevant Draft # Commenter Comment Summary or Quote USFWS Response EA Section Cabrera, ESA and EFH consultations for this project? Fisheries) that the proposed project is not likely to adversely Friends of Please provide copies of the consultation affect Essential Fish Habitat (EFH) or ESA-Listed species were the Mariana decision documents.” received on June 25, 2019 and June 26, 2019, respectively. Trench Request noted and copies will be provided.

10 Ignacio “Biological monitor(s) should be onboard with The suggestion of biological monitors is unwarranted. The cable Cabrera, specific procedures to follow if protected laying operation proceeds at a slow, measured rate and consists Friends of species are encountered.” of deploying the cable off of the back of the ship and allowing it to the Mariana settle onto the ocean floor. The potential risk to protected species Trench is adequately addressed in Section 3.3 and Section 4.4 of the EA, which concludes there is minimal potential risk to these species due to the nature of the cable laying operations and appropriate avoidance measures. Concurrence from the National Marine Fisheries Service that the project is not likely to adversely affect ESA-listed species was received on June 26, 2019.

Logistically to have biological monitors observe the work, they would need to be brought onboard the cable ship in Guam. Then after laying the cable through the trench, the monitors would need to be returned to Guam. This would require cutting the cable and travelling back through the MTMNM, at faster transit speeds rather than slower cable-laying speeds, towards Guam. Then, the ship would need to go through the necessary customs clearance which would take several days before the monitors could disembark. Finally, the cable ship would need to transit back through the monument and retrieve the cut end of the cable, splice the cut end to the rest of the cable onboard, and proceed toward Australia. This would potentially add weeks to the overall project timeline and would add two additional trips through the MTMNM, increasing the probability of encountering any ESA- 7

JGA South Cable Landing in MTMNM Draft EA Comments Response Matrix

Relevant Draft # Commenter Comment Summary or Quote USFWS Response EA Section listed species.

11 Ignacio “Please provide a copy of the Department of Request noted. A copy will be provided. Cabrera, Army Corps of Engineers permit for the JAG Friends of South Cable project referenced in the EA.” the Mariana Trench

12 Ignacio “The Monument Proclamation requires the No monitoring is proposed for this project within the MTMNM as Cabrera, Secretaries to provide: “monitoring and 1) there is no way to practicably monitor the cable once it is on Friends of enforcement necessary to ensure that scientific the seabed; and 2) once the cable is laid on the seabed it is immobile and does not have the potential to adversely impact the Mariana exploration and research, tourism, and marine resources; therefore, no monitoring is necessary. Trench recreational and commercial activities do not degrade the monument’s coral reef ecosystem or related marine resources or species or diminish the monument’s natural character”. Monitoring of possible impacts should be

carried out especially due to location within a marine national monument and because there is uncertainty regarding certain impacts (e.g. effects resulting from magnetic fields, heat dissipation), Within the EA and draft compatibility determination there are no provisions for a monitoring plan. “

13 Ignacio “Can pictures of any organisms attached to the It is not possible to take pictures of the cable once it is laid on the Cabrera, cable during repairs be photographed and seabed without expensive and time consuming ROV expeditions. Friends of provided to USFWS? “ In the exceedingly rare event that a cable repair is necessary, the cable is raised to the surface where repairs will be conducted the Mariana aboard a cable ship. Only a small portion of the cable is raised above the water and due to the time-sensitive nature of the repair 8

JGA South Cable Landing in MTMNM Draft EA Comments Response Matrix

Relevant Draft # Commenter Comment Summary or Quote USFWS Response EA Section Trench process, it is not feasible to document any organisms attached to the cable, if any. None of the cables that currently cross the MTMNM have needed repairs in the past, and the chances of the JGA South cable needing repair are very low.

14 Ignacio “Can undersea vibration data and temperature The cable is not outfitted with sensing equipment that would Cabrera, data be gathered from the cable and supplied to allow for the detection of vibration, temperature or collection of Friends of natural resource agencies and the public?” other forms of environmental data.

the Mariana Trench

15 Ignacio “Mitigation measures are lacking. Realigning Mitigation measures are not needed as the expected and Cabrera, the route of the cable to outside the boundaries identified impacts associated with the cable laying activities are Friends of of the MTMNM are possible and would be an not sufficiently high enough to require compensatory mitigation. This position has been concurred with by both USFWS and NMFS. the Mariana avoidance measure. IF the cable is landed

Trench within the MTMNM then offsets for the impacts should be incorporated into the ROW permit. Removal of inactive cables would be the responsibility of their Removal of inactive cables should be individual owners and is outside of the scope of this project. considered. Out-of-kind mitigation such as RTI providing resources for ecological awareness programs throughout the Marianas for the life of the permit could be one such consideration.”

16 Ignacio “ROW permits typically involve a fee, how is the Regulations covering the granting of rights-of-way (ROW) permits Cabrera, fee assessed and where are the funds directed on and across refuge lands are promulgated in 50 CFR, Parts 29.21 Friends of after collection? Will the funds be available for and 29.22. Any fees collected in association with ROW permits the Mariana MTMNM environmental awareness programs are deposited into the Migratory Bird Conservation Fund and are Trench for Guam and CNMI?” used for land acquisition. Thus, fees collected from this project will not be available for regional MTMNM environmental

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JGA South Cable Landing in MTMNM Draft EA Comments Response Matrix

Relevant Draft # Commenter Comment Summary or Quote USFWS Response EA Section awareness programs.

17 Ignacio “Why is the Department of Defense being Section 1 The Department of Defense is a co-consulting party because this Cabrera, included as a co-consulting party in the Purpose of and project traverses the Marianas Island Range Complex (MIRC) Friends of permitting process; what is their specific role in Need for training areas (W-517 and W-11), which are managed by the the Mariana determining Right of Way permits issued by Proposed Department of Defense. Trench USFWS? Is the Department of State reviewing Action this project as part of their responsibilities The State Department did not receive a copy of the Draft EA. within the Economic Exclusive Zone? Is the The CNMI Governor’s office has not yet named replacement Commonwealth of the Northern Marina Islands MTMAC board members. Congressional and partner notifications reviewing this project as part of their of the EA were provided by the USFWS Public Affairs Office. CNMI coordination role in management of the Government agencies such as DFW, DLNR, & BECQ were notified MTMNM?” but did not submit comments.

18 Ignacio “The EA states, “Exploration and research, such Section 3.6 Compared to the frequency of other vessels entering or using the Cabrera, as the 2016 Okeanos Explorer expedition Land and MTMNM (e.g., fishing and commercial ships), several scientific Friends of (Glickson et al. 2017), is conducted infrequently Water Use trips per year would be considered relatively infrequent. the Mariana in the Trench Unit with the oversight and Trench permits from the USFWS”; is this correct? From discussions with Refuge staff we understand that several permits for research to US and foreign research entities to conduct research in the Trench have been issued each year.”

19 Ignacio “The EA states, “Spill response materials will be Section 4.4 The cable ship will operate in accordance with the requirements Cabrera, available on board the cable ship and would be Threatened of MARPOL regulation 37 of Annex I of the International Friends of immediately deployed in the event of a release”, and Convention for the Prevention of Pollution from Ships, 1973, as the Mariana but no mention of the notification of a release is Endangered modified by the Protocol of 1979 relating thereto. The regulation Trench made to federal agencies and the public. Please Species requires the development and implementation of a Ship Board Oil explain the notification process and how clean- Pollution Emergency Plan (SOBEP). The SOBEP provides guidance 10

JGA South Cable Landing in MTMNM Draft EA Comments Response Matrix

Relevant Draft # Commenter Comment Summary or Quote USFWS Response EA Section up procedures are assessed.” to the captain and officers on board the ship with respect to the steps to be taken when a pollution incident has occurred or is likely to occur.

20 Ignacio “There is a typographical or sentence Section 4.8 Comment noted. The Final EA has been edited accordingly. Cabrera, construction error that should be corrected in Military Friends of this sentence. ‘Upon completion of the cable Training the Mariana installation, there Therefore, there would be no Trench effect on the Proposed Action Alternative from military training in the MIRC.’ ”

21 Ignacio “The EA states. “These include research and Section 4.9 Comment noted. Section 2.4 has been edited to make the Cabrera, exploration of the Mariana Trench with the Land and language regarding cable repair triggers clearer. “The typical Friends of proper federal permits, and commercial fishing Water Use triggers for emergency repair are such things as ship anchors the Mariana in compliance with federal regulations.” but in a being dragged across the cable route during active anchoring, and Trench previous section 3.6 commercial fishing is not fishing gear entanglement during active fishing (neither of which mentioned, and in section 2.4 the EA states that, would be a concern in the MTMNM because of the great depths), “The typical triggers for emergency repair are and equipment failure.” Anchoring and fishing are not feasible at such things as ship anchors and fishing gear the proposed project depths of 5,600 to 10,000 m. Loss of anchors entanglement (neither of which would be a or fishing equipment are possible within the MTMNM, although concern in the MTMNM), and equipment the environmental consequences of such actions or events would failure.” This sentence is also reused in the draft not be related to or caused by the presence of a fiber-optic cable compatibility determination. The statements are on the seabed. not consistent. If commercial fishing is allowed in the MTMNM, through a permitting process, then ship anchors and fishing equipment could cause damage to the cable even if it is due to accidental loss from the fishing vessel. Please

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JGA South Cable Landing in MTMNM Draft EA Comments Response Matrix

Relevant Draft # Commenter Comment Summary or Quote USFWS Response EA Section correct the inconsistencies in the EA and daft compatibility determination.”

22 Ignacio “Training should be provided to all ships staff Section 4.17.11 The probability of the cable laying activities adversely affecting, Cabrera, regarding procedures to follow if a bird is Migratory Bird harming, or “taking” any migratory birds is considered low. The Friends of incidentally injured or found injured during the Treaty Act, 16 risk of take would be less than that of other similarly sized fishing the Mariana project.” U.S.C. 703 and or commercial freight vessels that regularly travel through the Trench Executive MTMNM due to the cable ship’s low rate of travel. Order 13186, The following statement will be included in the special permit Responsibilities of Federal conditions to address this concern: Agencies to Birds at sea have the potential to be attracted to or confused by Migratory Bird lights on the vessel. At night the ship would use the minimum Treaty Act amount of light necessary for legal and safe transit when underway. Through coordination with the USFWS, the cable ship operators would be briefed on the potential for bird encounters and would follow these protocols: 1. The operators should pick up any downed birds and place them in a clean box to prevent soiling of their feathers. 2. The birds would be kept in a cool, safe place until daylight. 3. The birds would then be placed in an open area near the stern of the cable ship where they can take off when ready. 4. Photographs of any downed birds would be taken to document distribution of species at sea and the USFWS would be notified and provided with these photographs. 23 Ignacio “Procedures to ensure that the ship and cable Section 4.17.12 Procedures that ensure that the cable ship and cable do not Cabrera, do not introduce invasive species should be Executive introduce invasive species will be implemented. (Disinfection Friends of required. Disinfection protocols have been Order 13112, protocols will be provided in the special permit conditions.) The

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JGA South Cable Landing in MTMNM Draft EA Comments Response Matrix

Relevant Draft # Commenter Comment Summary or Quote USFWS Response EA Section the Mariana developed for research equipment and should Invasive cable ship will fully comply with 33 CFR § 151.2025 - Ballast water Trench be applied to this ROW permit.” Species management requirements.

24 Ignacio “The EA states, “The Proposed Action Section 4.17.17 The cable route was not surveyed for the presence of coral reefs, Cabrera, Alternative would not directly or indirectly Executive since only non-reef-building corals are found at the project Friends of impact any coral reef ecosystems, since these Order 13089, depths. The 2016 Okeanos Expedition identified corals on the the Mariana habitats are not found within the deep abyssal Protection of seabed within the MTMNM; however, these corals were soft Trench and hadal zones of the cable corridor. The Coral Reefs corals and octocorals rather than hard or stony reef-building known deep-sea coral and sponge communities corals. Precious corals were also observed near the project mapped by the 2016 Okeanos Explorer location outside of the MTMNM; the deepest of which were “gold expedition are located 28 km or more from the corals” (Calyptrophora sp.), with a maximum observed depth of proposed cable route and would be avoided by approximately 3,700 m. The proposed cable’s shallowest point the Proposed Action Alternative.” Can you within the MTMNM is approximately 5,400 m. confirm/clarify that the specific area that is proposed for landing the cable has been mapped and that no coral reefs exist in the area?”

25 Ignacio “The EA states that “Early pre-consultation and Section 4.18.2 The EFH consultation was completed on June 25, 2019. The ESA Cabrera, formal consultation meetings were held with National consultation was completed on June 26, 2019. The NMFS Friends of the National Marine Fisheries Service (NMFS) Marine concurred that the proposed action is not likely to adversely affect the Mariana during key phases of the project’s planning and Fisheries ESA-Listed species and Essential Fish Habitat. Trench design in order to minimize adverse impacts to Service EFH and ESA listed species to the maximum extent practicable. NMFS is the lead agency overseeing effects on EFH and impacts to protected marine resources under the Endangered Species Act”; but does not include the results of the EFH or ESA consultation.

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JGA South Cable Landing in MTMNM Draft EA Comments Response Matrix

Relevant Draft # Commenter Comment Summary or Quote USFWS Response EA Section Please provide copies of these consultations.”

26 Ignacio “Page numbers should be added to the Draft Appendix B Comment noted. The Draft Compatibility Determination has been Cabrera, Compatibility Determination.” Draft edited accordingly. Friends of Compatibility the Mariana Determination Trench

27 Ignacio The ROW permit should be for the proposed life Appendix B The Service will retain a 50-year Right-of-Way term. The 25-year Cabrera, of the cable, which is 25 years, not 50 years. Draft expected life of the cable, as described in Section 4.15 of the EA Friends of Compatibility and on page 3 of the Draft Compatibility Determination, Section “Retirement, Abandonment, or Removal of the Cable Systems” is the Mariana Determination an approximation and not an exact end-of-life date. Trench

28 Ignacio “The ES and draft compatibility determination Appendix B The impacts of the cable lay are de minimis, as would be the Cabrera, states that RTI plans to leave the cable in place, Draft removal. A cable left in place would have insignificant impacts, as Friends of but also indicates the ROW permit covers cable Compatibility it would be completely inactive.

the Mariana removal. Some deep-sea cables are removed Determination

Trench and repurposed, but the draft compatibility statement suggests that removal is less environmentally damaging; however, there is no discussion providing evidence for the environmental pros or cons of abandoning in place versus removing and repurposing. Please include a justification for abandoning the cable or confirm that the cable is to be removed after 25 years.”

29 Ignacio “A monitoring plan for the permittee should be Appendix B No monitoring is proposed for this project within the MTMNM as Cabrera, included in the compatibility determination and Draft 1) there is no way to practicably monitor the cable once it is on the seabed and 2) once the cable is laid on the seabed it is 14

JGA South Cable Landing in MTMNM Draft EA Comments Response Matrix

Relevant Draft # Commenter Comment Summary or Quote USFWS Response EA Section Friends of ROW permit.” Compatibility immobile and does not have the potential to adversely impact the Mariana Determination marine resources; therefore, no monitoring is necessary. Trench The Final EA and Compatibility Determination have been edited to state that routine monitoring would not be associated with the submerged cable within the MTMNM. 30 Ignacio “The draft compatibility determination states Appendix B No post-installation monitoring is proposed for this project within Cabrera, that the, “Refuge will periodically monitor and Draft the MTMNM as 1) there is no way to practicably monitor the Friends of evaluate the site to determine if objectives are Compatibility cable once it is on the seabed; and 2) once the cable is laid on the seabed it is immobile and does not have the potential to adversely the Mariana being met and the resource is not being Determination impact marine resources; therefore, no monitoring is necessary. Trench degraded. “We believe that the Refuge does not The Final EA has been edited to state that there is no routine have the staff or resources to monitor this monitoring associated with the submerged segments of the cable particular ROW permit and associated activities; within the MTMNM. The Compatibility Determination has been therefore, RTI should provide the funds for revised accordingly. Refuge staff to monitor the permit effectively or for the Refuge enter into an agreement with NOAA to provide monitoring services for his project/permit.”

31 Roy N. As noted, the cable route cuts through the Section 4.8 The applicant accepts the risks of crossing W-517. Coordination Tsutsui, Joint northern portion of W-517 and along the length Military with Catherine Creese, Director, Naval Seafloor Cable Protection Region of W-11. As these are areas where hazardous Training Office, disclosed an approximately 5 km radius avoidance area centered on 144° 38’E, 12°55’N where there would be an Marianas military activities occur, the potential exists for increased risk of the cable being adversely impacted by Naval damage to the cable from strike by military activities. The cable will remain outside of this area. expended materials from a variety of activities. Most concerning would be SINKEX. Unsure if existing cable routes are currently avoided during planning, but SINKEX has been conducted in W-517 and can occur throughout the MITT study area beyond 50nm from shore and at a

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JGA South Cable Landing in MTMNM Draft EA Comments Response Matrix

Relevant Draft # Commenter Comment Summary or Quote USFWS Response EA Section given depth. The potential for direct strike is remote due to the small footprint of the cable and the vastness of the Warning areas, but it does exist.

32 Roy N. Additionally, the EA does not clearly show the The full cable route has been considered with regard to areas Tsutsui, Joint cable routing IVO Apra Harbor or the cable designated for Naval training and use in the vicinity of (IVO) Apra Region landing site. Naval activities such as underwater Harbor, and the Applicant accepts the risks of entering or being in close proximity to these areas. Marianas detonations and mine warfare training occur proximate to Apra harbor and the routing should avoid those areas.

33 Roy N. Page 4-4 states "Given the measures that would Section 4.4 EFH and ESA consultations with the NMFS were completed on Tsutsui, Joint be implemented to safeguard ESA-listed species, Threatened June 25, 2019 and June 26, 2019 respectively. The NMFS Region the potential for vessel strikes, noise effects and and concurred that the proposed action is not likely to adversely affect ESA-Listed species and Essential Fish Habitat. Marianas pollutants would be minimized to less than Endangered significant levels. Therefore, the Proposed Species Action Alternative may affect, but would not adversely affect any threatened or endangered species listed by the federal government."

Is an informal ESA consultation with NMFS contemplated? A "may affect" determination requires NMFS consultation.

34 Roy N. Page 4-5 states: "There are no documented or Section 4.7 Comment noted. The Final EA has been edited to state that UXO Tsutsui, Joint known UXOs within the vicinity of the proposed Unexploded impacts are highly improbable and not likely to occur, rather than Region cable route, therefore, there would be no Ordnance “no impacts”. Marianas impacts from this hazard."

The waters around Guam were the site for fierce 16

JGA South Cable Landing in MTMNM Draft EA Comments Response Matrix

Relevant Draft # Commenter Comment Summary or Quote USFWS Response EA Section fighting during WW2 and UXO IVO Guam is to be expected. While there may be a low probability of impacts, I do not believe the "no impact" statement can be made without a qualifier.

35 Roy N. Page 4-4 also contains a typo and a Section 4.8 Comment noted. The Final EA has been edited accordingly. Tsutsui, Joint misstatement: "Under the Proposed Action Military Region Alternative, the cable route would traverse Training Marianas MIRC Warning Area 11, and pass within 2 km of Warning Area W-617 (Appendix A, Figure 4).

It is W-517 and Fig 4 clearly shows the cable within the northern portion of W-517.

36 Roy N. Once the cable is laid down on the ocean floor, Comment noted. The Applicant or their Contractor will coordinate Tsutsui, Joint there will be no impact to training from the with the MIRC to avoid these conflicts. Region perspective of the military units. During the Marianas laying of the cable, there is risk to the cable laying ship from live-fire training activities that may occur in the area, including surface firing and air-dropped weapons. Additionally, cable laying poses risk to submarine units that could contact the cable or associated equipment. Any information that can be passed to the MIRC about the schedule for cable laying would allow us to deconflict training events and ensure that all parties are safe. This information will be passed to the appropriate authorities to deconflict submarine waterspace.

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JGA South Cable Landing in MTMNM Draft EA Comments Response Matrix

Relevant Draft # Commenter Comment Summary or Quote USFWS Response EA Section 37 Roy N. Since the cable is proposed to be laid through Section 4.8 The Applicant accepts the risks of crossing areas W-11 and W-517. Tsutsui, Joint W-11 and W-517, planning should take into Military Region account there could be live ordnance expended Training Marianas as per NMFS Biological Opinion requirements which could result in UXO not exploding on the surface and instead reach the bottom before exploding. Although there is low risk to the cable due to low frequency of using live ordnance and preferred training locations are usually further south away from Guam within W-517, this potential hazard to the cable should be accounted for in risk calculation.

References

Taira, K., Kitagawa, S., Yamashiro, T., Yanagimoto, D., 2004. Deep and bottom currents in the Challenger Deep, Mariana Trench, measured with super-deep current meters. J. Oceanogr. Vol. 60. Pages 919–926.

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