Free Declaration in Support - District Court of California - California

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RONALD J. TENPAS Acting Assistant Attorney General Environment and Natural Resources Division UNITED STATES DEPARTMENT OF JUSTICE JEAN E. WILLIAMS, Chief KRISTEN L. GUSTAFSON, Senior Trial Attorney Wildlife and Marine Resources Section GUILLERMO MONTERO, Trial Attorney Natural Resources Section Environment & Natural Resources Division UNITED STATES DEPARTMENT OF JUSTICE Benjamin Franklin Station - P.O. Box 7369/ P.O. Box 663 Washington, D.C. 20044 (202) 305-0211 (tel.) / (202) 305-0443 (tel.) (202) 305-0275 (fax) / (202) 305-0274 (fax) [email protected] [email protected] Counsel for Federal Defendants

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN FRANCISCO DIVISION

NATURAL RESOURCES DEFENSE COUNCIL, ) INC., et al., ) ) Plaintiffs, ) Civ. Action No. 07-4771-EDL ) ) ) DECLARATION OF CARLOS M. GUTIERREZ, SECRETARY OF ) ARTHUR N. POPPER, PH.D. THE UNITED STATES DEPARTMENT OF ) COMMERCE, et al. ) ) Federal Defendants. ) )

DECLARATION OF ARTHUR N. POPPER Case No. 07-04771 EDL

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I, ARTHUR N. POPPER, declare that the following is true and correct to the best of my knowledge, 1. I am a professor in the Department of Biology at the University of Maryland,

College Park. I also am Interim Associate Dean of the College of Chemical and Life Sciences. Concurrently, I am Co-Director of the Center for Comparative and Evolutionary Biology of Hearing, an internationally known auditory neuroscience research group at the University of Maryland. I have also served as chair of the Department of Zoology (now Biology) at the University of Maryland (10 years) and as Director of its Neuroscience and Cognitive Science Program (six years). My curriculum vita is attached to this declaration as Exhibit A. 2. My Laboratory of Aquatic Bioacoustics at the university is primarily involved in

the study of hearing mechanisms and capabilities of aquatic organisms (topics of my research for over 40 years). Most of the research in my laboratory focuses on fishes, although we have done limited studies of other animals including sharks, alligators, birds, and marine mammals. Our studies focus on hearing including the basic structure and function of the auditory system in fishes and their sensory hair cells, behavioral investigations to determine what fishes can hear, and physiological investigations of the fish ear and brain responses. Most recently, my laboratory has become extensively involved in research related to the effects of human-generated (anthropogenic) sound on aquatic organisms, including explorations of the behavioral and physiological effects of increased ambient sounds on fishes. We have published some of the first peer-reviewed research that has specifically addressed issues related to the effects of humangenerated sounds on fish (e.g., Popper et al. 2005, 2007). 3. I received an undergraduate degree (B.A.) in Biology from New York University,

Bronx, New York in 1964. I received my Ph.D. in Biology from the City University of New York in 1969. My Ph.D. research investigated mechanisms of sound detection by fish. After
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receiving my doctorate, I accepted a position as assistant professor in the Department of Zoology at the University of Hawai'i in 1969. Subsequently, I was an associate professor in Hawai'i and then associate and full professor at the Georgetown University School of Medicine, which I joined in 1978. I joined the faculty at the University of Maryland (College Park) in 1987 as professor and chair of the Department of Zoology. 4. I have published over 178 scientific articles, most of which have been

peer-reviewed. I have edited over 37 books on hearing, including 33 volumes of the Springer Handbook on Auditory Research series (28 published, five in press). I have authored dozens of other publications including reports, conference proceedings, and abstracts. 5. I have been elected a Fellow of the Acoustical Society of America and of the

American Association for the Advancement of Science. I have served as American editor for the journal Bioacoustics and I serve, or have served, on the editorial boards of other journals including Hearing Research and Acta Zoologica. Until recently, I co-chaired the journal publications committee of the Association for Research in Otolaryngology and was instrumental in the founding of the journal for that society. 6. I have been involved as a subject matter expert with the development of the

environmental impact statements (EIS) for the U.S. Navy's Surveillance Towed Array Sensor System (SURTASS) Low Frequency Active (LFA) sonar. I authored and reviewed the sections of the Final EIS (FEIS) and Supplemental EIS (SEIS) documents that dealt with fishes and sea turtles. I also serve as a subject matter expert in studies of fish passage, effects of seismic air-guns, effects of pile driving activities, and other projects for private, state, and federal organizations in the U.S. as well as abroad. I served on several panels of the National Research Council (NRC) of the National Academies of Sciences that investigated the effects of human-generated sound on marine mammals, and I chaired the NRC panel that reported in 2000.
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Most recently, I have been co-organizer of the first International Conference on the Effects of Sound on Aquatic Organisms that took place in Nyborg, Denmark in August 2007. I also co-chair the Acoustical Society of America standards working group on the Effects of Human Generated Sound on Fish and Turtles. 7. Owing to my expertise and experience regarding fish hearing and bioacoustics,

especially relating to SURTASS LFA, I have been asked to submit this declaration to address issues related to possible noise effects on fish hearing from the use of low frequency sonar and to address specific statements made by Dr. Joseph J. Luczkovich in his October 12, 2007 declaration that was filed with this court. The topics I have been asked to address are: · My experiments to determine impacts from SURTASS LFA sonar on fishes and fish hearing including masking and extrapolating the results to other fish species; · · My experiments to determine impacts from seismic airguns on fishes and fish hearing; A synthesis of impacts to fish and fish hearing as a result of exposure to LFA sonar and seismic airguns; · Overview of other experiments and papers on impacts to fishes from non-impulsive sound; · Dr. Luczkovich's Declaration filed in support of Plaintiffs' motion for preliminary injunction. 8. Citations for any literature referenced in my declaration are included as Exhibit B. SURTASS LFA Sonar Experiments on Fishes 9. Over the past several years, my laboratory has been involved in a Navy-funded

research project to examine the effects of SURTASS LFA sonar on fish. I find it important to note that while the Navy provided funds for the project and gave us access to a site at which to do the work, they, in no way whatsoever, were involved in the experimental design, data
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acquisition (other than to provide some hydrophones to record data), or data analysis 1/. The study, the first part of which is published as Popper et al. 2007, was conducted at the Navy sonar test range at Seneca Lake in New York. This range is unique in that it enabled us to test the effects of an actual SURTASS LFA sound source on fish ­ something that can be done nowhere else and certainly not in the laboratory due to the size of the sound source and the large amount of power (1,600 volts) needed to produce the sounds from the source. 10. In the LFA experiments, rainbow trout (a "hearing generalist") 2/ and channel

catfish (a "hearing specialist") 3 / were placed in a specially designed test tank that did not alter the sound field to which the fish were exposed. 11. Fish were exposed to sonar sound in Seneca Lake, using a test signal and sound

levels that are similar to the in the ocean and exposed to the LFA sonar from a vessel. The experimental sounds were produced using a single LFA sonar transmitter, which generated signals very similar to the actual sonar signals used by the Navy. The sounds were measured in the tank using multiple hydrophones (underwater microphones) and found to be about 193 dB re 1 Pa 4/, a level that is equivalent to a LFA sound at about 200 m from an actual source. Each fish was exposed to the LFA sound for three 108-second periods, with each period separated by nine minutes (the separation between presentations was to allow the LFA sound source to cool down and to approximate the duty cycle of a signal during an actual LFA test). In total, each fish

/ In paragraph 6 of his declaration, Dr. Luczkovich points out that the Popper et al. (2007) study was funded by the Navy. However, as pointed out here in my declaration, in the SEIS, and in the Acknowledgements section of the Popper et al. (2007) peer-reviewed publication, the Navy did nothing whatsoever to influence the work done by my colleagues and myself. Indeed, our point of contact for the funding, Mr. Joseph Johnson, has never visited the experimental site during our experiments or my laboratory at the University of Maryland. 2 / Fish that have no special anatomical structures for increased hearing capacity. 3 / Fish that have special anatomical structures that help them hear better than other species. 4 / In underwater acoustics, dB re 1 µPa or decibels referenced to a pressure level of one microPascal, is the standard way to reference measured sound level.
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was exposed to the LFA sound at 193 dB re 1 Pa for 324 seconds. After exposure, the fish were taken to shore. Fish were then tested for hearing capabilities and hearing was compared to hearing in control fish. Control fish were not exposed to the sound, but were otherwise treated identically to the experimental animals, including placing the controls in the test tank, lowering them to the experimental depth, leaving them at depth for the same time period as the exposed animals, and then bringing them to the surface and to shore precisely as was done for the experimental animals 5/. After experimental and control animals had their hearing tested, the fish were then used for studies of ear structure. In addition, an expert fish pathologist, who collaborated with us on this project, examined other control and exposed fish for effects on body tissues. Additional animals were held for one or more days after they were exposed to sound for examination of any longer-term effects of the sound exposure. 12. There were no short- or long-term effects on ear tissue as a result of the LFA

sonar experiments (Popper et al. 2007). The ears' sensory cells of both species tested were intact both immediately after exposure and up to 96 hours after the end of exposure. A number of studies have examined the effects of high intensity sound on the sensory hair cells of the ear. These cells transduce (convert) the mechanical energy in the sound field into a signal that is compatible with the nervous system. Loss of these cells in mammals (including humans) results in permanent hearing loss (e.g., Fletcher and Busnel 1978; Saunders et al. 1991). Thus, it is
5/

We also did identical studies with a group of fish we called "baseline control." These animals were from the same stocks as the experimental and control animals, but they were never placed into the test tanks or moved to the barge. The purpose of the baseline controls is to "control for the controls." By this, we mean that these animals controlled against any effects from handling that may have occurred in the experimental or control animals. If there were differences in hearing or other structures between baseline controls and controls, it would mean that the handling of the fish had an impact on the animals and this would have led to concerns that any effects in experimental animals resulted from handling rather than sound exposure. However, no differences were found in any results between baseline controls and controls, thereby indicating that any changes in hearing or other tissues in the experimental animals had to be a result of the exposure to sound.
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likely that comparable damage to sensory hair cells in fish could also result in hearing loss. However, while there are studies, as discussed below, indicating some damage to sensory hair cells in fish resulting from exposure to very intense and relatively long signals, there has yet to be any study that has examined fish hearing before and after such damage. Thus, while it may be speculated that fish with damaged and destroyed sensory hair cells would also have hearing loss, to date this is only conjecture. 13. The catfish and some of the specimens of rainbow trout involved in the

experiment showed 10 to 20 dB of hearing loss immediately after exposure to the LFA sound when compared to baseline-control and control animals, but hearing appeared to return to, or close to, normal within about 24 to 48 hours for catfish. Other rainbow trout showed minimal or no hearing loss. We are not sure why some of the rainbow trout experienced this effect and some did not, although we suspect that it was due to genetic or early developmental effects. In other words, something may have happened to some of the fish during their early development that made them more susceptible to loud sounds, just as various environmental variables may affect the development of a human embryo. 14. In summary, the sound level to which fish were exposed in the Navy's LFA sonar

experiments was 193 dB re 1 Pa received level (RL), a level that is found within about 200 meters (m) (656 feet [ft]) of the LFA sonar source array. Thus, the likelihood of exposure to this or a higher sound level is small, considering all the possible places a fish might be relative to the sound source. The volume of the ocean ensonified by a single SURTASS LFA sonar source at a received level of 193 dB re 1 Pa or higher is very small compared to the ocean area ensonified by the LFA sonar source at lower sound levels or not ensonified at all. 15. In the LFA sonar sound experiments, the sound that was used represented a In effect, the exposures during the experiments were most likely
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"worst-case" exposure.

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substantially greater than any exposure a fish might encounter in the wild. In the LFA sonar fish study, each fish received three exposures to a high-level LFA sonar (duration of each exposure was 108 seconds, for a total of 324 seconds). However, under normal circumstances, the SURTASS LFA sonar source is on a moving ship. A fish in one location will only receive exposure to the highest sound level for a few seconds (depending on ship speed and whether the fish is moving or not, and its direction of motion and speed). 16. Further, the sound level as the LFA ship approaches and passes a fish is for a

much shorter duration than the exposure in our SURTASS LFA sonar experiments at Seneca Lake. Thus, rather than receiving 108 seconds at 193 dB re 1 Pa as happened at Seneca Lake, a fish in the ocean would be exposed to the maximum for a shorter time. Exposure at the maximum sound level (193 dB re 1 Pa) in our study occurred for a total of 324 seconds and did not cause damage to fish other than what appeared to be only a temporary, limited hearing loss. It is thus unlikely that a shorter exposure would result in any measurable hearing loss or nonauditory damage to fish unless they were so close to the SURTASS LFA sonar source that they received a maximum output of 215 dB re 1 Pa. Even then, exposure at maximum output would be for a minimal period of time. It should be reiterated that 193 dB re 1 Pa had no real adverse effects on the fish tested. 17. While it was not possible to present a higher sound level to the fish in this

experiment because that might have damaged the expensive equipment, it is very likely that a shorter exposure than 108 sec to an even higher sound level may not have adversely affected the fish. In effect, it is likely that fish could be even closer than 200 m (656 ft) to the source array and not be damaged by the sounds.

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Seismic Airgun Experiments on Fishes My laboratory has also been involved with other research on the impacts on fish

and fish hearing of other anthropogenic sound sources, such as seismic airguns. In Popper et al. 2005a, we presented the results of exposing fish to sounds produced by seismic air guns in the Mackenzie Delta in the Northwest Territories, Canada. This study used a variety of controls to ensure that the data obtained were accurate and not the result of experimental artifact. Importantly, this was the first study on effects of anthropogenic sound that examined effects on hearing sensitivity of fish (measured using recordings from the ear and brain). This airgun study was also the first study that paired investigations of the effects of these sounds on hearing and on the tissues of the inner ear. The effects on tissues were very recently submitted for publication in a peer-reviewed journal. 19. In the Popper et al. (2005a) study, we examined effects of seismic air guns on

three species of fishes endemic to the Mackenzie Delta, including the lake chub, northern pike, and broad whitefish. None of the fish exposed to the seismic air guns died as a result of the exposure. We demonstrated that there was some loss of hearing sensitivity (but far from complete loss) in two of the three species, namely the lake chub and northern pike. Both species with partial hearing loss showed full recovery within 18 hours of exposure to the air guns and returned to normal hearing sensitivity. The third species, the broad whitefish, showed no hearing loss. 20. Immediately after exposure to airgun-generated sounds, I examined the external

and internal structures of the fish. I found no damage to the swim bladder, the chamber of air found in the abdominal cavity of most fish species. The swim bladder has a variety of important functions in fish including hearing and in helping the fish maintain buoyancy at different depths. A number of investigators who have exposed fish to explosives have demonstrated that intensive
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concussive signals may damage the swim bladder and this always leads to death (reviewed in Hastings and Popper 2005). It has also been suggested, but never demonstrated, that the acoustic signals produced by seismic air guns or other intense sounds can damage the swim bladder. However, our study found no damage to swim bladders in the fishes we exposed to airguns. 21. There was also no apparent bleeding, either externally or internally, when I

examined and then dissected the fish and then inspected the swim bladder. I am not a trained fish pathologist, and my examinations were not as detailed as would be done by one (such as the expert who participated in our SURTASS LFA studies described below). At the same time, I have been working with fish for over 40 years, have done numerous dissections, and am expert at recognizing general damage to tissues, including bleeding and tissue ruptures. Subsequent analysis of inner ear tissue in my laboratory using scanning electron microscopy 6/ showed no effect on the sensory cells of the inner ear. The tissue from exposed animals was identical to that of control and baseline control animals. This study of the effects on the inner ear has been submitted for publication in a scholarly journal as Song et al. (In press). Synthesis of Impacts to Fishes from LFA Sonar and Seismic Airguns 22. In both the LFA sonar and seismic airgun experiments, the swim bladders of the

fish that were examined were fully intact after exposure to the sounds. While I personally examined the swim bladders in the seismic airgun experiments, the LFA study involved an expert fish pathologist (to ensure that the non-auditory tissues of the fish sacrificed were prepared and examined properly for histopathology [which is an analysis to determine if there were any effects on cells that could only be seen with a microscope]). Examination during the LFA study revealed no damage to tissues either at the gross or cellular levels. This included
6/

Scanning electron microscopy is a technique I have been using for over 30 years to examine inner ear tissues in fish and is an area on which I, and my colleague Dr. Jiakun Song, are experts and have published many of the papers in the field.
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examination of all body organs including brain, gills, kidney, gonads, muscles, blood, and others (see Popper et al. 2007). 23. The LFA sonar and seismic airgun studies were done with only a limited number

of fish species. Extrapolating these results to other fish species must be done with extreme caution. This caution is based on potential differences among fish species in their very broad diversity, the structure of their auditory system and hearing capabilities, and the very large number (29,000+) of living species. It would be impossible to test even those species most likely to be exposed to LFA to determine effects. Instead, one must examine select species and use them as "reference species" (e.g., species that are very similar to, but not the same as, the species of concern). It is very common to use reference species in animal studies, and a great deal of relevant information can be learned from such species. Indeed, much of modern molecular biology is done with mice, and zebrafish are becoming one of the most important models to understand molecular genetics. These data are commonly applied to human health issues. 24. The rainbow trout and channel catfish in the LFA sonar study, and the lake chub,

northern pike, and broad whitefish in the seismic airgun study (Popper et al. 2005a) are species that differ considerably from one another in hearing structures and in hearing capabilities. They are also evolutionarily very different and so represent distinct evolutionary lines of fish. None of these fish showed any tissue damage from sound exposure. There was no hearing loss in the broad whitefish, a salmonid. The lake chub and northern pike recovered hearing from any shift in hearing sensitivity after 18 hours of exposure. Recent work (Song et al., submitted for publication) found no damage to sensory tissues of the ears, as discussed above. Although, as discussed below, other species tested at Seneca Lake in the 2006 Halvorsen study, including black perch, hybrid sunfish, and largemouth bass, that are not found in waters likely to be
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exposed to SURTASS LFA sonar, do provide insights into fishes with different characteristics than found in the five species tested in the LFA and seismic airgun studies. Those characteristics include a different means of moving gas into the swim bladder, the structure that has been suggested to be the most likely damaged by very high intensity sounds (although none of the fish exposed to the sound signal in our SURTASS LFA sonar or seismic airguns had any damage to the swim bladder). Thus, while recognizing the need for caution when extrapolating among species, these results support the judgment that SURTASS LFA sonar is likely to have a negligible impact on fish. The significant point from the SURTASS LFA (Popper et al. 2007) and seismic airgun (Popper et al. 2005a) studies is that neither the LFA sonar sound nor the sound from seismic airguns, despite being very intense, had any effect on body tissues on fishes when examined using the eye (e.g., gross effects). In each of our studies, no fish died even days after the sound exposure, there was no discernable damage to the body surface (e.g., no bleeding, loss of scales), and the swim bladder was intact in all cases. 25. Animals (and humans) experiencing temporary hearing loss ("temporary

threshold shift" or "TTS") are probably at a disadvantage for detection of predators and prey during periods when hearing is impaired. It is significant, however, that fully half of the rainbow trout in the SURTASS LFA sonar study showed no TTS (Group II of that study) and another salmonid, the broad whitefish, showed no TTS in the Popper et al. (2005a) seismic airgun study, despite much longer exposure to high sound levels than is likely to occur as a result of SURTASS LFA sonar use. More data are still needed before a clear conclusion can be drawn. The results of the LFA sonar and seismic airgun experiments, however, along with the results from very long exposure of hearing generalists (including rainbow trout) suggest that very few, if any, endangered species that happen to be hearing generalists would have any hearing loss as a result of exposure to SURTASS LFA. In the long exposure experiments, the hearing generalist
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fishes were exposed to somewhat lower intensity sounds (like those occurring at greater distances from an LFA ship than 200 m) and showed no TTS, even after nine months of continuous exposure (as reported below). 26. Even without TTS, the presence of intense sounds in the environment can

potentially interfere with an animal's ability to hear sounds of relevance. This effect, known as "auditory masking," could interfere with the animal's ability to detect biologically relevant sounds, such as those produced by prey or predators, thus increasing the likelihood of the animal not finding food or being preyed upon. An example of masking occurs when it becomes harder for a human to hear another speaker as the noise in the background (the masker) increases (this is sometimes referred to as the "cocktail party effect"). 27. The masking effect of the SURTASS LFA signal will be limited for a number of

reasons. The bandwidth 7/ of the system is limited since the frequency range of the whole signal, from start to finish, is relatively small (about 100 to 500 Hz). Moreover, at any one point in time, the bandwidth of the signal (called the instantaneous bandwidth) is about 10 Hz because at any given moment only a very narrow range of frequencies is being emitted. Within the area in which masking is possible, the effect will be limited because animals that use the frequency range of the SURTASS LFA sonar typically use a broader frequency range of signals. The potential for a marine animal's signals to be entirely masked by an LFA sonar transmission will only rarely occur. Finally, the low duty cycle of 7.5 to 10 percent (based on historical LFA operational parameters) means that at least 90 to 92.5 percent of animal signals will not be affected by LFA sonar transmissions during active LFA missions. Therefore, the majority of the
7/

Bandwidth is the range between the upper and lower frequencies of an acoustical signal or a process. Thus, the bandwidth is 400 of a signal that has frequencies from 100 Hz to 500 Hz. The instantaneous bandwidth is the frequency spread at a given time within a signal. This term is most often used when the frequency range of a signal may change over time.
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time a fish is exposed to LFA sonar, its ability to hear environmental sounds will not be affected, and its survival will not be impacted by this cause. 28. Based on our current knowledge from the studies to date, effects on hearing are

primarily found in fishes that are hearing specialists, although after exposure to the very loud sounds from seismic airguns (Popper et al. 2005a) and SURTASS LFA (Popper et al. 2007) there is temporary hearing loss in some (but not all) generalists. Hearing generalists (such as cichlids; Smith et al. 2004a) showed no hearing loss as a result of the increased background noise. Indeed, in a paper from my laboratory that has just been published in the highly regarded peerreviewed journal Aquaculture (Wysocki et al. 2007), we showed that continuous (24 hours/day, seven days/week) exposure of rainbow trout (a hearing generalist) for nine months to received sound levels at 150 dB re 1 Pa) caused no effect on hearing sensitivity. Overall, the results on exposure of fish to longer duration sounds (including papers discussed in the SEIS), while limited to a few species, lead to the suggestion that hearing generalists, including the rainbow trout, a salmonid, are not affected by very long-term exposure to received sound levels as high as 170 dB re 1 Pa for extended periods of time. 29. The studies by Popper et al. (2005a, 2007) provide the first direct evidence that

while sounds, including seismic airguns and SURTASS LFA sonar, may be of concern, they have not been demonstrated to kill or damage fishes 8/.

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In a technical report funded by the Office of Naval Research, Edds-Walton and Finneran (2006) presented a review of the existing studies on the effects of human-generated noise on fish. It should be noted, however, that although the authors attempted to review the SURTASS LFA fish experiments detailed in the recently published Popper et al. 2007 article and included in the final SURTASS LFA SEIS, their review was based on preliminary experimental results rather than the results from the fully-analyzed dataset that were the basis for our recently published paper. Thus, Edds-Walton and Finneran did not review the complete experimental dataset and thus any conclusions arrived at by the authors regarding LFA sonar were consequently incomplete.
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Overview of Other Studies on Sound Impacts on Fish In the past four years, a limited number of other peer-reviewed studies on effects

of sound on fish have been published. In all cases, however, the peer-reviewed studies (several of which were in my laboratory) examined effects of long-term exposure to received sound levels that are much lower in intensity than SURTASS LFA sonar (e.g., generally below 180 dB re 1 Pa). These papers include (but are not limited to) work by Smith et al. 2004a, 2004b, 2006, Wysocki et al. (2007) (all in my laboratory), Amoser and Ladich (2003), Wysocki and Ladich (2005), and Wysocki et al. (2006). While several of these studies demonstrate some temporary hearing loss (commonly referred to as temporary threshold shift [TTS]) in some fish species, the effects were only after extended exposure to sounds. In the Smith et al. (2004a, 2004b, 2006) studies, the fish were exposed from 30 minutes to weeks of sound, while in the Wysocki et al. (2007) study, fish were exposed to sound for nine months. Moreover, the fishes recovered their hearing shortly after the exposure stopped. Hearing loss only occurred in hearing specialists, which include goldfish and catfish. All of the species of concern with regard to SURTASS LFA (at least that we know of) are hearing generalists. 31. Recent studies, including one currently being prepared for publication, based on

experiments with several other species, such as the black perch, hybrid sunfish, and largemouth bass, have provided even further data and given us more confidence in the finding of our initial LFA sonar experiments. These studies (Halvorsen et al. 2006, and paper in preparation for publication submission), using LFA sonar at the Seneca Lake site, tested three additional fish species under precisely the same experimental conditions as the previous experiments with rainbow trout and catfish. These species, like the rainbow trout, are hearing generalists. None of the fish involved in these studies died as a result of the exposure to LFA sonar nor did they experience any physical damage. In addition, none of the fish showed any loss in hearing
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sensitivity. 32. There have been very few studies of the effects of sound on eggs, larvae, or

juvenile fishes. One well-designed study is the recent work by Jørgensen et al. (2005) in Norway (also evaluated in the SEIS) in which eggs and larvae of several fish species were exposed to high intensity signals from 1.5 kHz to 6 kHz. The investigators found virtually no substantive effect on any of the species tested at different early life stages 9/. As Jørgensen et al. (2005) point out, the one exception where sonar had a substantive effect was very likely due to resonance effects on the swim bladder (Kvadsheim and Sevaldsen 2005), where the resonance of the swim bladder in these small herring was in the range of the sonar used. It is critical to note, however, that the sonar used in the Jørgensen et al. (2005) study was of far higher frequency than that used in SURTASS LFA. Therefore, extrapolations from this study to determine the effects of the much lower frequency signals used by SURTASS LFA are problematic. 33. Additional studies on sensory hair cells suggest that intense sound may result in

some small amount of damage to the hair cells in the ears of some species. Cox et al. (1986a, 1986b, 1987) exposed goldfish (Carassius auratus), a freshwater hearing specialist, to continuous pure tones (single frequencies) at 250 and 500 Hz at 204 and 197 dB re 1 Pa received level (RL), respectively, for two hours. They found some indications of sensory hair cell damage, but these were not extensive. Enger (1981) determined that some ciliary bundles (the sensory part of the hair cell) on sensory cells of the cod (Gadus morhua) inner ear were damaged when exposed to sounds at several frequencies from 50 to 400 Hz at 180 dB re 1 Pa RL for 1 to 5 hours. Hastings et al. (1996) showed that some small amount of damage occurred in the lagena of an oscar's (Astronotus ocellatus) ear after four hours of continuous pure tone

For fishes, life stages refer to the egg, larvae, juvenile, and adult phases of fish development.
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stimulation. Relatively few sensory cells, however, were damaged and only in one of the ear parts, the lagena, which is a structure that we think is far less involved with hearing than the saccule, another ear region (reviewed in Popper et al. 2003). Finally, McCauley et al. (2003) reported that some damage to the ears of pink snapper occurred after very extensive exposure to seismic air guns, but all fish survived for more than 50 days following the exposure; while the damage to small regions of the ear were considerable, the actual percentage of the saccule damaged was very small. The rest of the tissue was no different from that of the control animals. Response to Declaration of Dr. Joseph J. Luczkovich 34. I will now address specific point-by-point comments made by Dr. Joseph

Luczkovich in his Declaration. I first wish to point out, however, that Dr. Luczkovich bases the majority of his comments upon the behavior of animals in our test tank and his allegation that I, and the Navy, have attempted to extrapolate this behavior to that of wild animals. This was never the case, and both the SEIS and the peer-reviewed paper that presents the full experiment (Popper et al. 2007) studiously avoid making such extrapolations since they cannot be scientifically justified. Indeed, we state this repeatedly in the reports and peer-reviewed publications on our experiments (e.g., see SEIS page 4-19, last paragraph). We do discuss behavior of wild animals in the Popper et al. (2007) paper but without any specific reference to, or extrapolation from, the behavior of the fish in the experimental test tanks. 35. In paragraphs 4 through 8 of his declaration, Dr. Luczkovich makes a substantial

number of comments about the SURTASS LFA sonar experiments on fish that are based upon his review of the SEIS and a 2005 abstract describing this work (Popper et al. 2005b), which included little in terms of methods or data. Since the time Dr. Luczkovich read these early works, a full report and description of the fish and sonar experiments has been included in the Final LFA SEIS (DoN 2007), and published in the highly prestigious, peer-reviewed Journal of
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the Acoustical Society of America (JASA) (Popper et al. 2007). Portions of this work were also presented by me at scientific meetings, such as the Spring 2007 meeting at Duke University and August 2007 International Conference on Effects of Sound on Aquatic Organism (Nyborg, Denmark). Since Dr. Luczkovich provided his Declaration in October 2007, three months after the full study was published in JASA and after attending both scientific meetings, he had to be aware of the complete data and findings. Moreover, Dr. Luczkovich no doubt heard about the publication date of the JASA article at both the Duke and Nyborg meetings. Thus, many of Dr. Luczkovich's declaration statements are not based on the full knowledge of the subject he would have possessed had he read the full publication of our work. 36. In paragraph 8 of his declaration, Dr. Luczkovich focuses on the behavior of the

fish in our experiments. However, as was very carefully pointed out in the SEIS (4-19), and in talks that Dr. Luczkovich attended at the Duke University and Nyborg meetings, we cannot and will not extrapolate from the behavior of fish in a test tank to that of fish in the wild. The major focus of observing the fish behavior in our experiments, as pointed out in Popper et al. (2007), was to ensure that animals were not injured or killed during sound exposure and to get a general impression of their reaction to the sounds. Thus, while Dr. Luczkovich might be correct that farmed fish would behave differently than wild fish (paragraph10), since the experiment was designed to measure the physiological effects of LFA sonar exposure, and not the behavior of fish in the wild, whether the test fish were wild or farmed is irrelevant 10/. 37. The fish involved in the experiment, which were restricted to a test tank to ensure

that they were exposed to a precisely calibrated sound field, behaved no differently before and

10/

It is worth noting, however, that Dr. Luczkovich is not likely to know anything about the fish farms from which we got the experimental animals. Indeed, our fish are from very large ponds in which they were placed when young and, to our knowledge, never again handled until they were caught for transport to our study site.
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after sound exposure. This is of considerable interest, but it cannot be extrapolated to how fish not so restricted would behave when exposed to the same sound level in the wild. There were some interesting behaviors during sound exposure, especially by the catfish, but it would be scientifically inappropriate to extrapolate from these behaviors in a test tank to how any species would behave when not in a confined space. In the case of the rainbow trout, the observed behaviors lasted only a very short time (we have yet to quantify the time) at sound onset, and then they resumed the behaviors we saw before the sound onset. Many, but not all, channel catfish showed a more discrete behavior during the sound presentation (turning toward the LFA source), but as soon as the sound ended the fish resumed pre-stimulus behavior. 38. Dr. Luczkovich also suggests in paragraph 8 of his declaration that the fish in the

test tanks exhibited a "startle" response entailing the involvement of highly specialized nerve cells called Mauthner cells (M-cell). However, such responses are very fast, are very hard to see with the human eye, and can only be recorded with high-speed movie or video media. Since we were observing the fish on a TV with a normal (relatively slow) scan rate that had been captured using a standard digital video recorder and cameras, we would never suggest that we observed an M-cell response in any publication or presentation. (Note: this very point is made in a SEIS footnote (4-15.) It would have been only by pure chance that the scientific team would have seen M-cell responses (if such even occurred). Thus, I have no idea why Dr. Luczkovich says we observed such responses. Indeed, there is also no evidence that fish exhibiting the classic Mcell mediated "startle response" as described by Dr. Luczkovich always move from where they detected the stimulus. As an analogy, a human startled by a loud sound(s) is very likely to quickly look around or even turn the body to try and see the source of the sound; once the person has identified the source(s), they may very well exhibit no further response. Thus, it is very possible that fish showing a "startle" response (M-cell mediated or not), quickly decide that a
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stimulus is irrelevant and then continue their normal activities. 39. In paragraph 9 of his declaration, Dr. Luczkovich states that the Navy reported in

the SEIS that the sounds used in our studies had no marked effect on the behavior of the fish studied. Although Dr. Luczkovich disagrees, this statement is correct. The behavior of fish in the test tank was not very significant, and while rainbow trout showed some slight "startle" motions (as defined in the SEIS footnote, page 4-15) at sound onset, their normal swimming patterns did not change in any significant way. The catfish did indeed line up to face the sound source, and this is of interest. Indeed, Dr. Luczkovich's suggestion that the fish may have been trying to minimize exposure of the swim bladder to sound is interesting and might be worth future scientific inquiry. 40. In paragraphs 9, 10, and 11 of his declaration, Dr. Luczkovich characterizes the

behavior we observed in the test tanks as "avoidance" behavior. However, there is no scientific basis for saying that the behaviors observed were avoidance behavior. This suggestion by Dr. Luczkovich is a non-scientific extrapolation. Dr. Luczkovich acknowledges in his declaration that he has not seen the videos taken during the experimental exposure (these have never been shown publically since we are still working up the data), so it is impossible for him to accurately and scientifically estimate the behavior of the fish and whether they showed an avoidance response. 41. I am well aware of the Engås et al. (1996) study cited by Dr. Luczkovich in

paragraph 12 of his declaration, and the changes in catchability of several species during and after a seismic survey with an airgun (a signal that is acoustically very different than SURTASS LFA sonar and often far louder). However, it should be pointed out, as the SEIS does (4-20), that there were no observations on fish behavior in the Engås et al. (1996) study, and there is no evidence of fish death or any physical effect on fish. That is, it is possible that fish simply
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changed depth or moved out of the vicinity, making fishing for them harder, but without abandonment of feeding sites or harm to the stock. Indeed, a later study by Slotte et al. (2004) did show, using fisheries sonar, that fishes moved to greater depths during seismic airgun exposures but, again, this study produced no data that provide any information about the actual physical effects on fish. Moreover, as pointed out in the SEIS (4-20), work by Wardle et al. (2001) observed the behavior of several reef fish species in response to exposure to seismic airguns. These authors found little or no reaction to the sounds from the seismic devices, other than a reaction to the visual stimulus of the airguns being in the area. Fish were not damaged in any way that could be observed by TV monitors, and Wardle et al. (2001) noted that there was no reason to think that fish left the reef during the seismic airgun experiments. I note that Dr. Luckzovich did not cite these references in his declaration, although they were provided in the SEIS. 42. Dr. Luczkovich finds the species selected for study to be cause for concern in

paragraph 7 of his declaration. However, as explained below, these species were selected for very logical and scientifically sound reasons. In particular, the rainbow trout is an ideal reference species for endangered salmonids, the species of most concern. The ear of rainbow trout is virtually identical to that of endangered salmonids that live both in fresh and salt water (and/or are able to spend part of their lives in both). I, and not the Navy, chose to use these species. 43. As explained above, it would be impossible to test even those species most likely

to be exposed to LFA to determine effects. Instead, one must examine select species and use them as "reference species" (e.g., species that are very similar to, but not the same as, the species of concern).

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44.

The rainbow trout and the channel catfish are excellent reference species for fish

that do not hear well (trout) and those that do hear well (catfish). The LFA sonar fish experiments published to date have focused on addressing the Court's concerns regarding the potential impact of LFA sonar on the listed salmonids on the Pacific coast of the U.S. from the order Salmoniformes. Since the rainbow trout (a hearing generalist) is of the same taxonomic genus as the Endangered Species Act (ESA)-listed salmonid species on the Pacific coast, it is closely related to the endangered Pacific salmonids, and their major characteristics such as ear structure, hearing capabilities, etc. are very similar to those of endangered salmonids. Thus, rainbow trout can be used as the reference species to determine the potential effects on other salmonid species and, more generally, on other fish species that are hearing generalists. 45. Channel catfish were selected to be the reference species for hearing specialists

for this experiment. While the catfish used in the Seneca Lake studies may not be typical of any species likely to be exposed to SURTASS LFA, using this species does provide us with critical data on effects on fishes with adaptations to make them hear better. Catfish therefore give us important insights into hearing specialists in general. 46. The fact that rainbow trout is a freshwater fish is irrelevant. The nature of the

water habitat (fresh or marine) has no bearing on the hearing apparatus and hearing capabilities, nor would it have any possible impact on any potential effect of the sonar on the fish. We did not use marine species for several good reasons. First, the experimental facility at Seneca Lake is fresh water. Bringing a marine species into this environment would have added considerable complexity to the experiments, plus the potential of killing the test fish if they happened to get out of the apparatus into the fresh water of Seneca Lake. Second, it would not have been environmentally appropriate to use non-endemic (non-native) species in our studies, since such fish would have been potentially invasive (i.e., the fish could have been inadvertently released
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into the lake by accident, and harmed the ecology of the lake). Thus, for these experiments, we were limited to species that are normally found in Seneca Lake. Finally, the Pacific salmonids of greatest concern for the operation of SURTASS LFA are endangered under the ESA. While it may have been possible to obtain farm-raised specimens of the endangered species, it would have been logistically difficult to get the animals to Seneca Lake, because shipment would have been prohibitively expensive, many of the fish would have died in transit, and it would have been difficult to maintain the fishes in the large numbers needed for the experiment. 47. I have reviewed the work mentioned by Dr. Luczkovich in paragraph 5 of his

declaration regarding the effects of dolphin sounds on silver perch. I am indeed familiar with this fish species as I am co-author on a paper generated by my laboratory that examined hearing and ear structure in this species (Ramcharitar et al. 2004). It is critical to note that the responses of the silver perch described by Dr. Luczkovich are to sounds that are well above the range of sounds generated by SURTASS LFA sonar (100 to 500 Hz), and therefore, would not be masked by the sonar. It is also important to note that the silver perch is an in-shore marine species that lives in coastal areas that are shallower than those in which the Navy might use LFA sonar. Conclusion 48. Over the past several years, I have been investigating the effects of intense sounds

on fish. All of this work has been, or will be, published in peer-reviewed scientific literature. The results to date provide insight into potential effects of both seismic airguns and SURTASS LFA sonar on several different fish species. While more work needs to be done with airguns, the data to date suggest that only exposure to the most intense signals, and for relatively extended periods of time, will result in temporary hearing loss in some, but not all, fish species and that there is no apparent effect on the structure of the ear or non-auditory tissues. The work with SURTASS LFA sonar, in my view, shows that while there may be a small effect on some
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samples of rainbow trout, other rainbow trout show no TTS, and no TTS occurred in any other tested hearing generalist (publications in preparation). There are effects on a hearing specialist, a catfish, but there is relatively rapid recovery with no effects on the ear or non-auditory tissues (publication in preparation). Most significantly, the exposure to SURTASS LFA sonar needed to elicit any temporary hearing loss far exceeds any likely exposure of fish in the wild. Thus, it is a reasonable conclusion that SURTASS LFA sonar will not in any way affect the physiology or structure of any fish more than a few hundred meters from a LFA source, if there is any effect at all.

Pursuant to 28 U.S.C. §1746, I hereby declare under penalty of perjury that the foregoing is true and correct to the best of my knowledge, information, and belief.

Executed this 9th day of November, 2007 in Rockville, MD

_________________________

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EXHIBIT A: CURRICULUM VITA OF ARTHUR N. POPPER, PH.D.

Title: Professor, Department of Biology Co-Director, Center for Comparative and Evolutionary Biology of Hearing Address: Department of Biology University of Maryland College Park, MD 20742 University Phone: Fax: E-Mail: Web Site: 301-405-1940 301-314-9358 [email protected] www.life.umd.edu/biology/popperlab

RESEARCH INTERESTS Marine bio-acoustics (the study of acoustic behavior by aquatic organisms). In particular, research emphasis asks questions about: (1) Structure, function, and evolution of the vertebrate auditory system, with an emphasis on auditory mechanisms in fishes; and (2) Effects of human-generated (anthropogenic) sound on aquatic organisms, including effects of high intensity sources and longer-term but lower level increases in background sound. Studies in both areas involve morphological, physiological, and behavioral approaches to help understand hearing mechanisms and capabilities.

PROFESSIONAL EXPERIENCE 2006 - present:Interim Associate Dean, College of Chemical and Life Sciences, University of Maryland
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2004 - present:Adjunct Scientist, Mote Marine Laboratory, Sarasota, FL 1999 - present:Co - Director, Center for Comparative and Evolutionary Biology of Hearing, University of Maryland 1998 - 2003: Director, Neuroscience and Cognitive Sciences (NACS) Graduate Program, University of Maryland 1997 - present: 1996 - present: Aquarium 1987 - present: Maryland 1987 - 1997: Chair, Department of Zoology, University of Maryland, College Park, MD 1989 - 1992: Associate Director, Center for Neurosciences, University of Maryland (Acting Director, 9/90 - 8/91) 1983 - 1987: Professor, Department of Anatomy and Cell Biology, Georgetown University Schools of Medicine and Dentistry 1978 - 1983: Associate Professor, Department of Anatomy, Georgetown University, Washington, DC 1973 - 1978: Associate Professor, Department of Zoology, University of Hawaii 1972 - 1978: Associate Zoologist, Laboratory of Sensory Sciences, University of Hawaii 1975 - 1976: Postdoctoral Scholar, Kresge Hearing Research Institute and Visiting Associate Research Scholar, Division of Biological Sciences, University of Michigan, Ann Arbor, MI 1969 - 1972: Assistant Professor, Department of Zoology, University of Hawaii, Honolulu, Hawaii 1966 - 1969: Teaching Assistant, Queens College and City College of the City University of
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Affiliate Professor, Department of Psychology, University of Maryland Research Scholar, Edgerton Research Laboratory, New England

Professor, Department of Biology (formerly Zoology), University of

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New York 1966 - 1969: Department of Animal Behavior, American Museum of Natural History, New York; Doctoral research on auditory mechanisms and acoustic behavior of fishes.

EDUCATION B.A. (Biology), 1964, New York University, Bronx, NY Ph.D. (Biology), 1969, City University of New York

COURSES TAUGHT University of Hawaii Vertebrate Zoology (comparative anatomy) (undergraduate) Ethology (undergraduate) Evolution (undergraduate/graduate) Animal Behavior (graduate) Seminar in Sensory Biology Seminar in Animal Communications

Georgetown University Dental Neurobiology (organized course and was course director for 2 years) Medical Neurobiology (course director) Seminar in Computer Programming Seminar in Grant Writing

University of Maryland
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Neural Basis of Behavior (seminar) Neuroethology (undergraduate and graduate) Principles of Biology (Freshman Biology) Ethics in Scientific Research Vertebrate Form and Function

AWARDS AND HONORS NIH Predoctoral Fellowship NIH Research Career Development Award (1978-1983) Fellow, American Association for the Advancement of Science (1983) Outstanding Administrator, special recognition award from Maryland Association of Higher Education (1991) Fellow, Acoustical Society of America (1994) Outstanding Faculty Research, College of Life Sciences, University of Maryland (1996) Distinguished Scholar-Teacher, University of Maryland (1999-2000) Federal Highway Administration 2005 Environmental Excellence Award - for Excellence in Ecosystems, Habitat, and Wildlife: Fisheries-Hydroacoustics Mitigation for San Francisco Bay Bridges/Bioacoustics Workgroup (htp://www.fhwa.dot.gov/environment/eea2005/ecosystems.htm)

MEMBERSHIP IN LEARNED AND PROFESSIONAL SOCIETIES Acoustical Society of America (Fellow) American Association for the Advancement of Science (Fellow) American Fisheries Society
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Association for Research in Otolaryngology International Society for Neuroethology Society for Neuroscience

CURRENT GRANT SUPPORT Chief of Naval Operations (Marine Acoustics Inc.): "Effects of high intensity sound," 10/03-3/07. Total Award $672,000. Chief of Naval Operations (N45): "Effects of mid-frequency sonar on fishes," 4/1//06-3/31/08. Total Award, $1,290,401. Pacific Northwest Labs: "Predicting and mitigating hydroacoustic impacts on fish from pile installations," 4/1/06-3/31/08. Total Award, $150,000. National Science Foundation: "Acquisition of Analytical Spectrometers for the Creation of a Regional Electron Microscopy Facility for Research and Education," 9/1/06-8/31/07, Total award $500,000 (L. Salamanca-Riba, PI, Arthur Popper Co-PI). National Science Foundation: "EESE: Maryland Initiative on Research Ethics," 9/1/06-8/31/09, Total award $198,344 (S. Greer PI, Arthur Popper and Robert Dooling Co-PI's). National Institute on Deafness and Other Communication Disorders: "Core Center," 10/03-9/08, Total award $2,350,000 (Robert Dooling PI, Arthur Popper Co-PI). National Institute on Deafness and Other Communication Disorders: Training Grant "Comparative and Evolutionary Biology of Hearing," 1994-1999, 1999-2004, 2004-2009 (1 T32 DC 00046). Total current Award $1,680,000. Office of Naval Research: "International Conference on the Effects of Noise on Marine Animals," 11/06/06 - 6/30/08, Total Award $24,992. Office of Naval Research Global: "International Conference on the Effects of Noise on Marine
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Animals," 11/16/06 - 8/16/08, Total Award $15,000. National Science Foundation: International conference on the Effects of Noise on Aquatic Animals,"12/15/06 - 8/30/08, Total Award, $24,992. National Science Foundation: "Working group on the effects of sound on fish and turtles," 2/1/07-1/31/09, Total Award, $40,000 (via Mote Marine Laboratory)

PAST GRANT SUPPORT Army Corps of Engineers (Normandeau Associates): "Evaluating the Effects of Underwater Noise on the Hearing Sensitivity of Hatchery Chinook Salmon Smolts Barged from the Snake River Basin," 4/1/05-3/31/05, Total Award $114,250. The Conservation Fund: "Effects of aquaculture sounds on fishes, "7/04-12/05. Total award $50,000 National Institute on Deafness and Other Communicative Disorders: "Mechanisms of Ultrasound Detection," 2/99-7/05 (1 R01 DC03936). Total Award $1,340,000. National Institute on Deafness and Other Communication Disorders: "Hearing in Zebrafish," 5/2002-4/2004 (DC-05481). Total Award $75,000 (Robert Dooling Co-PI). Public Service Environmental Group "The Auditory System of Sciaenid Fishes," 7/00-6/02. Total Award $104,747. Maryland Higher Education Commission: "Enrichment of High School Biology Programs in Maryland," 1990-2000 (Dwight D. Eisenhower Mathematics and Science Education Act, P.L. 100-297) (90-03-214 214). Total award over 10 years $1,090,994; current year: $99,500. National Institute on Aging: "Development and Aging in the Auditory System," 1998-1999 (AG015681). Total Award $74,000. National Science Foundation: "Mechanisms of Hearing by Clupeid Fishes," 1996-1999
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(IBN9631354). Total Award $170,000. National Institute on Deafness and Other Communication Disorders: Training grant "Comparative and Evolutionary Biology of Hearing," 1994-1999 (1 T32 DC 00046). Total Award $250,000. Office of Naval Research: "Sound Localization by Fish: Mechanisms and Models" 1994-1997 (N-00014-94-10410). Total Award $340,506. Battelle Pacific Northwest Laboratories: The Structure of the Octavolateralis System in Salmonids: Ontogeny@, 1996-1997. Total Award $79,994. Office of Naval Research: Workshop on Hearing and Acoustic Behavior of Cetaceans, 1995-1996 (N00014-96-1-0130). Total Award $2,250. National Aeronautics and Space Administration: "Evolution of Gravity Receptors in the Ear," 1992-1996 (NAG 2-787). Total Award $155,000. Office of Naval Research: "Effects of Sounds on Hair Cell Receptor Systems of Fish." 1992-1994 (N-00014-92-J-1889). Total Award $167,332. Office of Naval Research: "Acoustic Transduction in Fish, 1987 1994 (supported since 1980) (N 00014 92-J-1114). Total Award $113,610. Office of Naval Research: "US-Russian Workshop on Sensory Biology," 1993-1994. Total Award $28,000. National Science Foundation: "US-Russian Workshop on Sensory Biology," 1993-1994. Total Award $32,000. Office of Naval Research: "Workshop on Recent Advances in Studies of Fish Hearing, 1991-1993. Total Award $20,000. National Science Foundation: "Research Experience for Undergraduates in Neurobiology and Behavior," 1991-1994. Total Award $149,000.
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National Institute of Neurological and Communicative Disorders and Stroke: "Processing of Acoustic Information," 1970 1992. Total Award $1.2 million (7 competing renewals). National Institute of Neurological and Communicative Disorders and Stroke: "Sensory Hair Cell Development in the Ear," 1984 1987 (RO1 NS 21646). Total Award $209,003. Office of Naval Research: "Acoustic Transduction in Fish, 1980 1986. Total Award $223,253. Office of Naval Research: "Electron Microscopic Examination of Biological Tissue, Multi User Equipment Grant, 1984 1985. Total Award $122,000 National Science Foundation: "Conference on Sensory Biology of Aquatic Animals, 1984 1986. Total Award $10,000. Office of Naval Research: "Conference on Sensory Biology of Aquatic Animals," 1984 1986 (N 0014 84 G 0107). Total Award $14,999. National Institutes of Health, Division of Research Resources: "Access to the Prophet Computing System,@ 1980 1987. National Science Foundation: "Ultrastructure and Development of the Ear, 1982 1985. Total Award $95,000. National Science Foundation: "Ultrastructure of the Ear in Fishes, 1980 1982. Total Award $87,356. National Science Foundation: "Multi user Equipment Grant for the Study of Sensory and Other Systems,@ 1980 1