The governor already expressed concern over the program in its earlier versions considered during an environmental review last year, including the possibility of vessel strikes and exposure of marine mammals to sonar.
Southern resident orcas are struggling for survival. Lack of adequate salmon, disturbance by boats and vessel noise and pollution are the three main threats scientists have identified to orca survival.
In addition to the issues Inslee raised, state agency directors stated the underwater equipment the Navy intends to use in anti-submarine exercises is much louder and more potentially damaging over a longer range than acceptable, and needs closer consideration of its effects.
The cumulative damage of military exercises also is inadequately considered, the agency directors said.
The program is estimated to inflict disturbance and varying levels of low-level harm on 68% of the southern resident population, according to Navy estimates. The cumulative effects on so many whales for so many years could cause the whales to abandon their home waters and key foraging areas, and even permanently damage the orcas' hearing, agency directors said.
The Navy's proposal to use lookouts to detect the presence of whales also is inadequate, agency directors stated, because orcas and other marine mammals are so rarely at the surface. Instead, the officials said, the Navy should rely on real-time alert systems to detect the presence of whales, such as those used by Washington State Ferries.
Even that is far from perfect, as the collision of a state ferry with a humpback whale showed earlier this month.
Attorney General Bob Ferguson blasted the testing program in his own letter to NOAA last week. While some of the program is a continuation of past activities, undersea warfare and sonar testing didn't get the hard look it should have from NOAA, Ferguson said, who contended the agency's finding of negligible impact was arbitrary and capricious and violates the Administrative Procedure Act.
The agency also didn't adequately consider the effects of noise from Growler overflights, Ferguson said, which the Navy recently authorized under a separate action to increase by 33%.
Some orca scientists said they were appalled at the military testing program, particularly given how small and fragile the southern resident population already is, at only 72 animals, the lowest population in 40 years.