Whidbey Environmental Action Network
Restoration Education Preservation
Box 53, Langley, WA USA 98260
(360) 579-4202 firstname.lastname@example.org
Dedicated to the preservation and restoration of the native biological diversity
of Whidbey Island and the Pacific Northwest
Dec. 31, 2013
TO:Naval Facilities Engineering Command Atlantic
6506 Hampton Boulevard
Norfolk, VA 23508
Attn: Code EV21/SS EA-18G EIS Project Manager
RE: Comments by Whidbey Environmental Action Network
Below are Whidbey Environmental Action Network’s comments regarding the scope of the EIS for NAS Whidbey.
1. Scope of EIS improperly limited.
The scope of the EIS as described in the Federal Register is improperly limited. The notice states that the ongoing EA–18G Growler jet operations will be used as the baseline. However, there has been no proper or adequate environmental analysis of the impacts of the existing Growler jet operations. Additionally, some aspects of NAS Whidbey operations that have been ongoing for even longer have never been subjected to environmental analysis and review, e.g., fuel dumping; limited definition of the entire impacted area. The EIS must address all significant impacts, including those resulting from existing Growler jet operations throughout the entire affected area.
2. Notification inadequate.
The Navy has failed to properly notify communities and interests throughout the affected area of the opportunity to submit comments on the scope of the EIS. The existing Growler jet operations adversely impact portions of four counties (Island, including both Whidbey and Camano Islands; Skagit; San Juan; and Jefferson counties), multiple state parks, and one National Park. Yet, there was no notification of the public, elected officials, or agency managers outside of a limited portion of Island County. The Navy needs to adequately notify these communities and interests, and extend the scoping comment deadline.
3. Data collection needs to be commenced.
The resumption of operations at the outlying field (“OLF”) south of Coupeville needs to be used as an opportunity to collect data on several aspects of Growler operations, particularly noise, and air and water quality as they are affected by fuel dumping. Data collected needs to be considered in light of the episodic spike in flights and fuel dumping that typically occur with the end of the fiscal year due to “use it or lose it” budget requirements.
4. Adverse noise impacts.
Adverse noise impacts need to be thoroughly studied and disclosed in the EIS, considering both the magnitude (loudness) and frequency range. Actual noise levels and frequencies need to be determined by measurement throughout the affected area, not just in the immediate vicinity of the OLF. This includes throughout central and north Whidbey, including Coupeville and Oak Harbor, all affected state parks and the affected portion of Olympic National park, affected portions of Skagit County, Port Townsend, San Juan County, and on the water where boaters may be subjected to the noise. Actual noise measurements should be used and not obscured by “averaging,” a method commonly used to attempt to obscure and downplay noise impacts.
a. Adverse noise impacts to human health.
The EIS needs to consider the variable ages of the affected human population (especially youth using the Patmore Road ball field and all schools in the Coupeville school system) and both immediate and chronic impacts to human health, including hearing damage, elevated blood pressure, stress, loss of sleep, etc. There needs to be particular consideration of exposed cohorts that have no refuge from the noise, e.g., travelers (measurements should be made of noise volumes in motor vehicles), boaters, people recreating at all of the affected state parks, etc. Results should be presented in terms of impacts to individuals (i.e., exposure thresholds resulting in hearing loss) and populations (i.e., epidemiological statistics, such as the increased rates of cardiovascular disease and resulting mortality for exposed populations).
b. Other adverse noise impacts to humans.
The economic impacts of noise generated by Growler jet operations also need to be disclosed. These include reduction in property values; reduction in income due to lost work opportunity and productivity (e.g., inability to perform time dependent farm work due to Growler noise), economic health costs, and reduction in recreation and tourism.
c. Noise impacts to wildlife and livestock.
The adverse noise impacts to wildlife must be studied and disclosed. In particular, impacts in areas where there are aggregations of avifauna should be determined, including Crockett Lake, Smith and Minor Islands, and areas of Puget Sound. This includes not just resident individuals, but periodic visitors (e.g., migrating birds). Noise impacts to listed species which may not occur in large aggregations, particularly Marbeled Murrelet, also need to be considered. Due to the frequency profile of the sound made by Growler jets, there is also the potential for noise impacts to marine mammals, both listed and unlisted. The degree to which the peculiar noise generated by Growler jets penetrates into the subsurface marine environment needs to be determined and disclosed, as well as any potential adverse impacts to marine mammals. Additionally, impacts of noise on livestock also need to be disclosed.
5. Fuel dumping.
No environmental analysis has ever been conducted for fuel dumping at NAS Whidbey. Reports by local residents strongly suggest that this increases dramatically during the increased operations that usually occur at the end of the fiscal year. First, the Navy needs to disclose any existing data regarding fuel dumping it may have and, if there is none, disclose this lack of data. Second, a formal monitoring program needs to be put in place that will log and record instances of fuel dumping, including where the dumping occurred, jet speed and elevation, and how much fuel was dumped. This system should operate in tandem with a well publicized easy-to-use system allowing members of the public to report fuel dumping. Third, experimental dumping should be conducted with data collection including: elevation and plane speed; local weather at the time; amount dumped; duration of discharge; and fate of discharged material at varying distances, including in terms of standard air pollutant standards. These results need to be evaluated both in terms of human and animal (livestock and wildlife) health and effects on vegetation, including forest trees with associated epiphytes whose upper portions are more exposed. Investigation of impacts of fuel dumping on forest canopies also needs to consider possible impacts of wind created by low flying jets. This review must also consider the rare status of some of the plant communities that may be impacted, including forest at Rhododendron Park, prairie remnants on Smith Prairie (including the presence of the federal and state listed Golden Paintbrush (Castilleja levisecta), the rare forest types along Whidbey’s west coast, Admiralty Inlet Natural Area Preserve, and various plant communities in both the affected state and national parks. Impacts to aquatic systems, including both freshwater and marine waters, that may be receiving locations for dumped fuel and it byproducts also needs to be investigated.
6. Electromagnetic radiation pollution.
The impacts to human health from electromagnetic radiation from antenna farms, radar installations, etc. on human and animal health needs to be investigated and disclosed. Anecdotal information regarding the ‘antenna farm” off of West Beach suggests that that facility was adversely impacting human health. Emission from other NAS Whidbey facilities need to investigated to determine the range and strength of their emissions on human and animal populations in surrounding areas.
7. Greenhouse gas emissions.
NAS Whidbey’s greenhouse gas emissions should be disclosed, including that portion attributable to touch and go carrier training. Existing and proposed mitigations should also be disclosed.
8. Cement block barricade around OLF.
We were told at the Coupeville scoping meeting that an environmental categorical exclusion was issued for this action, despite its location at the southern entrance to Ebey’s Landing National Historic Reserve, a unit of the National Park System. This proximity was not even considered, since the OLF is not within the Reserve boundaries. This rationale for avoiding proper environmental review is not consistent with NEPA’s plain statutory requirements or relevant appellate law, which have long held that a “hard look” at significant impacts must be taken. The conclusion by the Washington Department of Archaeology and Historic Preservation that this action has an adverse impact on cultural resources simply states the obvious. The Navy must perform an EIS for this action, including of the aesthetic impacts to the Reserve. Combining it with the larger operations EIS would make sense, but in any event, the Navy must perform proper environmental review of this action.
9. Impacts of human population increase.
The impacts of the human population increase attributable to the NAS operations must also be studied. This includes socioeconomic impacts, including effects on Oak Harbor’s crime rate (e.g., rates of domestic abuse, and violent crime), load on social services (e.g., rates of alcoholism and domestic abuse) and economic burden on local public schools. The economic costs to the City and County of dealing with these impacts must also be addressed.
10. Vegetation management.
There does not appear to be any coordinated management of vegetative resources, including both weeds and rare plants and communities. While a coordinated vegetation management plan would be advantageous, in any event the EIS must address the impacts of weeds and lack of management of rare plants and communities.
a. Weeds at OLF.
Since haying of OLF was ended, there have been complaints about that area serving as a source of wind borne weed seed that affects area farms, particularly Canada Thistle (Cirsium arvense). Ideally, regardless of air operations, NAS Whidbey would create a formal management plan for the vegetation at OLF. This might range in complexity up to restoration of native plant communities (e.g. prairie). While this approach would be preferable, cheaper, lower maintenance, and easier in the long run, in any event the EIS needs to address weed control around OLF. This must also consider the likelihood that the area immediately surrounding the newly placed cement barrier blocks (see above) will be prone to bird disseminated (via defecated seed) weed invasion, particularly of invasive blackberry.
b. Scotch Broom (Cytisus scoparius) infestations.
There are extensive areas of NAS Whidbey that are heavily infested with Scotch Broom (Cytisus scoparius). Based on soil mapping, these areas were formerly conifer forest, Oak woodland and savanna, or prairie. The EIS should discuss the impacts of leaving these areas in their current degraded state.
c. Rare plants and communities.
There are several rare plants and communities present on NAS Whidbey, including an Oregon White Oak-Snowberry association and the listed Golden Paintbrush occurrence on the sea plane base. There does not appear to be any ongoing active management of these. Without active management, degradation is predictable and should be discussed.
These comments are perforce limited in scope because of the restricted comment period. We would welcome an extension of that comment period so that we might present more comprehensive comments on the scope of the proposed EIS.
Navy Jet Noise EIS scoping issues, preliminary
1. impacts of jet noise, fuel dumping, and exhaust pollution on visitor experience in State Parks:
ii. Deception Pass (including islands)
iv. Joseph Whidbey
v. Fort Ebey
vi. Fort Casey
vii. Ebey’s Landing
Ebey’s Landing National Historic Reserve
2. impacts of jet noise, fuel dumping, and exhaust pollution on native plant & animal species and communities in:
State parks (as listed above)
National Park units (as called out above)
Nature Conservancy Lands
Pacific Rim Institute
3. impacts of land use and management on prairie ecosystem at:
NAS Whidbey Island (Garry oak savannah)
4. impacts of new wells and water rights on water table in watershed surrounding golf course.
5. Impacts on the visitor experience of being excluded from 21 miles of shoreline surrounded by state and national park units.
6. Impacts of runoff from large areas of impervious surface into wetlands and aquatic environment.
7. Impacts of increased NAS population.
8. Impacts of NAS activities on T&E species on NAS Whidbey.
9. Impacts of electromagnetic disturbance from antenna farms, radar installations, etc on human and animal health.
10. Off-site impacts of low flying jets (noise, fuel dumping, exhaust pollution) in remote areas of the Cascades and eastern Washington on humans and animals.
11. Impacts of jet noise, fuel dumping, and exhaust pollution in the San Juan islands.
12. Impacts of jet noise, fuel dumping, and exhaust pollution on Camano island.
13. Aesthetic impacts of new ecology block/cable enclosure around OLF Coupeville.
14. Impact on wildlife/ habitat of new ecology block/ cable enclosure around OLF Coupeville.