800,000 strong National Parks Conservation Association supports COER efforts

From: David Graves
Subject: Code EV21/SS EA-18G EIS Project Manager – Scoping Comments
Date: January 2, 2014 at 11:12:42 AM PST
To: “‘'”

January 3, 2014

EA-18G EIS Project Manager (Code EV21/SS)
NAVFAC Atlantic
6506 Hampton Blvd.
Norfolk, VA 23508

Dear Sir or Madam:

The National Parks Conservation Association (NPCA) appreciates the opportunity to provide scoping comments on the EA-18G Growler Airfield operations at Naval Air Station, Whidbey Island, WA. NPCA represents more than 800,000 members and supporters and is concerned with potential negative impacts this project may present to Ebey’s Landing National Historical Reserve.

Ebey’s Landing National Historic Reserve (the Reserve) is a 24,000-acre national park of environmental, cultural, and historical significance located on Whidbey Island. The Reserve protects the agricultural and cultural traditions of Ebey’s Landing – both native and Euro-American – while offering spectacular opportunities for recreation. NPCA believes the following issues deserve a detailed analysis in the Environmental Impact Statement (EIS) being developed for this project:

· Wildlife – The Reserve is an important wildlife and migratory bird habitat that is in the vicinity of an antiquated World War II landing strip, the OLF, that is used by the Navy for practice exercises. The wildlife species and migratory birds in this area may be negatively impacted by the noise and air pollution caused by these operations. The impacts to migratory birds and other wildlife from these operations should be closely analyzed in the EIS.

· Visitor Use and Enjoyment – Many visitors to the Reserve enjoy the peace, tranquility, and silence this area provides. The Navy’s own audit found that its jet aircraft emit noise well in excess of the normal human pain threshold. Training flights have occurred at all hours of the day and night and often continue for extended periods of time. Nearby residents experience high levels of jet noise even within their shuttered houses. The potential negative impacts to the use and enjoyment of the Reserve should be considered carefully in the EIS.

· Public and National Park Service (NPS) Employee Safety – These training exercises, particularly those at the Outlying Landing Field (OLT), occur within a populated area and present accident and health hazards to the public and park service employees. The OLT runway may lack proper clearances for safe take offs and landings and should be considered for closing. Furthermore, some tests found that maximum sound levels from Growlers using the OLF were well above the levels requiring hearing protection and are high enough to potentially result in permanent hearing loss. Finally, the EIS should analyze the various health effects of aircraft noise, including permanent hearing damage, blood pressure and cardiac problems, how children have a greater susceptibility to jet noise, and the health effects of exposure to toxic jet aircraft pollution. These potential dangers to the public and NPS employees should be closely analyzed in the EIS.

· Economics – The louder and more frequent use of the OLF since 2006 has devastated the local real estate market. Home sales in the OLF area have shown a steep decline from 2008 to 2012, compared to increases in Langley, Freeland and Island County in general. A cost/benefit analysis should be completed in the EIS.

· Air Pollution and Climate Change – NPCA is concerned with the negative impacts to the air and climate potentially caused by this project. Pollution from jet aircraft may have an impact on the visibility and air quality of the Reserve and release tons of harmful greenhouse gases that will contribute to climate disruption. An analysis of these potential impacts must be completed.

In conclusion, a detailed analysis of the impacts to wildlife, visitors, public safety, economics, and air quality must be completed in the EIS. Finally, the OLF has not been used for nearly six months, during which time flight training has been safely continued elsewhere, proving that the Coupeville OLF is not an essential facility. Closure should be a viable alternative considered in the EIS.

Thank you for considering these comments and we look forward to reviewing the Draft EIS.


David G. Graves
Northwest Program Manager
Northwest Regional Office

National Parks Conservation Association
1200 5th Ave, Suite 1925
Seattle, WA 98101
PH: 206-903-1645
Cell: 206-462-0821
FX: 206-903-1448

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