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APZs Not Up To Navy Requirements

APZs (accident potential zones) are areas where an aircraft mishap is most likely to occur.

APZs follow departure, arrival, and flight pattern tracks and are based on analysis of historic data. The AICUZ includes three APZs: the Clear Zone, APZ I, and APZ II. The Clear Zone extends 3,000 feet beyond the runway and has highest potential for accidents. APZ I extends 5000 feet beyond the Clear Zone, and APZ II extends 7,000 feet beyond APZ I.

Per the 2005 AICUZ, the OLF is a class B runway. The APZ I area for a class B is 3000' wide by 5000' long. The APZ II area is 3000' wide by 7000' long. Neither APZ designations have been created for the OLF, because it was determined in 2005 that the frequency of flights was too few to require them. Nevertheless, the Navy criteria for establishing APZs have been exceeded at OLF Coupeville. The Clear Zone should be 3000' long, and in our case part of it is owned privately. As well, the number of flights has more than tripled since 2005, so the need to officially recognize the APZs at OLF Coupeville is past time for evaluation.

Island County has allowed development around OLF, including the Whidbey Island Transit District building, which is in an APZ I crash zone. Admiral's Cove, another example, is a 400 home housing development, which by current Navy safety regulations, should be an APZ I. A recreational County Park, a dog park, and a commercial zone are located inside the potential crash zones.

The fact that the safety requirements are not being met, and the unsafe location of the OLF is counting on 'nothing ever going wrong' to avoid catastrophe is bad enough under the best of conditions, but in our case the OLF is specifically used to train inexperienced pilots, who do not stick to flight paths or flying protocols as accurately as experienced pilots.


Naval Audit Service, Interim Audit Report N2009-0008, 31 October 2008

"According to PMA265 representatives, the F/A-18E/F aircraft emits, and the EA-18G will emit, a maximum of 150 dBs, which is well above the noise level considered hazardous to hearing (greater than 84 dBs). According to PMA265, they made no initial attempts to mitigate the flight-line/deck jet noise hazard through design selection. This is contrary to the system safety design order of precedence specified in the MIL-STD-882D

PMA265 representatives stated that they did not pursue minimizing noise generated by the F/A-18E/F engines through design because warfare sponsors (Commander, Naval Air Forces representatives) did not identify noise requirements as KPPs within the Operational Requirements Document (ORD).

PMA265 did not attempt to mitigate the jet noise hazard in the initial design and development of the aircraft, did not follow required guidance relating to risk levels and risk acceptance authority levels, and did not track the flight-line/deck jet noise hazard and its residual mishap risk. These conditions may contribute to a hazardous environment of high noise exposure associated with jet aircraft that, according to the Naval Safety Center, increases the likelihood of permanent hearing loss to sailors and Marines.

PMA265 representatives stated that many flight-deck personnel exceed total daily exposure limits in approximately one launch while wearing hearing protection that provides 30 dBs attenuation."

E2S2 Symposium –May 2009

USN currently not compliant with the following standards:

•DoD Design Criteria Std., MIL-STD-1474D, Noise Limits, page 65, para 4.2.1, Aircraft Noise

•DoDI 6055.12, Hearing Conservation Program

•OPNAVINST 5100.23F, Navy Occupational Safety and Health Program Manual

•NAVMEDCOMINST 6260.5 Occupational Noise Control & Hearing Conservation

•AFOSH STD 48-19, Hazardous Noise Program

•AFOSH STD 161-20, Hearing Conservation Program

•OSHA 29 CFR, Occupational Noise Exposure

•85 dBA, 8 hrs, 3 dB/doubling exchange rate