FINAL REMINDER: Comments due August 8th

Final Reminder: August 8 2017 - Comments to Department of ecology

FINAL REMINDER: Comments are due to the Department of Ecology by August 8th. Email them to: ecyrefedpermits@ecy.wa.gov.

Public comments are most useful if they address issues of air quality, water quality and integrity of the coast/shoreline (this includes wildlife and recreation).

The Washington State Department of Ecology (DOE) is conducing a federal permit consistency review on the Navy’s proposal to expand E/A-18G Growler operations at the NAS Whidbey Island (NASWI) Complex, which as you know, involves a 6-fold increase in operations at Outlying Field (OLF) Coupeville.

The Navy’s permit application can be found here.

DOE is reviewing the Navy’s proposal in light of its responsibility for the Coastal Zone Management Act. Under this act, DOE has to see whether the permit meets its enforceable policies, which include:
• The Shoreline Management Act
• State Environmental Protection Act (SEPA)
• The Clean Water Act
• The Clean Air Act

COER’s comments are more detailed – so please use suggested comments by CCA if you haven’t sent anything in yet.


Coupeville Community Allies has recommended the following comments:

1. Air quality

The increase in Growler CO2 emissions related to the proposal for expansion are not taken into account in the Navy’s application. The expansion would increase tons of CO2 emitted from air operations to by 40-60% to almost 178,000 metric tons. These emissions would have a profoundly negative effect on the climate and the local air quality, and are in direct conflict with Washington State’s laws and regulations to reduce CO2 emissions.

Background: The Navy’s proposal would result in an overall doubling of air operations, from 21,000 per year to an average of 42,000 per year when spread over Ault Field and Outlying Field Coupeville [Table 2.3.2 of the Navy’s Draft Environmental Impact Statement (EIS)].

The Navy omitted the CO2 emissions of its operations in its greenhouse gas analysis in the DEIS. Its CO2 emissions were not included in its Department of Ecology permit submission. The Navy did calculate these emissions, but buried them in the DEIS Appendix B.

NASWI’s current air operations emit 99,000 metric tons of CO2 annually, almost 10 times the CO2 emissions of the remainder of base operations (11,000 metric tons). Another 10,000 metric tons of CO2 are emitted by personnel commuting to work, rivaling the emissions of the base itself.

Per the Navy’s analysis, CO2 emissions caused by air operations (and commuting) will rise by another 39,000 to 57,500 metric tons per year, bringing emissions as high as 178,600 metric tons of CO2 emitted annually by all of NASWI. (DEIS Table 4.4-19, appendix B, page 49). The Navy feels “the level of impact of these [mobile] emissions is inconclusive”, though admits that mobile emissions can affect compliance with National Ambient Air Quality Standards. This is an inconsistent message given NAS Whidbey’s efforts to reduce CO2 emissions on the main base, and the recognition it has received for doing so.

Ironically, the Navy has excluded consideration of other airfields for the Growler expansion (NAS Lemoore, CA and MCAS El Centro, CA) because the impact of their operations would worsen air quality. ( DEIS, Chapter 2, pages 2-15 to 2-16).

The State of Washington, however, has laws about greenhouse gas emission. Per RCW 70.235.020:

The State shall limit emissions of greenhouse gases to achieve the following limits for Washington State:

  • By 2020, reduce overall emissions of greenhouse gases in the State to 1990 levels
  • By 2035, reduce overall emissions of greenhouse gases in the State to 25 percent below 1990 levels
  • By 2050, the state will do its part to reach global climate stabilization levels by reducing overall emissions to 50 percent below 1990 levels, or 70 percent below the State’s expected emissions that year

A 40-60% increase in greenhouse gas emissions due to the Navy Growler expansion is completely incompatible with Washington State Laws and Initiatives. Even if NASWI could run on zero energy, it would not be enough to compensate for the major increase CO2 emitted by air operations.

2. Water quality

Increases in operation increase risk of continued aquifer contamination with aqueous film forming foam (AFFF) used to fight fires on airstrips.

Background: Aquifers at Ault Field and Outlying Field (OLF) Coupeville are currently contaminated with perfluroalkyl compounds (PFCs) from aqueous firefighting foam, with many wells far above the EPA lifetime limit of 70 ppt. The Navy is continuing to use its large stockpiles of PFC containing AFFF, with no current mitigation plan for residents.

The region surrounding OLF Coupeville, including coastal wetlands, is dependent on groundwater, as Whidbey Island is served by an EPA determined sole-source aquifer. The sparse rainfall (18 inches per year) and proximity to the shoreline create a high risk of saltwater intrusion for deeper wells. The existing PFC contamination, and threat of additional contamination with increased OLF operations, is a high risk to the precious groundwater resource.

3. Impact to wetlands

A proposed 6-fold increase in operations at OLF heavily impacts local wetlands, and increases the risk of bird strike, and aircraft mishap.

Background: In the field carrier landing practice (FCLP) path of OLF is Crockett Lake, which borders Keystone Spit and Admiralty Inlet. According to the Audubon Society, Crockett Lake is “a critically important migration staging area for 17 species of shorebirds, and for raptors such as peregrine falcon and merlin that follow the migration south. The lake provides winter habitat for bald eagles and nine species of ducks. Whidbey Audubon Society has observed 213 species at the site.”

Large flocks of ducks and Canada geese use Crockett Lake as a stopover, and fly between the lake and local agricultural fields daily where they feed – directly through the FCLP flight path. Seagull nesting off Admiral’s Cove seasonally disturbed and fly up into on-coming aircraft. This is a major Bird Aircraft Strike Hazard (BASH). Aside from killing and disturbing the birds, a crash resulting from a BASH incident would be a major environmental catastrophe.

4. Decreased public access to coastline areas in shorelines of significance due to the public impact of increased operations and noise

Background: The extreme increase in noise levels resulting from a 6-fold increase in flight operations at OLF will reduce public access to the coastline areas near the flight paths. The Shoreline Management Act prioritizes public access to shorelines of significance in the State, which includes all coastal access on Whidbey Island.

Around Coupeville these areas include Fort Casey State Park, Keystone Spit (State and County parks), Fort Casey Underwater Park, Washington State Ferries Coupeville landing, Keystone Conservation Area, Admiralty Head Marine Preserve, Admiralty Inlet Natural Area Preserve, Ebey’s Landing National Historical Reserve, Coupeville Town Park and Captain Coupe’s Park and Boat Launch. There are many similar public shoreline access areas in the region that will similarly be affected (e.g., Port Townsend and San Juan Islands).

5. Increased risk of fuel dumping

An increase in flight operations means an increased risk of emergency fuel dumping into marine waters of the Strait of San Juan de Fuca and the waters of Puget Sound, both shorelines of statewide significance. The Navy needs to release data on frequency of fuel dumping under current operational configuration so that the Department of Ecology can assess the impact of fuel dumps on the marine environment.

Background: Federal regulations and Navy procedure require fuel to be dumped at 6,000 feet above ground elevation to allow the fuel to atomize before reaching the ground. During emergencies it is often not possible to climb to a higher altitude to dump fuel, and it has to be dumped at a lower level. To our knowledge, the Navy must track, but has not publicly reported, the amount of fuel dumped locally from operations at NASWI.

As there are shorelines of significance and wetlands on the approach to OLF, we ask the Department of Ecology to ask the Navy for this information. With a 6-fold expansion of flights at OLF comes the increased risk for fuel dumping on this sensitive environment.


Email the Department of Ecology at: ecyrefedpermits@ecy.wa.gov.

You may also mail your comments (postmarked by 8/8) to:

Department of Ecology
SEA Program
Federal Project Coordinator
Post Office Box 47600
Olympia, Washington 98504

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