The Navy's Wrongheaded Approach to Whidbey Island Jets - Brian Cullin

According to Brian Cullin, who wrote an opinion piece for the Seattle Times today, the Navy is eventually going to have to figure out how to work with the local citizens instead of rolling over them. He says if it doesn’t, the Navy will inevitably “lose”.

Who is this Brian Cullin, and why does he think he knows anything about this subject?

He is a retired Navy captain who most recently served as a senior adviser at the State Department. In the ’90s he served as assistant White House press secretary in the Clinton Administration.

Here is his letter, below. The original publication with the Seattle Times can be seen here.

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All of COER DEIS Comments - Navy expansion on Whidbey Island

Now that the DEIS comment period is over, we have quite a bit of information we compiled for our official comments.

We’re happy to share them all with you.

Note: these are downloadable files, not pages. Look for the ‘save as’ permission popups to get the files.


Cover Letter

Coalition Resolution

Legal Analysis

All COER Comments

Addendum 1Addendum 2Addendum 3Addendum 4Addendum 5

Governor Inslee's DEIS Comments - Navy Jets - Whidbey Island

Recently (as we hope everyone has), Governor Inslee submitted his comments to the Navy’s Draft EIS proposals. Here are his thoughts on the subject.

A PDF of the original letter with Governor Inslee’s DEIS comments can be seen HERE.

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State Board of Health investigates Island County Board of Health - Jet noise negligence

Can you go to the Washington State Board of Health’s public meeting in Tumwater, March 8th? They are going to discuss the investigation into the Island County Board of Health’s negligence in dealing with the jet noise problem.

If you can, please go and let them know how much this matters. Public support is critical to draw attention to this issue and raise it high on the priority list.

If you want to testify, go to this webpage and submit an online form by FRIDAY 3rd before the meeting. http://sboh.wa.gov/HowDoI/Testify

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The Hidden Costs of NASWI - Whidbey Island

COER has paved the way for other groups throughout the region and on Whidbey Island.

We take pride in our efforts that have supported emerging groups to challenge the Navy’s new and extensive militarization of our communities in Puget Sound: Quiet Skies of Lopez, STOP and POP in the Olympics, the Coupeville Community Allies, the Sustainable Economic Collaborative, The Whidbey Water Keepers, and the Pacific West Coast Alliance, now made up of eleven groups throughout Puget Sound.

We feel validated by The National Park Service that did a six-week Acoustic Study over the Reserve that supported COER’s two independent Noise Studies of real sound in real locations in Central Whidbey. Civilian societies require active citizens to maintain their freedoms.

In 2016, a diverse group of residents of Island County, Washington, with both civilian and military backgrounds, came together to investigate the opportunities and obstacles to building a thriving, just, and sustainable local economy.

They understood that economies like Island County’s that depend on a single large employer—in their case, the US Navy—appear to be strong but actually are quite vulnerable to forces beyond their control. Previous published works had focused on gross wages paid by the Navy, but many other questions were not being asked:

  1. How much of the Navy’s activity was flowing back into the local economy through sales and property taxes, and through purchasing from local suppliers?
  2. What kinds of burdens was the Navy placing on taxpayer-supported services and infrastructure, including schools?
  3. How were existing Navy programs and proposed expansions affecting local health and property values?

To read Invisible Costs by Michael Shuman, find the report by the SEC at: http://sustainable-economy-collaborative.com.


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Join COER Response - Reject Navy DEIS

Your Action Is Requested… Join our Response to the Navy’s DEIS 

COER will be filing its comprehensive response to the Navy’s additional Growler DEIS, including voluminous scientific studies and reviews, in the next few days.  A summary of our comments and points for anyone to review is available below.

Anyone who wants to attach their name as a co-respondent to COER’s response is welcome and encouraged to do so. If you want your name included with COER’s response, simply send us an email authorizing COER to do so no later than this Friday, February 17, 2017. 

The more names attached to COER’s response, the better. 

Our attorney has advised that by adding names, each person added would be able to be a party to any lawsuit based on all of COER’s comments as well as any they may have individually filed. 

Please send your name, address and email to: mbrabanski29@comcast.net by Feb 17th.

Thank you,

COER’s Board of Directors

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Helen Price Johnson Votes for sanity, Rick Hannold and Jill Johnson try to punish Coupeville

Helen Price Johnson, County Commissioner for Central and South Whidbey

An article from the Whidbey News-Times – the original link is HERE: http://www.whidbeynewstimes.com/news/commissioners-deny-grant-calling-coupeville-anti-navy/

Head over to the Whidbey News Times online and let them know your thoughts on this article. Thanks WNT!

In a move highlighting growing tension between North and Central Whidbey, two Island County commissioners are refusing to approve a grant for a community greens project in Coupeville because they believe the community is anti-Navy.

Commissioners Rick Hannold and Jill Johnson, whose districts are in North Whidbey, said they took offense to a series of actions by the Town of Coupeville and Central Whidbey citizens in recent months.

The last straw, they said, was a Coupeville council workshop last week in which council members spoke bluntly about their concerns with the Navy’s plans to increase the number of EA-18G Growlers that conduct touch-and-go landings at the Outlying Field outside of town.

“IT’S A POOR use of tax dollars to support a town that is hostile toward the economic driver of the county,” Hannold told a Whidbey News-Times reporter, pointing out that the funding for the grant comes from sales taxes generated largely because of the presence of Naval Air Station Whidbey Island on the north end of the island.

Johnson doesn’t deny that her decision was political, nor that it will increase the acrimony between Oak Harbor and Coupeville, but she blames Coupeville for starting it. “When you punch someone in the face,” she said, “I don’t think you should be offended when you are punched back.”

Commissioner Helen Price Johnson, whose district covers South and Central Whidbey, argued against the decision.

“Denying access to local economic development funds shouldn’t be used as a tool to punish people who may have a different perspective on a federal issue,” Price Johnson said, adding that decisions regarding two completely separate issues should be kept separate.

COUPEVILLE MAYOR Molly Hughes said she is shocked by the action.

“I feel it’s inappropriate to mix their personal feelings about one subject with a funding decision in a completely different matter,” she said, adding that she may look into taking legal action.

It’s inaccurate to label an entire community as “anti-Navy” just because some citizens and leaders asked questions and expressed concerns, Hughes said, noting that the two commissioners never met with her or council members to discuss the issue.

The plan for the community green includes the addition of a public bathroom, lighting, increased parking and other improvements to a 3.9-acre open space in the center of town.

The town applied for a $600,000 grant from the rural county economic development funds.

Under the program, the state credits the county back 0.09 in state sales tax. The funds are administered by the county commissioners.

THE COMMUNITY GREENS project was approved by an economic development group that reviewed grant applications as well as the Council of Governments. Hughes said the project received nothing but positive comments.

But Hannold and Johnson put the kibosh on the town’s application Wednesday.

“I’m not turning the cheek anymore on something that matters this much,” Johnson told the News-Times.

Convergence of two Navy-related issues late last year precipitated the recent focus on the Navy and its impact on surrounding communities.

First, the Navy released a draft Environmental Impact Statement, or EIS, on plans to add 35 or 36 Growlers stationed at NAS Whidbey. That would translate to a 47 percent increase in operation, including aircraft carrier landing practice at Outlying Field Coupeville.

TWO CITIZEN groups in Coupeville raised concerns about the increase in jet noise. One group, Citizens of Ebey’s Reserve, sued the Navy to require an EIS and publicly protested Growler noise.

A new group, Coupeville Community Allies, stated it isn’t anti-Navy and is focused on educating the community about the draft EIS.

Both groups — as well as the Navy — encouraged citizens to submit comments about the EIS to the Navy during the ongoing comment period.

The town hired a couple of professionals to evaluate the draft EIS and prepare comments. The council discussed the draft comments last week.

Some council members expressed concerns about how an increase in noise will impact the way of life in the rural landscape, as well as the town’s tourism and agrarian economy.

A draft letter states that a five- or six-fold increase in jet operations “is inconsistent and not tolerable to everything we have worked for in Coupeville and Central Whidbey.”

IN A SEPARATE issue, the Navy started testing drinking water wells near OLF Coupeville and the Ault Field base for a potentially harmful chemical that’s found in firefighting foam. The town conducted independent testing of wells that are near OLF Coupeville.

One of the chemicals was detected but at levels well below the lifetime health advisory level set by the EPA.

Hughes said she believes it would be irresponsible not do independent testing, but Hannold said the town could have just trusted the Navy’s results.

“They apparently don’t need the money,” he said of town officials. “They had money to do their own EIS, their own water tests and to double the pay of the mayor.”

THE STANCE on Coupeville taken by Johnson and Hannold has the potential for impacts beyond the town’s grant request.

Councilwoman Pat Powell is also the director of the Whidbey Camano Land Trust, which has a history of partnering with the county and has received grants in the past through the county’s Conservation Futures Fund. The fact that Powell is part of the Coupeville council won’t be lost on him when grant applications come around again, Hannold said.

“I would be lying if I said it wouldn’t be in the back of my mind,” he said.

Letter to Editor: Growlers no Boon to Whidbey

This letter was sent to the South Whidbey Record, and since we don’t hear so often from the folks in the south of the island, we thought we’d share his excellent points.



Clinton man Steve Gutzmer wrote in a recent letter to the editor that the projected Navy influx to Whidbey is a boon. From his quiet armchair, drinking clean water, the patriotic concept of Navy fighters training on Whidbey sounds uplifting. I live in quiet Langley. Several of my friends in and around Coupeville live right under the Growler-buzzsaw flightpaths and it ain’t pretty.

Quiet-dwelling Gutzmer: “The Growler is much quieter than the Prowler.” Simply wrong. Even the Navy insists they are equal, yet downplays their huge “sound spectrum” difference. Reputable Wiley Labs asserts Growler “low frequency sound pressure levels” dwarf that of Prowlers. Translated: they “rumble your insides” (your house too). Many Coupevillians signed early mortgages, tolerated the Prowlers, but find Growlers a whole new animal. Sure, a jackhammer-volumed jet roar (100+ dB) at 200-400 feet over your roof loses its thrill 40-80 times a day, three times a week, nights included. Then it’s PTSD hell. (The Navy wants 100/day, four-plus days/week!) Frazzled, anxious, and sleepless with heart, blood pressure, and organ issues, their animals act weird, their children cower in adult laps, hands on ears. Not a “boon.”

Gutzmer: “then simply move.” There’s no “simply.” Flight-lane property values spiral downward; other properties (yours Mr. Gutzmer?) are dramatically up. Sell at a loss and move? Try it! Some are worse off; wells recently testing high in cancerous PFOS (fire foam) chemicals leached from a polluted well at Outlying Field Coupeville.

Gutzmer: “the Navy brings more students; increases tax base.” Reality: crowded Oak Harbor School District now has huge yearly deficits as military families on government land, buying at the commissary, pay miniscule local taxes. The Navy skimps on paying “compensation” to Oak Harbor. Navy “immigrants” use our infrastructure and public services supported by our taxes. Now Navy personnel crowding is already raising rents over much of the island.

Am I “Navy, go away?” No. “Be a better neighbor?” Yes. “Training flights elsewhere?” Yes. Suitable alternatives on vast Washington, California and Nevada Navy-owned lands are already used for overflow flights. The Navy knows it’s inserting a humongous training foot into a petite Whidbey shoe, at citizens’ expense. The very real risk factors for a catastrophic crash, don’t get me started on all the factors! Unsolved cockpit oxygen issues still haunt. Twenty-two Growlers and F-18E/F cousins have already crashed elsewhere. No boon, sir!



Elected Officials Request Navy to Extend DEIS Comment Period for Whidbey Island

NEWS RELEASE January 4, 2017

Contact: Cate Andrews (612) 306 -4800

Maryon Attwood (360) 6781414



Larsen, Murray, and Cantwell Join Citizen Organizations in Request for Navy to Extend Comment Period on Environmental Impact Statement


Congressman Rick Larsen, Senator Patty Murray and Senator Maria Cantwell cosigned a January 3, 2017 letter to Assistant Secretary of the Navy asking that he “extend the ongoing public comment period” on the Navy’s plans to increase EA-18G Growler jet operations on Whidbey Island.

The January 3 letter from the elected officials followed a December 20, 2016 New Release issued by a Coalition of citizen organizations calling for an extension of the Navy’s January 25, 2017 deadline for receiving public comments on its controversial expansion plans outlined in a Draft Environmental Impact Statement (DEIS).

The Navy’s DEIS proposes drastic increases in ‘Growler’ jet numbers and over-­‐all operations on Whidbey Island. Growler operations and their adverse environmental, economic and public health impacts have been the subject of litigation and the source of noise complaints from throughout the Puget Sound region.

COER and other coalition organizations, including Friends of the San

Juan’s, Concerned Island Citizens, Oak Harbor; Quiet Skies Coalition, Lopez Island, Protect the Olympic Peninsula, Save the Olympic Peninsula, North Olympic Group, Sierra Club; Protect the Olympic Peninsula, Whidbey Environmental Action Network, Washington Physicians for Social Responsibility, and Veterans for Peace requested an extension of the comment period.

On December 20, 2016 coalition members met with representatives of Governor Jay Inslee to request his support for an extension of the Navy’s deadline and to voice concerns over existing and planned adverse impacts of Growler operations over Whidbey Island, the San Juan Islands, and the Olympic Peninsula.

On December 23, Mayor Molly Hughes of Coupeville, where the Navy wants to conduct up to 65,000 Growler operations a year, became the first Whidbey Island public official to request an extension.

“Our organizations generated hundreds of calls, emails and letters to our public officials urging them to take this action,” said Cate Andrews of Citizens of Ebey’s Reserve (COER). “If the Navy grants this extension, it will be because citizens took the lead and the elected leaders followed, “she said. “We are still waiting on the Governor and other local politicians to express their much needed support for this extension,” she added.

According to COER’s attorney, the Navy’s 1,400 page document contains “highly complex technical analysis” that requires more time to review. This includes the Navy’s reliance on “complex computer modeling” instead of actual measurements to analyze the noise impacts of proposed increases in operations.

The attorney’s December 19 letter to the Naval Facilities Engineering Command Atlantic stated that the request for an extension should also be granted due to the ongoing investigation of toxic contamination of private and public wells that supply drinking water, according to the attorney.

The Navy notified the owners of more than 100 private and public drinking wells of potential contamination on November 7, 2016. A growing number of public and private wells have been found contaminated with chemicals first discovered on Navy property. The Navy’s investigation is ongoing and an increasing number of residents are being told by the Navy not to drink or cook with their water.

Perfluorooctanoic Acid found in the their drinking water has been linked to kidney and testicular cancers, birth defects, damage to the immune system, heart and thyroid disease, and complications during pregnancy. EPA’s Science Advisory Board labeled it a likely human carcinogen.

“We appreciate the elected officials’ support for an extension,” said COER board member Maryon Attwood. “We hope they will consider speaking out against the harmful operations the Navy is conducting and is proposing in their Draft Environmental Statement.”

Here's what you can do to fight the Navy DEIS for Whidbey Island

Here’s what you can do to help—Be Heard!

Comment Deadline is February 24, 2017.

Here’s How in Five Easy Steps:

  1. Go to the Navy’s draft EIS comment page by copying and pasting into your browser: http://whidbeyeis.com/Comment.aspx
  2. Fill out the form (name, etc.). Under Agency/Organization put, “Abused Citizen of the USA” or something like it
  3. Cut and paste one comment from below into the comment box
  4. Hit Submit
  5. Repeat one comment at a time for as many or all of the comments below (Note: that the more individual comments on a given subject the more weight they must place on that concern or problem area of the draft EIS.)
Note: if you prefer to send written comments via the US mail, send them to:

EA-18G EIS Project Manager

Naval Facilities Engineering Command (NAVFAC) Atlantic

Attn: Code EV21/SS

6506 Hampton Blvd.

Norfolk, VA 23508


  1. The DEIS did not comply with the National Environmental Policy Act (NEPA) by failing to judiciously examine off-Whidbey Island sites to conduct flight carrier land practice (FCLP).
  2. The annual Day-Night Noise Level (DNL) noise contours depicted in the DEIS are misleading and fallacious for two reasons: (1) inappropriate use of 365-day averaging rather busy-day averaging, and (2) holding up as scientifically valid an outdated, misleading, and scientifically invalidated DNL threshold for high noise annoyance.
  3. The DEIS claim that the JGL noise study was “flawed” is disingenuous and unsupportable, whereas in actuality the Wyle modeled noise levels have not been validated with on-site noise data.
  4. The DEIS misconstrued important finding of the National Park Service’s 2015 noise study at Ebey’s Landing Historic National Reserve and obfuscated forthright analysis of the impacts on visitor experience. That misconstruction has to be credibly revised to properly characterize the real impacts.
  5. Much like the tobacco industry did years ago, the DEIS selectively and reprehensively cites and relies on out-of-date medical research findings on impacts of noise on human health that are at odds with the overwhelming body of contemporary research. This obfuscation renders the DEIS findings incomplete and disingenuous and demands an honest, complete, forthright evaluation of the contemporary formal medical literature.
  6. The Navy has adopted standards that protect their personnel from health and hearing harm due to excessive noise, yet these standards were ignored by the DEIS for civilians exposed to the same or greater levels of noise. This DEIS needs to examine how many civilians would receive exposure doses that exceed the Navy’s defined “hazardous noise zone” threshold (i.e., an area where the 8-hour time-weighted average exceeds 84 dBA [or 140 dB peak sound pressure level, SPL, for impact or impulse noise] for more than 2 days in any month).
  7. Island County has unconscionably ignored the Navy’s 2005 AICUZ land-use directives for Outlying Field Coupeville, especially as reflected by construction permits issued in Noise Zone 2 areas, where the AICUZ stipulates no residences should occur, as well as other land uses. Whether due to the County’s willful intent to ignore or due to lack of Navy assertiveness, it aptly demonstrates the meaningless and ineffectiveness of the AICUZ and similar land-use provisions in the DEIS. Given the alternatives under consideration in the DEIS, the Navy should immediately advocate that the County place a moratorium on all construction permits not compatible with the 2005 AICUZ and DEIS land-use stipulations until the final EIS is approved.
  8. The two most dangerous aspects of flying are the approach, landing and takeoff — in other words most of the OLFC flight path. The risks are significant (a) because of unrestrained and major encroachment problems, (b) because OLFC is about 49,000 acres below and the runway about 3000 feet short of FCLP standard for Growlers, (c) because the pilots are mostly students flying the F-18 airframe which is 5.5 times more likely to crash than its EA-6B (Prowler) predecessor, and (d) FCLP operations occur at low elevations that increase likelihood of bird strikes exacerbated by the significant shoreline bird population. These risks cannot be mitigated other than by moving the FCLPs to a suitable 21st century off-Whidbey site.
  9. Environmental Justice analysis overlooked the fact that farm workers, gardeners, and recycle center workers are almost entirely composed of low-income and/or ethnic minorities, and because they must work outside, they are disproportionately affected by overhead Growler noise.
  10. Perfluoroalkyl substances (PFAS) have been discovered in numerous wells adjacent to OLFC and are believed attributable to fire-retardant foam use at OLFC. The DEIS, however, dismissed addressing the related past, present, and future impacts and problems associated with PFAS, even though the EPA has set a Health Advisory that has been exceeded by 16-fold in some of the impacted wells. Leakage of PFAS in storage or their use in a crash event is a hugely relevant environmental impact that must be addressed. And the public must be given the opportunity to comment.
  11. The DEIS noise levels were based on about 30% of the proposed 8800 to 35,000+ operations at OLFC being conducted on Path 14. Since 2013, when the transition to Growlers was relatively complete, the highest use of Path 14 has been about 2 to 10% because, as base commander Captain Nortier explained Growlers are only rarely capable of using Path 14. The DEIS 30% use projection of path 14 greatly understates the DNL noise impacts for path 32 and overstates the impacts on Path 14. This mistake must be corrected.
  12. The DEIS fails to address the potential effects of sleep disturbance due to Growler overflights, despite the admission that there will be an increase in the “percent probability of awakening for all scenarios…”  While music torture is still permitted under US law, the United National Convention against Torture defines torture as “any act by which severe pain of suffering, whether physical or mental…”  Sleep disturbance results in serious physical and emotional symptoms such as cognitive impairment, impaired immune system, adverse birth outcomes, risk of heart disease, risk of diabetes, not mentioning the number of work hours/days lost from lack of sleep. The DEIS must forthrightly address the impacts of sleep disturbance on residences affected by OLFC night operations.
  13. The DEIS obfuscates the effects of FCLP jet noise on classroom interruptions by averaging interruptions with periods when jets are not practicing. The average understates interruption events compared with event frequency during FCLP sessions, which are as frequent as an interruption every 1-2 minutes. Interruptions of such frequency complicate teaching and thwart student concentration and break the focus of teacher and student. In addition the EPA states, “Noise can pose a serious threat to a child’s physical and psychological health, including learning and behavior,” but the DEIS has not recognized the contemporary research. These oversights and failings must be properly addressed and reanalyzed.
  14. The DEIS fails to address the effects of noise on hearing and tinnitus and consequential medical costs associated with hearing loss by stating that civilians would need to be exposed to noise emitted by the Growlers for 40 years before there is a permanent shift in hearing.  This defies all scientific and audiological evidence to the contrary, even by the US military itself.  Hearing loss and tinnitus are the MOST compensated injuries in the military and increasing annually (US Dept. of Veteran Affairs.) That and failure to address the effects of impact or sudden noise must be more fully delineated.
  15. The DEIS fails to adequately address the effects of high noise levels during pregnancy that provoke significantly higher risk for smaller newborns, gestational hypertension, cognitive abnormalities, and permanent hearing loss.