December 5, 2013
EA-18G EIS Project Manager (Code EV21/SS)
6506 Hampton Blvd.
Norfolk, VA 23508
Re: EIS to evaluate the potential environmental effects associated with ongoing and planned EA-18G Growler airfield operations at NAS Whidbey Island’s Ault Field and Outlying Landing Field (OLF)
We appreciate the opportunity to provide comments as part of the Navy’s scoping process to identify community concerns and issues to be addressed in the EIS for the EA-18G Growler Airfield Operations at the Naval Air Station on Whidbey Island. Our comments are on behalf of the 800 Sierra Club members on the North Olympic Peninsula directly affected by the extremely loud noise generated by the Navy’s training exercises in the area.
Whidbey Island, where these facilities are located, is a vibrant, beautiful, and historic region that has been adversely affected by the extreme aircraft noise from the Navy’s training flights. Ebey’s Landing National Historic Reserve, a 24,000-acre national park of environmental, cultural, and historical significance has been particularly affected. 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 touch and go exercises.
In addition to adversely affecting wildlife, 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 and visitors are unable to avail themselves of state and federal park and recreational lands during these times.
These training exercises, particularly those at the Outlying Landing Field (OLF), also occur within a populated area and present unacceptable accident hazard to residents and visitors. The OLF is an antiquated World War II runway that lacks the proper clearances for safe take offs and landings and it should be closed.
For these reasons, the Sierra Club’s North Olympic Group joins with local citizens in requesting the Navy address the following concerns in the Environmental Impact Statement (EIS) being prepared for EA-18G Growler Airfield operations at the Naval Air Station on Whidbey Island:
Scope: The scope of this EIS should be expanded to include all EA-18G and EA-6B operations at the Coupeville OLF and at Ault Field as no Environmental Impact Statements have ever been completed studying the impacts from these operations on local communities and the environment. Local communities affected should include those on Whidbey Island as well as those in neighboring Skagit, Jefferson, and Clallam Counties.
Noise: Real-time high noise events experienced with each operation should be examined rather than averages which include periods when the jets do not fly. Recent 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.” Real measuring and not computer modeling should be the test.
Health: Address the numerous peer-reviewed studies documenting 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 harm to livestock and wildlife. Studies include those by: The World Health Organization; The U.S. Department of Transportation; and The U.S. Environmental Protection Agency. The health effects of exposure to toxic jet aircraft pollution should also be studied.
Safety: Consider how flights over populated areas pose potential safety problems. Pilots and residents are at risk whenever the Navy uses the short, outdated World War II era Coupeville OLF.
Environment: The OLF is adjacent to Ebey’s Landing National Historic Reserve, a National Park of environmental, cultural, and historical significance and an important wildlife and migratory bird habitat. Ebey’s Reserve supports valuable recreational, tourist, agricultural and wildlife uses. The effects of OLF flight operations (both noise and pollution) on these uses must be considered.
Property Values: Consider how 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.
Alternatives to OLF: 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. The Navy should close the outdated Coupeville OLF and permanently relocate all EA-18G and EA-6B flight training to safe, state-of-the-art facilities in non-populated areas.
Thank you for your attention to our concerns,
Chair, North Olympic Group Sierra Club