Another Port Townsend EIS comment, EA18G noise, a regional problem

TO: U. S. Navy
EA-18G EIS Project Manager (Code EV 21/SS)


I am submitting the following letter regarding EIS Whidbey.
The OLF was not used for the second half of 2013, during which time training has been conducted elsewhere. Less populated areas should be considered for Touch & Go traffic required for training. This would make it safer for everyone including the 
Navy families living under the planes. Yakima is an option with airfields and 
facilities to accommodate staff. It is less than ten minutes by growler to eastern WA. &
 these planes all ready use this area regularly.

I have come to this conclusion for the following reasons:
NOISE: The Navy considers any sound above 84dB as noise hazardous, or having the potential to cause hearing loss. The F/A-18E/F Growler aircraft emits, a maximum of 150 dBs, high enough to result in permanent hearing loss. Actual noise levels and frequencies need to be determined by measurement throughout the affected area, not just in the immediate vicinity of the OLF. This includes throughout central and north Whidbey, including Coupeville and Oak Harbor, all affected state parks and the affected portion of Olympic National park, affected portions of Skagit County, Port Townsend, San Juan County, and on the water where boaters may be subjected to the noise. Real-time high noise events experienced with each touch-and-go operation should be measured rather than averages over periods when the jets aren’t even flying.

The economic impacts of noise generated by Growler jet operations also need to be disclosed. These include reduction in property values; reduction in income due to lost work opportunity and productivity (e.g., inability to perform time dependent farm work due to Growler noise), economic health costs, and reduction in recreation and tourism.

The adverse noise impacts to wildlife must be studied and disclosed. In particular, impacts in areas where there are aggregations of birds should be determined, including Crockett Lake, Smith and Minor Islands, and areas of Puget Sound. This includes not just resident individuals, but periodic visitors (e.g., migrating birds). Noise impacts to listed species which may not occur in large aggregations, particularly Marbeled Murrelet, also need to be considered. Due to the frequency profile of the sound made by Growler jets, there is also the potential for noise impacts to marine mammals. Additionally, impacts of noise on livestock also need to be disclosed.

HEALTH: Aircraft noise can permanently damage hearing, raise blood pressure, and harm livestock and wildlife, and children have greater susceptibility to harm. Studies include those by: the World Health Organization, the US Department of Transportation, and the US Environmental Protection Agency. The EIS needs to consider the variable ages of the affected human population especially youth in the Coupeville school system There needs to be particular consideration of travelers in motor vehicles, boaters, people recreating at all of the affected state parks, etc. Results should be presented in terms of impacts to individuals (i.e., exposure thresholds resulting in hearing loss) and populations (i.e., such as the increased rates of cardiovascular disease.

The Navy needs to disclose any existing data regarding fuel dumping it may have and, if there is none, disclose this lack of data. Second, a formal monitoring program needs to be put in place that will log and record instances of fuel dumping, including where the dumping occurred, jet speed and elevation, and how much fuel was dumped. This system should operate with a system allowing members of the public to report fuel dumping. These results need to be evaluated both in terms of human and animal (livestock and wildlife) health and effects on vegetation, including forest trees. Investigation of impacts of fuel dumping on forest canopies also needs to consider possible impacts of wind created by low flying jets. This review must also consider impacts to aquatic systems, including both freshwater and marine waters that may be receiving dumped fuel.

The impacts to human and animal health from electromagnetic radiation from antenna farms & radar installations needs to be investigated and disclosed. NAS Whidbey’s greenhouse gas emissions should be disclosed, including that portion attributable to touch and go carrier training.

SAFETY: Flights over populated areas pose potential safety problems. Pilots and residents are at risk when the Navy uses this short, outdated World War II era OLF. Keeping it open will cause some of the people of Coupeville permanent hearing loss; air pollution from fuel dumps in the air; risk of jets crashing into civilians’ houses.

ENVIRONMENT: The OLF sits next to Ebey’s Landing National Historic Reserve, a 24,000-acre National Park of environmental, cultural, and historical significance and an important wildlife and migratory bird habitat, supporting recreational/tourist use and appreciation. Please fully consider the real effects of OLF operations on these significant values. Air Pollution and Climate Change Pollution from jet aircraft releases harmful greenhouse gases that will contribute to climate disruption.

REAL ESTATE VALUES: Home sales in that area have shown a steep decline from 2008 to 2012, whereas sales in Langley and Freeland and in Island County, as a whole, have increased during that period. With the continued jet problem this downward spiral is certain to escalate.

 The EIS needs to address weed control around OLF, particularly of Canada Thistle, blackberry & Scotch Broom. There are several rare plants and communities present on NAS Whidbey including forest at Rhododendron Park, prairie remnants on Smith Prairie (including the presence of the federal and state listed Golden Paintbrush, the rare forest types along Whidbey’s west coast, Admiralty Inlet Natural Area Preserve, and various plant communities in both the affected state and national parks Without active management, degradation is predictable and should be discussed.

GEOLOGIC IMPACT: An examination of the possible impact of aircraft noise and ground vibrations on the various island slide areas including in the Ledgewood Beach community and the bluff collapse at Chetzemoka Park in Port Townsend.

Thanks for receiving my testimony

Doug Milholland

Port Townsend WA

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