Letter to ACHP: Navy’s Plan is Incompatible with Community Purpose

This letter was submitted to the ACHP (Advisory Council on Historic Preservation), in response to their request for community comments concerning the Navy’s stated plans to drastically increase jet training volume and tempo over the Ebey’s Landing Historical Reserve.

This is one story about the historic nature of Whidbey Island, which is now at risk of irreversible destruction. There are many more.

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January 3, 2019

The Honorable Leonard Forsman, Vice Chair
Advisory Council on Historic Preservation
via Whidbeyislandcomment@achp.gov

RE: NASWI expansion EIS impacts upon the Walter S. Crockett Sr. Farm

 

Dear Mr. Forsman:

My name is Paula Spina and I am the Managing Member of Crockett Farm, LLC, (a Washington State Limited Liability Corporation) the owner/operator of the remaining acreage and structures that formed the core of the 1851 Colonel Walter Crockett land donation claim above Crockett Lake in Central Whidbey. Unfortunately, we were unable to attend the ACHP meeting held in Coupeville on December 19, 2018. As a party directly impacted by current U.S. Navy flight operations at the Coupeville Outlying Field (“OLF”), I am submitting this letter to you addressing our concerns regarding the June 16, 2018, “Section 106 Determination of Effect for the EA-18G ‘Growler’ Airfield Operations at the Naval Air Station Whidbey Island Complex” (“106 DOE”) and specifically with regard to the inevitable impacts of any increase in operations at the OLF upon the historic property and structures we steward.

The Colonel Crockett Farm (“Crockett Farm”) is located approximately two miles to the southwest of the Coupeville OLF. Growler operations flying on Path 32 fly directly down Crockett’s Prairie and over the Crockett Farm.

A Brief History

Colonel Walter Crockett, Sr., was a close friend of famed Colonel Issac N. Ebey. Colonel Ebey and Colonel Crockett’s son Samuel were the first European settlers to establish permanent land claims in Central Whidbey circa October 1850. In 1852 Colonel Crockett, the remainder of his family and Colonel Ebey’s wife and sons joined Colonel Ebey and Samuel Crockett on Whidbey Island. The Colonel Walter Crockett donation land claim was filed in October or November of 1851 at the southern end of what would come to be known as Crockett’s Prairie (“Crockett Prairie”).

Colonel Walter Crockett was one of the original settlers of what is now Ebey’s Landing National Historical Reserve (“the Reserve”) and figures prominently in Central Whidbey history. In addition, his sons Samuel Crockett, John Crockett, Walter Crockett Jr., Charles Crockett, and Hugh Crockett were all original settlers. Samuel, John, Charles and Hugh Crockett all had early donation land claims on the Crockett Prairie. Hugh Crockett was the first sheriff of Island County. Walter Crockett Jr. served for four years as Island County Commissioner, and was a member of the Washington Territorial Legislature in 1873 and of the State Legislature in 1893. The Crockett family is a significant part of the early history of Central Whidbey, Island County and the State of Washington.

Of Colonel Walter Crockett’s original 640 acre donation land claim approximately 11.5 acres, including the Crockett home, barn, motor shed and chicken coop, are owned by Crockett Farm LLC. I personally own another (approximately) 27 acres of the original claim upon which is sited the historic granary. In addition, one of the two historic blockhouses built by Colonel Crockett in 1855 survives and is located on Ft. Casey Road just off the property we own. In 1973 the Colonel Walter Crockett Farm was listed on the National Registry of Historic Places as a cluster of Contributing Structures (Crockett home, barn, granary, motor shed, chicken coop, and separately the blockhouse).

The provenance on the history of the Crockett home is unclear. The immediately preceding owners, the Whitlows, claimed that portions of the home dated back to the 1850s. Our belief is that it is much more likely that the original portions of the house were constructed in the 1870s, probably by the Lovejoy Brothers, shipwrights out of Port Townsend. We base this belief on certain exterior construction elements that the house has that are trademarks of the Lovejoy Brothers later construction in the Town of Coupeville. Also, the provenance is clear that Walter Crockett, Jr. hired the Lovejoys in 1894/95 to construct the Crockett barn. It is possible that the Crockett home was the first Lovejoy “country” Victorian built on Whidbey Island.

The Crockett barn is also unique. We have been told that it is the only example of a hip-roofed barn in the Pacific Northwest, a style brought from the east by the Crocketts. The barn features a stone foundation and original growth fir beams and boards constructed in a mortise and tenon fashion. There are two levels to the barn. The upper level was used primarily for hay storage. There is one cupola that provided the air flow to dry the hay. The lower level has two root cellars set off on the west side while the remainder was used for housing horses and cattle. All of these features are preserved and visible to the public today.

Although active farming remains the primary activity on most of the Crockett Prairie, farming, other than haying, is no longer feasible or practiced on the 11.5 acres that contain the contributing structures of the Crockett Farm. Prior to 1980 many of the structures on the Crockett Farm had fallen into disrepair. On October 1, 1984 Robert and Beulah Whitlow purchased the Crockett Farm. In 1985, after making substantial repairs, they opened the Crockett home as a full-time bed and breakfast and wedding venue. In 2004, desiring to retire, they closed their bed and breakfast business and put the property up for sale.

Crockett Farm LLC purchased the property from the Whitlows in November 2005 and set about reestablishing both the bed and breakfast and the wedding trade. The interior of the barn resembles an Elizabethan era theater with its fir beams and board walls and is a favorite gathering place for the public.

Navy OLF Flight Operation Impacts on Use

During the time the Whitlows ran the Crockett Farm and for the first six years of Crockett Farm LLC’s tenure Navy operations at the Coupeville OLF primarily consisted of EA6-B “Prowler” training flights. The Prowler’s flight pattern was tighter and its noise and vibration levels less than the EA18-G “Growler.” The Navy also provided a responsive citizen complaint line when Prowler pilots strayed near the Crockett Farm.

Prowler pilots seldom flew directly over the Crockett Barn and never over the Crockett House. In addition, operational numbers during these years were minimal compared to the current Navy plan. As a result, neither bed and breakfast nor wedding guests at the Crockett Farm were significantly impacted by Navy operations at the OLF. The Whitlows were able to make a nice living for themselves operating the Crockett Farm, and Crockett Farm LLC was able to begin funding major renovations.

The introduction of the EA18-G “Growler” in 2011 brought about the end of most bed and breakfast operations at the Crockett Farm. The Growler’s power plant creates much more thrust than did the Prowler’s resulting in a wider and louder flight path. Pilots regularly began flying directly over the Crockett Barn and noise issues became extreme. Scheduling became a problem. Local business operators including the Crockett Farm were unable to plan around future operations at the OLF due to the Navy’s inability, or unwillingness, to provide a realistic schedule of upcoming flight operations.

Upon receiving published Navy flight operations schedules, the Crockett Farm bed and breakfast manager would immediately notify all future guests impacted that flight operations were scheduled. Most guests immediately cancelled their reservations not wanting their stay to be impacted by Growler jet noise. Growler flight operations often bore no resemblance to the published schedule, flying when not scheduled and not flying when expected. Operations became much more frequent and numerous. In 2012 Growler operations topped 9,000 operations.

It became impossible to schedule guest stays during the week and ultimately we were forced to suspend all bed and breakfast operations other than those associated with the weekend wedding business. Even under the current operational limit of 6,120 annual operations we have found it impossible to reopen a weekday bed and breakfast trade in the Crockett home.

There would be absolutely no possibility of reopening or reorganizing a bed and breakfast trade at the Crockett Farm under the Navy’s planned increase to 24,000 annual operations.

In response to the destruction of our bed and breakfast trade due to Growler operations, we came to rely upon our wedding business for financial stability. Weddings at the Crockett Farm typically include an outdoor wedding rehearsal on Friday evening, an outdoor wedding ceremony on Saturday afternoon, followed by reception activities both outdoors in the gardens and inside the historic barn. The Crockett home is also offered as a guest house, with most wedding parties opting to stay on Friday and Saturday nights. We also offer Sunday afternoon weddings, usually without any access to the Crockett home unless the Saturday wedding previously declined its use.

In 2018 the Crockett Farm hosted a total of 28 weddings along with 14 guest stays in the Crockett home. This trade enabled us to fund the maintenance and preservation of the historic structures at the Farm and also to make the Historic Crockett Barn available for public events at no charge. These public events included the 11th Annual Ebey’s Community Pot Luck (all ten of the previous potlucks have also been in the Crockett barn) and a first ever Solstice Ball. We also provide ready access to the public to the gardens and grounds at the Farm so that the public can experience and enjoy the history of the Crockett settlement.

Last year the Coupeville High School seniors took their class graduation photograph in front of the Crockett Barn. Bicyclists and tourists regularly stop to view the buildings. Artists can frequently be found painting the sights at the Crockett Farm. All of this public access is only possible because we can raise the revenue through adaptive use (such as the wedding trade) to preserve and maintain the buildings and grounds.

Should the Navy’s proposed operational increase in Growler flights out of the OLF be approved or allowed our wedding trade will be lost completely to us. We will not be able to schedule weddings, being unable to rely upon the accuracy of any Navy scheduling. Furthermore, for the Navy to fly 24,000 operations at the OLF it can be reasonably foreseen that the OLF will be in continuous operation including Fridays and Saturdays. This is hinted at by the Navy as the EIS only states that there will be no operations on Sunday mornings.

It is also interesting to note that the Navy has not provided any form of sample calendar of operations in its EIS so that the actual impact upon businesses and residents can be understood. Weddings and Growler operations cannot co-exist. If the Growler expansion goes through as planned by the Navy, neither a bed and breakfast nor a wedding business will be possible at the Crockett Farm.

The question therefore arises as to whether there are other adaptive uses to which the historic structures at the Crockett Farm can be put.

We see only one other possible use for the Crockett home: as a single family residence. However, the home is not constructed to the noise suppressing standards required for single family residences near the Coupeville OLF. To render the home suitable as a single family residence would require a major renovation that in all likelihood would mean the loss of the historical integrity of the building.

To make the building suitable as a residence would mean losing an important contributing structure in the Reserve. To retain the contributing structure would mean leaving it vacant or subjecting its residents to unwelcome and health damaging noise. Additionally, turning it into a private residence would remove the public’s access to experience the home.

The situation with the Crockett barn is even more extreme. The structure of the Crockett home is in fairly good condition after the series of repairs we have completed so that regular maintenance is all that is required at this time. The Crockett barn requires much more maintenance and renovation. The southeast wall of the barn needs to be completely rebuilt soon and the cedar shake roof is aging and will need replacing within ten years.

To perform these repairs in accordance with the Secretary of Interior’s requirements requires considerable funding. The current wedding business is providing much of that funding. If the wedding business has to be shut down the only possible remaining adaptive use for the barn, without destroying its historical integrity, would be as a storage space as the barn can no longer be used for agricultural purposes. Rent for miscellaneous (or even agricultural) storage could never provide the funding necessary to preserve the Crockett barn.

There simply is no other adaptive use other than using the barn as a public gathering venue, and that is not possible with Growlers flying overhead. Without an adaptive use that can provide sufficient funding for these renovations, it will be too costly to preserve the historic barn. When the roof finally goes, the rest of the structure will follow and yet another contributing structure will be lost to the public.

As stated, the historic structures of the Colonel Walter Crockett Farm were listed as a cluster on the National Register of Historic Places in 1973. In addition to the Crockett home and the barn, the other structures that are part of the cluster include the Granary, the Motor Shed, and the Chicken coop. We have already completed significant repairs to the Motor Shed, but both the Granary and Chicken coop need expensive repairs.

These structures all rely upon the funding derived from operating the home and barn. They have no adaptive uses that could provide funding of their own. Should the home and barn stop providing adequate funding from their respective adaptive uses because of expanded Navy flight operations at the Coupeville OLF the other historic structures at the Crockett farm will all deteriorate and be lost as well.

Damage to Structures from Vibration

As detailed in the August 15, 2018 Citizens of Ebey’s Reserve Review (“COER Review”), the Growler aircraft produces far more low-frequency noise (“LFN”) than their Prowler predecessor. LFN travels further than higher frequencies because its attenuation rate is less. LFN travels through walls, and other relative hard surfaces, because its reflection rate is far less than higher frequencies. Hence, LFN produces more noise-induced vibration, and that is problematic for structures. (COER Review pages 7 to 8).

The foundations of the Crockett barn are rough cut field stone and mortar. The foundations have solidly stood since the barn was built by the Lovejoy brothers for Walter Crockett, Jr. in 1894/95. Earthquakes since then have not damaged the foundations. We have, however, experienced a rapidly increasing fracturing of the mortar in the foundation wall concurrent with the arrival of the Growler at NASWI and flights out of the OLF. This deterioration is readily observable with the mortar turning to powder.

The problem is growing more expansive with each passing year of Growler operations. There have been no other possible causes for the mortar to suddenly start failing at the Crockett Farm; so there is no other explanation for the damage we are encountering other than the vibrations caused by Growler operations. Additional Growler operations at the level sought by the Navy in its expansion EIS will inevitably cause even more crumbling of the foundations’ mortar. There are areas in the barn where failing mortar cannot be seen or accessed yet will weaken the foundation unless repaired. Given expanded vibrations for sufficient period of time the Crockett barn foundation will inevitably become unstable rendering the building unfit for use.

As the barn is the only contributing structure with an exposed stone foundation, we haven’t seen any other visible signs of negative impact from Growler vibrations upon the other structures. That is not to say there is no other physical impact, rather it has been much more obvious with the stone as opposed to the wooden structures.

The Navy dismissed these potential impacts upon structures from noise induced vibrations in its EIS. The COER Review points out in detail how the Navy’s explanation is flawed and scientifically unsupportable:

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Assessment of Growler FCLPs on Historic Structures.

—The 106 DOE asserts that,

The DNL metric is the current standard for assessing potential effects to historic properties because it factors the number, frequency, and energy (loudness) of noise events. The DNL metric is a cumulative measure and represents long-term noise exposure rather than a sound level heard at any given time, which makes it appropriate for assessing long-term direct and indirect auditory, visual, and atmospheric effects to historic properties (page 25).

The Navy contradicts itself in making that assertion. As discussed below, the 106 DOE concludes that 130 dBC is the approximate threshold for vibrational noise damage. Hence, by selecting the A-scale DNL average as the metric to evaluate noise damage to buildings, there can be no damage because the DNL says nothing about how long or how often that 130 dB is approached or exceeded. That is, the DNL hides the damaging component of noise in the same way that the average New Orleans wind speed in 2005 provides no insight whatsoever about the damage caused by 150 mph winds of Hurricane Katrina.

Pressure is the damaging component of sound that can cause solid surfaces to vibrate. The greater the noise, especially LFN, the more intense the pressure and the greater the vibration. There are a number of other metrics that could be used that would quantify the amount of damaging noise exposure (e.g., sound equivalent level, maximum un-weighted Z-scale). So again, why has a misleading metric been used instead of an informative one?

Pages 59-61 of the 106 DOE, briefly discuss the only studies done on historical structures from jet (the supersonic Concord) noise, but there is no data or information to indicate what the dBC noise levels were at the buildings studied. Nor does the 106 DOE describe structural aspects of the historic buildings evaluated and how they may differ or be similar to the Reserve’s structures. Absent that critical information, the two cited studies cannot be credibly related to the Reserve’s structures and are of little value or pertinence.

The 106 DOE, however, goes on to reference a 2012 study at NAS Whidbey Island that:

…suggested that sounds lasting more than 1 second above a sound level of 130 C-weighted decibels (dBC) are potentially damaging to structural components (Kester and Czech, 2012),” but that none of the conditions evaluated for the study caused C-weighted sound levels to exceed 130 dBC…[albeit] takeoff conditions had C-weighted sound levels greater than 110 dBC for both types of aircraft, creating an environment conducive to noise-induced vibration (Kester and Czech, 2012).

This does not inform what the dBC levels were during takeoff but if they were conducive to noise-induced vibration, presumably they were at or near 130 dBC.

Importantly, the type of Ault Field area structures examined in that 2012 study are not described to permit their comparison to historic structures on the Reserve. That is, were the structures contemporary to-code buildings or older historic ones? We also noted that the Kester and Czech 2012 is not included in the literature cited section, i.e., is it a peer-reviewed publication in the formal literature?

Nevertheless, the 106 DOE does seem to waffle on the applicability question:

Because of a wide range of variations in building code and aircraft types, the U.S. has yet to develop a precise threshold for adverse effects to the integrity of buildings and structures. Therefore, this study [the 106 DOE] applies the same standards used in the 2012 noise study for the assessment of noise and vibration from Navy airfield operations to historic properties within the APE.

So, presumably the 130 dBC for >1 second is the Navy’s accepted standard.

In 2016, the National Park Service (NPS) conducted a 31-day noise monitoring study at two historic buildings in the Reserve: the Reuble Farmstead [approximately under Path 32] and the Ferry House [further away]. The highest recorded sound pressure level was 113 dBA during FCLP activity over the Reuble Farmstead (note, that was the A-scale, not the C-scale, which will always be greater).

The NPS study evaluated the A-scale that affects human reactions, and not C-scale, which manifests the potential for vibrational damage. The 106 DOE, however, concluded that “it is unlikely that sound pressures would approach a peak unweighted sound level greater than or equal to 130 dBC, which is the level that would be considered potentially damaging to structures at those locations.”

It may well be that 130 dBC is a realistic threshold for structural damage, or it could be less for ancient structures, but we are willing to accept that 1 second at ≥130 dBC is perhaps a general threshold to induce noise damage.

However, we reiterate that noise levels have to be measured on site. So why has the Navy strenuously resisted and on-site evaluations of Growler noise in spite of the fact they know that several credible published studies have shown modeled noise to significantly underestimate on-site monitoring.

Because the Navy provided no on-site monitoring, COER hired noise expert, JGL Acoustics, to examine noise under OLF path 32 in June 3013 and again in February 2016 . Among other metrics, JGL recorded maximum un-weighted peak noise levels of 131 to 134 dB at five separate recording locations under the Path 32 flight path. Two of those stations were less than a mile from the Crocket Barn and the Reuble Farmstead.

NOTE: the maximum un-weighted noise levels JGL recorded equaled or exceeded Navy’s 130 dBC threshold for noise damage.

As a result, the JGL findings, the only un-weighted peak levels recorded on site and on two separate occasions, strongly indicate a potential for vibrational damage to historic structures. The A-scale data for both the 2016 NPS sound study and the two JGL sets of recordings are quite similar, supporting the veracity of each.

So, whereas the 106 DOE concludes that it is “unlikely that sound pressures [in the Reserve] would approach a peak unweighted sound level greater than or equal to 130 dBC,” the information presented above shows that peak unweighted sound level is over 130 dB on nearly every fly-over. While the 106 DOE dismisses any likelihood of Growler damage to Reserve structures, the information here indicates the Navy’s conclusion is not supported with reliable data. In contrast, mutually supportive on-site recordings (JGL and NPS) strongly indicate that structural damage is actually quite likely.

Source: (COER Review pages 8 through 11)

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In the previous section I discussed how the ability to use the Crockett home and barn to produce revenue for maintenance and renovation purposes is essential for the preservation of the historic Crockett Farm contributing structures. With regard to the damage being done to the barn, and possibly other buildings, from Growler noise induced vibrations, there is no means of mitigating the damage. The only mitigation is to remove the source of the vibration.

Conclusion

The importance of Ebey’s Landing National Historical Reserve cannot be overstated. In preserving the early history of the settlement of Whidbey Island there is no other similar historical reserve anywhere in the Pacific Northwest. The Town of Coupeville is the second oldest settlement in Washington State after Tumwater. The two first settlements are connected. Colonel Crockett’s son Samuel was part of the 1845 founding of Newmarket, later renamed Tumwater, in disputed territory with Colonel Michael T. Simmons and George Bush (the first African American in the Territory).

It was only in the next year, 1846, that the Oregon boundary dispute was finally settled between the U.S. and Britain placing the boundary between the two countries at the 49th Parallel. As previously stated, Samuel Crockett later accompanied Colonel Ebey in exploring settlement possibilities on Whidbey Island. The Reserve is the closest thing that the Pacific Northwest has to Williamsburg, Virginia. Preservation of this early history is of such importance as to merit Congress creating the designation and establishing Ebey’s Reserve as the first of its kind in the nation.

The first two agricultural settlements on Whidbey were at Ebey’s Prairie (originally settled by Colonel Ebey) and Crockett Prairie (settled primarily by Colonel Crockett and his sons). When the Reserve was being established it was recognized and designated that the order of preservation priority would be Ebey’s Prairie followed by Crockett Prairie. The essential importance of Crockett Prairie to the Reserve was understood and established in the formation of the Reserve.

This importance was not only due to the fact that the Crockett Family were, along with the Ebey Family, the original settlers of Central Whidbey, but also because the Crockett Prairie retains more historic contributing structures than anywhere else in the Reserve with the exception of the core of the Town of Coupeville itself. More early agricultural history remains accessible to the public in the Crockett Prairie than elsewhere in the Reserve.

Despite the historical importance to the public of the Crockett Prairie, the Navy’s preferred flight path, Path 32, is concentrated directly down Crockett’s Prairie as opposed to Path 14 (which impacts newer, non-contributing structures and far fewer historical sites and structures). The primary public access to the southern portion of the Reserve is on the Crockett Prairie side of the OLF, not in the private residential areas on the eastern side. Yet there was no discussion of the difference in impacts upon the Reserve and the history of the area in the Navy’s EIS with regard to preferred flight paths. [Curiously, the meteorological conditions at the OLF should favor flying on Path 14 over Path 32 – See: Citizens of Ebey’s Reserve October 2018 Comments on: Residents & National Parks, Final Environmental Impact Statement for EA-18G “Growler” Airfield Operations at Naval Air Station Whidbey Island, Addendum RN.4: Path 14 vs. 32, for a detailed discussion.]

This is a glaring deficiency that must be addressed prior to any final decision on the EIS or any decision by your council.

The Navy has not adequately examined the impacts upon the historic structures, viewsheds, and public uses in the Reserve in either its Growler expansion EIS or the Section 106 consultations. There are significant impacts that must be mitigated. Funds alone cannot adequately mitigate the potential loss to the public of the history and historic structures of Central Whidbey. These properties and contributing structures must be protected.

Speaking only with regard to the historic Crockett Farm we are preserving, there are three main ways Growler operations impact: (i) they eliminate our adaptive uses and ability to raise the revenue necessary for the preservation of these historic contributing structures; (ii) noise induced vibrations from Growler operations are directly damaging the contributing structures (and in particular the Crockett barn); and (iii) they eliminate the public’s ability to experience and use this precious resource we are doing everything we can to protect and preserve.

Hundreds of young (and some not so young) couples have been married at the Crockett Farm. Charities and community events have taken place at the Farm. The historic buildings at the Crockett Farm are visible from viewsheds all around Crockett Lake. The Crocketts were an indispensable part of the early settlement history of Whidbey along with Issac Ebey. Their homestead has been protected. It should continue to be protected.

The Navy has no valid reason for wanting this Growler expansion other than convenience. Others have pointed out the many siting alternatives available to the Navy. Navy decision makers just don’t seem to care. But this is our history. Why are we so determined to have a strong defense if it isn’t to defend our people, our history and our culture? Aren’t our people, our history and our cultural heritage exactly why we devote so much of our national wealth to defense spending? If not our way of life what are we defending?

Navy flight operations do not belong in Ebey’s Reserve. The Reserve is a trust for our people today, tomorrow and in our future. It was not established as a training ground for the Navy. Our national parks, reserves and monuments were set aside for use by the public. The U.S. military has been provided with millions of isolated acres for this type of training where impacts are minimized. They don’t belong in the People’s Places.

Country Weddings and community gatherings in the fields and in the barn are a rich and so-human part of our American heritage. The Sound of War is simply not compatible with that.

Please reject the Navy’s plan. It is unacceptable and must be stopped. Thank you.

Respectfully submitted,
Crockett Farm, LLC

By:
Paula Spina, Managing Member