The first step is to get as informed as you can about this issue before attending a public hearing or submitting your comments to the Forest Service. Forest service officials have mistakenly stated that they will only consider “substantial evidence” to deny the Navy a special use permit. These officials then refused to explain what they meant by substantial. As a member of the public, know that your opinion counts. But the more informed comments that are submitted to the Forest Service, and the more issues we raise in our written comments, the more issues we will have available to appeal the Forest Service decision should they grant a special use permit to the Navy. We have posted many important source documents on our Resources page. In addition to reading the information on this website, you can read the comments submitted by others at the following link:
https://cara.ecosystem-management.org/Public/ReadingRoom?Project=42759
Second, submit your concerns in written comments to the US Forest Service at the following link. Unless the Forest Service extends the deadline, all comments must be received by November 28, 2014.
https://cara.ecosystem-management.org/Public//CommentInput?Project=42759
Third, copy this link to our website and share this link with everyone on your personal email list along with an email encouraging your email contacts get informed about the danger of allowing the Navy to turn the Olympic Peninsula into a war zone.
http://washingtonenvironmentalprotectioncoalition.org/
Fourth, email your State Legislators and national Congress people and demand that they take action to stop the Navy from turning the Olympic Peninsula into a war zone.
Fifth, join your local legislative district political party and start attending their monthly meetings. Demand that all political parties pass resolutions opposing the Navy plan to turn the Olympic Mountains into a war zone.
Sixth, write letters to your local newspapers urging neighbors to get informed about the Navy plan to turn the Olympic Mountains into a war zone.
Seventh, if public hearings are held, make time to attend them and email your friends to do the same.
Eighth, join our coalition to protect the environment in Washington State and sign our petition to Congress to pass a bill prohibiting the Navy from using populated areas or areas near critical habitat for endangered species as a war games zone. Click on the petition link in the main menu of our website. You can also sign up for our newsletter to receive updates about future activities. It is likely that we will be joining other organizations to sue the Forest Service and the Navy if the Forest Service grants a special use permit to the Navy or fails to extend the public comment period and or fails to hold public hearings on this issue as required by NEPA.
Here is a copy of our Petition:
Resolution to End Military Jet Destruction of Endangered Species Habitat
Whereas the Endangered Species Act, passed by Congress in 1973, is widely supported by more than 80% of the American people,
Whereas endangered species such as the spotted owls and marbled murrelets require quiet undisturbed habitat typically found in Old Growth forests for nesting and foraging and
Whereas a normal Old Growth forest has a sound level of 20 decibels - compared to a human whisper of 30 decibels and
Whereas the Old Growth forests in some National Parks and National Forests, including Olympic National Park and Olympic National Forest, have been protected as critical habitat essential for the survival of these endangered species,
Whereas critical habitat for endangered species includes not only the landscape (ground, trees and streams) but also the airscape (air and noise levels),
Whereas background noise in excessive of 60 decibels, the sound of a normal human conversation, has been shown to decrease reproductive success of spotted owls and is therefore harmful to the survival of spotted owls,
Whereas military jets such as the Navy F18 Growler emit noise up to 150 decibels, the sound of continuous high powered rifle blasts, capable of causing permanent hearing damage and
Whereas an increase of 10 decibels is a doubling of the noise level and therefore 150 decibels is more than 500 times louder than 60 decibels and more than 8,000 times louder than 20 decibels - the normal background sound of an Old Growth forest – and
Whereas the Navy has proposed turning the western slopes of the Olympic Mountains into an Electronic Warfare Training Zone wherein four or more F18 Growler jets would attack 3 mobile transmitters per operation 11 times per day and 260 days per year for a total of 2,900 operations per year involving at least 11,600 military jets per year and
Whereas allowing more than 11,000 extremely loud military jets per year to fly near or over critical habitat for spotted owls is likely to lead to their extinction,
THEREFORE we ask the Washington State legislature, the US Congress and the President of the United States to pass legislation prohibiting military jets from flying near or over any designated critical habitat for the northern spotted owls and marbled murrelets.
http://washingtonenvironmentalprotectioncoalition.org/petition-to-end-military-jet-destruction-of-endangered-species-habitat
Graphic Representation of Decibel Sound Levels
The decibel system (dB) uses sound ratings whereby every 10 decibels represents a doubling of the sound volume. Since this is a difficult system for most folks to understand, below is a visual comparison of various decibel numbers.
http://washingtonenvironmentalprotectioncoalition.org/petition-to-end-military-jet-destruction-of-endangered-species-habitat
Below is more information about past informational hearings to help you get better informed about what has happened so far. Feel free to email me with any questions or comments. And welcome to the battle to Save the Olympic Peninsula.
Regards,
David Spring, M. ED. Director, Washington Environmental Protection Coalition.
Further evidence of NEPA violations... the “informational” hearing in Port Angeles.
Here is an image of the informational meeting that was recently held in Port Angeles:
Here is a report on the informational meeting in Port Angeles:
About 250 people attended a two-hour "informational meeting" in Port Angeles last night, and expressed dismay when they learned that it was not only not an official public hearing under the NEPA process, but that no verbal comments would be accepted for the official record. Testimony from the public was limited to one minute, which was a departure from the expected format of three minutes, which had been allowed to the public in California during meetings on this topic.
The moderator made it clear that general comments were not wanted, and that any person speaking must ask a question. There was a signup sheet for the public to ask questions, but so many people signed up that anyone who had arrived a half hour early rather than a full hour early for the meeting was not allowed to speak, because the time ran out. The signup sheet was briefly lost just before the meeting started, which upset people who'd arrived an hour early to ensure they could sign up to speak. But then it was found. Navy rep John Mosher read text from 20 minutes' worth of slides and was frequently interrupted by a frustrated and now angry audience, who wanted to get to the question and answer period. With only two hours allowed for the meeting, this delaying tactic meant that fewer than 80 out of the 250 people were allowed to ask a question.
None of the formalities went over well with the people who squeezed into the City Hall chambers. They loudly expressed their feelings and frequently interrupted the officials when answers seemed vague. Tension was already high over the fact that the public has largely been left out of this process, and raucous catcalls from some reflected the frustration.
When the Q and A period finally started, the public asked questions about increased fire danger from Naval activities, safety issues connected with use of electronic attack weapons in the Growler jets, why this meeting was not an official hearing, the omission of numerous items and data from official documents, the unavailability of many of those documents, endangered species issues, unannounced forest closures, effects of chronic radiation, jet noise, why the National Park Service wasn’t represented at the meeting, and demands that the Forest Service conduct its own research to verify the Navy's claims of "no significant impacts" in every category on the Environmental Assessment.
District Ranger Dean Millett confirmed that the Forest Service had done no independent research to verify the Navy's claims of no significant impacts, and that it was relying entirely on the Navy's research. He said, "I believe the Navy's analysis does a sufficient job for us." When asked if he intended to re initiate formal consultation with wildlife agencies to correct the deficiencies in using data more than 5 years old, he said simply, "No."
He also made it clear, after citing a Memorandum of Understanding (MOU) between the Department of Defense and the Department of Agriculture, that his "decision space" for the Navy's special use permit concerned only the roads within the Olympic National Forest, not the airspace above either it or the Olympic National Park or the Quinault Reservation or local communities. When asked about the degradation of the soundscape over a famously peaceful area, he replied, "That is outside of my decision space."
Navy official John Mosher said the Navy had consulted with the National Park Service, and also with 5 Tribes, though he did not name them. Dean Millett said the Forest Service had consulted with the Quinault, Hoh and Quilleute Tribes. Both declined to disclose how Tribes reacted to the Navy’s activities by citing Government-to-Government confidentiality.
After the meeting, Mr Wahl, who is the Forest Service representative in charge of collecting and responding to written comments, replied when asked about the possibility of drones in the Olympic National Forest as a result of issuing the permit, that neither he nor Mr Millett saw anything in the Navy's specifically proposed activities for national forest roads that was outside the appropriate multiple uses of those lands. When asked what would stop the issuance of the permit, both stated that they needed to receive "substantive written comments," but refused to define what substantive meant. Mr Wahl indicated to a questioner after the event that he had neither seen nor heard anything at the meeting that would stop the issuance of the permit.
Connie Gallant President of the Olympic Forest Coalition contested the Navy's assertion that the trainings will have no impact on the peninsula¹s threatened species. "This activity does not belong in the Olympic National Forest," She noted that Olympic Mountains are a key nesting site for the marbled murrelet, a small seabird whose populations have declined sharply over the last decade.
David Graves, the program manager for the National Parks Conservation Association noted that outdoor recreation would be impacted by aircraft noise and the closure of national forest roads during training. "Many visitors come to Olympic National Park to find opportunities for solitude. Increased overflights would significantly impact these opportunities."
Donna Osseward, President of the Olympic Park Associates stated:
“Olympic Park Associates argues that the stated purpose of this permit does not compare to the damage to the human and wildlife values of the Olympic Peninsula. The value to the people of the United States is far better served by not placing this warfare training range in the proposed location. As proposed it would cause significant economic and environmental harm to the people living on the Olympic Peninsula, and the many tourists that visit this area every year. Because this is federal land set aside for the benefit of all United States citizens, this proposal degrades those benefits to all citizens. More study is needed before the proliferation of these training ranges are spread across the nation in the laudable attempt to save jet fuel and reduce away time of Navy jet crews from their families. A degrading of the environment could be more costly to all Americans, including the Navy personnel and their families, than the perceived savings of this training range. Olympic Park Associates asks that the United States Forest Service not issue this permit to the Navy. At minimum, a full EIS is needed before this project proceeds. Our earth’s environment is our home; its degradation gives us all less to defend.”
Donna Osseward, President, Olympic Park Associates,
Many more topics were raised, and questioners frequently had to ask for clarification from the panel or tell them their questions had not been answered. This took place while the moderator tried to keep the meeting on track by saying, "You're out of time." The attendees appeared to be angry and dissatisfied when the meeting was ended promptly at eight. The panel appeared to be relieved. There is one more meeting in Port Townsend (no date announced yet) but this meeting will only discuss jet noise. No comments outside that realm will be allowed.
A Long Term Solution to this Important Problem is Needed
The Navy claims that they already have a right to use the airspace over the Olympic Peninsula and that they are merely expanding this existing right to include three mobile electronic warfare trucks on National Forest Service lands. However, granting this permit would effectively drive away the general public from Forest Service and National Park service lands as the public would not want to be exposed to the danger of toxic electromagnetic radiation and toxic levels of noise resulting from the presence of these trucks on Forest Service land and near National Park land. Allowing any one user of Forest lands to drive away all other users of Forest Land is contrary to the Forest Service mission statement – which requires the National Forest to be managed for the maximum benefit of the maximum number of users and not merely for the benefit of any single user.
In addition, the Forest Service has a legal obligation under the 1994 Record of Decision (1994 ROD) to protect endangered species by providing critical habitat for those endangered species. The Forest Services is not allowed to permit any action that would eventually result in killing spotted owls and marbled murrelets by reducing the quality of their critical habitat. This habitat includes not only the trees and streams but also the airspace over those trees and streams. In addition, the Navy as an agency of the Federal Government, is not allowed to act in a manner which violates Federal laws. These federal laws include the Endangered Species Act (ESA).
Therefore neither the Forest Service or the Navy are allowed to take any action which would be a violation of the Endangered Species Act. In this study, provides substantial scientific evidence that the Navy's proposed Electronic Warfare Range in the Olympic Mountains would be likely to result in the extinction of spotted owls and possibly the extinction of marbled murrelets. It therefore would be a violation of the Endangered Species Act.
The long term solution to this problem is for the Forest Service, the National Park Service, the Washington State legislature, the Congress, the President and/or the Federal Courts to impose a ban on any flights by Growler Aircraft over any airspace that includes critical habitat for spotted owls and/or marbled murrelets and a ban over any air space that is within 10 miles vertically or horizontally of such critical habitat. This would effectively end any Growler Aircraft flights over the Olympic Peninsula and end any threat that such flights would create for the future survival of spotted owls and marbled murrelets. The Navy would still be able to use their Electronic Warfare Range in Mountain Home Idaho and the price for this solution would be only $5 million per year in extra fuel cost for the Navy. This is much less than the cost of a single Growler aircraft which is claimed to be $80 million per Growler aircraft. The total cost of the Growler project with 135 aircraft now scheduled is well over $14 billion. So the additional fuel cost of $5 million per year is a small fraction of one percent of the cost of this project.
Here is more information from their website:
Sound measurements are on a complicated log scale, but the short of it is that sound intensity doubles with every 3-dB increase. But its not that complex. The Navy’s own data clearly states that Growlers, as they approach a landing, register at 114 dB compared with 107 dB for Prowlers. Given the log scale, that 7-dB difference expands to Growler noise being 4.33 times (433% of) as intense as the average reading for Prowlers.
On the other hand, loudness is a more qualitative measure of what people seem to hear, which is different from the actual sound intensity their full body experiences. Loudness, too, is on a log scale, such that a 10-dB increase in noise doubles the human perception of its loudness. So, again, looking to the Navy’s own data, the 117-dB they report for Growler takeoff registers at 1.3 times (133% of) the 114-dB loudness of a Prowler takeoff.
Serious health consequences of the noise levels of jets. http://citizensofebeysreserve.com/Files/Community%20Aircraft%20Noise_A%20Public%20Health%20Issue.pdf
Thanks to public pressure, there are now two more public hearings on the Whidbey Island portion of this problem: FOR IMMEDIATE RELEASE Press Release – 47-14
November 12, 2014 Navy to Host Additional Public Meetings on NAS Whidbey Island EIS
At the request of elected officials, the Navy plans to host two additional open-house scoping meetings for the ongoing Environmental Impact Statement (EIS) for EA-18G Growler airfield operations at Naval Air Station (NAS) Whidbey Island.
These meetings will provide members of the public with the opportunity to review project-related information, ask questions of Navy representatives, and submit comments on the scope of the analysis and content to be addressed in the EIS. Each of the meetings will be informal and consist of information stations staffed by Navy representatives. The meetings will be conducted between 3 p.m. and 6 p.m. on the following dates and locations:
Lopez Island Meeting Wednesday, December 3, 2014, 3-6 p.m.
Lopez Island Center for Community and Arts
204 Village Road, Lopez Island, WA 98261
Port Townsend Meeting Thursday, December 4, 2014, 3-6 p.m.
Fort Worden Commons, Building 210
200 Battery Way, Port Townsend, WA 98368
Scoping meeting information booklets are available for individuals attending each public scoping meeting. If you are unable to attend a scoping meeting, scoping meeting booklets are available for download from the project website at http://www.whidbeyeis.com or can be reviewed in the reference section of 14 area libraries. Furthermore, the project website includes up-to-date information on the project and schedule, as well as related documents associated with the EIS.
Written comments may be submitted to the EA-18G EIS Project Manager, Naval Facilities Engineering Command (NAVFAC) Atlantic, Attn: Code EV21/SS, 6506 Hampton Blvd., Norfolk, VA 23508. Written comments may also be submitted online at the project website at http://www.whidbeyeis.com on the “Comments” page. Additionally, written and oral comments may be submitted at the scoping meetings. The names, street addresses, email addresses and screen names, telephone numbers and other personally identifiable information of individuals who provide comments will be kept confidential and will not be released, unless otherwise specifically indicated by the commenter or as required by law. The city, state and 5-digit zip code of individuals who provide comments may be released.
Comments may be submitted at any time during the public comment period, which has now been extended through January 9, 2015 due to these additional scoping meetings.
Here is an edited version of an article this group wrote about the Navy application for a Forest Service permit on the Olympic Peninsula:
The issue boils down to: should the Forest Service issue a permit to the Navy to use roads in the Olympic National Forest to run their electronic radiation-emitting truck-and-trailer combinations, which would entail numerous unpredicted closures and chronically irradiated vegetation and wildlife, and possibly some chronically irradiated people who live or work near the fixed tower, for decades to come? The science being advanced by the Navy is shakier than the San Andreas fault. For example, the Navy’s most scientific documents don’t include the effects of jet noise in the area they want to use. The scanty biological information they’re using is at least 5 years old and doesn’t include climate change or species that are currently not endangered or threatened with extinction. The definition of “no significant impact” is that they won’t cause a species to go extinct throughout its range, which is a pretty low threshold. We don’t know what effect “airborne and surface active jamming” of all detected electronic signals in an area will have on navigation, firefighting, search and rescue, police or 911 dispatch signals. We don’t know what effects decades of jet noise for “up to 16 hours a day” will have on the ecosystem, of which humans are a part. And the Navy confirmed that the jets will be flying over our communities, not over the Strait. The more the public opposes this, the more compelling it will be for the Forest Service to not rubber-stamp the permit.
Furthermore, the law says that the Forest Service cannot rely on data from other agencies to make decisions on how it will manage its land. They must do their own research and investigation. And we need to know exactly what that research says. Right now we know nothing except reports from independent researchers who tend to say radiation like that, especially over many years, can’t be good. Here is something you should know about the public meeting. I learned today that the Navy has similar electronic warfare takeovers of public land going in other areas, and public meetings there have been equally unsatisfactory to ours so far. Comments are typically limited to three minutes, after which they may interrupt you and force you to stop. UNLESS YOU ASK A QUESTION at the end of your comments, the only reply you will get is “Duly noted.” If you do not ask a question, they do not have to respond to you. So ask a good question, and if you have not yet commented in a letter, please consider writing one to
According to PMA265 representatives, the F/A-18E/F aircraft emits, and the EA-18G will emit, a maximum of 150 dBs, which is well above the noise level considered hazardous to hearing (greater than 84 dBs). According to PMA265, they made no initial attempts to mitigate the flight-line/deck jet noise hazard through design selection. This is contrary to the system safety design order of precedence specified in the MIL-STD-882D
PMA265 representatives stated that they did not pursue minimizing noise generated by the F/A-18E/F engines through design because warfare sponsors (Commander, Naval Air Forces representatives) did not identify noise requirements as KPPs within the Operational Requirements Document (ORD).
PMA265 did not attempt to mitigate the jet noise hazard in the initial design and development of the aircraft, did not follow required guidance relating to risk levels and risk acceptance authority levels, and did not track the flight-line/deck jet noise hazard and its residual mishap risk. These conditions may contribute to a hazardous environment of high noise exposure associated with jet aircraft that, according to the Naval Safety Center, increases the likelihood of permanent hearing loss to sailors and Marines. PMA265 representatives stated that many flight-deck personnel exceed total daily exposure limits in approximately one launch while wearing hearing protection that provides 30 dBs attenuation
Naval Audit Service Interim Audit Report N2009-0008, 31 October 2008
Here is the group contact information: COER’s toll free Complaint HOT LINE number is: 1-800-830-4078, available at any time of the day or night. We will make sure you can speak to a real person instead of a recording, and that your complaint will be forwarded to the Navy effectively. Sign our petition at MoveOn.org Become a member of our organization Donate to help cover our expenses. Link our articles, Facebook, and Twitter to your social network - share and retweet as much as you can! Print our media and display it wherever you can.
A Navy official stated the reason they should use the Forest Service land instead of some other alternative is because: “The land is associated with the air space.” He also states that there would be about 1,200 flights per year over the Western slopes of the Olympics. But other information indicates it will be up to 3000 flights per day.
For links to all of these studies, visit the Home page of our website:
http://washingtonenvironmentalprotectioncoalition.org/
This concludes our summary of the Navy plan to turn the Olympic Mountains into a war zone.
If you have any questions or comments, feel free to email me.
David Spring M. Ed. Director, Washington Environmental Protection Coalition.
