Letter to the Forest Service regarding the Navy Training Electronic Warfare Environmental Assessement

Quick overview: Why is this an issue?

The DOD has stated they plan to do this training:
11.152 events per day
2900 events per year. Current number in the Olympic MOA is 1200.
Run up to 12 hours a day
In use 45 minutes of each hour
The equipment will be in use up to 260 days a year
The Navy’s own figures state that a jet flying at 1000 ft above ground level creates 113 decibels, which is far above the threshold for hearing damage.
So, 113 @ 1000 for one aircraft = 123 for two, and 128 for three. In other words, permanent damage instantly. (Twice as loud for two and an additional 50% louder for three.)

So here’s the response to the Forest Service:

To whom it may concern:

I am writing to express my concern with substantive issues of  the Environmental Assessment being carried out by the Forest Service on behalf of the Navy’s Pacific NW Electronic Warfare Range.

There are number of issues that I am raising:

DOD Department of Agriculture Master Agreement 1988 

  • DOD, Department of Agriculture (FS) Master Agreement on “Use of National Forest Service Lands For Military Activity” (1988)
    • As stated in this 1988 document: “Training activities on National Forest Service  Lands will be authorized when compatible with other uses and in conformity with applicable forest plan(s), provided that the Department of Defense determines and substantiates that lands under it’s administration are unsuitable or unusable.” 

I see nothing in the EA or the EIS that substantiates that the current lands in Eastern Washington or Idaho are unsuitable or unusable. In fact , It is clear on page 2-8 of the EA that Roosevelt and Okanagan are still possible to use. I see a case  made that it is too far for local pilots. But this is neither an unsuitable or unusable  argument as they are being used for this purpose now. Could the lands be used if necessary? The answer appears yes, but the Navy would prefer to do it in the Western Olympic Peninsula. That does not seem to meet the criteria as outlined in that foundational document between the DOD and the FS.

  • The 1988 agreement, noted above goes on to say that:
    • “This agreement does not apply to the airspace over National Forest System Lands unless directly associated with the land based training.”

Questions of overlooking the issue of aircraft

There is an implied issue that is not addressed in the current EA that I am commenting on, and seems critical to the EA.  IF there will be active flyovers of public land (USFS, ONF, WSDNR), and IF there will be active electronic engagement with mobile emitters then it seems that  potential adverse environmental impacts MUST be addressed in the EA. Any reasonable person would conclude that they are tightly coupled, and that one relies on the other, as they do in fact. Any attempt to suggest that these aerial activities are NOT a part of this Environmental Analysis and have been or are going to be addressed in a separate EIS are inexcusable considering potential adverse impacts to the human and natural environment.

Again, the airspace requirements for this EA are distinctly directly associated with the land based training, so while it is not addressed in the current EA, it is required by the 1988 Master Agreement to be considered in the EA and likely an EIS that would take into consideration both issues. That the Forest Service has not bound the airspace issues with the land based issues seems to be a significant oversight on behalf of the FS reviewer. Previous EISA entries from the DOD/Navy did not address this specific use of the airspace, which may significantly alter the altitude and noise impact to both the National Forest and the National Park. So the question I ask is “Why is it not bound to this EA?”

Also, the flight paths of these jets flying unmuffled at 1200 feet are not even shown on diagrams. What population areas, businesses and homes are going to be affected by these flights?

  • Section B of the 1988 Master Agreement states:
    • Military Training activities on Forest Service lands are actions that require the analysis of environmental impact in conformance with the National Environmental Policy Act (NEPA) and other statutory and regulatory requirements. The Department of Defense and the Department of Agriculture will cooperate to accomplish the appropriate NEPA compliance.

Questions of Noise

A question of whether the activities of the DOD are compatible with  other uses and conform with applicable forest management plans can be questioned, since hiking, fishing, camping and other human activities are expected to take place both on FS land and the adjacent Olympic National Park (ONP). The noise of the jets participating in the testing and training of the pilots, and directly associated with the land based training, flying at heights of 1200 feet, will be at decibel levels that are known to damage human hearing (greater than 80 decibels for example).

These planes, which are required to make deployment of the electronic gear being requested necessary, will be heard inside the Olympic National Park, in such locations as the Hoh River campground, and other campsites close to the deployed gear, according to the maps provided by the FS and Navy.

In earlier court cases, the National Park Service has found that Snowplane noise violated park standards. Has the Park Service weighed in on whether the noise of the unmuffled jets flying training sorties at 1200 feet will meet noise criteria in the areas of the National Park over which the jets will fly? And what about the noise levels generated adjacent to the Park? This has been successfully argued in court to be a violation of the Wilderness Act.

Questions of Fire 

There is no mention of possible fire, caused by either the jets themselves or the equipment. If a jet crashes, especially if it happens in late summer, what measures do the FS and the Navy expect to take to fight the subsequent fire?  This seems to be an oversight in the EA.

Quantities of training 

The DOD has stated they plan to do this training:

  • 11.152 events per day 
  • 2900 events per years. Current number in the Olympic MOA is 1200.
  • Run up to 12 hours a day
  • In use 45 minutes of each hour
  • The equipment will be in use up to 260 days a year
  • The Navy’s own figures state that a jet flying at 1000 ft above ground level creates 113 decibels, which is far above the threshold for hearing damage.
    • So, 113 @ 1000 for one aircraft = 123 for two, and 128 for three. In other words, permanent damage instantly. (Twice as loud for two and an additional 50% louder for three.)  

This cannot be construed to be “no harm” as exposing human and animal hearing to the directly associated unmuffled air training that is done in conjunction with the required land based equipment could cause human hearing impairment. There has been no Environmental Impact Statement done on the joint use of the two distinctly directly associated activities. I request that one be done.

A reasonable person who would live, work or recreate near such activity would not consider adding 260 days and 12 hours a day of unmuffled jet noise associated with this activity, along with the coming and goings of trucks at all hours of the day and night, to be “no significant impact”. So what was the criteria in establishing that ruling in the FONSI?

Question Of Conversion Of And Taking Of Private & Public Property 

An issue not addressed is the implied conversion of private property under the flight paths of these jets, in the vicinity of the transmitters. (Flight paths are not even considered in the EA) Citizens are being told that they will be living under a war training zone, that unmuffled jets may be going over their homes and businesses at 1200 feet as much as 12 hours a day and up to 45 minutes in those hours. Would they consider this an impact on their businesses and personal lives?

This seems to be a “taking” of the private property use, without properly addressing the issue of whether there is going to be a loss of value or reimbursement  to the homeowner, business person or property owner.  This kind of issue has been dealt with in many locales when flight paths in and out of airports brought jet traffic over homes. These homes often are purchased and destroyed. Seatac has two such locations, north and south of the runways.   When the Navy has created training ranges such as Yakima Firing Range, there was a condemning or purchase of the land there. This issue has not been raised in either the EIS nor the EA.

Loss of Wilderness Soundscape

The loss of wilderness soundscape over the ONP is also, per my comments above, a possible violation of the Wilderness Act. It could also be seen as a violation of NEPA because it appears there has been no adequate consultation with the Park Service prior to the EA nor documented on this issue in the EA.

Use of DNR Lands

It also appears that there are use issues with DNR lands in that vicinity, has that been documented somewhere other than this EA?

Loss of tourist trade

There are unknown losses that may occur due to tourist activities that may not happen due to the understanding by recreation users and others that low flying unmuffled jets are in the area. That is not addressed at all in the EA, nor the Navy’s EIS for the training areas. Are there similar locations in the Continental US that could be looked at for possible loss of incomes and tourist trade?

Issues with the Finding Of No Significance (FONSI) 

In the comments in the FONSI there is mention of having referred to the FS NW Forest Plan, but no mention of which sections of the FS NW Forest Plan the writer is referring to. Which ones is he referring to?

The FONSI appears to have been arrived at with no public input and insufficient scientific data, thus violating NEPA.

In the comments section of the FONSI there is no mention of jet aircraft in consideration of  the actions proposed on page EA-2.  However, the jet aircraft are required for this training. They are not a separate entity, but intrinsically part of the whole.  A reasonable person would assume that would be taking into consideration in this EA.

I request that the FS rewrite the EA to take into account the jet aircraft in use specifically for this training be done.The EIS that was originally done by the Navy regarding airspace did not consider or discuss this use, but was specifically calling out issues related to training at sea.

In the comments section of the FONSI the reviewer only considers the Navy’s needs in the alternatives, and not whether citizens who live and use the National Forests of the affected areas on the Olympic Peninsula would request an alternative.

In the comments section of the FONSI the reviewer states that there will be no effects on the human environment. Most reasonable people living, working or recreating on these lands would consider 200 training exercises a year requiring jets flying low enough to produce sound above the range of damage to human hearing to be a negative effect of any such activity.


Given all these issues, I respectively suggest that the EA is inadequate in addressing the possible impacts to public health and safety, biological resources, Noise, Air Quality, and Visual Resources, along with the lack of proof that the use of Forest Service Lands by the Navy has not been adequately shown to adhere to the 1988 Master Agreement (referenced above), and wish to see it withdrawn and or rejected.

UW-made tool displays West Coast ocean acidification data – UW Today

Science research adds another real time diagnostic tool to help monitor the ocean acidic levels.

Increasing carbon dioxide in the air penetrates into the ocean and makes it more acidic, while robbing seawater of minerals that give shellfish their crunch. The West Coast is one of the first marine ecosystems to feel the effects.

A new tool doesn’t alter that reality, but it does allow scientists to better understand what’s happening and provide data to help the shellfish industry adapt to these changes.


Jefferson County Democrats Unanimously Pass Resolution On Navy Plans

On Tuesday night, the Jefferson County Democrats unanimously voted to ask elected officials at all levels to get the Forest Service to schedule public hearings (not public meetings which have less weight in deliberations), as required by law, on it’s environmental assessment of the Navy’s Pacific Northwest Electronic Warfare Range Plan and the FS’s Finding of No Significant Impacts. The EA was done without legal public input, which is required by law.

The Dems also requested that the Forest Service initiate it’s own scientific investigations and include them in an “honest and open Environmental Impact Statement (EIS) process (which is not what is happening now). At present, the person making the decision at the Forest Service indicated at the Port Angeles meeting last week that he was going to approve the EA. It seems a done deal unless we demand the legal process be followed, which at present, it is not.

If you are are concerned with the process the Navy and Forest Service is following, it is recommended you phone, not email,Senator Patty Murray, Senator Maria Cantwell and Representative Derek Kilmer in Washington and demand they push for these simple requests to be fulfilled.

Scientists Find Out What’s Killing West Coast Starfish – Earthfix

Well, the answers are finally in, and it appears a mutated strain of a common virus to starfish has set this in motion.

SEATTLE — After months of research, scientists have identified the pathogen at the heart of the starfish wasting disease that’s been killing starfish by the millions along the Pacific shores of North America, according to research published Monday.

…The research team also plans to continue investigating environmental factors such as warming water and ocean acidification that may have caused starfish to be more susceptible to the viral infection.

Read the whole story here:


EVENT in PA – Movie “Return of the River” at Elwha Klallam Heritage Center

Wednesday, November 19, 2014 Time 6:30 pm – 8:30 pm PST

Where: Elwha Klallam Heritage Center 401 E. First St.Port Angeles, WA
Audience: Kids, Teens, Singles, College Students, Dads, Moms, Seniors,
Cost: By donation
Contact Name: Suzie Bennett Contact Email:suzie.bennett@elwha.org
Contact Phone: 3604178545

“Return of the River” offers a story of hope and possibility amid grim environmental news. It is a film for our time: an invitation to consider crazy ideas that could transform the world for the better. It features an unlikely success story for environmental and cultural restoration. Fundamentally, the Elwha River in Washington State is a story about people and the land they inhabit. The film captures the tenacity of individuals who would not give up on a river, mirroring the tenacity of salmon headed upstream to spawn. It is a narrative with global ramifications, exploring the complex relationship between communities and the environment that sustains them. The camera soars over mountain headwaters, dives into schools of salmon,and captures turbines grinding to a halt; as the largest dam removal project in history begins. The film features people and perspectives on all sides of the Elwha debate, reflecting the many voices of the Elwha valley.

The Director will be available for a Q&A after the film.

My letter to the Navy on Whidbey Island Training Expansion – Update

Republishing this, as it has relevancy today. Originally published in January of 2014.

I have been  a resident and tax payer of Port Townsend/Jefferson County since 1999. I am opposing the expansion of the Whidbey Island training base for the Growlers. I am not against training our Naval pilots. The issue is more about the appropriate use and location of a Navy jet training facility. I live near Jefferson County Fairgrounds. I am approx. 15 miles south-southwest of Ault field. There are many nights when the Growlers are flying, that I am woke up after midnight, sometimes as late as 1AM by their engine noise. This is not the normal sound of a well silenced passenger jet approaching SeaTac. It is enormously loud. If you would have asked me if I ever would  voluntarily live under a Navy flight training range, the answer  would be no. Did I ever imagine that by living 15 miles away from any airport that I would be woken up in the middle of the night by roaring jets? Not likely. Would you?  15 Miles is the distance from Boeing Field to Shoreline. Or Seatac to Tacoma. We would not ever allow drag racing to take place within Port Townsend after 10PM. We shut the County Fair down at 10 to keep the noise down. Can you imagine the outcry if we were going to allow four wheel drive mud racing  at 1AM? There are thousands of people in eastern Jefferson County that need to get up in the morning and go to work. The least we can expect is not to be subjected to high speed jet noise in the middle of the night.

Since 2001 there has been a 300% increase in training flyovers. The Navy also plans to bring 737s to the base this year! People on Whidbey Island have measured noise levels inside their homes at 94 decibels.  94 decibels can damage hearing. Some comparisons: A Boeing 737 or DC-9 aircraft at one nautical mile (6080 ft) before landing (97 dB); power mower (96 dB); motorcycle at 25 ft (90 dB).  Newspaper press (97 dB).

The Navy planes are, obviously, not well muffled, if at all. I don’t believe they could be muffled. I would assume because they need to be highest performance.   That’s understood.  However, given the times of day that they are used, it is totally inappropriate to fly these planes over the populated areas of Admiralty Inlet.

There was a time, many decades ago, when the Admiralty Inlet area was sparsely populated. Those days are long over. The time has come to say no, politely, to the Navy, and ask that it reassign these wings to one of the other 10 training sites around the country, many of which are likely to more appropriately locate the aircraft to a less populated area, such as Tinker AFB, in OK. Or find a new home in Eastern Washington. It’s only a hop and a jump from here to there in a plane traveling over 300 miles an hour. Oak Harbor will find another way to make money without the Navy airbase, as have all the areas around it who don’t have a base next door.

I am concerned at the unlimited expansion of military training that is happening here in North Puget Sound. We are giving away to the US military a lot for our privacy  and quiet. We have witnessed in the last 10 years alone expanded activity and security at Indian Island, with increased random stops of boaters out for an afternoon. We also have been designated a Navy training airspace  area over Admiralty Inlet and Port Townsend Bay that allows helicopter overflight for training at low altitudes without warning,  along with a doubling of capacity at Bangor on Hood Canal, barely regulated sonar testing in an area that has Orcas and other whales, increased closings of the Hood Canal Bridge at all hours for military boat traffic, and now expansion of high speed jets on Whidbey Island. Now there is the proposal floated to do low level electromagnetic training on the west end of the Peninsula, another idea floated with very little initial press. It was only when some locals in Forks saw a flyer hanging in the local shop, and posted on a blog were the public brought to it’s attention. When added together, these create a picture that we are giving away our peace and quiet, to become surrounded by high security operations that are outside our ability to control, let alone expect a good night’s sleep. It’s time to say no to this. There are other options for the Navy. There are not for us. This is our home. We pay our taxes to create and maintain these bases. We should have some say where to locate them.

The  Navy has extended the scoping period for the Environmental Impact Statement (EIS) for EA-18G Growler airfield operations at NAS Whidbey Island’s Ault Field and Outlying Landing Field (OLF) Coupeville, including the proposed introduction of two additional expeditionary Electronic Attack (VAQ) squadrons and the addition of aircraft to the Fleet Replacement Squadron (FRS). There will be a public meeting, only done because of continued pressure on the Navy, on Thursday December 4th in Port Townsend. (other sites on Whidbey as well). The closing day to get letters like this to the Navy January 9th.

Send letters to EA-18G EIS Project Manager (Code EV21/SS); Naval Facilities Engineering Command (NAVFAC) Atlantic, 6506 Hampton Blvd, Norfolk, VA 23508. Comments may also be submitted to the project website at whidbeyeis.com. You can also contact Representatives Kevin Van De Wege, Steve Tharinger, and State Senator James Hargrove, in addition to Representative Derek Kilmer and State Senators Patty Murray and Maria Cantwell.

Event: How Do Our Hazardous Waste Site Cleanups Compare?

Thursday, November 20, 2014

6:30 PM   The Landing Mall – Second Floor

115E.Railroad Avenue     Port Angeles WA


Dr. Peter L. deFur will be in Port Angeles on Thursday, November 20 to give a presentation comparing cleanup sites on which he is working in USEPA Region 10 — Rayonier-Port Angeles Harbor, Seattle Duwamish River and Portland Harbor.

He will cover the contaminants at each site, compare cleanup options and plans for each site, cover alternative cleanup methods available to be used on particular contaminants, and compare agency support of the citizen groups at the different sites.

These cleanups are overseen by the WA State Department of Ecology and/or the USEPA.  In WA State, these cleanups are part of the Puget Sound Partnership Cleanup Initiative.  The Rayonier-Port Angeles Harbor and the Duwamish River are  Ecology priority cleanup sites.

Dr. Peter L. deFur is president and owner of the consulting firm Environmental Stewardship Concepts, LLC, based in Henrico VA.  and an Affiliate Associate Professor in the Center for Environmental Studies at Virginia Commonwealth University (VCU) in Richmond VA.   Dr. deFur has research and practical experience in the areas of ecological risk assessment, environmental regulations and policies, and toxicology.

Dr. deFur received his B.S. and M.A. degrees in Biology from the College of William and Mary, in Virginia, and a Ph.D. in Biology from the University of Calgary, Alberta.  He has held faculty positions at George Mason University and Southeastern Louisiana University before joining the staff of the Environmental Defense Fund (EDF) in Washington, DC.  In 1996, deFur formed an independent private consulting firm, Environmental Stewardship Concepts, LLC, and accepted a part-time position at VCU.

Dr. deFur has extensive experience in human health risk assessment and ecological risk assessment regulations, guidance and policy. He served on the National Academy of Sciences/National Research Council (NAS/NRC )Risk Characterization Committee that prepared Understanding Risk, on several subsequent study committees and served on the NRC Board on Environmental Studies and Toxicology from 1996 to 1999. He presently serves on the/NRC/NAS committee on Uranium Mining in Virginia. He served on a number of scientific reviews of EPA ecological and human health risk assessments, including the Framework for Cumulative Risk Assessment, the assessment for the WTI incinerator in Ohio and EPA’s Ecological Risk Assessment Guidelines. Dr. deFur was a member of each of the three federal advisory committees for EPA’s Endocrine Disruptor Screening and Testing Program. Dr. deFur was chair of the peer review of EPA’s Dioxin Reassessment in 2000.


Darlene Schanfald

Project Coordinator

Rayonier –  Port Angeles Harbor Hazardous Waste Cleanup Project

Olympic Environmental Council Coalition

PO Box 2664

Sequim WA  98382




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