Navy holds Public Meeting for “noisy” Draft EIS. Public holds silent protest

The U.S. Navy began the first of five public meetings at Port Townsend today, in order to roll out their new “draft” Environmental Impact Statement (EIS) to expand the use of the Whidbey Island Airbase. The airbase is primarily used for carrier and expeditionary (land based wings) training of cadets. A group of approximately 40 protesters sat in a silent protest during the event. While police looked on, no arrests were made nor was their anything other than a peaceful sit down protest.


The Navy is no longer asking for any lowering of cadet training, and in fact is looking to expand by 35 or 36 aircraft. Personnel increases range in the proposals from 371 to 664, with an expected expansion of dependents (family) of 509 to 710). They are planning to increase operations/year from 88,000 to 130,000 an increase of 33%. One thing to understand that was explained to me by Ted Brown, the Installations and Public Affairs Officer for the Navy, is that these operations actually need to be divided by 2 to more clearly understand them. A jet taking over and do a touch and go is engaging in a minimum of 2 operations. However, this increase in the levels takes us from a low range where we have been since approx 1996 to a much higher level, more closely aligned to the levels leading up to the first Gulf War (1976-1988).

The more problematic issue of all this is that the Navy will be impacting many more people with noise levels at or above 65dB. To put this in perspective, 65dB is considered “normal” level of talking to someone at 3′. However, we are talking about jet aircraft noise and not human voices. Hearing loss can occur at sustained levels above 85dB. A navy aircraft sound print lasts approx. 30 seconds usually peaking at 93.5 dBs and sustained above 80 for most of that 30 seconds.  In the summer, I routinely am roused out of sleep after 12 midnight by jets taking off and landing 16. 2 nautical miles away from my house. That qualifies for what the navy calls sleep disturbance but it does not track that from my distance, so any of us affected by this are not included in their calculations.

The Navy assumes that in our area of Port Townsend, we can expect noise levels capable of affecting speech comprehension inside an additional 4 times an hour. Outdoor events would increase up to an additional 3 events per hour. 

Events  that the Navy expects to be so loud as to disturb indoor classroom activity is expect to increase by 2 events per hour. 

Sleep disturbance events between 10PM and 7AM are expected to increase up to 48% in some locations.

It is also worth noting that the Navy primarily flies these during times when the aircraft carriers are in port. They have a window of opportunity and the pilots also need to achieve night flight status. This means that with darkness falling later and later, they end up spilling into the later evening. So expect more noise late in the summer, and with more planes, it will only get worse.

There is a hope on the horizon, much longer out, in that the touch and goes are now in the early phases of having a onboard computer fly the plane with greatly increased safety, and less wear and tear on the plane and flight deck. At some point, we may see a dramatic decrease in touch and goes, as computers take over that function, decreasing training on it. Newer F-35s have the ability installed but older ones do not. The software is not yet operational though, being in testing now.

What can be done about the intrusion into our peaceful surroundings? There is a no action alternativethat the Navy isn’t seriously considering, but should be proposed in writing by anyone concerned about this growth. However, don’t expect the Navy to choose this. If you are planning to contact any of our Congressmen or Senators, you might as well push for it. That’s the only way you will protect yourself and your family from increased unmuffled jet noise.





US Forest Service finds “No Significance” in the Navy expanding war games next to Olympic National Park

In an expected ruling, the Forest Service rubber stamped the Navy’s plans to expand their war games using electronic warfare using high speed unmuffled jets right next to one of the quietest places on earth, the Hoh Rain Forest. In a ruling that can only be called cynical political point-making with the incoming Trump Administration, Dean Millet, the District Ranger in charge of the ruling, ignored tens of thousands of signatures on petitions and thousands of letters of concern, many of them from scientists, political figures and people with a stake in the economy of the Peninsula. He claims to have, “carefully considered public input” in making the decision, but that he found nothing at all to criticize in the Navy’s plans, means that he really didn’t try.

Now, we turn to the courts, and to the elected officials, like Derek Kilmer, who has done very little to stop this, somewhat understandably given the population of military retirees and Bremerton Navy jobs at stake in Kitsap County.

We hope that Representative Kilmer brings his earplugs with him when he and his family go hiking in the Olympic National Park next year, he’ll likely need them. Jets which are supposed to be flying at over 6000ft have been seen and recorded on numerous occasions  by many different eyewitnesses flying at less than 1000, despite the assurances of the Navy. In a video shot at a public hearing out on the coast a couple of years ago the head trainer from Whidbey admitted as much, saying that he had to discipline his cadets  sometimes for flying too low. But other than this one man, there is no real oversight to keep them above 6000′. We don’t have public records to look at even on something as non-essential to security as this.

Is that what a National Park is supposed to represent? Do we want to turn all our places of solitude from the stresses of our industrialized world into low level fly over training sites by unmuffled jets?  What exactly is something that the Forest Service considers a “significant finding?”  I just have no idea of what Ranger Millet’s threshold is. Should we take recordings of jets and go to his house, Representative Kilmer’s house, Senator Murray and Cantwell’s house at night and play them at full volume? Would that help understand the ask? And at what point do we have “enough” training spots in the US that we don’t need more? And who ultimately should decide that? Us, the military or a combination of the taxpayers and those in our employ. Why did the 1988 MOU between the Department of the Military and the FS not come into play?  That document seems pretty clear. Very short and to the point. Less than one page of law.

These are just questions that we would love answers from the people in power, some of whom we elected as recently as this November. It seems clear from this ruling that the Forest Service is not acting in our best interests. Since the Spanish American war we have set about turning the Puget Sound and Strait into a militarized zone. And now we seem to be at a point where our military does what it wants, regardless of what us, the taxpayers, want of it. This is truly the tail wagging the dog.

Also from Ashley Ahearn

Navy Granted Permits For More Growler Jet Training On Olympic Peninsula
The Navy has just been granted permits by the U.S. Forest Service to expand electromagnetic warfare training over Washington’s Olympic Peninsula. Now the Navy is cleared to drive trucks out into the Olympic National Forest, armed with electromagnetic signaling technology. Then growler jets will take off from Naval Air Station Whidbey Island and fly overhead, searching for the signal trucks from the air. It’s essentially a military training game of hide-and-go-seek. The trucks simulate cell towers and other communications behind enemy lines that the Navy wants to scramble. Ashley Ahearn reports. (KUOW)

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

UPDATED FOR DECEMBER 1, 2016. Originally posted in 2014

Quick overview: Why is this an issue?

The DOD has stated they want permission from the Forest Service  to do this training.

To be clear, this is from the Forest Service EA on behalf of the Navy:

The Navy wants to run Electronic Warfare Training runs on the west side of the Olympic Peninsula, including over habitat for endangered Spotted Owls, towns such as Forks, areas very close to the Hoh River campgrounds, and generally all over the Peninsula’s west side.

From the Navy’s own documents:

-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 claims that they will fly at a height no lower than 6000 feet. However, numerous eye witnesses from both inside the Olympic National Park and outside report that the Navy routinely flies much lower than that. Sometimes barely above tree top level.

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.)
There are no answers, only questions at this point:

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, starting with the 1988 DOD/Agriculture MOA:

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 snow plane noise (from planes landing in the snow in areas like Alaska) 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.

Department of Natural Resources offers draft plans for comment on harvest, seabird – PDN

The state Department of Natural Resources has released draft environmental impact statements on the agency’s 10-year sustainable harvest calculation and its marbled murrelet long-term conservation strategy. Public comment will be taken until 5 p.m. March 9 on both documents, DNR spokesman Bob Redling said. Public meetings and webinars are planned next month. The 160-page sustainable harvest draft environmental impact statement, or EIS, and instructions for submitting public comments are available at The 600-page marbled murrelet draft EIS and instructions for submitting public comments are available at Rob Ollikainen reports. (Peninsula Daily News)

Study: Most clammers stick to single beach – Kitsap Sun

While this isn’t really a surprise to many of us, it is interesting to finally see the data collected on clamming and the people that clam.

Close down a clammer’s favorite beach, you’re likely closing down the clammer. A new study looking at the behavior of Puget Sound’s recreational shellfish harvesters indicates that the increasingly frequent pollution and marine biotoxin closures are having a bigger impact on clammers than previously thought. About two-thirds of the sound’s shellfish harvesters say they gather all their clams and oysters from a single beach, according to surveys administered by the National Oceanic and Atmospheric Administration. If a “Toxic Shellfish” sign pops up at a favorite spot, most harvesters simply quit. They don’t seek out alternatives. Tristan Baurick reports. (Kitsap Sun)

Quiet: A Soldier’s Fight for the Most Silent Place in America – SeattleMet

Very interesting story on a retreat for veterans using what was thought to be a quiet, remote forest that now is threatened with greatly increased fighter jet noise.

The military’s plan to send newer, more disruptive jet planes over the Hoh and Quinault rain forest region has unraveled not only townspeople throughout the Olympic Peninsula, but the veterans who thought they’d found a refuge.

Whidbey Restoration Project Makes a Difference, For Shore -Ear to Ground/WDNR

More good work restoring shoreline habitat. One of the primary benefits of this is to remove creosote chemicals from entering the nearshore habitat, where sand lance and herring live and reproduce. These  two species are critical to the the food chain of the Salish Sea.

Salmon, crabs, clams and shorebirds got a happier home recently as DNR’s Aquatic Restoration crews freed up beachhead on southeast shore of Whidbey Island. Partnering with the Whidbey Camano Land Trust, the restoration program removed 440 feet of creosote-treated bulkhead from the Glendale Beach and Waterman Shoreline Preserve north of Clinton. Removal of the bulkhead allows the beach to again move in the free, dynamic way it naturally does. (Ear to the Ground/WDNR)

Oyster-caused illnesses on Vancouver Island linked to same supplier- CBC

In case you happened to be in Tofino in November.

Island Health says norovirus is likely to blame after more than 100 people who ate raw oysters in Tofino earlier this month fell ill. Roughly 120 people, many of whom had attended the Clayoquot Oyster Festival, suffered gastro-intestinal symptoms last week. But Island Health says people got sick at more than one location, and that people reported being ill over the course of several days. They say it appears everyone who became ill consumed raw oysters from the same supplier, who is not being named. (CBC)

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