Letter: An open letter to U.S. Rep. Rick Larsen on Navy’s EIS


The following is a letter to U.S. Rep. Rick Larsen:

As a constituent of yours and an active member of Citizens of Ebey’s Reserve and the Sound Defense Alliance, I have reviewed your Nov. 21, 2018, letter to Navy Secretary Spencer addressing the Environmental Impact Statement (EIS) for the expanded Growler fleet at Naval Air Station Whidbey Island (NASWI).

I have been one of the primary researchers on some of the technical issues related to Growler impacts, and I feel compelled to share some information you may find relevant and useful. First, thank you for your recent letters to the secretary.

I concur that you, indeed, identified a major shortfall in the EIS for the expanded Growler fleet at Naval Air Station Whidbey Island, as presumably further evidenced in the congressional briefing you received.

The problem is the EIS’s use of the term “historical distribution” as it relates to flight carrier landing practice operations at Outlying Field Coupeville, and what it meant regarding FCLP numbers being “consistent with past levels of airfield operations.”

Both are so vague they can be used and construed in whatever way suits the user’s interest.

That is, what composes history or past levels, starting and ending when, and should history be the maximum ever flown or an average over what period? And how should the evolution of ever-louder aircraft and changing population demographics and distribution be reconciled to be “consistent with history?”

In the absence of credible answers, there are, however, several critical and potentially useful points for decision-makers to weigh in that regard.

1. For the past two decades, FCLPs at the Outlying Field have averaged 5,751 operations per year (range 2,548 to 9,668), and that, by default and intended or not, established a reasonable usage expectation based on those most-recent 20 years.

2. The 2005 Air Installation Compatible Use Zone (AICUZ) supported that expectation by establishing 6,100 operations at OLFC as the number that local governments should plan on going forward. It even stated that “the current locally adopted [land-use planning tools] should remain unchanged … [and that] [m]aintaining the current local noise contours and land development regulations are supportive of continued protection of life, safety, and welfare of the local citizens.” [Section 8.1.2]

Now, 20 years later, the Navy wants to take that back, obfuscate history and encroach on those who invested in and put down roots under the Navy’s misleading assurances that it was okay to do so.

That status quo expectation, coupled with nothing in the AICUZ informing anyone to expect anything else, let alone a fourfold increase, is far more relevant than the Navy’s hiding behind its undefined meanings of “history” and “consistency,” or its bogus claim of an “insignificant change” from its preferred interpretation of history.

Instead of that pointless debate, those two decades of usage and the 2005 AICUZ actually establish the status quo and 21st century expectation, rather than a manufactured, outdated Vietnam War Era obfuscation.

Even the FEIS recognizes the status quo with a euphemism, the “no-action alternative.”

Relatedly, the FEIS correctly explains, “The greater than 75 dB DNL noise contour is the area where there is the highest level of community annoyance associated with aircraft noise.

Therefore, these populations would be significantly impacted.” [page 4-30] It follows, the next greatest impact would be in the 70–75 dB contour. The two together form the highly toxic noise zone.

As extrapolated from the FEIS preferred option (Scenario A in Table 4.2-1), the population in the >75 DNL contour at OLFC increased from 583 to 1,374, a 2.36-fold increase over the most recent two decades of established usage, i.e., over the status quo no-action alternative.

At Ault Field, the population increased by just 139 from 3,581, or by only 0.04 percent. More dramatically, the population in the combined 70-75 DNL plus >75 DNL contour at OLFC increases from 583 to 1,524, or 261 percent. This is anything but consistent with the established 21st century usage or status quo, rather, it is a reversal.

I offer the above in the sincere hope that you can use it to help convince the Navy to reconsider their numbers and make better choices for all impacted – not just what works for them. If the Navy was all set to buy out 20,000 acres in the swamps of eastern North Carolina for an Oceana outlying field and if they can day-in/day-out practice in two military operation areas in Central Washington, then they can afford to construct a handy close-by outlying field in the abundant empty lands in central-western Washington.

Another option: They could move the Growler training squadrons, or end single-siting of Growlers at NAS Whidbey and begin dual-siting elsewhere to improve national air security challenges.

The DoD and Navy have many alternative options that could be met with support from a community that has done more than its fair share to support the base on Whidbey Island.

I look forward to your continued determination on our behalf to find a real and sustainable solution to this bizarre military maneuver in the face of the significant snowballing public resistance and animus.

Robert Wilbur


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