–from Chom Greacen, Member, Quiet Skies over San Juan County–
The Navy plans to add 36 EA-18G “Growler” fighter jets and roughly double the number of Growler flight operations out of Whidbey Island Naval Air Station. The only thing standing in its way is completion of the Environmental Impact Statement (EIS) process as per the National Environmental Protection Act (NEPA).
In the Federal EIS process there are two paths to making a decision. A non-federal entity seeking a permit works with a permitting agency (e.g. Army Corps of Engineers) who gathers public input and makes a final decision. In the second approach, for example, the Growler additions, the Navy manages the process for themself. The draft EIS is prepared by the Navy, for the Navy and is approved by the Navy.The only way to hold the Navy accountable to relevant laws, including NEPA, is through citizen participation and, as a last resort, litigation.
The Navy has produced a Draft EIS (DEIS), so now the onus is on us to point out if and how the DEIS fails to comply with the law. [Editor’s note — See orcasissues.com/navy-agrees-extend-environmental-impact-study-public-comment-period/]
The over-1,400 page DEIS is intimidating, and the Navy appears to act like a royalty. But in reality, the Emperor may have no clothes.
Take for example the flawed noise assessment of the DEIS.
Growler noise impacts are the number one controversy and concern, and so the quality of the noise analysis is at the heart of the DEIS. Unfortunately, this heart has serious flaws which renders much of the remaining report scientifically questionable.
First, the Navy chose to simulate noise levels with a computer model instead of conducting actual noise measurements in the region. But the computer model used is so outdated that a Department of Defense report found that new software was needed to provide “scientifically and legally defensible noise assessments” of the modern, high-thrust jet engines used in the Growlers. New, improved software is available, but the DEIS did not use it. In addition, no attempt was made to benchmark the model with actual measurements. Why not?
Second, even if the noise computer model was scientifically sound, the quality of data used as inputs is still questionable. Despite the document’s excessive length, the DEIS failed to provide pertinent details regarding the empirical data used to calculate noise levels.
The lack of data transparency is not surprising given that in 2009 the Navy itself identified the problem of inadequate noise measurement data, lack of consistent noise measurement methodology and standards, and lack of jet noise database. It appears that the Navy has not taken steps to address these deficiencies. The Navy needs to start now by taking proper Growler noise measurements which are key for preparing a scientifically and legally defensible DEIS.
The above deficiencies of the DEIS are among many that have been found. The Navy may seem all-powerful, but citizens can point out the naked deficiencies and obfuscation in the DEIS. Quiet Skies is putting out more info and holding two sessions to help people write comments. See www.quietskies.info for details.
Please submit comment letters by Jan 25.