EA-18G Growler EIS Project Manager

Naval Facilities Engineering Command Atlantic

Attn: Code EV21/SS
EBEY'S LANDING 6506 Hampton Boulevard
NATIONAL HISTORICAL RESERVE
Norfolk, VA 23508

Trust Board Members Date: February 17, 2017

Wilbur Bishop, Chair

RE: Response to Draft Environmental Impact Statement (Draft EIS) for the
Mark Sheehan, Vice Chair
continued and increased EA-18G Growler Operation at Naval Air Station
Al Sherman, Treasurer
Whidbey Island (NASWI).
Lisa Bernhardt, Secretary

Fran Einterz

Lisa Meserole
Dear EA-18G Growler EIS Project Manager:
Harry Anderson

Jon Crimmins Established by Congress in 1978 (National Parks and Recreation Act, P.L .95-625),
Ebey's Landing National Historical Reserve (the Reserve) is a 17,572 acre area of
nationally significant historic resources with boundaries defined by the Central
Whidbey Island Historic District. As stated in its enabling legislation, the Reserve
Kristen Griffin, was established "to preserve and protect a rural community which provides an
Reserve Manager
unbroken historical record from nineteenth century exploration and settlement in
Puget Sound to the present time."

The Trust Board of Ebey's Landing National Historical Reserve coordinates

administration and management of the Reserve according to the mandates of an
Trust Board Partners Interlocal Agreement between the National Park Service, Island County, the
Town of Coupeville, and the Washington State Parks and Recreation
National Park Service
Commission.
Washington State Parks
For almost 40 years, the Navy and the Reserve have been neighbors, sharing a
Island County precious historic and cultural environment. The Trust Board, in commenting on
this Draft EIS, has carefully considered the importance of the Navy to our region
Town of Coupeville and nation. Although we support the Navy and its mission, we conclude that
the action proposed in this Draft EIS, which would increase OLF Growler
operations by as much as five fold, is not consistent with the preservation
mission of the Reserve and would have long term and cumulative effects on the
Reserve we are charged with protecting.

The Navy has the means to develop a viable "everybody wins" scenario in which
NASWI supports the Growler operation, pilots are effectively trained, and
Post Office Box 774 surrounding communities avoid significant adverse impact.
Coupeville, WA 98239
Phone (360) 678-6084
www.nps.gov/ebla
The Trust Board responded previously to this EIS by providing comments during scoping in
2013 and 2014, and as a consulting party in the Section 106 review initiated in accordance with
the National Historic Preservation Act. These comments requested that the EIS address
concerns about noise measurement methods, definition of the affected area, and the operation's
overall impact on Reserve residents, visitors and nationally significant resources.

The Trust Board finds that the Draft EIS lacks key information and analysis needed to evaluate
impacts to the Reserve and prepare the Navy for making a well informed decision. Especially
concerning is the lack of noise measurement data and analysis requested during scoping,
because this data informs every impact and analysis that is relevant to the protection,
preservation and interpretation of the Reserve and our community.

The Trust Board urges the Navy to reject the proposed alternatives and consider a No Action
Alternative that reflects no increase over current (2016) operations, with viable compromise
alternative scenarios that use strategies such as detachment training spread across multiple
locations to diffuse, and not increase, the most impactful aspects of the Growler operations to
the Reserve and community.

The Trust Board appreciates the opportunity to comment on this Draft EIS and looks forward to
an expanding collaboration with the Navy as this analysis and decision are concluded. Specific
comments on the draft are attached.

Respectfully,

Wilbur Bishop, Chair

Trust Board of Ebey' s Landing NHR

Cc Senator Patty Murray

Senator Maria Cantwell
Congressman Rick Larsen
Congressman Derek Kilmer
Governor Jay Inslee
Mayor Molly Hughes
Commissioner Helen Price-Johnson
Eric Watilo, Washington State Parks & Recreation
Capt. Geoff Moore, Naval Air Station, Whidbey Island
Charles Arndt, Friends of Ebey's
Allyson Brooks, WA St. Dept. of Archeology & Historic Preservation
Palmer Jenkins, Deputy Regional Director, National Park Service
Karen Taylor-Goodrich, Superintendent, North Cascades National Park
Judith Rocchio, PWR, Air Quality, Natural Sounds, Night Skies Coordinator, NPS
Roy Zipp, Operations Manager, NPS
Trust Board Members
file
 SPECIFIC POINTS NEEDING CORRECTION OR RESPONSE

GENERAL:

1. With local support, Congress established Ebey's Landing National Historical Reserve as
an area to be protected and preserved for the public, in perpetuity. Although the
proposed action could undermine that intent, the Draft EIS does not fully consider how
extreme noise and other changes will impact the Reserve's resources, values and visitor
experience. Environmental Impact Statements are intended to provide a full and clear
discussion that informs decision-makers and the public, and include alternatives that
could avoid or minimize adverse impacts. By excluding alternatives that could meet the
Navy's need without impacting the Reserve, this Draft EIS seems instead to justify
decisions and plans that have already been set in motion. As a result, the Draft EIS does
not provide what is needed for the public or the Navy to understand the proposed
action's long term and cumulative effects on the Reserve or the community that
supports it.

2. The Draft EIS states that noise and vibration from Growler operations should not be
regarded as detracting from the historic nature or character of historic properties or the
Reserve because there has been consistent military presence in the Reserve. The Final
EIS should clarify that the proposed Growler expansion is not linked historically or
thematically to the Reserve's cultural landscape or 426 contributing structures.

AREA OF POTENTIAL EFFECT (APE):

3. The Draft EIS defines APE based on a 65 DNL sound contour mapped with modeled Day-
Night Average Sound Level data. The Trust Board restates its concern that this method
does not fully characterize noise exposure and impacts to the Reserve's resources,
values and visitor experience, which are primary concerns of the Trust Board. In
addition, public perceptions and a sound monitoring study in the Reserve question the
accuracy of the 65 DNL contour mapped through Day-Night Average Sound Level. These
concerns are extremely important because the APE informs every analysis of impact in
the Draft EIS.

ALTERNATIVES AND SCENARIOS:

4. All of the scenarios in the Draft EIS sharply increase FCLP operations at OLF over current
levels (6,100 operations in 2016), introducing to the Reserve more of the loudest planes,
more of the loudest operations, and more area exposed to significant noise. No
evidence is presented showing that the Navy has evaluated whether the people who live
in, or use, the Reserve or surrounding community can tolerate the extreme noise
impacts from as many as 35,100 operations per year. If consistent with current OLF
FCLP scheduling, this could result in as many as 135 incidents of significant, disruptive
noise every weekday. The Final EIS should note that the Reserve and Coupeville
community experienced operations near these levels in the 1980s and 1990s and the
community was not able to tolerate the noise. Public outcry was so intense operations
 were reduced. Planning to reintroduce this level of noise impact will create significant
conflict between the Navy and a growing number of communities.

5. The Draft EIS arbitrarily proposes percentages (up to 80%) of FCLP operations (the most
extreme noise impacts) assigned to OLF. The EIS should explain the need, data or
rationale responsible for these percentages. In addition, it is not equitable for risks and
impact from a proposed action centered in one community to be shifted to another
community. Scenarios that concentrate FCLP operations (and the most extreme noise
and risk) at OLF pose an unfair impact to Coupeville and the Reserve. The Reserve and
surrounding community represent a longstanding, collaborative effort to protect rural
character and a way of life. Less dense development in this area is the result of planning
and investment and should not be sacrificed because the Navy regards it as a superior
training environment.

POPULATION COUNTS:

6. The Draft EIS understates the numbers of people (and children) who could be impacted
by noise or exposed to risk in the Reserve. Population estimates should go beyond
census block data, and consider the millions of people who use, travel and recreate
within the Reserve each year. These include people using the three Washington State
parks in the Reserve (1,057,439 in 2016); people using the Washington State Ferry at
Coupeville (over 819,000 riders in 2016); and a busy Scenic state highway (2015 average
daily total 8492, over 3 million annually, based on a WSDOT traffic recorder in the
Reserve). Camp Casey is another example of a location within the Reserve that attracts
tens of thousands of visitors each year (especially children) who would not be reflected
in a census count. Visitation figures from festivals should also be considered.

NOISE AND NOISE MEASUREMENT:

7. The Draft EIS does not respond to requests during scoping and consultation that the EIS
incorporate noise measurement methods that fully characterize noise exposure and
impacts to the Reserve's resources, values and visitor experience, and meet NEPA's
requirements to characterize environmental impacts according to intensity, context and
duration. Instead of relying solely on Day-Night Average Sound Level, this would require
the use of metrics such as "time audible" and "time above," maximum A-weighted
sound level, sound exposure level, equivalent sound level, and number-of-events-above
a specified sound level. The Trust Board recognizes that the Day-Night Average Sound
Level metric is the baseline measurement of aircraft noise for the Department of
Defense (DOD), but DOD sources, such as the Defense Noise Working Group (DNWG)
also recognize that supplemental noise metrics and analysis tools may be necessary to
fully inform the public and support analysis and decision making in processes like this
EIS (2009 DNWG Technical Bulletin "Using Supplemental Noise Metrics and Analysis
Tools"). For this Draft EIS, appropriate noise assessment and analysis should include
actual ground measurement of noise intensity, frequency, and vibration as they are

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 experienced by Reserve users, historic structures and other resources and these
measurements should occur at a wide range of locations within the Reserve.

8. The additional POis (Point of Interest) locations noted in the Draft EIS have increased
the number of noise data collection points in the Reserve, but they use the same Day-
Night Average Sound Level noted above and therefore do not respond to scoping
comments requesting actual ground measurement of noise intensity, frequency, and
vibration as they are experienced by Reserve users, historic structures and other
resources.

9. The Final EIS should expand its discussion of a 2016 National Park Service sound
monitoring report for the Reserve that offers a highly credible, on the ground
measurement to compare to the Navy's Day-Night Average Sound Level modeling
method (Draft EIS page 1-23). One of the monitoring locations suggests that areas
outside the Navy's 65 DNL noise contour may be experiencing noise that is louder and
more impactful than modeled. This is important because it challenges the modeling data
on which all of the Draft EIS estimates of impact from noise are generated.

CULTURAL RESOURCES:

10. According to 36 CFR 800.8(a), NEPA and NHPA (Section 106) reviews of cultural
resources should be coordinated. The Draft EIS was routed for comment without a
complete Section 106 review (no defined APE or identification of historic properties),
making it difficult for reviewers to understand and comment on impacts to cultural
resources. This is especially a problem for a federal undertaking with an affected
environment that includes a large National Historic District and a 17,572 acre Reserve
with 426 contributing structures and an intact, nationally significant cultural landscape.

11. Analysis of cultural resources in the Environmental Consequences chapter concludes

that noise and vibration from Growler operations would not detract from the historic
nature or character of historic properties or the Reserve because there has been
consistent military presence in the Reserve, and because the Reserve's interpretive
themes include aspects of military history (page 4-195). These are not valid criteria for
considering adverse impact under NEPA or NHPA.

12. Several comments and conclusions about Cultural Resources in the Affected
Environment and Environmental Consequences chapters need correction in the Final
EIS. These especially include statements that imply Section 106 review is completed;
discussion of adverse impacts under Section 106; discussion of noise and vibration
impacts without identification of specific historic properties; and inadequate discussion
of impact to the defining features of the historic district's cultural landscape, which
include setting and soundscape.

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 13. The Draft EIS does not consider ways that a new APZ for OLF would impact preservation
of historic character in the Reserve. Required by Navy regulations for each of the
proposed scenarios, the APZ would trigger expanded land use regulations restricting the
rehabilitation and adaptive use of historic properties, and expand the reach of
regulations and noise mitigation measures that affect the preservation of features like
historic single pane windows, original cladding, and traditional construction techniques.
These impacts would primarily be experienced by local government and private
property owners.

VISITOR EXPERIENCE:

14. Although the affected area includes an intensively used outdoor recreation network and
a National Historical Reserve established to preserve, protect and share a rural
landscape with the public, the Draft EIS does not adequately analyze how expanded
Growler operations will impact the ability of residents and visitors to use and enjoy
these areas as intended. The Draft EIS (page ES-5 and elsewhere) reports that, according
to Department of Defense data, about 87 percent of the population is not highly
annoyed by outdoor sound levels below 65 dB DNL (data from FICUN - Federal
lnteragency Committee on Urban Noise, 1980). The Draft EIS should recognize that the
FICUN data regards noise that exceeds 65 dB as "Significant Exposure" and the threshold
at which land use controls are needed. This means that the proposed Growler expansion
results in significantly more land, residents and visitors subjected to "Significant
Exposure" sufficient to require land use controls. Given the importance of public use
and outdoor recreation to the Reserve, the Final EIS should compare and supplement
the nearly 40 year old FICUN data with sources that are more recent (such as Fidell,
2005), and more relevant to the type of outdoor experiences people seek and value in
the Reserve.

15. The Draft EIS (page 4-195) describes noise and vibration from the expansion of the
Growler operation as "a potential annoyance to visitors in the reserve," but concludes
that because noise and vibration are temporary and occur "outside the airfield," the
result would be a minimal to moderate annoyance. This might be true where noise is
minor, but it is unlikely to be true for the expanded areas and instances where residents
and visitors experience extreme or "Significant Exposure" as described above. It is also
unlikely to be true for people seeking the Reserve's rural character and opportunities for
outdoor recreation, especially under a scenario resulting in as many as 135 incidents of
extreme noise from FCLP operations every weekday.

GROUNDWATER CONTAMINATION:

16. Because aspects of the Growler operation, including aviation mishaps, could result in
contamination of groundwater, the Final EIS should analyze this as a potential adverse
impact, including an analysis of risk to the public and the Reserve's resources. Wherever

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 potential impacts are considered or analyzed, impacts to agriculture and economy
should be considered along with human health.

APZ IMPACTS:

17. All nine of the proposed scenarios increase operations at OLF to levels requiring the
designation of an Accident Potential Zone (APZ). Although an OLF APZ would cover large
areas of the Reserve and possibly Coupeville, the configuration will not be disclosed
until after the EIS is completed and a decision rendered. The APZ would have an
undisclosed effect on land use regulation, and most likely a negative impact on property
values. The resulting shortfall caused by lower property values will likely increase
property taxes paid by all other property owners in Island County. This information
should be disclosed to the public and local government so they can gauge how they will
be impacted.

RUNWAY EXPANSION:

18. Appendix H (Airfield Analysis) in the Draft EIS acknowledges that the OLF runway does
not meet Navy FCLP requirements, but the Draft EIS does not describe how this will be
corrected. If corrective actions include runway or other expansion into the Reserve, this
should be discussed in the Affected Environment and Environmental Consequences
chapters. Associated costs should be included in estimates of overall cost to accomplish
the proposed action.

SOCIOECONOMIC ANALYSIS:

19. The Draft EIS fails to fully consider socioeconomic impacts to a unique community that is
sustained by a long and remarkable tradition of recreation and collaborative
preservation. The Reserve, and the community that supports it, are part of a "place
based" economy, defined as a place in which a significant part of the economy comes
from businesses and spending that depend upon the local environment and local
character. This includes economic activity from land preservation, historic preservation,
strong property values, specialized agriculture, parks and outdoor recreation, eco-
tourism, cultural tourism, and businesses that include retail, visitor services, overnight
accommodations, special events (such as festivals and the wedding industry) as well as
local art, crafts and local foods. Extreme noise from an expanded Growler operation
would disproportionately impact this economy. Socioeconomic analysis should
recognize that the Reserve represents a longstanding pattern of investment in the
community. Loss of integrity of the landscape and diminished outdoor recreation
opportunities due to noise threaten this pattern of investment. Examples include:
Continued Voluntary Participation in Land Protection: Hundreds of residents in
Ebey's Reserve have committed to preserving the Reserve's character and
environment by voluntarily limiting their ability to develop their own property, and
reducing their own property values, by placing easements or other restrictions on
their property. The benefits from preservation are shared by the entire community.

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 Continued Financial Investment in Protecting the Reserve: Federal agencies, Land
Trust organizations, non-profit preservation organizations and thousands of citizens
(local and otherwise) have invested many millions of dollars to secure conservation
easements for the express purpose of protecting and preserving the Reserve's scenic
beauty, natural and cultural resources, recreational opportunities, heritage, rural
character and way of life.
Continued Citizen Participation: Because the Reserve is valued within a broad
community, it attracts an extensive network of volunteers and in-kind donations,
centered on protecting and preserving the Reserve's resources, heritage, rural
character and way of life.
Local Government Participation and Commitment: Because the Reserve is valued
by their citizens, local government partners help it succeed with official support.
o Island County, the Town of Coupeville, Washington State Parks and the
National Park Service share responsibility and collaborate in the
management and administration of the Reserve;
o Island County supports the Reserve by incorporating the Reserve's strategic
plan into its own Comprehensive Plan;
o Island County and the Town of Coupeville protect the Reserve's historic
character with a joint design review process;
o State and federal agencies regularly contribute special support for the
Reserve because of its recognized state and national significance.
o The Growth Management Act (GMA) guides local government planning
across Washington State and requires communities to identify "Urban
Growth Areas" for future expansion. The only community to seek an
exception to identifying an Urban Growth Area is the Town of Coupeville.
This demonstrates the Town of Coupeville's commitment to protecting the
rural character of the Reserve that shares its boundaries, and its
determination to protect its own local character and way of life, even at the
at the expense of financial gain through growth.