Military contamination of America’s drinking water – How bad is it?

no drinking water

March 3, 2017 – At least 664 sites nationwide to be examined by Department of Defense, including sites at Puget Sound. EPA study finds 6 million Americans in 33 states dealing with contaminated drinking water from perfluorinated chemicals.

This is a long and rather disturbing post. News stories are popping up across the country and beyond, about contamination of aquifers and residential drinking water supplies caused in large part by the US military’s long-term use of Aqueous Film-Forming Foam (AFFF) for firefighting and training on base hangars and runways. This stuff looks harmless – here’s a closeup:

AFFF closeup

Aqueous film forming foam (AFFF) closeup. It’s used by the military for for training and firefighting.

So that you know what Aqueous Film-Forming Foam looks like in action, (because it’s amazing) here are videos from two foam spill accidents, both from hangar system malfunctions, one at the San Jose (CA) airport and another covering an entire city block of a suburb of San Francisco. The latter was described by news media as a “tidal wave of suds.” Screen shots follow:

AFFF foam covers street

AFFF spill in SF Bay Area, California.

People watching foam spill

People were fascinated by the “tidal wave of suds.” Newscasters mostly made light of it because they didn’t know about its harmful qualities.

Unfortunately, either nobody knew or nobody mentioned that these suds, through which you can watch a bicyclist disappear as he speeds along, contain some of the most toxic and persistent substances ever known, and cause a variety of illnesses including cancer.

Foam-covered bicyclist

Nobody warned the public about the carcinogenic nature of AFFF; the worst caution was, “It can burn your eyes.” As a result, some people played in the suds. In 1997, the US Army Corps of Engineers told other branches of the armed services to treat AFFF as a hazardous material. That’s 20 years ago.

While quantities of AFFF chemicals stored on military bases and in fire trucks along runways seem small, consider the fact that 600 gallons of it would combine with about 20,000 gallons of water to make about 80 tons of fire suppressant. Being hard to clean up and easily airborne, most of it ends up seeping into the ground or flowing into waterways. It doesn’t take much of it to contaminate a large body of clean water.

An article in the Colorado Springs Gazette reported: “An EPA advisory in May warned that water could be harmful if such chemicals surpassed more than 70 parts per trillion – significantly lower than an advisory issued in 2009. Speaking again to the power of the foam, the 3 percent chemical with 97 percent water solution used to fight fires is 300,000 parts per trillion. A tablespoon of the chemical in 20 Olympic-sized pools would easily exceed the EPA threshold.”

Wind catches foam2

AFFF is light and easily windborne.

There’s no getting around the fact that while AFFF really works on fires, one must consider that when entire aquifers get contaminated and cancer strikes children as well as adults, we have to ask ourselves if the cost is too high. According to an online brochure from the Department of Defense’s own program for addressing contamination by AFFF, there is no way to treat groundwater in situ for perfluorinated compounds (PFCs) and very limited options for treating it ex situ, meaning the Navy would have to build a massive and very expensive treatment plant to extract and treat the groundwater, like the one they’re considering building in Bethpage, New York.


Diagram of the contamination plume around a military runway at Bethpage, NY. Deepest contamination found so far is 800 feet underground.

In mid-October 2016, 150,000 gallons of AFFF-contaminated water [the equivalent of more than 16 gasoline tankers] were spilled from an Air Force base in Colorado into a municipal sewage system, thoroughly contaminating it. Military officials said they weren’t required by law to notify downstream users of the water in the contaminant’s path because, as one said, “at this point it is a non-regulated substance.” The base didn’t even sample the wastewater to determine the level of contamination, and did not make the spill public for 6 days. Now an entire aquifer is contaminated, and thousands of people are without reliable drinking water.

bottled water

These perfluorinated chemicals, which are very persistent in the environment, kill slowly. Immune system and liver damage, along with cancers, especially of the kidneys and testicles, plus fetal development problems and low birth weight are a major concern. At a minimum, AFFF chemicals can cause high cholesterol, a precursor to heart disease. A 2011 Army study found a possible link to autism. A European study has found that the replacement chemical for AFFF is already being found in blood and is causing similar health concerns. Hundreds of towns across the country are dealing with this and other military-caused contamination problems.

Groundwater flow in blue arrows

The hard-to-see blue arrows show the direction of travel of a mile-long contaminated groundwater plume at Whidbey Island. Unfortunately, the plume is moving in multiple directions.

This bad news has come home to roost. The Navy has used AFFF for decades at Whidbey Island’s Ault Field and at its outlying landing field (OLF-Coupeville,) a WW2-era runway that’s 3,000 feet too short for Growlers to land on. OLF Coupeville is also smack in the middle of a residential area where many people get their drinking water from private wells. Since November 2016, roughly 2,000 people whose drinking water has been contaminated by a mile-long expanding underground plume coming from the runways, have been forced to turn to bottled water for home use. For awhile, the Navy was only testing wells if residential owners requested it, which meant that only those who were aware of the contamination problems were getting their water tested. This has many people whose wells have not been tested now wondering if their water is safe to drink. Given what is well-known about the movement of toxic plumes through soils and groundwater from similar situations in other areas, that’s a daunting question. In January 2017 the Navy produced a report detailing its plan to test drinking water, but it’s so heavily redacted that it’s not very useful. (See below.) Why would the Navy withhold so much information? It’s not classified, it should all be public knowledge. The Navy isn’t drinking that contaminated water, the people are, and some probably have been drinking it for awhile. The Navy at Whidbey Island gets its drinking water from another source, not groundwater.

And remember, the more Growlers there are near residential areas, and the shorter the runway, the more crash risk there is, and the more need there is to train to fight fires. 

Screen Shot NAVFAC report redacted

Cover of Navy testing plan report.

Redaction, NAVFAC report

One of many redacted pages in the above report.

Earlier this year, the Port of San Diego sued the Navy over a toxic plume that is contaminating San Diego Bay. Literally, the whole bay. In 3 counties in Pennsylvania, drinking water for 70,000 people has been contaminated with the same toxic chemicals as on Whidbey Island, and people are falling ill. Because the Navy was so unresponsive, even refusing to pay for blood tests and ignoring a request from Pennsylvania’s Governor, a state legislator had to publicly urge these victims to sue. What does it say about the Navy’s arrogance when elected representatives are so powerless after exhausting all avenues, that they tell you, in order to get the Navy to do the right thing after it has poisoned your water, you must spend your own money on a lawsuit? What does it say when they redact a report you need to see?

NAVFAC report redacted page

Another redacted page from the above report.

The most disturbing part? They’ve known all along. For decades the military has ignored warnings from its own researchers. According to a news article in Colorado from last October, “Multiple studies dating back to the 1970s found health risks from the foam, and even an agreement 16 years ago between the Environmental Protection Agency and the foam’s main manufacturer did not curtail the Air Force’s usage. Until drinking water tests announced by health officials this year revealed contaminated wells here, the Air Force did almost nothing to publicly acknowledge the danger of the firefighting chemical.”

Although we’d love to give the Navy the benefit of the doubt about possibly not knowing the foam is so toxic, that’s not going to happen, considering the other unacceptable ways they’ve behaved toward their neighbors. They knew AFFF was harmful. A long time ago. In 1991, the Army Corps of Engineers had told Fort Carson to stop using the foam, and in 1997 it told soldiers to treat it as a hazardous material, calling it “harmful to the environment.” There is no way the Navy did not know that AFFF is harmful.

New chemicals to replace PFCs are proving problematic to health. 

A legal settlement reported in the National Law Review would require EPA to create regulations on this contamination by 2019, but if EPA is defunded or eliminated, what then?

Another irony on Whidbey Island is this: In a media interview, Whidbey Island Navy spokesman Mike Welding sought to reassure a nervous public by saying the Navy will remove the contamination, but the Navy knows full well that this cannot be done. He said, “The Navy is going to provide those people with safe drinking water until we can figure out how to remove the contaminant from the water well, filter it out or something like that. It’s something that still needs to be worked out.” Unfortunately, a statement from the Department of Defense’s own “MERIT” program that is easily found on the internet contradicts Mr. Welding: “Currently, there are no in situ technologies and very limited ex situ options to treat soil or groundwater contaminated with PFCs.” This comes from a bulletin that has long been published and distributed to federal and state agencies.

Contaminated water

So why would the Navy mislead people into thinking their water can be decontaminated? Sadly, these are not isolated examples. The plight of hundreds of towns nationwide where drinking water has been contaminated by firefighting foam chemicals called PFCs and PFOAs, are being revealed in a long line of stories, which are most decidedly not fake news.

Let’s look at a few, shall we? The following 19 stories are FROM THE LAST TWO MONTHS ONLY, and do not include anything about recently discovered explosive ordnance in places such as the Padre Island National Seashore in Texas, or the Plum Tree Island National Wildlife Refuge in Virginia, or along a popular hiking trail in Hawaii. This is depressing as hell to read and it may make you very angry, but unless people get informed about the magnitude of the problem, many of us and future generations are going to need whatever remaining insurance we have to pay for treating the cancers and other diseases from unwittingly drinking water contaminated by our military.

Grateful thanks to the Center for Public Environmental Oversight for tracking this issue. 

19 stories from January and February 2017, of a few of at least 6 million people whose drinking water has been contaminated by the military:

Feb 22, 2017 – Long Island, New York: Chemicals used by the National Guard in airport firefighting exercises were found in eight of the 41 private water wells they tested. Five of them are above the EPA’s advisory level. Story here.

Feb 19, 2017 – Okinawa, Japan: Since 2002, at least 270 environmental accidents on U.S. Marine Corps bases on Okinawa have contaminated land and local waterways but, until now, almost none of these incidents has been made public. U.S. Marine internal reports highlight serious flaws in training and suggest that the lessons of past accidents have not been effectively implemented. Moreover, recent USMC guidelines order service members not to inform Japanese authorities of accidents deemed “politically sensitive”, raising concerns that many incidents may have gone unreported. Story here.

Feb 19, 2017 – Camp Lejeune, North Carolina: A daughter and her father, who both lived at Camp Lejeune, have been diagnosed cancer within a few months of each other, the cause being the water they drank while living at the base. Story here.

Feb 18, 2017 – Palm Beach, Florida: Several sites tested around Palm Beach International Airport, which was the WW2-era Morrison Field and the Palm Beach Air Force Base during the Korean War, show dangerous levels of contamination. A Trump club is included on a list of sites being investigated by the state. Story here.

Feb 10, Lake Huron, Great Lakes: Toxic chemicals from an abandoned military base have contaminated residential wells and reached Lake Huron; residents are worried about how far the plume will spread. Story here.

Feb 8, 2017 – San Francisco Shipyard: Fake soil tests have delayed the transfer of some parcels of land to the city for development, a Navy spokesman admits. Story here.

Feb 3, 2017 – Laurel Bay, South Carolina: New Navy guidance to medical providers treating those who’ve lived in the Laurel Bay housing area in South Carolina expands the concern over potential exposure to cancer-causing agents, now addressing adult cancer risks as well as pediatric ones. Story here.

Feb 2, 2017 – Three towns in Colorado: An Air Force official revealed to the county commissioners on Thursday that the service has a five-year plan to mitigate water contamination that recently had southern El Paso County residents searching for clean water sources after wells in Security, Widefield and Fountain were tainted by perfluorinated compounds from toxic firefighting foam. A news investigation in October revealed that the Air Force kept the foam in use despite Defense Department studies over the years that showed it was harmful to laboratory animals. Story here.

Feb 2, 2017 – Merrimac, New Hampshire: Residents concerned Army might renege on its agreement to provide safe drinking water to the town after contamination from the former Badger Army Ammunition Plant. Story here.

Jan 26, 2017 – Puget Sound, Washington: The Suquamish Tribe and two environmental organizations have sued the Navy for Clean Water Act violations that would harm salmon. Navy is scraping the hull of a decommissioned aircraft carrier and allowing copper-based paint to fall into bottom sediments. Story here.

Jan 24, 2017 – Four New Jersey towns: Air Force is testing drinking water wells used by private residences in four towns for contamination caused by fire fighting foam. Story here.

Jan 21, 2017 – Oak Harbor, Washington: A mile-long plume of chemical contamination that’s likely carcinogenic has migrated from the Navy base to under the city. Story here.

Jan 19, 2017 – Westfield, Massachusetts: Officials with the Barnes Air National Guard said this week they are taking all appropriate steps to investigate groundwater contamination that may have emanated from the Westfield air base. Story here.

Jan 16, 2017, Long Island, New York: Everyone is applauding passage of a bill that requires the Navy to report to Congress annually on the toxic groundwater plumes emanating from former manufacturing facilities run by the Navy and Northrop-Grumman. Story here.

Jan 12, 2017 – Ivyland, Pennsylvania: For the first time, public information reveals how much of the toxic, unregulated chemical PFOA has made its way into the blood of a local resident, who discovered she had 15 times the national average, and sued the Navy. Story here.

Jan 13, 2017 – Laurel Bay, South Carolina: Military moms fear contaminants at military housing base are giving children cancers. Story here.

Jan 12, 2017 – Niagara County, New York: More than 70 years after World War II-era bombs were manufactured at a site in Niagara County, the U.S. Army Corps of Engineers has discovered soil there still contaminated by TNT and lead, and is proposing to clean it up. Story here.

Jan 10, 2017 – Lansing, Michigan: The state or federal government must now provide alternative water supplies to users whose water is contaminated as a result of substances migrating from government owned and operated properties, under state legislation signed today by the Governor. The legislation was prompted by groundwater and well contamination at the former federal Wurtsmith Air Force Base in Oscoda. Story here.

Jan 6, 2017 – many locations: A review of a book by Joseph Hickman, titled “The Burn Pits: The Poisoning of America’s Soldiers,” describes the open fire pits operated on over 230 U.S. military bases across Iraq and Afghanistan during our wars there. Every kind of waste – plastics; batteries; old ordnance; asbestos; pesticide containers; tires; biomedical, chemical and nuclear waste; dead animals; human feces; body parts; and corpses – was incinerated in them. Review here.

We could go on, with more stories from December 2016 about lead contamination at Bennington, Vermont, the same at Snohomish, Washington, we could talk about veterans drinking contaminated water in Michigan, pollution at a base in South Korea being 500 times normal levels, or with more stories from the US and beyond.

Testing water

A final bit of bumfuzzlery we report is this: On page 3-62 of the Navy’s recent Growler Draft EIS, which was published AFTER all the drinking water warnings came out and deals with Growler aircraft, but not with the toxic firefighting foam for the runways they use, all concerns about drinking water contamination are dismissed with this incredible statement about something that happened almost 20 years ago: “Remediation construction was completed in September 1997, human exposure and contaminated groundwater exposures are under control, and the OUs [Operable Units] at Ault Field and the Seaplane Base are ready for anticipated use (USEPA, 2016e).”

Say again? Human exposure and contaminated groundwater exposures are under control? This statement does not reference which contamination incident is being remediated, so unless a reader catches “1997,” it’d be awfully easy to misinterpret it. Given the weight of the other deficiencies in that Growler Draft EIS and the Navy’s foreknowledge of the drinking water contamination problem long before they published it, it looks like something more deliberate. It makes one wonder: why would the Navy print such a claim, knowing that its interpretation could mislead the public into thinking the contamination is under control, when in fact it’s just the opposite?

1 Where the Birds are - arcgis viewer

A reminder of where the birds are, too.

What can you do? USE YOUR VOICE! Now more than ever, you are needed. Every one of us is. Call a congressperson. Do it every day if you can, or at least 2 or 3 times a week. Write letters – to elected reps, the Navy, and to editors of newspapers. Inundate them all with mail objecting to this injustice, and to the noise, the pollution, the ruination of our local economies. To the fact that our entire national economy is based on war and oil. No single person has a magic cure for what’s ailing us, but together we can force elected officials to listen to us en masse, and to begin to heed our words and do what’s right. And if they refuse to do the right thing, we can keep working to get other people elected who will.

What should you NOT do?  Don’t allow the Navy to fall back on their old strategy, called “Monitored Natural Attenuation,” which is a bureaucratic piece of frippery that means, “Do nothing and let time take care of it.” We need action, and we need new policynow.  So that you’re ready for it, here is the Navy’s web page on Monitored Natural Attenuation, so you can inform yourself on what they are likely to propose for Whidbey and other areas. They’ve even developed software for estimating how long the plume will take as it travels through your drinking water wells.

Monitored Natural Attenuation

Navy diagram of “Monitored Natural Attenuation” of a contaminated groundwater plume.

Maybe it’s not too much to ask of a military that could get as much as an extra $54 billion out of our hides, to clean up after itself, take care of the innocent civilians it has harmed, and protect future generations without poisoning them. We can’t think of a more patriotic thing to do, unless perhaps it’s avoiding the elimination of the very agency that would oversee this massive cleanup on behalf of those current and future generations.

Child with cancer

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Navy’s invisible cost to Whidbey communities: $122 million

Irony alert

February 20, 2017 – Island County residents to Navy: Pay your taxes!  Two Island County Commissioners to Coupeville residents: Go pound sand.

Let’s start right off by saying this story is a bit bizarre. Imagine owning a lot of land and not paying your property taxes, even though you’ve been given a reduced rate. Now imagine that you haven’t paid it for many years. Think you could get away with that? The US Navy did. But nobody knew about it until recently. Well, nobody in the public, that is.

It begs two questions: Why hasn’t the Navy paid what it owes? And: Who let them off the hook?

Six months ago, an ad hoc and diverse group of Island County residents who weren’t aware of the missing tax money formed the Sustainable Economy Collaborative because they were concerned about invisible and unreported costs of Navy Growler operations, such as the steep drops in property values, the Navy’s contamination of residential and commercial drinking water supplies, and the impacts of Navy SEALs using 68 Puget Sound area beaches and state parks for combat training without consulting with the public, and oh we could go on.


Island County, WA shown in red.

The group’s concern was that economies in communities that depend on one large employer – in this case, the Navy – may appear strong but are actually, as they put it, “quite vulnerable to forces beyond their control.” So they asked some questions, pooled their money, and hired one of the top economists in the country.

The result is a report called Invisible Costs, released this week, that contains a bombshell: Over a 10 year period, Naval Air Station Whidbey Island has cost Island County $122 million dollars. These monies are due to the county, but have never appeared in its coffers. A brief report summary is here.

Burning money

Some of the report’s startling findings include:

1. An estimated $5.7 million per year in sales and property taxes is lost from Island County’s tax revenue because military installations pay no property taxes* and on-base purchases are exempt from sales tax.

2. The Federal government compensates the county for only 20% of the cost of public education of dependents of federal employees.

3. Property values in areas affected by excessive jet noise have declined by nearly 10 million dollars.

4. Island County residents pay $2.3 million per year for health costs due to the Navy’s activities.

*Actually, this is not really a property tax but is called a “Payment in Lieu of Taxes,” abbreviated PILT or sometimes PILOT. Federal landowners are supposed to pay a reduced rate to local governments on the property they own, in order to prevent a disproportionate burden of property taxes falling on private landowners who must make up the shortfall from federal lands that cannot be taxed. 

This bombshell lands in the middle of a rather large ugly crater from last week: two Island County Commissioners, who have steadfastly refused to consider testimony from Coupeville residents that includes medical documentation of harm from Growler noise, and who have actually treated them with what can only be called contempt and ridicule, refused to approve a $600,000 grant that would allow the town of Coupeville to build a public bathroom and beautify a community park.

Their reason? “Coupeville is anti-Navy.” Yes, they actually said that.

Commissioner Rick Hannold told a reporter, “IT’S A POOR use of tax dollars to support a town that is hostile toward the economic driver of the county.” He also threatened to veto grant funding for a local land trust that has a history of partnering with the county, because its director is a City Councilwoman who is a member of a group that is trying to educate the public on the Navy’s Growler EIS.

Note to Rick: Revenge is unbecoming in a public servant.

Comm Rick Hannold

Island County Commissioner Rick Hannold on right.

Referring to residents’ attempts to be heard about Growler noise, which Commissioner Jill Johnson evidently takes as a personal affront to her own patriotism, she said, “When you punch someone in the face, I don’t think you should be offended when you are punched back.”

We are not making this up. You can read the story here.

Note to Jill: Subtlety, while not your strong suit, would be better than a tantrum.

IC Comm Jill Johnson

Island County Commissioner Jill Johnson

The third Commissioner, Helen Price Johnson, exhibiting her characteristic empathy for constituents, voted to approve the grant but was overruled. Price-Johnson said, “Denying access to local economic development funds shouldn’t be used as a tool to punish people who may have a different perspective on a federal issue.” She also said it’s inappropriate for the two Commissioners to mix their personal feelings about one subject with a funding decision for a completely different matter.

Note to Helen: Thank you for your objectivity.

Comm Helen Price-Johnson

Island County Commissioner Helen Price-Johnson

So here are two of the three Commissioners, Rick Hannold and Jill Johnson, elected public servants who also happen to oversee the Island County budget, telling their Coupeville constituents that they are going to be punished, because they tried to exercise their First Amendment rights in trying to get the Commission’s attention about medical harm from Growler noise.

sarcasm loading

A quick google search reveals that Island County’s budget, which the Commissioners oversee, has not escaped pain from budget cuts in the last several years, to essential services such as police and fire, courts, and others. In fact, in 2011 the Island County sheriff’s office had the distinction of the lowest staffing level in the state based on officers per 1,000 population. So, it’s not like Island County is rolling in dough and doesn’t need any more. And it’s not like they haven’t had other revenue options. Money that was due to them, for example. Every year. Money that might have prevented cuts in essential services. Money they apparently never told their constituents was due.

Does anyone else think it’s time for an investigation? 


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To comment on the Navy Growler EIS by Feb 24, read this:

19a back end of hornet550x281-300x153

If you disagree that endless increasing loud jet noise belongs in residential areas and quiet wildlands in the Pacific Northwest, now’s your time to make your voice heard.

January 31, 2017 – The deadline for comments on the Navy’s Growler Draft EIS (Environmental Impact Statement) is February 24, which is an extension granted thanks to letters from Governor Jay Inslee, Senators Patty Murray and Maria Cantwell, and Reps. Rick Larsen and Derek Kilmer. This makes up for lost time over the holidays.

The West Coast Action Alliance has prepared notes that you can adapt and use to formulate your own comments. There are two ways to comment: by regular mail or online. Instructions are in the docs below:


Navy Growler EIS comments – Word document

Navy Growler EIS comments – PDF format


Consider sending a copy of your comments to your elected officials; they need to hear from you.

Congressional addresses:
154 Russell Office Senate Bldg, Washington DC 20510
DC: (202) 224-2621
DC: 866-481-9186 (toll free)
FAX (202) 224-0238
Seattle: 866-481-9186 (toll free)
Tacoma: 253-572-3636
Everett: 425-259-6515
311 Hart Senate Office Bldg, Washington DC 20510
DC: 202-224-3441
FAX: 202-228-0514
Olympic Peninsula (Tacoma): 253-572-2281
King Co: 206-220-6400
Pierce/Thurston/Kitsap: 253-572-2281
NW (Everett): 425-303-0114
Okanogan Co: 509-353-2507

1429 Longworth House Office Building
Washington, DC 20515
DC: 202-225-5916
Port Angeles: 360-797-3623
Tacoma: 253-272-3515
Bremerton: 360-373-9735

2113 Rayburn House Office Building Washington, DC 20515
DC: (202) 225-2605
Fax: (202) 225-4420

2264 Rayburn House Office Bldg.
Washington, DC 20515
DC: (202) 225-8901
Renton: (425) 793-5180
Renton Fax: (425) 793-5181

P O Box 40002, Olympia WA 98504-0002
Phone: 360-902-4111
FAX: 360-753-4110


As always, thanks for caring enough to participate in this important public process.

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Public objections pour in


UPDATE, January 16, 2017: The Forest Service comment period for the electronic warfare permit is closed and cannot be extended; however, the Navy has extended the comment period on the Growler EIS to February 24, 2017. Thanks to Senators Murray and Cantwell, Rep. Larsen and Governor Inslee for making these requests. We will notify people on our mailing list when suggested text we are working on is ready to adapt for your own comments. Sign up for occasional emails from us (on the right side of this page) if you want to be notified.

January 13, 2017Today is the deadline The deadline has passed for filing objection letters to the US Forest Service over their decision to grant the Navy a permit to turn the Olympic National Forest  into an electronic warfare range. Some people are having trouble finding the Forest Service’s web site, which, other than snail mail, is the only way you can comment. With a web address like this, it’s no wonder:  The other problem is that the comment box is at the very bottom of this web page, and people are not seeing it unless they scroll past big blocks of text all the way down. UPDATE: A third problem surfaced, in which some objection letters filed on January 13, before the deadline, were labeled in the database as having been filed on January 14, after the deadline. This problem happened in 2014, and back then we were assured by the Forest Service that they knew when comments were actually filed. 

We thought that some of these objection letters, all of which can be seen in the Forest Service Reading Room, might be worth posting, so here are a few of them:

West Coast Action Alliance/Olympic Forest Coalition objection letter

National Parks Conservation Association objection letter with support document

Forest Service Employees for Environmental Ethics objection letter

Olympic Park Associates objection letter

Sierra Club North Olympic Group objection letter

Olympic Peninsula Audubon objection letter.

Many people have asked for an extension of the comment period, since our federal and state government has “coincidentally” delivered to the public FOUR major comment periods over the holidays: this one for the Forest Service Navy permit, the 1400-page Navy Growler EIS, and two state Draft EISs (over a thousand pages) for marbled murrelets, both of which dismiss jet noise as a threat. Nice, huh. This is not what the public meant when we asked government agencies to work together.

If the Forest Service refuses The Forest Service refused to extend the objection period, citing legal constraints, so the next phase will be: They can take 30 days (or more) to review the public’s objections, then they make the final decision. We expect the final decision will be: screw you, public. This is why the number and quality of public objections has been important.

12:30 PM Friday: WE JUST LEARNED THE FOREST SERVICE’S SERVER WAS DOWN last night, and was put back online at 3:30 am this morning. If you filed comments during that time, check their Reading Room to ensure they’re still there. We have emailed Olympic National Forest Superintendent Reta LaFord and point of contact Greg Wahl, to ask for a 30-day extension of the objection period.

2:30 PM Friday: After notifying Forest Service of the above and asking for an extension, we received this statement from Greg Wahl: “I’m unaware of any scheduled server maintenance last night. We encourage online submittals but also offer hand-delivery or fax too. Unfortunately, per the regulations, we are not allowed any extension of the objection period.”

If you still want to object (before close of business today) go here, scroll down to the big black arrows, download the big file or the Cliff’s Notes version, and copy and paste your objections (or attach them as a file) here. (Scroll down to see comment box.) Don’t wait – they might not extend the objection period. COMMENT PERIOD IS NOW CLOSED.

Next up: Comments on the Navy Growler EIS, which closes January 25. FEBRUARY 24.  We will keep you posted and will help you with comments. After reading the Navy Growler EIS, we can say without reservation that it portrays an ugly time ahead.

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For more information from the Forest Service, get out the pry bar


January 3, 2016 – UPDATE: Just received this answer from the Forest Service, on whether there is a character limit on text that can be entered in the comment box on their web site: “The answer from our IT folks is “There isn’t a limit to how much text can be entered into the field on the web page. Technically there is an upper limit to how much text can be stored in a single field in the database but it should be around 2 gigs.”

We also just discovered this: While flying Navy training missions on weekends is not mentioned in the Growler DEIS, the Forest Service’s Draft Permit says the Navy will be allowed to fly on weekends so long as it does not interfere with “…opening day and associated opening weekend of Washington State’s Big Game Hunting Season for use of rifle/guns.” To see this incredible statement for yourself, go here, scroll down to “Decision,”and  click on the 4th link down, called “2016-11-29.NavyPermitDNAppendixC_DraftPermit.” Go to page 11, bullets 5 and 7. And ask yourself, why would our government do this behind our backs?

Why was this additional flight time period not mentioned in the Navy’s Growler EIS? It has long been understood, and the Draft EIS acknowledges, that the Navy will cooperate with local officials and populations by not flying training missions on weekends and holidays. No communities have had the opportunity to evaluate these additional noise impacts. Weekends are peak times for local economies, and to have that quiet obliterated by jet noise from a rapidly expanding mega-base is a threat to local economies. People come here throughout all 4 seasons to relax in peaceful, unspoiled surroundings. To not disclose weekend flying in the EIS, and then to extend such a courtesy to the big game hunting industry without consulting with municipalities and other economically viable (and vulnerable) tourism and recreation entities, is unwise, irresponsible, and does nothing to rebuild trust between the Navy, the Forest Service, and the public. 160 jets (yes, another 42 are coming after this EIS ends) and weekend flying will also make the Navy’s current noise level projections obsolete even before they are finalized.

There are several days left to comment on the Forest Service’s draft permit before it ends on January 13. Please participate. We have created draft comments for your consideration in this post. You can find them between the big arrows. To comment on the Forest Service’s web site, click here.

December 22, 2016 – This is an email exchange with Forest Service representatives in which we tried to find out the answer to two simple questions:

  1. In the Forest Service’s comment box where we are supposed to write or paste our comments, is there a limit to the number of characters? For example, Navy and Congressional comment boxes normally limit it to 5,000 characters, which is about 500 words. This precludes the public’s ability to participate by limiting what they can say in a public process. So it’s important to know if content will be cut off by such a limit.
  1. Is there an email address to which the public may send comments? There always has been in the past, and it is the most simple and convenient method of participation.

One would think answers would be simple, forthcoming and easy to understand. One would be wrong.


To: Greg Wahl,   From: Karen Sullivan                                                            Date: December 21, 2016

Subject: Can comments be emailed to you?

Hi Greg,

What if anything is the character limit on the Forest Service’s online comments box, and will the Forest Service accept comments by email if they are sent to you?

Thank you,

Karen Sullivan


To: Karen Sullivan  From: Wahl, Gregory T, USFS

Hello Karen, you can always attach your comments (word, pdf, etc) if you think there will be a concern with length. Please visit the project website here ( ) for more information about the proposed activities and the current objection period (and how to submit objections). Let me know if you need any other information.



To: Greg Wahl  From: Karen Sullivan

Thanks, Greg.

I have visited this web site, and the information I asked you about is not clear, which is why I’m asking, because usually there is an option to email comments in a public process, and people have noticed there’s no email option in this one, though in 2014 you kindly accepted comments by email and forwarded them to the database. The pertinent paragraph says:

Objections must be submitted to Reviewing Officer Reta Laford. Electronic objections should be submitted to: Objections may alternatively be submitted by FAX (360-956-2330) and by mail or in person (1835 Black Lake Blvd. SW, Olympia, WA 98512) during business hours (M-F 8:00am to 4:30pm). In all cases, the subject line should state “OBJECTION Pacific Northwest Electronic Warfare Range”.

No email address is listed, but the public is used to being able to email their comments. This lack makes it harder. The character limit concern comes from the Navy, which limits its characters in comment boxes to 5,000, which for complex topics like this is insufficient. So, that’s why I’m asking what the Forest Service’s character limit is, because people who copy and paste their comments will have content cut off unless they check before hitting send. This is a real concern.

So, sorry, but I’ll have to repeat my questions: what is the character limit in the comment box, and if there is one, is there an email to which comments may be sent? Knowing the character limit will help people decide on whether or not to attach a file or paste contents in the comment box.


To: Karen Sullivan   From: Wahl, Gregory T, USFS

Karen, objections should be submitted to the link below through the project website. I have asked our IT people if there is a limit but I probably won’t get an answer from them today.



To: Greg Wahl   From: Karen Sullivan

If you could get me an answer whenever possible it would be much appreciated.


(No answer.)


Next day:    To: Greg Wahl    From: Karen Sullivan

Hi Greg,

It would be great to get an answer asap about a comment box character limit before everyone at IT goes on Christmas vacation.

Thanks again,




I’m currently out of the office until 3Jan17. If you need immediate assistance, please contact Tim Davis, Natural Resources Staff Officer, at 360-956-2430 or

If you have questions about the Navy permit project, please visit our website at for more information.


Greg Wahl

This electronic message contains information generated by the USDA solely for the intended recipients. Any unauthorized interception of this message or the use or disclosure of the information it contains may violate the law and subject the violator to civil or criminal penalties. If you believe you have received this message in error, please notify the sender and delete the email immediately.


To: Tim Davis

From: Karen Sullivan

Hi Tim,

Can you tell me if there is a character limit in the comment box on the Forest Service’s web page where citizens can write their comments on the Draft Record of Decision regarding the navy permit? Also, is there an email address to which comments can be mailed? Normally there is in a public process. I checked the web page, but neither question is answered; I asked Greg Wahl, but he is now out until January.

Thank you

Karen Sullivan


To: Karen Sullivan

From: Tim Davis


I am not aware of a character limit in the comment box associated with the comment method we are using with the Navy permit project. I copied the following from the letter announcing the start of the objection period. We request that electronic comments be submitted using this system.

Objections must be submitted to Reviewing Officer Reta Laford. Electronic objections should be submitted to:  Objections may alternatively be submitted by FAX (360-956-2330) and by mail or in person (1835 Black Lake Blvd. SW, Olympia, WA 98512) during business hours (M-F 8:00am to 4:30pm). In all cases, the subject line should state “OBJECTION Pacific Northwest Electronic Warf are Range”.  The comment method also allows the attachment of a document up to 10 MBs in size. The attached document has a link to the comment page.

I hope this answers your questions. If not please let me know.

(Letter from Dean Millett attached)


To: Tim Davis   From: Karen Sullivan

Thank you for responding right away.

Are you an IT person? I’m just seeking a definitive answer, because it seems to be the rule that comment boxes have character limits – in fact, I’ve never encountered one without them. All Navy comment boxes have them, and so do Congressional contact pages, so it would be unusual for the Forest Service not to have one. The usual limits are around 5,000 characters, which is about 500 words, but someone who contacted me said he managed to post 7,000 characters without getting cut off. It’s important that we know, because some peoples’ comments are longer than 500 words, and they may not realize when they hit send that all extra content is cut off if the length exceeds the character limit.

Thank you for anything you can do to clarify this.


To: Karen Sullivan   From: Tim Davis

I am not an IT person so won’t be any help there. I did call a contact in our Regional Office who works on administrative reviews and she is not aware of any character limits in that comment box. I agree that many similar systems have limits but to my understanding the “cara” system does not. If it is not too much trouble it might be safest with longer comments to write them in a Word document and attach them to the comment response.

Hope this helps.



To: Tim Davis   From: Karen Sullivan

Thank you, Tim.

I noticed in the letter you attached to your last email that the directions to the public are to address comments to District Ranger Dean Millett, not Reta Laford, as was previously instructed. If you could please clarify this, it would be much appreciated.




To: Karen Sullivan   From: Tim Davis

Sorry for any confusion. Please address objections to Reta Laford, who is the Reviewing Officer. Hopefully I didn’t add to the confusion in my previous messages. We are using a system originally designed to capture comments on projects to accept objections on the Navy permit project. This system helps us more efficiently manage objections.


To: Tim Davis   From: Karen Sullivan

Got it. Thanks, Tim. I asked Greg this question and haven’t received a satisfactory answer, so I will ask you, even though you may also not be able to answer it. I appreciate that the system helps the Forest Service manage objections, but it may not be that helpful to the public whose comments you are seeking, when a major option for public comment is eliminated.

There has always been a simple email option for comments, but this time there is not. This makes it harder for the public to participate, if for no other reason than it is eliminating a convenient option that people are used to. Unknowns such as whether or not there are character limits, coupled with finding your web site with its byzantine URL and learning the system, add to the confusion.

Back in 2014 the Forest Service’s comment web site malfunctioned in October, and lost a bunch of comments, including mine. It required another input of comments, with no certainty that they were accepted, and no certainty that the people whose comments were lost knew about it and were able to put them back in again. So, many people remember that well, and are leery of comment boxes that have given them too many surprises. The idea behind public participation in a NEPA or any other process is to make the participation of as many people who want to, not only possible but convenient. This system may be going in the right direction for the Forest Service, but not the public.

I know you can’t do much about this as the unlucky person who has to work when everyone else is on Christmas break, but would you please forward these concerns to senior management, including Reta Laford, and ask them, because these concerns have still not been addressed, that the comment period be extended by 30 days to allow the time needed for the public to find, learn and use the Forest Service’s new system for managing objections?

I hope to hear an answer by January 3, when everyone returns from Christmas vacation.

Thank you.




(No answer.)


As for the message from Mr Wahl’s last email warning that unauthorized use or disclosure of the contents of these messages that may result in civil or criminal penalties to the violator, well, we didn’t get his authorization to publish this, so we are accepting any and all Christmas fruitcakes with nice raspy metal files baked into them.


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Get Ready to Rumble: Navy Jet Noise to Dramatically Increase

Child with headache

Some school classrooms will experience hundreds of jet noise interruptions per day.

December 2, 2016 – The public is being hit by an avalanche over the Thanksgiving, Christmas and New Years holidays. Two major federal actions toward militarizing the Pacific Northwest threaten to affect the lives of those who live not only on Washington’s quiet, lushly forested Olympic Peninsula, but also on Whidbey and the San Juan Islands, Canada’s Gulf Islands, and the southern Vancouver Island coast. Two separate public comment periods are now open; one is called an “objection period.”

Although the Forest Service had publicly said it would wait until February 2017 to issue their decision on granting a permit to the Navy for mobile emitters to conduct electronic warfare in Olympic National Forest, that decision is here now, piled on to the Navy’s Draft Environmental Impact Statement (EIS) on Growler jet increases. This means that the public must try to focus on these two important issues during the most distracting time of year, when the focus is normally on family gatherings and holidays, and despite the fact that the Forest Service was specifically asked to stick to its original date, so this wouldn’t happen.

It’s worth noting that this tactic of coinciding with holidays and other distracting dates is no coincidence; for example, the Navy’s only public meeting on an Environmental Assessment they released over last year’s holiday season, that quietly quintupled the number of pier pilings they had previously told people could be installed in Port Angeles Harbor, occurred on the same date and in the exact two-hour time slot occupied by the first Presidential debate.

jet noise at holidays

So, here are the two major things that we must all try to focus on before both comment periods end shortly after the holidays:

1.) The US Navy recently released its Growler Environmental Impact Statement (EIS,)  detailing huge increases in jet noise, including a 600% increase in low-level training operations at Outlying Field Coupeville, exposure of nearly 3,500 more children to noise at health-damaging levels, and interruptions in some classrooms at rates of 45 times per hour. A typical training day around OLF Coupeville would have 10 different Growlers doing 10 touch and goes each totaling 100 loops around the airfield. This would be spread over both day and night training and would happen on 175 days of the year. Since training is needed when squadrons are scheduled to deploy, this intense activity would be 5 days/week for 3-4 weeks at a time, pause for 3-4 weeks, then resume.

The Navy made no actual noise measurements in communities, just computer modeling that averages jet noise with periods of quiet. Naval operations will cause huge increases in jet noise over communities throughout the region, and in wilderness areas of Olympic National Park, obliterating its famous quiet. Air pollution will dramatically increase, too, as will the risk of jet crashes. The only thing that is guaranteed to go down is property values.

If you want to know what it’s like for a soldier who is recovering from PTSD and trying to help others do the same on the western side of the Olympic Peninsula, but whose recovery is now threatened by all this jet noise, read this story.

The Citizens of the Ebey’s Reserve issued this press release, which graphically explains some of the public’s concerns. The National Parks Conservation Association just released this statement. The West Coast Action Alliance will also provide assistance in preparing your comments in time for the closing deadline of the Navy’s comment period, which ends January 25, 2017. Meanwhile, in early December you might want to attend what will be the only public meeting with the Navy on the Olympic Peninsula; it’s not really a meeting but an “open house” on the Growler Draft EIS, held from 3 p.m. to 6 p.m. on MONDAY, Dec. 5, at the Fort Worden State Park Conference Center/USO Hall at 200 Battery Way, Port Townsend.

Canadians are feeling the jet noise pain, too. The Navy refused to hold a meeting in Canada, despite requests; instead, they say Canadians must come to the US if their concerns are to be heard. The only other scheduled Navy public meetings are December 6 in Oak Harbor, WA, December 7 on Lopez Island, December 8 in Anacortes, and December 9 in Coupeville. Details are here. A post from the Citizens of the Ebey’s Reserve details all public involvement opportunities. Another page lists all the acronyms so you aren’t thrown off by not knowing them. Here is the Navy’s web site saying how you can comment. In another post we will provide help with Growler EIS comments.

For the rest of this post, we’ll focus on the second major federal action:

2.) The US Forest Service just announced its decision to grant a 5-year special use permit to the Navy to conduct electronic warfare using mobile emitters on national forest roads. The public has 45 days, starting November 29, to read up and comment. We will help you to do that. The Forest Service’s deadline is January 13, 2017. Forest Service District Ranger Dean Millett, whose title includes the term “Responsible Official,” has for two years voiced his unequivocal support for the Navy and his lack of support for public concerns. Some of his remarks that show this disregard, along with the Navy’s overt control over a Forest Service public process, were videotaped by citizens. Mr. Millett’s bias has been clearly established.

The Forest Service “ …based its draft decision on more than 3,000 public comments on the proposal, and on the Navy’s final environmental assessment, published in September 2014.” To get that many comments on an EA is unusual. Despite acknowledging the fact that the public’s comments, many of which described substantive legal and ethical issues, “have been overwhelmingly against the plan,” the Forest Service’s decision came down to this: Screw you, 3,400 commenters.

2 Growler-kill-mark-close

Graphical honesty from a Growler pilot about human targets.

So, let’s raise our voices. This chance to speak up about militarizing our region won’t come again, and an avalanche of public comments is a good way to tell them that the public intends to make a stand. The volume and content of comments and public resistance from 2014 helped get the public two more years, and thousands of comments this time may also help the legal cases that will be filed in pending lawsuits–because the legal and ethical holes in this EA and its processes are big.

Say No

Here’s how to comment on the Navy permit: A Forest Service “objection period” is open until mid-January. Objection periods are a bit different from comment periods, in that you must build on the original comments you made in 2014 with new information you have learned since then, and then suggest a remedy and explain why it should be adopted. Basically it’s a way of saying, “Dear Forest Service, in 2014 we expressed concerns about XYZ and you didn’t address them; therefore, we are objecting to your decision because you never addressed our original concerns. Here is a suggested solution to this problem; the reason we think this suggestion should be adopted is because XYZ concerns could be properly addressed and mitigated.” Or something like that.

Which leads to another problem: only the people who commented during the Forest Service’s open comment period in 2014 will be allowed to file objections now, so if you did not comment back then, your comments will be disqualified… UNLESS… perhaps you know someone who did comment back then; if so, try to get together with them and combine your feedback to build on their original comments. Make them the lead commenter, and co-sign the document. If you’re not sure who commented two years ago, you can find all those comments and names of all 3,000 commenters in the Forest Service’s database here.

Since organizations frequently team up to write and sign comment letters, there’s no reason why citizens can’t do this, too—as long as the lead person signing your letter had submitted comments in 2014. The Forest Service’s instructions are elaborate and easy to mess up, so we have prepared a sample comment letter and a 17-point analysis of this Electronic Warfare Range EA and its process that you can cut, chop, paste, edit, print, sign and send. Or place your comments in the electronic comments box, but be aware there is probably a 5,000 character there’s no character limit – we finally got an answer to this questionbut you can probably split it into multiple comments.

This letter raises factual issues on the Navy’s Environmental Assessment (EA), the flawed public process, and the Forest Service’s acceptance of an EA that excluded the public and contains scientific and procedural flaws that the Forest Service has not corrected, despite numerous public requests. You may use or adapt the 17-point analysis and/or the condensed letter as you see fit, to build or augment your own comments. Mailing addresses and all the required information are on them. The condensed letter is 11 pages long, single-spaced and without footnotes to supporting documents; the 17-point analysis/letter is 37 pages, 1.5-spaced, and contains footnotes with links to supporting documents that you can find online if you copy and paste the URLs. Both are highly detailed, but the condensed letter is the “Cliff’s Notes” version; we suggest becoming familiar with full version contents, too.


Here is the sample objection letter, condensed version no footnotes:

Microsoft Word file        PDF file       Plain text file

Here is the 17-point analysis/letter with footnotes to supporting documents online:

Microsoft Word file       PDF file       Plain text file (footnotes at end)


The Forest Service’s first notification of their draft decision contained errors, so there may be some confusion on who to send comments to; send them to Reta Laford, not Dean Millett, but use the same address. Our sample letter has the corrected information.

composing comments

The Forest Service’s draft Decision Notice and Finding of No Significant Impact is here. At the bottom of that web page is where you can submit your comments electronically, and attach supporting files as long as they don’t exceed 10 mb. We do not know if there is a character limit on this form, but we suspect there is (it’s usually 5,000 characters) so if you choose to go electronic you might have to submit your objections in a series of separate comments–but at least you can attach files.You can also print and mail or fax your comments.

The Forest Service’s page containing backup materials is here.

A lot of learning by the public has happened since November 2014, when we were all caught flat-footed without enough information to comment in much depth. You are to be congratulated on your willingness to follow difficult and complex topics. Remember that the Forest Service’s web site in 2014 originally contained almost none of the documents we all needed to learn about this, even the EA itself, and by the time they put them all online, most of the comment period had passed and many people had given up in frustration. That’s part of why that comment period was extended twice. Now that we all know a lot more about electronic warfare than we ever wanted to, let’s use that knowledge, because as we said, lawsuits that are pending might find your comments, and the sheer volume of them, useful.


Beach camping, Olympic National Park.


Forest Service updated instructions: “Objections must be submitted to Reviewing Officer Reta Laford. Electronic objections should be submitted to: Objections may alternatively be submitted by FAX (360-956-2330) and by mail or in person (1835 Black Lake Blvd. SW, Olympia, WA 98512) during business hours (M-F 8:00am to 4:30pm). In all cases, the subject line should state “OBJECTION Pacific Northwest Electronic Warfare Range.” For additional information about this proposed decision or the Forest Service objection process, contact Olympic National Forest Environmental Coordinator Greg Wahl (Phone: 360-956-2375. Email: Address: 1835 Black Lake Blvd. SW, Olympia, WA 98512.)”

Let’s roll up our sleeves and get to work, and thank you for caring enough to participate.


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Special report from Standing Rock – how the same abuses of law are causing injustice

November 26, 2016 – Special Report on Standing Rock:  Some members of the West Coast Action Alliance have traveled to Standing Rock. Here is an initial report from November 19, and,

Here is an update from today, on recent events.

The same abuses of the National Environmental Policy Act (NEPA), the Endangered Species Act (ESA), and the National Historic Preservation Act (NHPA) that we have seen here by Pentagon agencies in the Pacific Northwest have led to this crisis for Native Americans in North Dakota.

what the Morton COunty sheriff called a %22fire hose%22

Water cannon used on water protectors at Standing Rock.

Here is the main issue:
The oil company called Dakota Access Pipeline (DAPL), after splitting an eleven hundred-mile pipeline into multiple environmental assessments so that people could not assess its full impact, reacted to strenuous objections from the people of Bismarck, North Dakota by re-routing the pipeline’s original crossing point, so it wouldn’t threaten their water supply. DAPL re-routed it through former Sioux Nation treaty land that had been seized by the US government, sold into private ownership, and eventually sold to DAPL. The pipeline route is destroying sacred burial grounds, and is directly upstream from the water supply for the Sioux Nation and 18 million people downstream. Despite its claims to the contrary, DAPL did not consult properly in a government-to-government manner with the Sioux Nation, and is now defying requests from three federal agencies and a court order to stop construction. It is about to proceed with drilling under the Missouri River, despite no permit issued yet by the Army Corps of Engineers. It will likely begin that drilling in the coming week.

Bismarck is 90 percent white. Standing Rock is Native American. Do the math. This is a perfect example of where abuses of laws designed to protect clean water, air and land end up prioritizing whose environment they’ll protect. Eventually you end up with a social justice issue as well as an environmental one, not to mention a mortal threat to the sovereignty of the Sioux Nation.

Without mincing words, what we have here is the US National Guard, federal marshals, local and state police from 7 states and others acting as armed corporate security for an oil company that is willfully violating federal law. If that’s too strong a statement without factual support, read this letter from the President’s Advisory Council on Historic Preservation.

If you read the legal documents prepared by DAPL for the purpose of obtaining a permit, it’s clear they’ve cheated. It’s also clear that the Army Corps of Engineers has allowed it. The same abuses of laws regulating environmental and cultural damage that we in the Pacific Northwest have seen in the Navy’s extreme expansion of activities are also occurring at Standing Rock via the Army Corps. The same types of abuses are also contributing to the struggle of the Chamorro and Carolinian peoples in the Northern Marianas Islands, where the Navy wants to kick them off an island they’ve inhabited for 3,000 years so it can be used as a bombing range. The same abuses are causing anguish among Native Alaskans as their lands, waters and livelihoods are being threatened. Deep as it is, Standing Rock is the tip of an iceberg of legal abuse, and these legal abuses threaten Tribal sovereignty as well as the environment, across the nation and beyond.

Here is the other main issue:
Elders of the Great Sioux Nation have instructed that all protests be done in peaceful ceremony and prayer, with no anger, foul language or non-peaceful tactics, no matter what the provocation. No. Violence. Period.

Yesterday the US Army Corps of Engineers (“ACE”) issued an order that it intends to close the camps that are currently leasing former Sioux land from the ACE, and it has said everyone must be out by December 5, which is a week from Monday. Here is a news release with the ACE’s order and a response from the Standing Rock Sioux Tribe.

It should be noted that the largest single customer for fossil fuels in the world is the US military, and that the Pentagon, of which the Army Corps of Engineers is a part, has institutionalized the chronic abuse of environmental and cultural/historic protection laws as standard operating procedure, across all branches of the Armed Services when it is to their benefit. One of many examples of that in the Pacific Northwest can be found here. Such abuses of law, along with lack of adequate notification for Tribes and the public, have resulted in uneven decisions on whose environment or history or culture is protected. We all know how disproportionately minorities continue to bear that burden.

It’s similar here; except for the immediate environs of the naval airfields at Whidbey Island, Tribes on the West End of the Olympic Peninsula are experiencing the worst jet noise, have had deadly contaminants dumped in their Usual and Accustomed fishing grounds, and were told in government-to-government consultation, when it finally occurred, that the massive increases by the Navy were mere “adjustments.”


The Navy has recently released another EIS, on adding Growler jets to its fleet. We are analyzing it and will prepare a report.

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The Navy’s Toxic Legacy, Part 3


Sockeye salmon run. NOAA photo.

November 15, 2016 – What else besides depleted uranium has been and will be dumped by the Navy in Pacific Northwest waters? Find out in this article published today, by Truthout investigative reporter Dahr Jamail. He includes a list of toxic chemicals that are usually found on Superfund site lists of the most poisonous substances known to man. You can’t keep dumping this stuff in the coastal oceans for decades and then disavowing responsibility for it without bringing suffering to the animals and people who live there. Jamail’s article cites the Safe Drinking Water Act definition of “contaminant;” the government creates “not to exceed” levels based on what it knows about each, to minimize human exposure to a large list of them. The trouble is, new information about toxicities emerges fairly frequently, and exposure standards are sometimes revised.

As we reported last week, the Navy closed the books on its Northwest Training and Testing EIS by signing a Record of Decision, which basically means, “Let the destruction begin.” We do not say that facetiously; the Navy’s job out here is to teach its personnel to destroy targets by explosive or weaponized electronic means. Training is necessary for safe operations, but at the expense of more than a million marine mammals?


Orca whale

How to read a Navy EIS:You can start at the beginning and feel your brain melt, or you can use keywords and the search function available for PDF files, as long as the files are not too old. This is important because the latest EIS, published November 10, is about Growler jets, the third piece of this giant puzzle, and you can find it here: Growler Draft Environmental Impact Statement Available for Public Review Comments are due on January 25, 2017.

Download a piece of the EIS, open it and start using keywords. This lets you bypass boilerplate gobbledygook. Let’s try the keyword “explosive.” Take the percentage, for example, of High Explosive compounds (HE) by weight, shown on a chart: Medium and large-caliber projectiles are 48% HE, and missiles, bombs and sonobuoys are 21, 24 and 7 percent HE, respectively. Some projectiles have explicitly stated loads, such as torpedoes, which have an explosive weight of about 1,000 pounds. By counting the numbers of projectiles fired (where that information is available,) and multiplying by the percentage by weight of explosive, you can estimate approximate contaminant loads, even though it’s important to understand that you’ll miss a lot, and also that some but not all of these compounds will be consumed in explosions. Also, the Navy only covered training but not testing, so your estimates will be low.


Jamail’s article also talks about tons of duds that don’t explode as planned. These are euphemistically named “residual explosive material” resulting from “ordnance failure.” About them the Navy says, “Chemical, physical, or biological changes in sediment or water quality [from these “unconsumed explosives”] would be measurable, but neither state nor federal standards or guidelines would be violated.”

We have several problems with that disingenuous statement. First, since the Navy operates just beyond 12 miles offshore, which is also the boundary where state and federal clean water standards and guidelines would apply, how then could such standards possibly be violated outside a jurisdictional boundary? Can the Navy prove their claim, even if they were within the 12-mile limit, especially over time as the metal jackets containing raw unconsumed explosives corrode and act like extended-release poison capsules? We doubt it. The Navy quoted a study admitting, “leaching of unconsumed explosives is considered a major source of sediment contamination in seas and waterways, and contaminants can subsequently move from sediments and accumulate in aquatic organisms.”


A 2007 report from the Army about closing open burning/open detonation pits at Sierra Army Depot in California said, “…direct contact with UXO [unexploded ordnance] would primarily present a safety hazard” due to potential for inhalation of particulates, direct contact with surface and subsurface soil, ingestion of groundwater, and indirect pathways such as consumption of contaminated crops and livestock if the contaminated areas were used for farming.”

Would someone please tell us why similar processes might not occur in an underwater ecosystem? Check for yourself the lists of known carcinogens, DNA-damaging chemicals, public health alerts, and toxicology reports; you’ll find all of these compounds. So it boggles the mind in ways that not even the current election season could, to read the Navy’s statement in its October 2015 EIS: “Most of the components are subject to a variety of physical, chemical, and biological processes that render them benign.” Excuse us please, while we throw up.

We should ask our government: Do you really know? Who is actually out there thoroughly measuring for contaminants, and where is the funding for research, analysis and mitigation?

If you hear a ringing silence it’s because these agencies are stretched so tight they probably wouldn’t know when standards are being violated because they’re not able to monitor, and they sure as hell won’t know where to measure because the Navy isn’t telling where they put the poison.


At current firing rates for duds only, Jamail’s article states that it would add up to an additional 9 tons of dangerous residual explosive material in our waters every 20 years; since they’ve been training here for six decades, there could be 27 tons of dud explosives sitting on the bottom, leaching dangerous toxics into our waters. As one of the most serious sources of major contamination in our seas, waterways and in the food web, it boggles the mind that the Navy’s EIS all but dismisses it.

It begs another question: why are there so many duds, and why is the Navy allowing lack of quality control in manufacturing to put its ships and submarines at risk by firing so many duds? Cleaning up the lapses in manufacturing to reduce the dud rate would be a good first step to increase safety and reduce pollution.

A good cumulative impacts analysis includes detailed discussion of the overall impact that can be expected if individual impacts are allowed to accumulate over time. With this much toxic contamination scattered along the coasts of a three-state area, there will be both individual and cumulative impacts as the amounts increase over the years. The Navy has proposed a 20-year time frame, but provided the public with a cumulative analysis that is incomplete, substandard, and completely lacking in hard data.

According to the President’s Council on Environmental Quality, “Evidence is increasing that the most devastating environmental effects may result not from the direct effects of a particular action, but from the combination of individually minor effects of multiple actions over time.” In the section of the 2015 EIS on Cumulative Impacts, the Navy says, “Long-term exposure to pollutants poses potential risks to the health of marine mammals, although for the most part, the impacts are just starting to be understood.” The impacts include “…organ anomalies and impaired reproduction and immune function.” One has to think that with this statement, the Navy has put the lie to its own specious claim that most toxics dumped in the ocean are “rendered benign.”

In the EIS section on Sediments and Water Quality, the Navy claims that “slow but significant removal” of two types of explosive material (RDX and HMX) happens through a chemical reaction whose speed is dictated by the pH [acidity] of seawater.Adequate proof is not provided, yet risks to human health from these toxins is well documented. It’s also commonly known that the oceans are acidifying, and that the pH of seawater affects the capacity of the living community of marine bacteria and benthic organisms to bio-degrade or encrust these toxic components, even to build shells on their own bodies. In May 2014, NOAA released a study on the acidic waters off the West Coast that are causing the shells of marine snails to disintegrate.


These marine snails are part of the diet of pink salmon, mackerel and herring. Can anyone say that’s not something to be concerned about?

So, an acidifying ocean would considerably slow the rate of neutralization, but the Navy does not acknowledge that. Without these organisms, RMX explosive would take at least 100 years and HMX will take more than 2,100 years to disappear. So why is climate change not factored in? The Navy knows all about it, and ocean acidification, too.

Since climate change is known to change the chemistry and qualities of seawater, including its pH, and since climate change is not addressed by the Navy in this context of the span of future centuries of leaching and degrading of such toxins, and since the quantities being dumped actually do provide a “reasonably forseeable” number to work from, then claiming they are “rendered benign” in seawater is not just laughable, it’s an insult to future generations.


In addition to all the Navy’s omissions and disingenuous statements, such as the whopper that its massive increases are “adjustments,” how can a government agency keep telling us that decades of firing and dumping these materials into the ocean isn’t causing a toxic buildup? At what point is that buildup dangerous? Is anyone being given the funding to take a comprehensive and holistic look at wildlife behavior changes, cancers, metabolic, reproductive and immune system problems, or a host of other problems?

At present, ocean dumping is predominantly banned by international law. “Almost nothing is known about the tolerances of deep-sea organisms to the gradual build-up of anthropogenic chemicals, and there is a potential for changes to be widespread if they do occur,” said Fred Grassle, benthic ecologist and director of the Institute of Marine and Coastal Sciences. “Measurement of pollutants, descriptions of deep-sea communities from many parts of the ocean, and in situ toxicity studies are urgently needed.”

How can the Navy insist there are no adverse impacts to species or humans year after year, or unilaterally define what’s “acceptable” when the science insists that levels of concern for so many of these toxins haven’t even been identified?

How they do it is by claiming 63 percent of the entire one billion dollar federal budget for public relations; the Navy can afford to tell us just about anything they want, while expecting us to believe it.

Salmon Art



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Navy Doubles Down on Disturbance, Environmental Destruction


November 7, 2016 – Huge Expansion of Navy Activities Follows Record of Decision. The Navy announced that it will increase training and testing of bombs, torpedoes, explosives, sonar, and secret equipment in our beautiful Northwest waters. Changes include:

New biennial training exercises conducted in the offshore area;

Biennial mine warfare exercises in Puget Sound;

Testing of undersea systems, subsystems and components in Puget Sound;

Testing of “unique undersea hardware” and fixtures;

Resumption of testing activities at the Carr Inlet (Alaska) Operations Area;

Hundreds of sonar blasts from pierside maintenance and life cycle testing;

More ship activity;

Maritime security operations that will likely interact negatively with recreational boating and commercial fishing communities.

In addition, we can all look forward to enduring more harmful jet noise like this video, over our National Parks, and this video.


Dead whale, Puget Sound, 2016

On October 31, 2016 the Navy signed its Record of Decision on the Northwest Training and Testing EIS, despite overwhelming public opposition. Calling their massive increases “adjustments,” they pushed their agenda over the objections of the Olympic Coast National Marine Sanctuary, the US Fish and Wildlife Service, the President’s Advisory Council on Historic Preservation, and the State of Washington’s Department of Archaeology and Historic Preservation. They pushed their way through despite leaked emails that showed clear intent to break the law, despite public objection to Washington’s massive Navy SuperPac, and without completing legally required consultation with a Native American Indian Tribe.

They did it despite the toxic legacy they will leave to future generations, despite concerns expressed by UNESCO, pleas from the public, and  despite the public learning of the fraudulent process that let them get away with driving massive numbers of pilings in Puget Sound, 5,300 in all. The hubris is breathtaking. Brushing away American citizens as if we are little more than future collateral damage, they claim to have “carefully weighed” the factors in this decision, but the elephant in this ugly room is the fact that this decision was actually made many years ago, funds were committed long before the public process ever began, and what the public thinks matters to the Navy about as much as a gnat’s buzz. This Record of Decision is nothing more than retrofitted window dressing. Which begs the question: what decisions have been made that public “process” will be the window-dressing for in the future?

This behavior is not new. The Navy was named the “Top Polluter in Puget Sound in 1998, and was lambasted for spilling 181,453 gallons in seven years around US ports, averaging a spill every two days. Maybe they’re more careful with oil now, but we are looking at hundreds of thousands of “expended materials” made of extremely toxic materials in Northwest waters over the next few years, which will affect our salmon, tourism and other resources that are the cornerstones of our economy.

Humpback feeding

A humpback whale feeds.

This is the point where most of us want to wring our hands and give up. But consider this: Do serving men and women really want to see the millions of people their agency tramples unnecessarily, not just in this country but around the world, so alienated? Does the entire Navy really want to cultivate a reservoir of ill will from the agencies it intimidates and bullies? We doubt it. So don’t give up, even though saying “make your voice heard” sounds a little hollow right now.

Is it ever going to be possible to once again say the Navy is a good neighbor? Maybe not, but giving up will ensure that they continue to destroy the quiet soundscapes, richly diverse waters, and strong economies of communities in the Pacific Northwest. And that’s unacceptable at any price.

flag and statue of liberty

It’s not unpatriotic to ask your government to follow the law and respect people and the environment.

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The Navy’s Toxic Legacy, Part 2

Davy Crockett Weapons System from 1960s

A soldier readies a depleted uranium-tipped projectile on an Army base firing range. This 1960s-era weapons system was called “Davy Crockett.” Thousands of pounds of DU fragments and dust remain lying in the open on bases throughout the US, and multiple tons of it are lying on the sea floor in coastal waters.

October 31, 2016 – Investigative reporter Dahr Jamail has written another exposé on the Navy’s use of depleted uranium in Pacific Northwest waters. There are many disturbing revelations, among them:

  • The Navy did not phase out DU in 2008 as it claimed in a public EIS (Environmental Impact Statement.) In fact, a Freedom of Information Act request revealed that DU was still being shipped from Naval Magazine Indian Island in Puget Sound in 2011, and that guns were being modified/designed to continue using it.
  • The Navy continues to claim that DU dumped in the ocean is no more harmful than any other heavy metal. They cite a study done by a British military contractor that actually does not support their claim.
  • This UK study states that there are 31 tons of DU lying on the seabed in one firing range. The Navy’s use of DU in our own waters was at a similar rate, and calculations based on number of rounds of just one type of cannon shell fired indicate there could be 34 tons of DU in our waters, starting as close as 12 miles from shore. This would not include DU the Navy fired in other types of munitions.
  • Nearly a thousand pounds of depleted uranium fragments and dust are lying in the open at Joint Base Lewis-McChord in Washington’s Pierce County, and the Army has a new permit from the Nuclear Regulatory Commission to let it all stay there. According to a government permit, 12,566 pounds of pure DU scattered in fragments and dust, across 20 US bases, with questionable oversight.
  • Health effects on not just humans but also wildlife and the ecosystem we depend on are flying under the public’s radar, but should be of great concern. For example, the lung cancer rate in Pierce County, where Joint Base Lewis-McChord is located, is one of the highest in the state. Read the article for details.
Navy Warning Area-237

As much as 34 tons of depleted uranium lies in area W-237, starting 12 miles from shore.

The Navy and Army aren’t the only ones, either. Air Force bases and other branches of the armed services have even more depleted uranium. Eglin AFB in Florida, for example, asked for authorization to decommission a DU test area, and reported 3200 kg, or 7,054 pounds of DU in one 4-acre test area. That translates to 198 grams of DU per square meter! The in-soil concentration alone rivaled the average concentration of natural uranium ores mined in the US.

Can DU remain on the ground harmlessly? Not if dust blows into surrounding communities, or it leaches into the groundwater to contaminate soils and drinking water, or the soil on which it lies erodes and is washed into waterbodies, or new rounds hit DU debris or dust, pulverizing and spreading it further. According to a recent study, “Depleted uranium introduces large quantities of radioactive material that is hazardous to biological organisms, continues to decay for millennia and is able to travel tens of kilometres in air.”

And what about when the military does “controlled burns” in order to torch unwanted vegetation growth on firing ranges where DU fragments are laying? Why wouldn’t the intense heat and updrafts cause DU particles to become airborne? A recent independent study concluded, “The annual dose limit for the population can be exceeded within a few years from DU deposition for soil inhalation.”

According to a safety report published by the Nuclear Regulatory Commission (NRC), the duty of the person in charge of radioactive DU lying on the ground at military bases is to “ensure that occupational and public doses are as low as reasonably achievable (ALARA).” But “ALARA” standards referenced by NRC in this report apply to radiation workers, such as medical X-ray techs. They don’t apply to the general public living in communities nearby, which is borne out by the fact that the phrase “public dose” is mentioned ten times more often than the phrase “public health.”

Screen Shot 2016-10-19 at 4.17.34 PM

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