Does the Navy use the best available science? An essay.

Assessing damage to Los Angeles class submarine USS San Francisco in dry dock after running aground near Guam, January 2005.

Assessing damage to the billion-dollar Los Angeles class submarine USS San Francisco in dry dock after running aground near Guam, January 2005. While this photo is shocking and somewhat dated, it makes one wonder why the high number of ship collisions and aircraft crashes in 2017 alone (at least 6) continue, and what the Navy isn’t doing to prevent them. There is science in safety, and safety in science.

December 16, 2017 – This essay covers another angle of public concern about the US Navy in the Pacific Northwest. But our region isn’t alone in its frustration with a military hell-bent on expanding into civilian areas without regard for its neighbors.

Besides being intuitively obvious, the phrase “best available science” is also a legal directive in the Endangered Species Act, the Marine Mammal Protection Act, and the Magnusen-Stevens Fishery Conservation and Management Act. Basically, all of them instruct federal agencies to use the best available scientific and commercial data when making decisions under those laws.

2 Data Knowledge Action

As stated above, the meaning of this phrase might seem obvious, and most of us might assume that its use is being enforced by courts, but that would not be accurate. There have also been dozens of efforts by Congress to politicize it by allowing political appointees, rather than the scientific community, to determine what is best available science in their agency decisions. In 2017 alone, Republicans introduced 63 proposals to undermine species protection and force agencies to abandon the requirement to use “best available science” in their decisions.

So far, legislative challenges to weaken, limit, burden or stop use of best available science have mostly failed, except for a two-sentence paragraph that was inserted into a massive appropriations bill back in 2001, by a legislative aide who was anti-regulation. Nobody saw it until it was too late. The 2-sentence Data Quality Act is heavily biased toward industry and exploitation, and is a potent tool for beating back regulations that are based on science.

3 Data

In domestic examples of the consequences, the Competitive Enterprise Institute sued the EPA in 2002 to prevent dissemination of a Climate Action Report on the basis of not meeting the requirements of the Data Quality Act. A lobby group for salt producers actually sued the Department of Health and Human Services for claiming that too much salt is harmful to health, even though that claim was backed up by the National Institutes of Health, which said that the food industry was adding too much salt to foods. The Data Quality Act forces agencies to ignore the precautionary principle in order to meet the Act’s “information quality” requirements. The precautionary principle basically says that if the effects of your proposed action are unknown, then you probably shouldn’t do it. Which is exactly where we are with the Navy’s exponentially increased assaults on the environment, our local economies, and public health. We don’t know what the impacts will be, and frankly, neither do they. If you’ve read their documents, as we have, proof of “no significant impacts,” especially cumulative ones, is entirely missing, as is any definition of the word “significant.”

Unfortunately, the Data Quality Act is interpreted to mean this: if you can’t prove adverse effects beyond a doubt, you should go ahead with your action because the science is not proven, and therefore is invalid for purposes of the agency’s decision-making process. Got that? So where does the Navy come in?

New Navy ship

The last thing the Navy wants is to be caught contributing to the extinction of an endangered species or the reduction of a fishery, so anything that might make it easier to get around federal law is evidently welcome. We’ve discussed in previous posts how the Navy separates impact analyses into multiple pieces in their Environmental Impact Statements and Assessments, in order to water down the public’s knowledge of the full picture of effects. Now we’ll show how the Navy benefits from this speed bump on the road to using proper science.

5 Sperm whale

Right after the Data Quality Act was passed, 12 endangered species were immediately downlisted or delisted. Recently an oil company successfully sued to get another species off the list so it could develop an area. Without the slight margin of error we get from the precautionary principle, which is bedrock to the conservation of ecosystems, we walk the razor’s edge of extinction without a safety net.

The federally threatened marbled murrelet.

The endangered marbled murrelet.

So, with the Navy so resistant to give up data that would help scientists to understand the harm being done, even going so far as to classify information that was once freely available, it’s more difficult than ever. The National Parks Conservation Association saw their Freedom of Information Act request about Navy activity in the Olympic National Forest granted, but the Forest Service deliberately delayed sending them the data for six months, until after just the comment period closed and the information could no longer be used in their comments. NPCA sued, but it’s doubtful they’ll be able to affect the final record of decision. Why would the Forest Service violate the law on behalf of the Navy? Is this fair to the public? Let’s answer that by addressing another question.

7 FOIA cartoon

Is the Navy using best available science? We can assume that the Navy is well aware of the unevenness around the use of best available science. After reading dozens of Navy EISs, EAs, letters and internal materials provided by a whistleblower, our answer to this question would have to be: they use best available science when it’s to their advantage; when it’s not, they don’t. But we are not the first to say that. The Natural Resources Defense Council (NRDC) is one of many observant organizations that have written letter after letter to the Navy over the years, saying similar things. Here are some quotes from a variety of letters by NRDC to the Navy, starting in 2009. It almost doesn’t matter what the subject was, the complaints made then are the same complaints we have now.

“…dismisses or improperly minimizes any significant risk to fish and wildlife in this area.”

“…assessment of impacts is consistently undermined by failure to meet these fundamental responsibilities of scientific integrity, methodology, investigation and disclosure.”

“…analysis substantially understates the potential effects of sonar on marine wildlife.”

“…concludes that only one harbor seal would suffer serious injury or die during the many hours of proposed sonar training. The Navy reaches this conclusion by excluding relevant information adverse to its interests, using approaches and methods that are unacceptable to the scientific community and ignoring entire categories of impacts.”

“…analysis entirely fails to account for cumulative impacts for the years of anticipated activity.”

8 Navy explosion2

It’s worth noting that the NRDC has won nearly every lawsuit it has filed against the Navy. But it’s like trying to play a giant whack-a-mole game with someone who has all the advantage. The Navy keeps violating legal requirements so often that some attorneys have described the Navy’s position as default noncompliance with environmental and public health laws.

10 Orcas

Many of us have been saying these things for years, and we’re still saying them on almost every proposed action the Navy makes. Tribes, environmental groups, concerned citizens, local governments and even Members of Congress have been pointing out these deficiencies. County Boards of Supervisors in Mendocino, Marin and Humboldt counties in Northern California and in Lincoln County, Oregon, plus the City Council in Port Townsend, Washington, and multiple other local government bodies throughout all three states have sent official letters strongly objecting to the harm caused by various “…inadequacies, contradictions, lack of reliable data, insufficient mitigations, lack of transparency, and lack of commitment to public engagement.” A 2009 letter from seven Senators in the Pacific Northwest complained about the astounding number of marine mammal takes – 11.7 million over five years, and questioned the Navy’s justification. Eleven city councils in Alaska have passed resolutions objecting to the Navy’s timing of its war games in that state. The Navy’s Northwest Testing and Training Range manager told this writer privately at a meeting where 150 people were lined up to give testimony that was never officially accepted for the record, “We’re here to listen to what they have to say, but we’re not going to do anything about it because we don’t have to.” Yes, he actually said that.

Special Report KTVU Ten OClock News

So, to demonstrate our claim that the Navy only selectively uses best available science, here are just five out of dozens of recent examples, all of which come from Navy-produced documents:

Example #1. Twenty thousand tons of heavy metals that are toxic to the environment will be dropped, exploded or discarded into our local Puget Sound and Washington and Oregon coastal waters over the next twenty years. This will be the equivalent size and weight of one Yorktown-class aircraft carrier, but totally made of contaminants. Without citing any scientific proof, the Navy’s 2015 Environmental Impact Statement (EIS) claims the contaminants will be “neutralized” by chemical reaction with seawater, or “rendered benign” by organisms that will consume them. It does not discuss cumulative effects from previous decades of toxic deposition, or the prior use of more than 30 tons of depleted uranium in cannon shells, much of it in waters where 4 Northwest Tribes have Treaty rights. Another EIS for “Phase Two” with more increases is coming out in 2018.

12 Underwater

Example #2. In 2014 the Navy wrote an EA for proposed actions on Forest Service roads. They said amphibians are not found in disturbed areas, therefore there would be no harm done to amphibians. Any third-grader knows that a), this is a rainforest, and b), you find amphibians in rainforests, whether disturbed or not. Many of us pointed this out in comment letters, but the Forest Service did not even attempt to correct it before endorsing the EA and issuing the permit.

USFWS Spotted_Owl_and_Marbled_Murrelet_Habitat

Example #3. The Navy uses a 28 year-old scientific literature review in its EISs and EAs in the Pacific Northwest, to inject doubt into claims that noise adversely affects wildlife. This is despite the existence of far more recent and voluminous scientific evidence, including a brand-new literature review that was available before publication of a recent EIS that relied on the 28 year-old studies. It didn’t even acknowledge the existence of any more recent research. And by the way, most of the studies in that old literature review did indeed conclude jet noise harms domestic animals, wildlife and humans. The Navy lifted a single sentence out of context from one of its papers. From whistleblower materials, we discovered that they also refused to provide the Fish and Wildlife Service with the information it needed to accurately predict impacts and insisted via a series of leaked emails that they use of a 41 year-old study on domestic poultry, while at the same time requiring those predictions to be valid for the next 20 years. In an ironic twist, the Navy scolded the Superintendent of the Olympic Coast National Marine Sanctuary in a November 2015 letter that said she should be more careful about establishing “hot spot” locations for several species, because the research she and her staff used was funded by… the Navy.


Example #4. The Navy’s aircraft noise modeling software is outdated. It does not analyze the low-frequency noise that’s a signature of the Growler jets that replaced the old Prowlers in 2005. A Department of Defense commissioned study found that the software they’re using is not appropriate for Growler engines. The modeling uses a software called NOISEMAP, that was developed in the 1970s and whose most recent upgrade was 12 years ago. It uses a library of aircraft sounds from the Air Force, with no actual measurements from affected areas. I’ve also read accounts that say the Air Force’s sound library is out of date. The modeling they do is for the flat island terrain near the base, and not coastal mountains, which bounce sound waves differently and have completely different weather. In looking at NOISEMAP’s inadequacies, the DOD’s Strategic Environmental Research and Development Program, or SERDP, determined that new software is needed “…to provide legally defensible noise assessments of current and future aircraft operations.” It found that NOISEMAP’s linear acoustics were inadequate for modeling the acoustic environments in the vicinity of higher thrust engines used in the Growler.

2 Growler-kill-mark-close

New software was developed in 2010 to address this, but conversations we’ve had with Navy officials indicate they are satisfied with the old software and don’t intend to upgrade it. The Navy also ignored Congressman Derek Kilmer’s request for a “neutral” sound study by FICAN (Federal Interagency Committee on Aviation Noise). It’s worth noting that researchers have found evidence of a higher incidence of vibroacoustic disease (thickening of heart tissue caused by low frequency noise) in residents living near air bases, than in residents elsewhere. Yet the effects from low-frequency noise have been neither measured nor analyzed, and if they have, were not made public. As a result, use of outdated studies and faulty software allows the Navy to conclude that “…it cannot be conclusively stated that a causal link exists between aircraft noise exposure and the various types of non-auditory health effects that were studied.” As an aside, a former Navy officer said, in an interview at radio station KXIR 89.9, on June 19, 2015, that he considered local residents who are being harmed by naval activities to be “collateral damage” in the war on terror. Yes, he actually said that.

Child with headache

Example #5. A Professor Emeritus at Washington State University who is a recognized expert on electromagnetic frequency, or EMF, effects on living tissue said, “the U.S. Navy provided in this Final EIS not a single citation to justify its claim that we don’t need to worry about such health effects. Since 1971, there have been well over 8,000 additional studies on non-thermal health effects. The Navy provides not even a single citation to the scientific literature to support its claims. In this entire EIS, the Navy has produced not a single study of biological impacts of the EMFs it plans to unleash on the people, animals and plants of the Olympic peninsula. Their entire argument for safety is based on a theory that only thermal effects need be considered, a theory that the Navy itself knew to be false 44 years ago and is widely known in the scientific community to be false. This alone should be more than sufficient to throw out this entire EIS.” Watch the video here.

Unfortunately, a growing body of case law shows too many agencies failing to use best available science, while the courts defer to agency judgment, even in some egregious cases of failure.


The National Environmental Policy Act of 1969, abbreviated NEPA, imposes a lesser standard: rather than insisting on the best scientific information available, its regulations require information of “high quality” and professional integrity. There’s wiggle room in how that could be interpreted. Regardless of how best available science is defined, the phrase describes a plainly-worded concept that is irrevocably woven into public trust responsibility: Best. Available. Science. Not second rate, not outdated. Best. If it’s been peer-reviewed and published, it’s available.

At the beginning of this article we featured a shocking photo of a nuclear submarine with its bow bashed in. This was the result of colliding at flank speed (about 43 mph) with an underwater mountain. This link leads to the Navy’s final report, which faulted bad procedure. Good procedure is based on the same precautions that underlie good science: unless you are certain of the effects, proceeding with your proposed action would be risky, even rash. By alienating and harming its neighbors, that’s the gamble the Navy is taking with public health, our economies and our environment.

So what can you do? In every comment letter you write to the Navy, you should be insisting that they use the best available science. You should be demanding that they demonstrate professional integrity with the data they use to back up claims, and when they don’t, you should call them out on it, publicly. You might also steer them toward that best available science, so that continued reliance on outdated or incomplete evidence is unsupportable.

Merely questioning the Navy’s failure to use best available science or the fairness of its public processes, or asking for data that should be available, does not mean we are questioning Navy’s legitimate need for training its sailors and pilots. Yet the questioner is too often labeled unpatriotic. In answer to the reasonable question from those 11 Alaskan communities, “would you please move your training to a non-peak migration time that does less damage to fisheries and marine mammals?’ the Navy moved it to coincide more precisely with peak whale and salmon migration. The public took it as a stick in the eye. Asking the Navy for a fairer public process has resulted in online nastiness from pilots and threats of bodily harm from Navy supporters, which is why we have disabled comments and do not sign the posts on this web site. Some people don’t like it when you question the military, even if your questions have merit. But wrong is wrong, no matter who does or says it.

Citizen questions navy

We need a well-trained military, but right now the Navy decides what it’s going to do long before opening the public process, and then they don’t listen to suggestions on how to minimize their impacts, unless they are taken to court. That’s got to stop. So, create a loud chorus of demands that the Navy use the best available science, and with your letters, articles, public comments and other communications, call them out on it when they don’t. Let your elected representatives hear your displeasure. We may not have enough money to sue them every time they break the law, but collectively we can try them in the Court of Public Opinion. Because they cannot ignore forever the legitimate economic, environmental and public health concerns of the people who pay for their salaries and equipment.


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Navy to Neighbors: “You’re F**ked.”

Navy skywrites phallus

A Navy plane drew this picture in the sky over Okanogan County on Thursday, Nov. 16, 2017.

November 17, 2017~Dear Whidbey Island Navy Growler Pilots,

Yesterday, one of your aircrews went to a lot of trouble to skywrite a giant erect phallus over one of the local areas in which you train and make a lot of noise. Your neighbors who endure this noise have always known that subtlety is not the Navy’s strong suit, what with all the decibels, bombs, irradiation, state park and beach combat training and general whooping it up for war that it has imposed on us.

You have, however, taken chest-thumping to, shall we say, a new low. When everyone has finally stopped laughing and backslapping and saying whoa, dude, awesome, would you please take a quiet moment to reflect on the symbolism of what has been done?

The exquisite timing of this stunt makes a number of messages as clear and vulgar as the dick in the sky:

  1. That boys will be boys, now and forevermore, amen.
  1. That all of your neighbors who’ve objected to your intrusions into once-quiet lives in these once-quiet regions can just s**k on it.
  1. That our tax dollars are yours for the wasting;
  1. That starving or eliminating domestic programs and laying a real hurtin’ on people who don’t deserve it, in order for you to gas up your planes and go play is our loss and your gain;
  1. That women should look up and always remember who’s on top. Also, even the sky is having a #MeToo moment.
  1. That each $68 million dollar fighter jet your neighbors see flying overhead is under the command of a guy who wants everyone to know there’s a reason the controls that affect all of our lives are in a place called the cockpit.

Yes, we know, this is not the first time it’s happened, so you can’t even claim originality. An Air Force retiree recalls a dick in the sky at Lackland AFB a number of years ago; the base commander put the pilot on disciplinary leave. We are led to believe that the Navy takes this incident seriously, because it says it will exercise “zero tolerance” and “hold the aircrew accountable.” Since holding naval personnel accountable for previous bad behavior that the community has called out has not happened in a long time around here, we have no idea what that means: a lecture? a slap on the wrist? a memo to the personnel file? a wink and a nod? next time, draw a vagina?

This writer does not normally resort to colorful language, and you will notice that these posts are also never signed, because threats in the past due to speaking out (which the Navy has never addressed) have deemed it wiser to not reveal our names.

So, dear Whidbey Island Navy Growler pilots, please know this: we realize not all of you are like the dickheads who pulled this stunt, but we bet a lot of you are laughing about it anyway. If you pass this off as harmless, you will be complicit and reinforcing the six messages above. And you’ll be confirming another one: that the Navy holds its neighbors in contempt, because, as retired naval officer and former Island County Commissioner Mac McDowell, who speaks up for the Navy locally, said in a radio interview and call-in show,* “…the citizens of the area are collateral damage in the war on terror.”

It may as well have been a middle finger, but the dick was probably easier to draw.

But it’s always good to know where we stand, which will eventually be as constituents on the throats of the people who control the Base Realignment and Closure (BRAC) process. We don’t expect results any time soon, because you are too busy converting Whidbey Island into one giant polluted mega-base and this region into a giant defense contractor Disneyland, but as you’ve shown to people in other regions of the world who’ve endured your arrogance, your neighbors will not forget, and we will prevail. Should you decide to become better neighbors, most of us would support you.


Your Neighbors in Okanagon, the San Juans, Whidbey Island, and the Olympic Peninsula


*Radio interview was on KSER 90.7 and KXIR 89.9 on Friday, June 19, 2015 from 4 to 5:00 pm, hosted by Ed Bremner and Darrell Gray.

UPDATE NOVEMBER 18: Letter to Navy from Rep. Derek Kilmer, and Seattle Times article. There are also articles in the Washington Post, BBC, San Diego Tribune, Guardian, and other media.


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How to Gaslight the Public

Gaslight poster

The movie from which the term “gaslighting” originated.

August 13, 2017 ~ What is gaslighting? The word comes from a 1944 movie where a husband who was trying to drive his wife insane would (among other tactics) slowly and steadily dim the flame on gas lamps in the house while denying that there had been any change. The disoriented wife ended up becoming dependent on him to tell her what was real and what was not, believing him despite clear evidence he was lying.

Psychologists call it a form of mental abuse. Gaslighting is a pattern of willful and sophisticated manipulation used by individuals and organizations to gain control over people by creating doubt in their minds. Because the actions of gaslighters do not match their words, and because they will not admit that they are the problem, their intent is to keep people off-balance. When you question their actions or object to their tactics, gaslighters will twist, reframe, deny or change the subject, tell blatant lies, minimize your concerns, or discredit you and try to make you question your own sanity. You end up feeling ignored, crushed, alienated, insulted, and irrational. Gaslighters know confusion and disorientation weakens people, including their own followers, who end up overlooking severe flaws, refusing to question distortions, and showing irrational loyalty.

It is worth noting that mentally stable people have no desire to control or manipulate others. Thinking, reasoning and questioning are not a threat to them; they do not have to lie or deceive, because there is no reason to.

gaslighting definition

After nearly 3 years of informed, rational, and evidence-based objections by the public in the form of thousands upon thousands of comment letters, petitions, questions at public meetings, and urgent pleas to elected officials and public health, safety and environmental agencies, we witnessed the Forest Service granting the US Navy a permit to conduct electronic warfare testing and training over our communities, using EA-18G Growlers, the loudest fighter jets on the planets, flying over mobile emitters using (and closing) roads in the Olympic National Forest. This permit cemented a cornerstone of the Navy’s acquisition of skies, public and private lands, and the seas around Washington’s Olympic Peninsula as their own military combat training zone. How did this happen over so much widespread and informed public opposition? Have we been gaslighted?

Let us present six selected pieces of evidence so you can decide for yourself.

  1. The Forest Service’s August 2017 press release announcing this permit says, “Approval of this special use permit would not increase the number of training flights by more than 10 percent, or one additional flight per day, from what the Navy is currently conducting.” But wait, the Navy’s October 2016 Draft Environmental Impact Statement (EIS) says electronic warfare operations are increasing by 72 percent, and that the number of flights out of Whidbey Island will increase by 47 percent, to 130,000. Of these, 79,000 are Growler flights. The purpose of a Growler is electronic warfare. The purpose of all this training is for aircrews to learn to conduct electronic attack. So, to say they’re adding only ONE flight per day to current levels is disingenuous and sounds ridiculous… unless they’ve already raised the numbers of flights illegally before the public process was completed, or perhaps changed the definition of the word “flight” (they still won’t define terms we’ve asked for.) But when it comes to massive recent increases in duration, frequency and loudness of Growler noise, our ears don’t lie.

being lied to

  1. After admitting at a videotaped November 2014 public meeting that the Navy never put notifications in local papers so people could learn about and comment on its Environmental Assessment (EA) for establishing an Electronic Warfare Range over our communities, Navy representative John Mosher said he hoped the discussion would “…answer and address concerns and help alleviate some of the misunderstanding, clear the air, and let us [Navy] move forward…” However, they didn’t really answer questions, they mostly batted them away. And neither the Navy nor the Forest Service accepted any comments from the 3 meetings as part of the official record, because they were not officially “hearings.” No official hearings that recorded or accepted written public testimony were ever held in these affected communities, and in fact the 2 agencies refused to take written comments when offered them; therefore, none of the public’s comments counted in the Navy’s EA, and nobody gained the necessary legal standing to take them to court.
  1. A source document referenced in the Navy’s 2014 EA said, in bold text, “Friendly electronic attack could potentially deny essential services to a local population that, in turn, could result in loss of life and/or political ramifications.” (Section 2h, “Unintended Consequences, page III-5) When questioned by a 911 dispatcher who was concerned about the potential of the fixed emitter at Pacific Beach to interfere with local emergency communications, the Navy’s John Mosher answered, “There was an opportunity for comment, there were no comments, received, it was advertised in local papers.” (This was videotaped.) “Which papers?” the dispatcher pressed. “Obviously it was not in the North Coast News, which serves Pacific Beach, so how can you receive comments if we do not have the information?”  Mosher: “We do the best to get the information to you.” Citizen: “How can we get you to address our issues?” Mosher: “You can talk to your representatives. We have completed the comment period.” Citizen (angered): “You have extended the comment period right here.” Mosher: “I’m not going to debate this.” Another concerned person asked about effects of such intense military activity, including unknown electromagnetic impacts, on property values, and Mosher replied, “Well I don’t think those fears are real.”

The Forest Service’s August 2017 press release announcing the permit said, “Public input received during the designated scoping, comment, and objection periods was considered in making the decision.”

Neither Senators Maria Cantwell nor Patty Murray have ever responded, beyond form letters urging us to “work with” the Navy, to concerns about this from thousands of constituents who voted for them.

On August 10, Congressman Derek Kilmer was quoted at a town meeting as saying, “…the establishment of the jet warfare range targeting area was vital for the nation’s security and the safety of the Growler jet pilots who will engage in the training exercises,” but he later clarified it by saying he “has not taken a position on the Navy’s electronic warfare range” and the page 1 story “erroneously gave the impression” that he personally supported the plan, while he was merely “outlining the Navy’s point of view.” This happened just after he voted for the largest military budget in history. It’s no secret that back in 2012, Cantwell, Murray and Kilmer all signed a pact (explained here) to benefit the Navy and the defense industry. Got that?


  1. The Forest Service’s press release says, “Training would not typically occur on weekends…” Operative word here is “typically.” Weekend flying was never mentioned in the Navy’s 2014 environmental assessment, nor in any Forest Service materials. The first time the public heard about weekend flying was when the Forest Service put it in their draft permit in early 2017. It said Growlers will be allowed to fly on weekends so long as they don’t interfere with opening day and opening weekend for big game hunting season with rifles. Why big game hunters and no other stakeholder exceptions? Why no discussion of weekend flying in the EA, or in agency outreach materials? Why no chance for tourism and other economic stakeholders to ask for exemptions, too? These questions were never answered because we were never allowed to ask them, and now the door is open for the Navy to conduct electronic warfare over our communities and Olympic National Park on weekends, without the public ever being allowed to comment on it.
  1. It is illegal to erase important features like rivers, National Park boundaries, or even entire lakes, from maps in an EA in order to make it look like they’re going to be operating in the middle of nowhere, but that’s exactly what the Navy did. Federal law, 18 U.S. Code § 1515 to be specific, defines “misleading conduct” in part, as: “(D) with intent to mislead, knowingly submitting or inviting reliance on a sample, specimen, map, photograph, boundary mark, or other object that is misleading in a material respect.” A federal agency also can’t legally break up what should be a larger EIS with a more thorough public process into multiple small EAs, to avoid a broader public discussion, or to avoid examining the full cumulative or overall impacts. It cannot pre-decide what it is going to do and commit federal funding in advance, before presenting the proposal to the public as a retrofit that’s mere wind-dressing. But that’s what they did, and continue to do. For a rather shocking comparison of spoken and written statements by the Navy and Forest Service based on official documents compared with transcripts of video recordings from public meetings, go here.manipulation
  1. The Navy uses a process called Joint Land Use Studies (JLUS) when looking for ways to reduce potential conflicts between military installations and surrounding areas. Their guidance manual states, “The JLUS program relies on strong community planning … The JLUS program is community controlled and community directed.” The problem is, as pointed out in this editorial, if the community is never informed of the Navy’s intentions, or of existing or potential land use conflicts, then the community cannot be involved in the process, can they? Very little is known about munitions stored at Indian Island just across the bay from Port Townsend, but a document obtained from a whistleblower indicates the Navy is building three new storage magazines there for Tomahawk missiles, which can carry nuclear as well as non-nuclear warheads. Most people are unaware of this. At the submarine base in Bangor, which will soon be handling explosives equal to 7.44 million pounds of TNT in the form of rocket motor propellant and whose newly expanded blast zone now extends far into residential areas (but not to naval housing areas), the Navy has called citizens’ concerns “fears” and “urban myths” while at the same time spending over $32 million to beef up its own buildings against possible blasts. It also falsely asserted that the explosives are being handled “in accordance with requirements” set by the Navy. The latter is patently false, because the Department of Defense Explosives Safety Board refused to approve the siting of these 2 new explosives handling wharves in Hood Canal, due to its concerns about blast zones extending into residential areas. They asked the Navy to prove that one accidentally exploding missile at Bangor would not “promptly propagate” to the other 23 missiles on each submarine, coalescing the blast waves into a single explosive source. The Navy answered them by saying that satisfying public concerns was not feasible. Sadly, that’s probably one of the most accurate things they’ve ever said.


So make up your own mind. In our opinion, “gaslighting” may not be a strong enough word to describe how the Navy and its supporters have managed to bully the public into this massive expansion. “Imperil” sounds more accurate.


A marbled murrelet egg in its old-growth nest. We include this as a symbol of not giving up hope. Stay engaged. The more people who do, the sooner we stop the Navy’s gaslighting and other irresponsible behaviors.

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The Navy is bringing in another 40 of the loudest jets on the planet

Burning money

May 16, 2017 – If you think it was loud before, wait until 40 more Growlers arrive, bringing the totals to 157 or 160, not the 118 they’ve been telling us about. This new order is on top of the 36 jets that were just evaluated in a draft EIS (Environmental Impact Statement.) The next 40 probably won’t be given the EIS treatment because the only reason the Navy did a full EIS for the last 36 is because they were sued by citizens who wanted a fair public process. Piecemealing, via at least 6 separate processes, the insertion of 160 Growler jets into our lives is illegal, yet the Navy has openly violated the law for years. If you want a stark example, the impacts from the 36 Growlers that were analyzed in the recent Draft EIS represent only 50% of the impacts from the newest jets, and if you do the math, less than 25% of total impacts from all 160. But breaking the impacts into small pieces allows the Navy to declare that each piece has “no significant impacts,” while they refuse to acknowledge that when combined, the impacts from all these separate “pieces” will be quite serious.

And we do not know if 160 is even the top limit. With squadrons of other types of aircraft also being transferred here, it’s obvious that their aim is to make Whidbey Island into a mega-base. The Navy also could not promise, in their recent EIS, that the air pollution they create would not drop our formerly clean, clear air below national air quality standards. That means our air could be similar to that of large polluted cities. They even piecemealed the air pollution and noise impacts by analyzing only takeoffs and landings, and not flight operations beyond a small area surrounding each runway.

Remember when we first heard about the use of Olympic National Forest as an electronic warfare range, back in September of 2014? Remember how the Navy’s John Mosher stood in front of audiences and told them the number of flights would increase by only 10%? Well guess what – the number of overall flights will be increased by 47%, and 79,000 of those will be Growler flights. In just 7 years, between 2010 and 2017, the number of “touch and go” flights at the Outlying Field at Coupeville alone are increasing from 3,200 to 35,000. That’s over a 1,000 percent increase. John Mosher is in charge of the Navy’s NEPA processes in the Pacific Northwest. He knew he was lying to us when he said there would be only a 10 percent increase.

They violate the law knowingly. A March 2016 Department of Defense procurement report stated that these additional 40 aircraft were not only ordered but in the process of being delivered. That report came out 7 months before the Draft EIS analyzing only 36 of the total 76 new Growlers. We repeat: This. Is. Illegal. And a violation of the public trust. They cannot lawfully make major decisions and commit government funding before initiating a public process under the National Environmental Policy Act of 1969 (NEPA), but that’s exactly what’s happening. Read this analysis to learn why “segmentation” is against the law.

Now the Forest Service’s Dean Millett is trying to figure out a way to justify that the flight increases are only a small percentage and won’t have a significant impact. The Forest Service has pushed their decision on issuing a permit to the Navy into June. The fact that they’ve delayed their decision from October 2014 to June 2017, plus removed all Navy information from their web site except for the 2014 Environmental Assessment, is evidence that even though the avalanche of public comments has been ignored, they appear to realize the public is on to them and that a decision to grant the permit will be a matter of tortured logic at best.

ONP hiker

On the Olympic Peninsula, San Juan Islands and Whidbey Island, Senators Maria Cantwell and Patty Murray have thrown their constituents under the bus. They avoid answering hard, sometimes anguished questions and send form letters that advocate for “working together” with the Navy. Rep. Rick Larsen thinks the Navy can do no wrong, and has openly jeered the people who’ve complained about noise (This has been recorded on videotape.) Navy supporters throw the “Sound of Freedom” argument at us, as if our unwillingness to support militarization of places like the quietest National Park in the nation is unpatriotic. Rep Derek Kilmer is the only one who’s been responsive at all – he has asked hard questions of agencies, but this only noodles with process and does not address our more substantive questions.

And this does not even address the increase in Navy SEAL war games on our public beaches, state parks, and private lands–how is it legal to close these lands to public access, even temporarily, without a public process for each one? How does a blanket permit to close off our public lands for war games meet the original purpose and mission of these public lands?

It feels hopeless. What can one person do? First, take care of yourself. Don’t allow the stress to overwhelm you; take time off if needed, but allow that to refresh you so that you can come back, choose something you can do to make a difference, no matter how small it may seem, and then do it. Remember, this is a marathon, not a sprint. If we collectively don’t keep the pressure on those who are supposed to represent us and on those for whose salaries and activities we pay dearly, then we give up even the pretense of a democracy. Don’t let this happen.

Say No

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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.

Posted in Uncategorized | Comments Off on Public objections pour in

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.


Posted in Uncategorized | Comments Off on For more information from the Forest Service, get out the pry bar

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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