UPDATE MARCH 24, 2018 ~ Comment period is closed. Thank you to everyone who made the effort. For what it’s worth, here are the joint comments of the West Coast Action Alliance and the Olympic Forest Coalition.
February 15, 2018 ~ Here is how to comment on the Navy’s proposed Special Operations (combat) training in our communities. COMMENT PERIOD HAS BEEN EXTENDED TO MARCH 23, 2018
As a result of the public uproar about this training, all four members of our congressional delegation (Kilmer, Larsen, Cantwell and Murray) and Governor Inslee wrote a letter to the Navy asking for a 30-day extension of the comment period.
To view a PDF of a slide show obtained from the Navy via a whistleblower, showing what combat training actions will be done at 68 sites along 265 miles of shoreline in western Puget Sound, click here. It’s 17 mb, so give it time to load.
Send snail mail to: Naval Facilities Engineering Command Northwest Attention: Project Manager, EV21.AW 1101 Tautog Circle, Suite 203 Silverdale, WA 98315-1101
Or email to: email@example.com Subject line for email should be: Comments, Naval Special Operations EA–EV21.AW
To download the Draft Environmental Assessment (EA) to read for yourself, click here.
To download the comments we have provided below in Word, click here. For PDF, click here. Or you can simply copy and paste these comments into the body of your email, which should then include the hyperlinks.
These comments are intended to give you a better understanding of what we are all facing, and for you to use or adapt as you see fit:
Thank you for the opportunity to comment on the Navy’s “Special Operations Training in Western Washington” Environmental Assessment (EA). Thank you also for extending the original comment period by 30 days. The affected public did not previously have enough time to understand and evaluate potential impacts of the Navy’s proposed action. My main request is that the Navy cease and desist with this training in state parks and on private property.
I object to the Navy’s use of private lands and state parks for covert combat training for the following 10 reasons:
1. Parks are not intended for military training. The military use of state parks is at odds with Washington state law. For example:
a.) WAC 352-37-095, “Disturbances,” specifically prohibits any conduct which “..impedes or disturbs the general public in the use and enjoyment of state park areas…” Navy personnel have stated that a safety officer will survey the park for users and ask them their intention so that the Navy can “train around them.” Most people who are told that a combat training activity is going on “around them” will certainly be disturbed.
b.) WAC 352-37-230, “Firearms,” specifically prohibits discharging of a firearm “except for good cause authorized by the commission.” The possession, display, carrying, discharge or use of a firearm is regulated under 9.41 of RCW. The Navy’s use of firearms – ‘simulated’ or not – is not in keeping with the peaceful nature intended in Recreational Parks.
c.) WAC 352-32-010, “Intimidate,” prohibits engaging in conduct in state parks “…that would make a reasonable person fearful.” Based on remarks by Navy personnel at recent open houses who said civilians might wander unawares into a secret military exercise, uninformed that by doing so they become participants, and going so far as to suggest that people should no longer have any expectations of privacy in the woods because the Navy might be watching, this Draft EA is so egregious in its deliberate introduction of anxiety into what were once normal outdoor activities that it should be withdrawn.
2. Protection of children insufficient: Despite legal requirements set out by WAC 352-32-010 and by Presidential Executive Order 13045, “Protection of Children from Environmental Health and Safety Risks,” the Draft EA dismisses in one brief sentence any potential effects on children who may witness training events that include “direct action” mock gun battles by military members in full combat gear. It fails to recognize that children are especially prone to being frightened by realistic violence, and that they do not have the maturity to self-regulate or cope with trauma.
3. Military Bases need to be used first: The Navy makes a big deal about needing the strong currents and cold water of Puget Sound. The Navy already HAS 46 miles of coastline and 151,000 acres of land in this region; plenty at Bremerton, Kitsap and Whidbey Naval Air Station (on both sides of the island). And there are plenty of people in those military bases and surrounding communities who love interacting with the Navy. Now the Navy has chosen more than 265 additional miles of shoreline, much of it private property, but it has not demonstrated why existing locations with willing participants are inadequate. No training can be perfect – the divers aren’t going to be shot at with real bullets. So what’s the big deal about needing “more realistic” training? This training in and around communities who object to it amounts to an unprecedented military taking of public lands and privacy protections, by the use of intimidation; it should be conducted on the lands that are already owned by the Department of Defense; that’s why the public set them aside. Normalizing military training into the lives of civilians regardless of their objections because it is “convenient” for the Navy displays a stunning level of contempt for these communities.
4. Failure to assess impacts to communities, the environment, and to our economies: The Draft EA fails to accurately disclose how many military personnel in total will actually be training or serving as support crews, and thus fails to predict or assess the level of impacts to multiple “secret” sites along the 265 additional miles of shoreline the Navy has selected. It fails to address the economic impacts to a vibrant tourism industry that will not react favorably, and it fails to address potential impacts on property values associated with, or adjacent to, the training. For example, in the event a property owner discovers that a “real estate agreement” exists between his/her neighbor and the Navy, is that property owner obliged to disclose that fact to potential buyers? What are the legal ramifications if a buyer backs out of a sale due to the existence of combat training on an adjacent property, or if the value of a property near one that hosts this training declines? Most of these exercises will happen at night. Trainees are trainees, so what if they make a mistake and invade the wrong beach or property? One with sensitive nesting habitat, or especially, one with young children who are easily traumatized?
5. Failure to disclose hazards to civilians: According to Navy materials, “building clearing” direct actions are slated to take place on both private property and in state parks. A Navy representative said “gentle” fake bullets will be used, which we assume means paintballs. The Draft EA does not address what happens when realistic-looking weapons are fired and civilians who are unaware of the exercise get caught in the crossfire. How will the paintballs feel if someone without protective clothing gets hit? Does the Navy pay for medical care and counseling for PTSD? What happens when an innocent bystander gets injured? Are “hostages” used in these exercises? What if trainees get discovered by someone with a real gun? And what if a gun battle ensues with real bullets? Who is legally responsible? If this happens in a state park, who gets sued, Parks or the Navy, or both? How has the Navy apprised the community of people who hunt?
6. Biological, cultural and historic impacts not analyzed: The Draft EA fails to evaluate the effects of sonar use by mini-submarines and other disturbances in the sensitive shallow-water ecosystems that support hundreds of species of birds, fish, crabs and other animals and plants. It dismisses impacts of repeated trampling in shallow waters, beaches and upland areas where birds may be nesting, and erosion of cliffs from climbing. Its analysis of cumulative impacts to Tribal, cultural and historic sites that may be impacted is one paragraph long and completely inadequate.
7. Marine navigation hazards not addressed: The Navy has said it will train divers to get on shore undetected. That means they’ll not have any dive lights or other devices to make them visible to others in or on the water. And since the Navy has said that the area won’t be roped off or restricted, kayaks, sailboats and other craft that use those waters could collide with a Navy vessel. Given the recent track record of Navy ships running into other ships and causing great damage, how can we expect this won’t happen here?
8. Drones, robotic surveillance technology not disclosed: It fails to mention or analyze the advanced technologies that will be used for military surveillance and communication inside our communities and state parks during these secret operations, which include unmanned underwater and aerial drones, and robotic devices. It ignores completely the privacy concerns of any passersby with electronic devices such as smart phones, who may be unaware they are being surveilled, tracked, and possibly recorded. It throws into question our Fourth Amendment protections.
9. Missing check list: During the open houses, a Navy trainer said areas would be assessed prior to any training deployment. However, no such check list or procedure is in the EA. How will the Navy know which birds are nesting where? Will they call Fish and Wildlife? The Audubon Society? No one was able to answer the question of how the sites are chosen with respect to doing no harm to wildlife and habitat. All we were told was, “Trust us.” Where is the checklist? Who will be contacted to know what areas are sensitive at training time? This smacks of “just give us permission and we’ll be careful.” Given that the military is driven by procedures and rules, where are the rules and procedures for site selection? How will the appropriate officials be notified PRIOR to training at a given site? Who is keeping track of which sites have been used how many times? The Navy has been very consistent in NOT disclosing information like this when there is no reason to keep it secret. Citizens and public officials alike have a right to know what is happening and where. The Navy is not above the law.
10. Using unwitting and unwilling passersby as proxies for “enemies” on which military trainees can practice their tracking skills is a most reprehensible form of bullying. This training intimidates those who have been accustomed to enjoying outdoor activities, and is an example of the unhealthy relationships and declining levels of trust that exist between the Navy and its neighboring communities. State parks and private property are not a military playground, and the people who live and recreate there are not military playthings. Therefore, I ask that this Draft EA be withdrawn and that the Navy cease and desist this training in state parks and private lands.
Unmanned surface drone.