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.
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.
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.
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 question – but 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:
Here is the 17-point analysis/letter with footnotes to supporting documents online:
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.
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.
Forest Service updated instructions: “Objections must be submitted to Reviewing Officer Reta Laford. Electronic objections should be submitted to: https://cara.ecosystem-management.org/Public//CommentInput?Project=42759. 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: firstname.lastname@example.org. 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.