Updated August 2017: First, some numbers: 260 days per year, 8-16 hours per day including weekends, up to 160 of the loudest jets on the planet, capable of 150 decibels, burning 1304 gallons per hour and producing more carbon dioxide in one hour of flying than the average Washington citizen produces in a year or a car produces in 29,000 miles of driving—flying right over Washington’s spectacular and famously quiet Olympic Peninsula. Plus: a 47 percent increase in flights at Whidbey Island to 130,000, with 79,000 being these EA-18G “Growler” flights. The number of flights at Outlying Landing Field Coupeville has, since 2010, increased from 3,200 per year to 35,000, a >1,000 percent increase. Their noise is disruptive to people living 13 to 16 miles away.
Also: Huge increases in at-sea war games, including a 72 percent increase in dropped chaff, >700 percent use of torpedoes, >3,000 percent use of flares and sonobuoys, a 244 percent increase in Growler aerial combat maneuvering, or “dogfighting,” which requires frequent use of afterburners, and a 1,450 percent increase in the number of “expendable devices.” Effects on fish and wildlife from all Navy activities are being heavily discounted. In just the waters from Northern California to Southeast Alaska, including Puget Sound and other inland waters, “takes” of marine mammals such as whales, dolphins, seals and sea lions are expected to exceed 1.2 million in a 5-year period.
Also: Potential contamination of the entire drinking water aquifer at Whidbey Island, with highly carcinogenic chemicals.
Also: Navy SEALs doing combat training on 68+ beaches and state parks on Puget Sound, the Strait of Juan de Fuca and Pacific ocean beaches in Washington, unannounced and undisclosed to the public and to state, local and federal agencies.
And: The Army firing rockets and causing potential large flashes and sonic booms, into South Puget Sound.
This is a major change to the quiet way things once were. The Department of Defense owns millions of acres of land and already has a lot of controlled airspace in which to train. Federal Government Accountability reports have said for more than a decade that the military is not utilizing its own properties effectively. So why do they now need to use our state and national forests and parks, and even private and tribal lands and national marine sanctuaries? The Navy is more than a decade overdue in responding to a 2005 GAO report that asked for better accountability of the properties and ranges it already owns.
The US Navy plans to permanently use and periodically close large swathes of the Olympic National Forest, along with airspace over it and the Olympic National Park as well as the Olympic Coast National Marine Sanctuary, for electromagnetic warfare testing and training. They are also ramping up their use of explosives and sonar and training activities in the waters surrounding the Olympic Peninsula. Their stated goal is to turn the western portion of the Olympic Peninsula and surrounding waters into an Electromagnetic Warfare Range. This means electronic warfare will be practiced over our homes, public lands and waters, and massive sonar and explosive activity will occur in the rich waters surrounding Washington’s Olympic Peninsula, in perpetuity. The US Forest Service recently issued the permit for operation of mobile emitters on Olympic National Forest roads.
The Navy’s Northwest Training Range extends from the innermost reaches of Puget Sound to the outer coast of Washington, and south to the Lost Coast region of California in northern Mendocino County. It goes out 250 nautical miles from the coast. Just the ocean part encompasses an area larger than the State of California. A lawsuit resulted in some concessions by the Navy to respect biologically sensitive areas in Hawaii and Southern California until 2018, but no such concessions apply in the Pacific Northwest.
There are three components to this issue: impacts from activities on land, at sea, and in the air. The Navy has split them into separate public processes with separate documents, with many similar timelines.
LAND, SEA AND AIR
The land issue boiled down to: Should the Forest Service issue a Special Use Permit to the Navy to use roads in the Olympic National Forest to run their electromagnetic radiation-emitting truck-and-trailer combinations, which would entail numerous unannounced forest closures and other problems? Despite massive public opposition over nearly 3 years, the Forest Service issued the permit in August 2017. You can read more here, on how it happened and the public’s reaction to it.
These emitters simulate “bad guys” by sending a variety of signals to be detected by pairs or trios of Growler jets, who detect the signals and fire a “simulated harm shoot” at each one. The Navy has not told the public about what level or type of directed energy constitutes a “simulated harm shoot,” or about the intensity or impacts of using an “Active Electronic Scanning Array” (AESA) to detect these emitter signals over populated areas, or about how such directed energy systems can differentiate between a person with a cellphone or VHF radio and an emitter. Most emitter sites are right at the boundaries of the Olympic National Park or overlooking State, Tribal and private lands. Two emitter sites are on DNR land, for which as of early 2015, the Navy had not applied for a permit. In February 2015, Commissioner of Public Lands Peter Goldmark wrote a letter to Admiral Jeffrey Ruth declining to allow DNR lands adjacent to Olympic National Forest to be used for this purpose. As of 2017 this ban still stands. The airspace over all of these lands (including private and tribal) and over the offshore waters is considered by the Navy to be within the Military Operating Area.
Around each emitter a 100-foot perimeter labeled “Warning – Personnel Hazard” will be taped off. Contractors, not Navy personnel, will be operating the emitters. Human beings and “observable” wildlife, e.g., large mammals, will be prevented from entering, or will be hazed out. However, small mammals and birds will not. A Navy spokesman said that 15 minutes of exposure was enough to destroy liquid eye tissue. All of the proposed emitter sites are within critical habitat for spotted owls and/or marbled murrelets.
The Navy insists that these emitters have no more potency than a cell tower, but this Memorandum from the Department of the Interior to the FCC describes the inadequacy of exposure standards to wildlife around cell towers. Similar concerns could easily be extrapolated about humans.
At least 2900 training “events” over 260 days per year (the word “event” is not defined and can last for minutes, hours or days) will be conducted for 8 to 16 hours per day. The habitat around each mobile emitter site will be exposed to electromagnetic radiation for as much as 468 hours per year. The Navy’s 2014 Environmental Assessment (EA) was not specific about the intensity or maximum potential exposure of the vehicles’ electromagnetic emitters. Navy officials admit they do not know the impact of the emitters on small animals and birds.
Below is the map used by the Navy in official documents, to explain to the public where the 14 proposed emitter sites are. Note that several major features are missing.
Now look at the map below, that ran in the Peninsula Daily News. It shows rivers, National Park boundaries and Lake Quinault. Why would the Navy use a map that erased details as big as these, that would have helped the public to know where these emitters will be?
In an odd twist, the Forest Service District Ranger assigned to make the decision on whether or not to issue the permit was limited to a very narrow scope. He, and therefore the public, could consider only the impacts and effects from the wheels of truck-and-trailer rigs on forest roads, and from the noise of generators that operate the emitters, and nothing else. No jet noise, no jet emissions or fuel dumps, no hazards from air-based electronic attack weapons, no chronic radiation, no fire danger or other concerns repeatedly brought up by the public were considered by the Forest Service. At a contentious public meeting, the District Ranger called these other concerns “outside of his decision space.” Yet issuance of the permit triggers all of the other air-based impacts, none of which were evaluated in the Navy’s Environmental Assessment. The separation of these issues precluded the public’s ability to evaluate impacts. Without the jets overhead, what’s the point of mobile emitters? Case law has repeatedly shown that segmentation of related projects into separate public processes is illegal. (All documents are available on this web site.) The Navy says it evaluated all such impacts in an EIS in 2010, but that statement is false because they didn’t evaluate things like emissions from the mobile emitters, or refer by name to this area for training, (their evaluation was actually for another area.) Nor did they accurately list the number of training events; the proposed number of new events is ten to twenty times higher.
Through the Freedom of Information Act (FOIA) process, the public learned in March 2015 that the Navy intends to drive its new mobile emitters on public roads throughout the Olympic Peninsula, and that they have been doing so using prototype mobile emitters, via a series of temporary permits issued by the Forest Service between 2010 and 2014. This was never publicly disclosed by either the Navy or the Forest Service. Here’s a photo of a Navy emitter at an area campground, from the 2011 permit application. To read a transcript comparing various statements made by both agencies at videotaped public meetings with what’s written in documents, click here and prepare to be rather astonished: http://westcoastactionalliance.org/wp-content/uploads/2015/07/A-Comparison-of-the-Navy’s-Spoken-and-Written-Remarks.pdf
The Forest Service hired a consulting firm to read through the nearly 4,000 comments that came in from the public, and a comment period for final objections was held in early 2017. Here is an example of an objection letter. The Forest Service has repeatedly indicated both publicly and in private phone conversations that despite the massive public opposition, it intended all along to issue the permit to the Navy, despite numerous delays. It even stated this before public comments were received.
Any public process must be a good faith effort. However, this one was not. No public notices were placed in any newspapers that directly serve north and west Olympic Peninsula communities to alert people that the comment period was open on the Navy’s Environmental Assessment. Below is the only notice the Navy provided for the entire north and west Olympic Peninsula. It was taped in a window at the post office in Forks, Washington, and was noticed by a citizen, who asked the editor of the Forks Forum what it was about. That editor investigated it and broke the news on September 24, 2014, but unfortunately, that was nearly six weeks after the Navy’s comment period had closed.
Shortly after the Navy closed that 15-day comment period, it issued a Finding of No Significant Impact. This finding stated that the Navy had “…received no comments from individuals, elected officials, government organizations, or Native American tribes in response to the Draft EA.” It went on to imply this meant nobody was interested, and to conclude, “Based on the analysis presented in the EA and coordination with the USFS, [Forest Service] the Navy finds that implementation of the Proposed Action … will not significantly affect the quality of the human environment and, as a result, an EIS need not be prepared.”
In the absence of an honest effort at notifying affected communities, the public never had to chance to judge this for themselves. The Navy later told people at a public meeting in Forks, “You’re too late. The comment period has closed.” None of the hundreds of oral comments that were given at 3 public informational meetings (which occurred in October and November, only because of the insistence of Congressman Derek Kilmer) were ever recorded for the official record.
Nearly 4,000 comments poured in to the Forest Service’s online comments page for its separate comment period on whether or not to issue the Special Use Permit. That comment period closed November 28, 2014, but hundreds more comments came in after that deadline.
The air-based issue is ostensibly about 36 new supersonic EA-18G Growler jets being added to the existing fleet of 82 Growlers at Naval Air Station Whidbey Island (NASWI.) In actuality, the Navy has asked to procure 157 – 160 Growlers — with final delivery taking place in 2017. The Navy prepared an Environmental Impact Statement (EIS) on only the addition of 36 new jets. However, no EIS was ever done for the 82 existing Growlers, and another 40 were not only on order but were being delivered before the Draft EIS was published. It is illegal to make decisions and obligate federal funding before the public process is complete. The Navy has turned public process into a sham.
The public is worried about jet noise, pollution, electromagnetic radiation, stress, loss of our tourism-based economy, decline in property values, and a number of other issues. An economic report has shown tremendous losses in property values along with increased medical costs, for people living near the base. It also revealed that the Navy has not paid its “payment in lieu of taxes” to Island County for many years, resulting in millions of dollars of lost revenue.
According to the Navy’s own statistics on older aircraft, a jet flying at 1000 feet of altitude, which they already do too often over the Olympic Peninsula, will produce 113 decibels, well above the human pain threshold and enough to cause permanent damage to hearing. A Growler can produce 150 dB. Hearing damage occurs at 85. For many sensitive species who rely on hearing to find food or mates, hearing damage thresholds are lower. A recent study in which a phantom highway was set up with noise only revealed the significant harm noise causes to wildlife.
The Navy’s noise modeling software is outdated and does not analyze the low-frequency noise that is a signature of Growlers. A DOD commissioned study found this is software not appropriate for Growler engines. The modeling is currently done using software called NOISEMAP that was developed in the 1970s, along with a library of sounds from the US Air Force. No actual measurements have been, are being, or will be, made. In looking at NOISEMAP’s inadequacies, a DOD Strategic Environmental Research and Development Program 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. New software was developed in 2010 to address this, but conversations I’ve had with Navy officials indicate they are satisfied with the old software and don’t intend to upgrade it. The Navy also ignored Rep. Derek Kilmer’s request for a “neutral” sound study by FICAN (Federal Interagency Committee on Aviation Noise).
Noise levels for Growler jets, which can reach speeds of 1400 mph, have been measured by independent professionals and found to be much louder than the slower Prowler jets they replaced. For example, noise levels inside some residential homes near the Outlying Landing Field (OLF) at Coupeville on Whidbey Island, which is a short runway near a residential area, have been measured at 100 decibels. In a yard outside the house, 132 decibels were measured. These jets are clearly audible in communities along the Olympic Peninsula’s north shore as they fly back and forth from the Military Operating Area, and they are causing tremendous noise and distraction in communities on the western end of the peninsula. Residents have reported sonic booms as well. Guests booking a week’s vacation at resorts are leaving days early in disgust. Over some land areas the Navy is authorized to fly at 1200 feet above ground level, and this is earsplitting to residents underneath them. Over water they must stay at 6000 feet above sea level, except over offshore waters in and around the Olympic Coast National Marine Sanctuary, where they are authorized to fly down to the water’s surface.
Harassment and intimidation have been an issue. Threats and abusive behavior have come from Navy personnel, and from a group of Navy contractors representing “Team Whidbey.” Within approximately 90 minutes of a judge’s rejection of a case brought against the Navy by the Citizens of Ebey’s Reserve, one or two Navy Growlers made extremely low passes, buzzing communities. Within 90 minutes of the issuance of the electronic warfare permit, a fleet of Navy jets flew low and loud over the northeastern Olympic Peninsula. The public interprets these gestures as contempt.
Is it appropriate or compatible, let alone neighborly, to fly unmuffled jets at low altitudes over residential areas and other places intended for camping, hiking, boating, fishing and protection of sensitive habitats and species?
According to trade publications such as Breaking Defense, the Growler fleet is being/has been joined by F-35 Hornets and as many as 50 attack helicopters. Six PA-8A squadrons have also relocated to NAS Whidbey Island. Navy jets and other aircraft will be conducting at least 11 “training events” per day on each of 3 mobile radiation emitters rotated through 15 different locations throughout the Olympic National Forest; emitters will be in use for 45 minutes out of each hour. The training is designed to familiarize pilots with a variety of electronic attack weapons carried on each Growler jet, such as lasers, high-powered microwave or EMP or anti-radiation energy in concentrated, directed beams. To view a History Channel video on directed energy weapons, click here. According to a Navy spokesman, “The pilot has to achieve an ID of the emitter, locate it and simulate a ‘harm shoot.’”
It’s not hard to imagine the discomfort of civilians who will be subject to war games being practiced over, around and actually inside their communities and public lands. Nor is it hard to imagine that threatened and endangered species such as the marbled murrelet, spotted owl, bull trout and short-tailed albatross will be further threatened.
A Navy source document says that these weapons are designed “…to attack personnel, facilities, or equipment with the intent of degrading, neutralizing, or destroying enemy combat capability…” Unfortunately, the Navy has not informed the public about levels of electromagnetic radiation that can be expected from simulated harm shoots initiated by trainee Growler pilots at emitters, nor about the level of radiation coming from detection equipment in jets, nor how they will differentiate between using simulated and real weaponry while flying, nor how differences between, say, a hiker with a cellphone or a fisherman with a GPS or marine radio, and an actual military emitter signal will be ascertained.
So, in addition to noise and pollution, the public is worried because so little information has been provided about the use of electronic attack weapons in training over populated areas, and exposure of humans and wildlife to chronic levels of electromagnetic radiation from directed energy weapons as well as emitters. We do not know what risks come with use of this technology over an area that is far more highly populated than it was 50 years ago, when the military first designated airspace over Olympic National Park and Olympic National Forest as their operating area. Nor do we feel comfortable taking the Navy’s word for it that electronic warfare technology is harmless, because we know it isn’t. An “emitter” can be a cellphone or marine radio unit.
According to a short video by the manufacturer Northrop-Grumman, “Friendly, enemy, and unknown emitters are all identified, displayed and powdered if needed.” What is “powdered?” What levels of directed energy weapons are safe around people and wildlife? Is this technology appropriate for training over populated civilian areas when the Navy has millions of acres of unpopulated Defense Department lands elsewhere at its disposal?
Probably the most damaging ecological effects of all will occur in the oceans and inland sounds and bays that surround the Pacific Northwest. They have already been damaged – see the series called The Navy’s Toxic Legacy: Part 1; Part 2; and Part 3. It’s obvious even to tourists that the increase in Navy activity in our Northwest waters, public lands, and skies is huge. A brief description based on the Navy’s own documents is here. A more in-depth analysis can be found here. A chart showing the numbers of “takes” of marine mammals (whales, dolphins, seals and sea lions) in 4 areas of naval operations is here. The numbers are horrific, in part because multiple takes on the same animals are expected.
This 1.5-minute video published on January 6, 2015, addresses the Navy’s proposed increase in the number of sonobuoys from 20 to 720, announced in December 2014, but the actual number of these disposable sonobuoys will be closer to 5,000. This corporate press release from August 2013 and this announcement by a marine news magazine from the same period in 2013 show that this dramatic increase had been planned long before the Navy announced them to the public. Still, they failed to announce them in the January 2014 Draft EIS, too.
The sea-based threats include the following:
* Expansion of sonar and explosive activities in the “training zone” to include the Strait of Juan de Fuca, the waters off Indian Island, Puget Sound, and the Olympic Coast National Marine Sanctuary, which consists of 2,408 square nautical miles of Olympic Peninsula coastline. According to a fact sheet from EarthJustice:
- “Some of the mid-frequency sonar systems the Navy employs are capable of generating sounds in excess of 235 decibels. A normal human conversation takes place at 60-70 decibels; a loud rock concert is about 115 decibels; permanent hearing damage for people can occur from short-term exposure to 140 decibels. The decibel scale is a logarithmic scale, and each ten-decibel rise along the scale corresponds to a ten-fold increase in power: a sound measuring 130 decibels is ten times more intense than a 120 decibel sound, a sound of 140 decibels is 100 times more intense, and a sound of 150 decibels is 1,000 times more intense.”
- This video shows the USS Shoup exposing endangered Southern Resident killer whales to mid-frequency active sonar in Haro Strait west of San Juan Island in Washington State. For more information, click here.
- This article from Scientific American describes lethal and sublethal effects on whales from sonar and sonobuoys, and this web site from the Natural Resources Defense Council contains information on the lethal effects of sonar.
* Marine Mammal kills: The Navy estimates hundreds of thousands of marine mammals would be killed or harmed. Millions more are to be disturbed multiple times.
* Maritime effects:
Bridge closures – The Navy predicts more and longer bridge closings at Hood Canal, which will not be announced until the last minute due to “national security.”
More Private vessel boardings – These are being called “visits.”
Notices to Move – Fishermen will be given one hour’s notice to vacate an area of Naval activity, and must abandon deployed fishing gear such as in-water nets or pots.
News stories state, “The Navy estimates that its activities could inadvertently kill 186 whales and dolphins off the East Coast and 155 off Hawaii and Southern California, mostly from explosives. It calculates more than 11,000 serious injuries off the East Coast and 2,000 off Hawaii and Southern California, along with nearly 2 million minor injuries, such as temporary hearing loss, off each coast. It also predicts marine mammals might change their behavior — such as swimming in a different direction — in 27 million instances.” ~ from NBC News, quoted by Seattle PI
In January 2015, the Navy released plans for converting the Ediz Hook area of Port Angeles Harbor into a base for submarine escort vessels. A sixth separate NEPA process in one year was initiated. The two ends of this submarine escort route have become separate public processes despite being functionally related. The Navy refuses to explain why.