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

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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.

Posted in Uncategorized | Comments Off on To comment on the Navy Growler EIS by Feb 24, read this:

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.


Posted in Uncategorized | Comments Off on Get Ready to Rumble: Navy Jet Noise to Dramatically Increase

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

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

Here is an update from today, on recent events.

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

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

Water cannon used on water protectors at Standing Rock.

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

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

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

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

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

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

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

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


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

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The Navy’s Toxic Legacy, Part 3


Sockeye salmon run. NOAA photo.

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

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


Orca whale

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

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


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

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


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

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

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

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


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

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

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

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

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


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

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

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


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

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

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

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

Salmon Art



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Navy Doubles Down on Disturbance, Environmental Destruction


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

New biennial training exercises conducted in the offshore area;

Biennial mine warfare exercises in Puget Sound;

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

Testing of “unique undersea hardware” and fixtures;

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

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

More ship activity;

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

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


Dead whale, Puget Sound, 2016

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

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

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

Humpback feeding

A humpback whale feeds.

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

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

flag and statue of liberty

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

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The Navy’s Toxic Legacy, Part 2

Davy Crockett Weapons System from 1960s

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

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

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

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

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

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

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

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

Screen Shot 2016-10-19 at 4.17.34 PM

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The Navy’s Toxic Legacy, Part 1


October 17, 2016 – Depleted uranium, thousands of sonobuoys litter Pacific Northwest oceans – what are implications for public health, fisheries? Commercial and recreational fishing and being out of doors are mainstays of economic, social, spiritual and tribal life in the Pacific Northwest; our waters have historically provided rich harvests free of dangerous manmade chemicals. But that’s changing. This article, published to day in Truthout, has more details and an interview with a toxicologist.

Last week the Port of San Diego sued the Navy over an underground plume of toxic chemicals that threaten to contaminate the entire bay.

The US Navy’s war gaming in our Pacific Northwest waters, with bullets, bombs, missiles, chaff, flares, drones, sonobuoys and expendable targets, many containing harmful chemicals such as high explosives, is increasing. It’s happening in coastal, offshore and inland waters from California to Alaska. They are dumping these toxic materials in areas designated as Essential Fish Habitat, while conducting their explosive and sonar exercises during peak times when important fisheries and marine mammals are present.

WA Essential Fish Habitat

The US Navy’s 2015 Northwest Training and Testing Final EIS (Environmental Impact Statement) estimates that in thousands of warfare testing and training events per year including gunnery, missile, torpedo and other explosive firings, the Navy produces nearly 200,000 “components or events” designated as “stressors” each year, just in our waters. It doesn’t define or measure the words “component” or “event,” but claims that two thirds of the number of “military items with metal components” dumped annually are small-caliber rounds. However, these small rounds make up only 2% of the total weight of all expended components. So where’s the rest? This 3-part series of articles will try to find out. With a few exceptions, all of our references come directly from the Navy or the federal agencies with whom it has consulted. It was just a matter of combing through the documents.

Let’s start with sonobuoys, or “sonar buoys.” We start here because there are so many of them.


Sonobuoy being dropped from an aircraft.

Weighing between 36 and 936 pounds apiece, with some containing up to 5 pounds of explosives, they are dropped from aircraft and are never recovered. Sonobuoys have been in use for decades, and make up 34 to 36% of the Navy’s “expended materials” by weight. Here is a screen shot from a brochure on a modern sonobuoy deployed; you can see that entanglement is a hazard for wildlife.

Deployed sonobuoy from brochure

Screen shot of deployed sonobuoy from manufacturer’s brochure.

Sonobuoys now in use have 8-hour life spans. Afterward, their debris either floats on ocean currents for a time, or, if scuttled, they sink to the bottom. Curiously, while the total number of sonobuoys was never mentioned in biological opinions from either the National Marine Fisheries Service (2015) or the US Fish and Wildlife Service (2016), despite the fact that in 2014 the Navy announced (in a Supplemental Draft to its EIS) that it would increase the number of sonobuoys it dumps into our coastal waters, from 20 to 720 each year. However, that number does not jibe with the fact that in 2010, the National Marine Fisheries Service had already authorized the use of 1,035 sonobuoys per year on average, totaling 5,175 over five years. So in 2016 we are starting on our second five-year cycle, with thousands more sonobuoys to come, as the next cycle lasts for 20 years, which means at least 20,700 dead sonobuoys littering our local ocean waters. Five Navy Annual Range Complex Unclassified Exercise Reports for the Northwest Training Range, from 2010-2015, provide some, but not all, numbers. Oddly, the Navy’s cumulative impacts summary for all species is classified. Why? The public deserves to know what the impacts are over time, to the species we care about.

The batteries from dead sonobuoys will leach lithium into the water for 55 years. Lithium can cause severe neurotoxic effects and birth defects in humans; its effects on marine wildlife are largely unknown. Heavy metals are another hazardous component of sonobuoys.

The US Fish and Wildlife Service estimated that a total of 39 “…explosive sonobuoys would be dropped per year during the winter, within 50 nautical miles of shore, for 20 years…” That’s interesting, because the Navy named 142 explosive sonobuoys for testing. And the National Marine Fisheries Service in its Biological Opinion said there will be “an average of 140 detonations (70 sonobuoys per year.)” This is not all of the explosive sonobuoy activity the Navy proposes. We presume the wildlife agencies selected only the sonobuoys predicted to be in locations and habitats that could harm the species they manage, but after 20 years of this you’re still talking between 780 and 2800 explosions that could directly harm listed species. And we wonder – why at least three different sets of numbers on the same topic, from three government agencies? It confuses the public.

MAMU - credit Audubon

The reclusive and threatened marbled murrelet.

Washington’s population of federally listed marbled murrelets, a diving seabird, has been declining at an average rate of 7.5% per year, which is unsustainable. The Navy’s activity may not make the species go extinct throughout its range, but it will surely help lower the numbers of murrelets in Washington. However, this article won’t be discussing the effects on wildlife of all that pinging, explosive detonation, and potential entanglement in thousands of sonobuoy parachutes and thousands of yards of line; it will focus on contaminants.

In all, 5,175 expendable 36-pound sonobuoys every 5 years are contributing 186,660 pounds, or 93 tons, of contaminants to our waters. That’s the equivalent weight of 53 midsize cars. Over 20 years, which is the Navy’s intent, it’ll add up to 373 tons, or about 213 midsized cars. But think about the older sonobuoy models already down there, which a 2009 Draft EIS described as weighing 936 pounds. The Navy could reasonably be expected to have used 250 per year over, say, a 20-year period, so 5,000 of them would add another 1,980,000 pounds, or 990 tons, or another 566 midsized cars, all made of heavy metals and leaking batteries. In a 40 year time span there could be the toxic equivalent of 1,363 tons, or 779 midsized cars made of materials that the ecosystem off the Washington-Oregon coast doesn’t need.

Remember, sonobuoys comprise only 34 to 36% of the total weight of expended components. The Navy says, “Hazardous materials leach slowly, and are not expected to substantially affect the environment.” Also, “…many of the components of concern are coated with plastic [PVC] to reduce corrosion, providing an effective barrier to water exchange. In instances where seawater corrodes the sonobuoy, that corrosion takes at least 40 years.” We would like to know when and where there are instances of seawater not eventually corroding metals such as are used in sonobuoys. That statement seems to imply that most of us need not worry about it in our lifetimes.

When you think of a single year’s contribution of toxic contaminants in a very specific area of a very large ocean like the Pacific, it’s easy to conclude, as the Navy repeatedly has, that it’s just a small amount, a drop in the bucket. It’ll be dispersed by ocean currents, neutralized by chemical reaction with seawater, or “rendered benign” by organisms that consume them. As an example of how lightly this is being treated, in the Navy’s 2015 Northwest Training and Testing EIS Appendix on Public Health and Safety, the words “toxic” and “contaminants” are not mentioned once. In the Appendix on Cumulative Impacts, those words are mentioned but never discussed in the context of decades of munitions and heavy metals dumping. Instead, the Navy minimizes its own contributions by lumping them in with all other forms and sources of pollution, as if to say, “Hey, we’re not the only ones polluting the ocean.”

The Navy’s justification follows its mantra that the ocean is too big to be harmed, and actually says this: “Most of the components are subject to a variety of physical, chemical, and biological processes that render them benign.” Benign? Really? Can depleted uranium be rendered benign? If so, then what is the Navy’s definition of “benign?”

Gunner's mates inspect linked belts of Mark 149 Mod 2 20mm ammunition before loading it into the magazine of a Mark 16 Phalanx close-in weapons system aboard the battleship USS MISSOURI (BB-63).

Photo credit: Navy. Gunner’s mates inspect linked belts of Mark 149 Mod 2 20mm ammunition before loading it into the magazine of a Mark 16 Phalanx close-in weapons system aboard the battleship USS MISSOURI (BB-63).

Let’s look at the depleted uranium legacy they’ve given us right here in the Pacific Northwest. In 1989, the Navy began phasing out its controversial use of armor-piercing depleted uranium (DU) in, among other weapons, 20-mm cannon shells. DU was supposed to be phased out by 2008, but a December 2008 Draft Navy EIS said, “Under the no-action alternative, a total of 7,200 rounds of 20-mm cannon shells [28% of total gunshells] would be used by close-in weapons systems (CIWS) training. Rounds are composed of depleted uranium (DU) as well as tungsten.”


“Various terminal effects.”

In the unique way the Navy handles NEPA processes, a no-action alternative in an EIS never means “no action,” but rather describes a pre-existing baseline activity. So, since the Navy was proposing at the end of 2008 to continue on its existing course of action using DU rounds, it does not look like depleted uranium was phased out in 2008. One would think that because the Navy knew DU was controversial, that it would keep track of where they put it in 2009 (public pressure finally forced the Navy to stop using DU in April 2009.) But by the time the Final EIS was published in September 2010, the Navy said, “No site-specific records are available to identify the areas in which such rounds were expended, but areas of accumulation likely exist beyond 12 nm from shore in the deep waters of [Warning Area] W-237.” (Northwest Training Range Complex Final EIS/OEIS, September 2010, Section, page 3.3-13)

Here is a map of the Navy’s W-237 “Warning Area.”

Navy Warning Area-237

Navy Warning Area 237. Note overlap with boundaries of Olympic Coast National Marine Sanctuary map below.

And here is a map of the boundaries of the Olympic Coast National Marine Sanctuary:


Olympic Coast National Marine Sanctuary. Its boundary extends well past 12 nautical miles, which is where the Navy dumped depleted uranium for years.

The Navy did not speculate on the actual amount of depleted uranium resting on the sea floor in Warning Area-237, large portions of which are within the boundaries of the Olympic Coast National Marine Sanctuary. But it did quote a 2006 British study on 31 tons of depleted uranium at the bottom of an oceanic firing range, put there between 1982 and 2003. The study concluded that radiation wasn’t washing up on the shoreline where people could be exposed to it, so there was no problem.

But what about fisheries, and ecosystems beyond the shoreline? According to a Japanese study in 2003, “…radioactive contamination of the environment by DU would remain almost indefinitely.” The study also said, “low-level radiation is more likely to cause biochemical abnormalities than intensive high-level radiation (“Consequence of the Chernobyl Catastrophe” edited by E. B. Burkova).” Further, it said, “It is wrong to make light of the hazard of low-level radiation.”


Phalanx gun system from which DU was fired in Pacific Northwest Training Range. This is a giant machine gun that can fire 4,500 rounds per minute.

How much DU per 20-mm Navy cannon shell was there? According to a February 2014 publication called Health & Drugs – Disease, Prescription & Medication, there were 180 grams of depleted uranium in each 20-mm round. Multiplied times 7,200 DU rounds per year, that’s approximately 1,296 kilograms, or 2,857 pounds of DU per year. But these guns fired 3,000 rounds per minute and were upgraded to fire 4,500 rounds per minute, so you’re looking at potentially just a couple minutes of firing to get to 7,200 rounds. For how many years has this been going on? DU has been in use by the US military since the early 1980s. So, speculating on the possibility of DU being used in training and testing firings of 7,200 20-mm cannon shells per year, in Pacific Northwest waters only, between, say, 1985 and 2008, the potential amount of DU resting on the bottom, from 20-mm cannon shells only, could exceed 34 tons. That’s close to the amount cited in the British study referenced by the Navy.

It’s commonly known that the military also used depleted uranium in much larger projectiles, such as missiles, so our estimate of DU, while admittedly speculative, comes from the Navy’s own numbers and is likely a gross underestimation.

What’s the big deal with using depleted uranium? They’re not classified as nuclear weapons. According to the above referenced paper produced at the University of Wroclaw in Poland, “While depleted uranium is less radioactive than natural uranium, it still retains all the chemical toxicity associated with the original element. This toxicity is made evident in missile conflict. When a projectile composed of DU hits a target, up to 70% of the DU vaporizes through the intense heat into a fine dust, which in turn settles in the surrounding area. While DU does prove effective and has a very high rate of destroying its targets, there is a great side effect. The after-blast of DU continues with an army of toxic substances surrounding the exploded area. The size of these toxic particles is smaller than 5 microns, and a human being can inhale anything under 10 microns. The DU radioactive dust settles in the soil, water and air, which then can be moved great distances by plants, underground water and wind currents. This transfer to drinking water or locally-produced food has enough potential to lead to significant exposures to DU. Once inhaled, depending on aerosol speciation, inhalation may lead to a protracted exposure of the lungs, blood and various other systems and begin to emit a dose of alpha radiation.” Now granted, this is about what happens on land, but we don’t know what happens at sea, so it’s all we have.

The report goes on to say, “Chronic low-dose exposure to depleted uranium also alters the genetic structure of developing organisms. Adult animals that were exposed to depleted uranium during development display persistent alterations in behavior and brain chemistry, even after cessation of depleted uranium exposure. Despite its reduced level of radioactivity, evidence continues to accumulate that depleted uranium, if ingested, may pose a radiologic hazard.”

Radiation is a different hazard from contamination by chemical toxicity. Depleted uranium is capable of both. This kind of dumping by the military is not new, it’s just harder to see when you do it in the ocean. A very large number of highly contaminated Superfund sites are also formerly used defense sites. Restoration has been costing the military $14 to $18 billion. These sites are covered under a suite of federal laws designed to prioritize and clean them up. Unfortunately, except for waters immediately surrounding a naval base, such as Kitsap Bangor, which has two Superfund sites,[2] there appears to be no responsibility or liability for pollution that on land would be regulated under these federal laws. Why is that?

Thankfully, the Navy no longer uses depleted uranium; in fact, those two words are only mentioned once in the 2015 Final EIS, in answer to several public comments of concern. The Navy proudly cited Best Management Practices along with Navy procedures and policies, concluding, “Any procedures or practices that benefit ocean sediments and water quality in turn, benefit all marine life in the ocean, from plants and invertebrates, to marine mammals.”

Yep, they should know.


Salmon fishing.

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Navy clears another hurdle: USFWS Biological Opinion signed.


The endangered short-tailed albatross is found in the Olympic Coast National Marine Sanctuary. Unfortunately, the Navy will be bombing and conducting missile and gunnery exercises there.

This is a long post, but you ought to know the details. The Navy is a step closer to full war operations in two areas:

1.) The Electronic Warfare Range it established without public comment over Washington’s Olympic Peninsula, and

Site locations on Forest lands for EW

Electronic warfare mobile emitter locations. Unlike the 2014 environmental assessment, this time the Navy did not erase major map features like important rivers and Lake Quinault.

2.) Vast increases in war operations in Puget Sound, the Strait of Juan de Fuca, and coastal and offshore waters.

NWTT action area

Offshore areas of naval war activities overlap with a National Wildlife Refuge, Olympic National Park, and the Olympic Coast National Marine Sanctuary, as well as Tribal usual and accustomed traditional places.

After a delay of 10 months, the US Fish and Wildlife Service signed a Biological Opinion on July 21, covering all proposed activities in the Navy’s Electronic Warfare Environmental Assessment and the Northwest Training and Testing Final EIS. Permits for incidental take of threatened and endangered species managed by the USFWS, specifically bull trout, marbled murrelets, short-tailed albatross, and possibly northern spotted owls, are likely to soon follow. The Navy will issue its Record of Decision later this month, and will have its Fait Accompli despite the fact that to the public, this is anything but case closed.


The federally threatened bull trout occurs in waters impacted by Navy activities. The FWS said “current information is inadequate for determining population status and locations of most spawning sites.”


The federally threatened marbled murrelet lives here, too. The total population in 2001 was 8,936; in 2015 it was 4,290.

This Biological Opinion was thoroughly researched and is a combination of retrofitting the missing biological data to support the “finding of no significant impacts” of the Navy’s 2014 Electronic Warfare Range Environmental Assessment, plus a detailed evaluation of the Northwest Training and Testing Final EIS, on what happens to these specific endangered and threatened species when exposed to explosions, sonar, and other threats at sea. No non-listed species are evaluated in a Biological Opinion, so remember, if the FWS calls effects of explosions and sonar on bull trout “insignificant,” don’t automatically interpret the same result for salmon or halibut or other fish not mentioned.

The FWS did us all a favor by going into a lot of detail; the document is a great learning tool, however depressing it is to read. However, a Biological Opinion is just that—an agency’s opinion, so unless the FWS can clearly show that the Navy’s proposed activities will place a species in actual jeopardy, or danger of extinction, it’s difficult for a small agency to resist the immense pressure the Navy has no doubt been applying. And what pressure would that be?

You may recall that just before the Navy’s Northwest Training and Testing Final EIS was published in October 2015 without a public comment period, the Navy was busily trying to convince the FWS that temporary hearing loss, behavior changes, and other impacts on animals and birds that are not visible or obvious injuries should not be considered a form of harm. This is in direct opposition to both the Marine Mammal Protection Act and the Endangered Species Act. A series of email threads (1, 2, 3) obtained from a whistleblower demonstrated the level of the Navy’s determination to undermine the Endangered Species Act by reinterpreting the definition of harm for their own benefit. In the emails they offered to write portions of the Biological Opinion and refused most mitigation measures, including having FWS train their observers. The normal “lifespan” for a Biological Opinion is 5 years, and the FWS asked the Navy to limit it to that. Nope, said the Navy, it’s 20 years. What are the chances that these calculated “probabilities” for species impacts will be accurate in 2036?


A marbled murrelet takes off in calm conditions.

The Navy also insisted on drawing a clear line between permanent and temporary “Threshold Shift,” a fancy name for hearing loss. Their long-held position, that temporary hearing loss and behavior changes are not harm, is explained in this letter to the superintendent of the Olympic Coast National Marine Sanctuary. The problem is, where do you draw the line on hearing loss for species that depend on hearing for survival? How do you know what damage is permanent and what’s temporary, in a rare, tiny and secretive marbled murrelet? Answer: you don’t, but if you’re the Navy you insist the FWS use a 1974 study by the military on domestic chickens, ducks and geese to calculate “probabilities.” Weight differences alone, never mind the wildness factor, would invalidate such measures. The FWS was obviously forced to come up with another method.

Pop density for MAMU

Where marbled murrelets have been found along Washington coasts. While they spend 90% of their lives at sea, they also fly inland to nest, sometimes more than 50 miles. They prefer old-growth forests.

What do the species that depend on hearing do for protection from predators while recovering from not being able to hear properly? Recovery can take hours, days or weeks, and may or may not be a full recovery. And what about repeated noise or explosive events as opposed to one or two? In the case of marbled murrelets, which are on the endangered species list and spend 90% of their lives on or in the water from along the coast to 50 and even 250 miles offshore, it’s not so easy to know what’s temporary and what’s permanent harm when it comes to exposure to undersea and in-air explosions, plus sonar, plus jet overflights. However, the law clearly spells it out: harassment is harm, and according to the FWS, so is any “Threshold Shift.”

MAMU at nest

Marbled murrelet on its nest.



Marbled murrelet egg in nest.

On jet noise, the Navy promised (and the FWS repeats in the Biological Opinion) that the jets do not fly lower than 6,000 feet above sea level, but news flash: anyone who lives, or stays at hotels and lodges, or walks the beaches and low-elevation forests of the West End knows from deafening experience (videotaped) that when you can read the numbers on jet fuselages when you’re at sea level, they’re not flying at 6,000 feet. In fact, a FWS biologist reported being concerned about a Growler jet flying so low and near the camera drone her team was testing to photograph wildlife on offshore islets, that there was a potential collision danger. That low swoop, not unusual at all, was probably within the prohibited “threshold distance” of harassing wildlife and causing stress effects like producing fewer young. Will the Navy respect the self-imposed boundaries it gave to the FWS as evaluation criteria? It’s violating them already.

MAMU chick

Marbled murrelet chick blends in with surroundings.

And what about the report from a fly-fisherman on the Hoh River, that the forest all around him was “humming like an electrical transformer”? Concerned, he left the forested river area immediately. He has a wife who’s pregnant, and after that experience they’re worried for their unborn child’s health and are thinking of leaving the area permanently. And sonic booms? Expect more of them – not just from Growlers but also from surface-to-air missiles, air-to-surface missiles, and surface-to-surface gunnery exercises.

The Incidental Take Permit for marbled murrelets will likely allow for a total of approximately 112 birds to be “taken” by the Navy over the next 20 years in offshore areas; in inland waters where explosions and a massive amount of pile-driving is occurring, the FWS did a separate consultation with the Navy; we don’t have those numbers because the FWS no longer puts consultations that are public record on its web site, and the Navy usually requires that citizens file a Freedom of Information Act request before releasing any public records. You have to be really determined to get information from our government these days. Maybe 112 murrelets over 20 years does not sound like a lot, but murrelets are extremely secretive birds and the Navy has refused to let the FWS train its observers, so how will they know when they’ve reached their take limit? And if they do, will they admit it, or will they count only obvious, visible injuries as take?

When it comes to “no significant impacts,” the Navy promises a lot, but they, not us, get to define what’s “significant” and what’s not. Sneaking a major controversial document past the public (the 2014 Electronic Warfare EA) so that nobody was aware of it and nobody commented on it guaranteed they got to define “significant” on that one. Later, when we found out, hearing them tell us that in essence we’re all complicit because we didn’t comment, was a confirmation of flat-out cheating.

So, how can we trust the Navy to honestly adhere to the non-discretionary Terms and Conditions of this Biological Opinion? (page 272.) We can’t. Since the Navy already argues with the established legal definition of harm, and since there’s no incentive for them to be honest with us or with wildlife agencies, and since they have the entire congressional delegation kowtowing, well good luck with honesty.


Gunnery exercise.

And the mitigation? Here it is: Develop a plan to search for and remove derelict fishing nets, and develop a plan to fund offshore removal of plastic debris. That’s all good stuff, but nowhere near enough mitigation when you consider the total population has gone from 8,926 to 4,290 in 14 years. The FWS probably asked for much more mitigation, and was probably refused.

Seabird exposure to projectile stressors

A visual on the estimation of seabird exposure to stress from projectiles such as missiles. Would you want to be sitting in any of these squares? Let’s just call this diagram “projectile dysfunction.”

Another fact that does not jibe is that the Navy gave the FWS “modeled sound levels at a range of altitudes that will result from operating the EA-18G [Growler jet] at three different power settings (78, 85, and 93 percent power.)” [Page 209.] “Unfortunately,” continued the FWS, “none of the power settings in the proposed action (80, 82, and 89 percent power) were included in the modeled SEL [sound exposure level] data” provided by the Navy. Which meant that the FWS had to extrapolate. They came up with a noise exposure threshold for murrelets that limited the jets to 80-89% power settings at altitudes from 2,000 to 6,000 feet. When you compare this restrained scenario to the fact that the EIS shows aerial combat maneuvers (dogfighting) are slated to increase by 244%, and that such flying often involves intensely loud afterburners using 12,000 gallons per hour at full power, it’s hard not to question: did the Navy give the FWS all it needed to truly evaluate noise exposure?

Regarding underwater stressors such as sonar and explosions, the FWS accurately points out, “Although affected murrelets may survive their exposure…, they are likely to have a reduced level of fitness and reproductive success and have a higher risk of predation. Exposed individuals may also experience: lethal injuries that occur instantaneously or over time; direct mortality; lung hemorrhaging; ruptured livers; hemorrhaged kidneys; ruptured air sacs; and/or coronary air embolisms. Murrelets that experience TS [Threshold Shift] are expected to have damaged hair cells in their inner ears and, as a result, may not be able to detect biologically relevant sounds such as approaching predators or prey, and/or hear their mates or young attempting to communicate. Murrelets that lose their hearing sensitivity are at increased risk of predation and reduced foraging efficiency. Some affected murrelets may regain some or all of their hearing sensitivity; however, they are still temporarily at risk while experiencing TS.”

FWS also remarked indirectly on the November 2015  Biological Opinion from the National Marine Fisheries Service by saying that despite NMFS asking the Navy to wait until the time of year when salmon abundance is at its lowest, there is “no guarantee” that the Navy would accommodate such a request during Explosive Ordnance Disposal training.

Orcas breaching

Guess who eats salmon? Our Southern Resident Killer Whales.

The Navy’s at-sea war operations discussed in this EIS will primarily be in Washington’s inshore, coastal and offshore waters. Marbled murrelets are found from northern California to Alaska. In Washington, nesting habitat is the big issue, so any efforts to ensure reproductive success are a priority. Although murrelet numbers in general are declining, the Washington population is going down five times faster than elsewhere. We doubt any biologist would agree that a population decline of 5.1% to 7.7% per year in Washington is sustainable, yet the FWS concluded, “the Service determined that this level of anticipated take is not likely to result in jeopardy to the marbled murrelet.” What does this mean? That eventual extirpation (local extinction) of this bird in Washington waters is acceptable in trade for militarizing the region, because it’ll still be found elsewhere? What do we do when the Navy wants the “elsewhere,” too? How do we justify throwing away the money American taxpayers have paid for recovery of species that the Navy doesn’t seem to mind bombing in peacetime?


Virginia-class submarine.

There’s much more on impacts, and we haven’t discussed the bull trout or short-tailed albatross yet, but let’s use an analogy for marbled murrelets: Suppose you’re having dinner with a romantic partner in a super-cool restaurant called the Olympic Coast National Marine Sanctuary. Suddenly someone walks in and starts firing a cannon. You’re both going to stop eating, run for the nearest exit, and you probably won’t return to that place for awhile. Your blood pressure will rise and your ears might bleed or hurt from the noise if you’re not in the blast zone and are killed outright, but you won’t know how badly damaged your ears are for awhile. You’ll feel stressed and afraid, and any thoughts of romancing your partner will be gone. Now imagine that happening regularly and frequently over the next 20 years, in the places you eat, gather and rest. Got the picture? War games are no games for birds, whales, seals or fish. Or the people over whose heads the Navy is conducting them.

So tell us please, Navy, how do you propose to monitor any of these impacts to murrelets and other species when you won’t allow independent observers aboard, and, according to your emails, you won’t even allow your own observers to be trained by the agency with wildlife expertise?

The FWS did its homework and included so many citations it’ll take awhile to find and read them. But some sources they used are not the strongest evidence on which to base conclusions. None of the three citations for the chapter on the northern spotted owl, for example, actually studied the northern spotted owl or its habitat in the Pacific Northwest. They studied the much larger Mexican spotted owl, in New Mexico and Colorado. There is not enough peer-reviewed research on the northern spotted owl, so the FWS had to extrapolate. The southwestern habitats that these three studies evaluated are rocky canyons and forests, while the northern spotted owl prefers old-growth forests with dense canopy closure. One southwestern study evaluated helicopter and chainsaw noise, which are different from jet noise, but there is no jet noise study on northern spotted owls. Ironically, the FWS is evaluating the northern spotted owl for downgrading its status from threatened to endangered, but there’s no funding for new research.


What a sonic boom looks like. Growlers and missiles make these.

Another study extensively cited was an unpublished, non-peer-reviewed Air Force evaluation of jet noise on Mexican spotted owls in Colorado. It contained a lot of information the FWS found useful, but that study evaluated noise from F-16s and Tornados, not Growlers. The maximum sound intensity of those jets is far quieter than a Growler. An F-35, for example, is similar to a Growler, and has 126 times the maximum sound intensity of the F-16. The human ear perceives that 126 times more intense, or higher pressure, sound as being more than four times louder. Therefore, it is possible that the Air Force study along with the incomplete Growler sound levels provided to the FWS by the Navy, combined with their proposed increases in aerial combat and electronic warfare, caused an underestimation of the actual level of sound exposure.

USFWS Northern_Spotted_owl

Northern spotted owl.

So the public should ask itself: Would federal wildlife agencies allow this level of peacetime harassment and injury of threatened and endangered species to any organization except the military? Would they accept this much “direction” and interference from anyone but the military? Would a National Park that’s also a World Heritage Site be so powerless to stop the ruin with any other entity but the military?

Who has the power to stop it but remains mute? Our congressional delegation, that’s who. Every one of them is so pro-military that they are happy to throw anyone and anything in the Navy’s way under the bus.

Let’s put it another way: Should the public be forced to sacrifice this much of our natural heritage during peacetime in return for spending more than 55 percent of all federal discretionary funding on a military that behaves so disrespectfully? US military expenditures are greater than the next ten largest countries combined, yet the Pentagon has not been able to pass a federal audit since 1994 and cannot account for trillions of dollars. Do we therefore believe that the Navy will admit accountability when the degradation of the most biologically rich and diverse rainforest and National Park in the United States becomes even more obvious? Or when whales no longer visit our waters in the numbers we’re used to?

Where does it stop? With a sustained, informed public effort that tells our so-called representatives that we’re mad as hell, we’re not going to take it anymore, and we are going to remind them of that during this election year.

Say No

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