DEPARTMENT OF THE NAVY

THE ASSISTANT SECRETARY OF THE NAVY

(ENERGY, INSTALLATIONS AND ENVIRONMENT)
10OO NAVY PENTAGON
WASHINGTON, DC 20350-1000

July 27, 2018

The Honorable Rick R. Larsen

United States House of Representatives
2113 Rayburn House Office Building
Washington, DC 20515

Dear Representative Larsen,

Thank you for your letter of June 29, 2018 concerning the Navy’s preferred alternative
for EA-18G Growler operations at Naval Air Station (NAS) Whidbey Island. I am responding
on behalf of the Secretary of the Navy to answer all your questions and concerns.

Throughout the development of the EA-18G Growler Home Basing and Airfield
Operations Environmental Impact Statement (EIS), the Navy has actively engaged and remained
in frequent contact with elected officials, business leaders, and concerned citizens to balance the
needs of the Navy with those of our neighbors throughout the surrounding area. We remain
committed to seeking input and considering the concerns of the local community to ensure there
is transparency and collaboration as we move forward.

Through the EIS process, we analyze alternatives that best balance impacts to the local
community, the safety and proficiency of our aircrews, and the operational requirements of the
Navy. The Navy’s final decision will seek to both minimize adverse impacts to the local
communities, and support the operational requirements of the Navy.

The enclosure addresses your specific questions regarding potential impacts and the
analysis behind the Navy’s preferred alternative.

If I may be of further assistance, please do not hesitate to let me know.

Enclosure:
Responses to questions contained in Representative Larsen’s letter of 29June 2018

Question #1 - The Final EIS will recommend conducting 80 percent of field carrier
landing practices (FCLPs) at the Outlying Landing Field (OLF). This is a significant
departure from the historical distribution. Only twice in the past 40 year's have more than
50 percent of FCLPs been conducted at the OLF. While I understand Ault Field is a full-
use facility, and the OLF can only support FCLPs, this is still a dramatic change to
operations. Why were the other scenarios with a less extreme distribution rejected?

Response #1 - The Navy has not yet made a final decision; the announcement last month
represented the Navy’ s preferred alternative.

It is important to note that there has been a significant change in the type of aircraft based
at Ault Field over the years. In the 1970s, Ault Field was home to tactical aircraft only.
Managing tactical aircraft operations alone (A-6E and EA-6B) enabled a much more
efficient flow of air traffic and allowed a substantial number of FCLP operations at Ault
Field without significant interference with other operations. As part of BRAC 1993, the
P-3C was introduced at Ault Field. The introduction of non-tactical aircraft and the
growth of Maritime Patrol and Reconnaissance Wing operations created new challenges
in the management of airfield operations due to differing speeds and mixed air traffic
patterns. Additionally, the number of maritime patrol squadrons at Ault Field will double
from three to six as three Hawaii-based squadrons relocate to Ault Field and transition to
the P-8A in the 2021 timeframe.

To more effectively manage operations and balance readiness requirements, the preferred
alternative shifts FGLP operations to OLF Coupeville to enable more efficient operations
at both airfields. In addition, OLF Coupeville offers far superior FCLP training than can
be achieved at Ault Field. The characteristics of OLF Coupeville very closely mirror the
conditions a pilot will experience in the aircraft carrier environment (OLF sits on a 200-ft
ridge surrounded by flat terrain, similar to how an aircraft carrier sits on the water). The
low ambient light around the OLF coupled with the ability to completely darken the
airfield closely approximates the conditions at sea and provides the most realistic FCLP
training in the Northwest Region. Conducting FCLPs at Ault Field creates congestion,
which results in delays and degrades available training time in the ranges. It also extends
the pattern impacting more communities, and creates a constant noise stream from
aircraft waiting to take off at the approach end of the runway. Further, FCLPs executed
at Ault Field are of minimal training value and much less representative of the aircraft
carrier environment.

Question #2 - Under Scenario 2A, the total number of Growlers at NAS Whidbey Island
will increase by 44 percent, but the total number of FCLPs will increase by 287 percent.
What accounts for this disproportionate impact, and is equitability a factor in determining
a preferred alternative?
Response #2 - Through the comprehensive and transparent NEPA process, Navy takes a
hard look at numerous factors including level of impact on local communities. Our
preferred alternative is based on that hard look.

The number of total FCLPs is driven by the number of pilots, not by the number of
aircraft. Each pilot must do a certain number of FCLPs prior to conducting landings on
an aircraft carrier. This is a critical component of safe pre-deployment training. As
discussed above in the answer to 'Question #1, OLF Coupeville provides a much more
realistic training environment for pilots. In addition, as part of our evaluation process we
considered the broader environmental impact from flight operations under all EIS
alternatives and scenarios. Moving the preponderance of FCLP operations to OLF
Coupeville ensures the safest and most effective training of aircrew, and takes into
consideration the impact of all operations to the communities around Ault Field and OLF
Coupeville. The proposed FCLP distribution does take into consideration the best
equitable distribution of noise impacts of all operations from the San Juan Islands to
Anacortes, Oak Harbor, Coupeville, Port Townsend, and Island Comity. While it is
correct that the projected increase in FCLP at OLF Coupeville under the preferred
alternative is significant (increasing from 6,120 to 23,700 FCLP operations), the total
increase in FCLPs under this alternative for the NAS Whidbey Island complex is
23 percent (increasing from 24,000 to 29,600 FCLP operations at both airfields). Finally,
where the Navy could reduce the total number of required FCLPs due to a reduction in
the number of pilots per squadron and through the introduction of Precision Landing
Mode (PLM) technology, we incorporated those factors into our planning. In general, the
scenarios that move a preponderance of FCLP operations to OLF Coupeville impact the
fewest number of people living in the community at large and ensure the safest most
effective training of aircrew.

Question #3 - At how many sites on Whidbey Island has the Navy conducted noise
monitoring, as distinct from noise modeling? For how many days was noise recorded?

Response #3 - The Navy does not conduct noise monitoring but instead uses the federal
standard for measuring noise impacts. This method is the industry standard
methodology, supported by guidance from the Federal Aviation Administration, U.S.
Environmental Protection Agency, Department of Defense, Federal Interagency
Committee on Noise, American National Standards Institute and World Health
Organization among others, and is the most accurate and valid method for evaluating the
impacts of noise under current and future conditions. In response to inputs and public
comments, the Navy included several supplemental metrics, including modeled single-
event noise, and expanded the number of points of interest (POI) for the analysis to 48
POIs. As a result, the analysis provided a comprehensive picture of noise impacts in the
region up to 30 miles away from Ault Field and OLF Coupeville.

The findings of the Navy?s modeling analysis were reinforced by noise measurements
taken by the National Park Service in Ebey’s Landing National Historic Reserve that
closely correlated to Navy’s noise model. Additionally, in court proceedings, Citizens of
Ebey’s Reserve submitted a JGL Acoustic report which measured noise at five locations.
In August 2015, the U. S. District Court in Seattle determined that the measurements
(from the JGL Acoustic report), when converted to the noise model standard, were not
significantly different or more severe from what was predicted in the 2005 Environmental
Assessment through the Navy's noise model. The court also determined that the
plaintiffs noise study actually supported the Navy’s position. Additional noise
measurements or monitoring would not, therefore, change the results of the impacts of ail
alternatives presented in the Growler EIS.

Question #4 — Concentrating aircraft and training in one location saves taxpayer money,
and I appreciate the Navy’s efforts to promote further efficiencies. But it also exposes
small communities to significant impacts, “Will the Navy commit to funding mitigation
efforts, including, but not limited to, construction of a hush house, funding for research
and eventual installation of chevrons and other measures as necessary, particularly if a
land use study makes disruptive zoning recommendations?

Response #4 - The Navy will continue to mitigate noise impacts to the greatest extent
practicable while meeting mission needs. The most recent example of our commitment to
noise mitigation technology is the deployment of PLM to fleet aircraft. This system not
only makes carrier aviation safer, but lowers the total number of FCLPs required to
prepare Navy pilots for carrier operations.

Funding for community mitigation measures is not authorized under current law;
however, the Navy will commit to working cooperatively with local leaders to mitigate
the impacts of flight operations in the Whidbey Island area.

Aircraft hush houses help reduce sound levels associated with ground-based high-power
jet-engine testing. While the Navy is considering funding the construction of a hush
house, any such project would have to compete for limited funding and a tremendous
backlog of infrastructure and readiness requirements.

The Navy is committed to pursuit of engine design technologies, to include chevrons, that
will reduce the noise signature of the F414 engine. Testing has confirmed that chevron
technology has some positive effect on noise output; however, it also demonstrated that
redesign and additional testing is necessary to fully assess any noise-reduction benefits
and potential drawbacks. Therefore, while the Navy continues to pursue research and
testing of chevrons, its potential as a noise mitigation measure remains uncertain.

The Navy has encouraged Island County to establish Accident Potential Zones (APZs)
around OLF Coupeville and to establish land use controls and building standards
appropriate for high noise areas. The establishment of Ebey’s Reserve (of which the
Navy is one of the many land owners), as well as the Navy’s Readiness and
Environmental Protection Integration (REPI) program, have helped to ensure compatible
land-use and development around OLF Coupeville. Under the REPI program, the Navy
partnered with Island County and various groups to acquire conservation easements from
willing sellers. As of January 2018, the Navy has invested approximately $ 14 million to
preserve compatible land uses around OLF Coupeville and has protected over 1^500 acres
of open space, working farms, and endangered species habitat while preserving the rural
character of Ebey’s Reserve. The existing REPI protections and land use controls should
be reflected in a future land use study and should minimize any perceived disruption from
zoning recommendations.