Case 2:19-cv-01059-RAJ-JRC: 36-2 - Declaration of Zachary K. Griefen Exhibit 2

Case 2:19-cv-01059-RAJ-JRC Document 36-2 Filed 02/13/20 Page 1 of 54
changes to the types of flight operations flown by the EA-6B arrivals departures pattern
operations the locations of flight operations flight tracks over land or water or the current
ratio of daytime and nighttime flight operations at Ault Field or OLF Coupeville In addition
there will be no change to the number or type of flight operations within national airspace
designated SUA and in the low-altitude MTRs from what has been conducted by the EA-6B
squadrons for several decades
Table 1-3 Flight Operation Changes for the Replacement EA-18G Aircraft at
NAS Whidbey Island
fTlj
Arrivals 4816 4588
Departures 4816 4588
36662 31345
Patterns Operations OLF Coupeville 7682 6120
Total 53976 46641
Source Wyle Laboratories Inc 2004a
Numbers in parentheses denote decrease
1.3 Purpose and Need
The purpose and need for the proposed action is to maintain the Navys Airborne Electronic
Attack AEA capability at NAS Whidbey Island by replacing the EA-6-B airframe which is
nearing the end of its service life with EA-18G airframe and providing the facilities and
functions in
support of the replacement without negatively affecting the Navys readiness to carry
out the AEA mission
The EA-6B aircraft has conducted the Navys AEA mission for more than 30 years
Although the airframe has remained operationally viable through systematic upgrades it is
approaching the end of its service life The EA-6B Program of Record beginning in the Fiscal
Year 2004 budget reflects the initial stages of drawdown the airframe should be retired by
2012 The Presidents Budget for fiscal year 2005 PB-OS and Program Objective Memorandum
for fiscal year 2006 POM-06 both reflect programmatic decisions to reduce support of this
aging airframe At the same time corresponding increases in the replacement platform the EA
8G are being programmed As result any delay in the transition from the EA-6B airframe to
11
GRR00030937
Llniced
_T 7- /Z$7
States Office of
Environmence Protection Noise Abatement arid Control REPO NO 550/982-105
Agency Wosflington DC 2O6O April 1982
EPA
GZXEDELINES EtR NOISE IMPACT ALYSI$
-.
........
....
GRR00008324
TECHNICAL REPOflT DATA

fflne rsi./ lnkZnnrrIs in eke ecI-ne tn/un ronestcleIe
REPORT RECIPIENTS ACCESDIOMNO

550/982105
T1TLE AND SIJDTITLE REPORT DATE
Anril 1982
PERFORMING ORGANIZATION CODE
Guidelines for Noise Impact Analysis
AUTkiORi5 PERFORMING ORGANIZATION REPORT NO
550/9821 05
PERFORMING ORGANIZATION RAME AND ADDRESS IC PHOGRAM ELEMENT NO

Office of Noise Abetnent and Control
LI EnvLrorunental Protection Agercy i-i-a RACUO RANT NO
401 St S.W
Washington D.C 2Q460
12 SPON5Q$ItG AGENCY NAME AND ADDRESS 1D TYPE DF REPORT AND PERIOD COVERED
74 SPONSORING AGENCY CODE
Report
15 SUPPLEMENTARY NOTES
JO ASSTR ACT
the purpose of the guidelines proposed in this report is to provide decision-

makers in heth the public and private sectors with analytic prccedures which can
be uniformly used to express and quantify inipacts fran noise so that such impacts
can be readily understcaI and fully considered within the canparative evaluations
which constitute noise environment decisions The procedures contained within the
guidelines are apnlical1e to the preparation of environmental noise assessments
and environreentai impact description of noiseS environment changes scu1d be useful
The procedures allow user to arrive at an objective and for nvst situations
quantitative definition of noise inpact In many situations the procedures
will allow the calcuJation of single niriter desoriptor which expresses the total
noise impact of proposed project on the population exposer
The quantification lods recarnended for impact assessment in these
guidelines are further developnents of the Practional Impact t4ethaolcgy used

for assessing the health and cl.Care effects of noise environment three
principal tynes of noise and viation environments are considered general

audible noise special noises arid vibrations There is separate chapter for
each of these principal types of environment
CEY WORDS AND DOCUMENT ANALYSIS
D55CRIPTORS b.IDENtIPIERSIOpSPj ENOED TERMS iCOS4TJ FicldCaup
Noise Lct Noise Effects

Noise iticisn Noise .ssessnent Noise
General Audible Noise
sigh-Energy Impulse Noise

Infrascund
Ultrasound
Vibration
ZISTRI SUrICN STATEMErIt 19 SECLJRI re acporq NO PACES
Unclassified 214
WA mailing list tS 20 SECURItY LASSitIriSiJr nPRICZ

Unclassified
EPA ForrIt 22221 1Q72I
GRR00008325
ROR tO 550/982105
April 1982
intnas ro zcis rcr insIs
This rert has been approv for ger1enl availability The ntsncs ot
this rert reflect the views of the ccntactcr who is rescnsib1e for the
facts ar4the acctacy of the data This reon does rEct
present herein
tecessarily reflect the officiaL ñ.ews or çolicy of ZA
This reon does
not constitute standard specification or reu1ation
Pcs3zcM cnrnz TC rrztt ccrcur tfl azrc
GRR00008326
FOREWORD
the purpose of the guidelines proposed in this report is to provide
decisionmakers in both the public and private sectors with analytic proce
dures which can be uniformly used to express and quantify impacts from noise
so that such impacts can be readily understood and fully considered within the
comparative evaluations which constitute noise environment decisions The
procedures contained within the guidelines are applicable to the preparation
of environmental noise assessments Adherence to the procedures within the
guidelines is strictly voluntary The guidelines are neither mandatory nor
regulatory in intent Specific numbers which appear in the guidelines should
not be construed as standards nor are they intended to supplant locally

any
established community noise level Limits or decisions on envirommental ac
eptability with respect to noise as fostered by certain states municipali
ties or other governmental jurisdictions Instead the guidelines are
ffered here as simply tool to allow decisionmakers to consider tradeoffs
between environmental benefits and costs anew for potentially noisy projects
the guidelines are based on the deliberations of the Committee on Hear
ing Bioacoustics and Uiomechanics CHABA Working Group 69 National Academy
of Sciences NAS from 1972 to 1976 in response to request in 1972 by
the U.S Environmental Protection Agency EPA In early 1977 recommended
procedures were published by the National Acadcniy of Sciences in document
entitled Guidelines for Preparing Environmental Impact Statements on Noise
That document provided comprehensive set of procedures for specifying the
physical descriptions of environmental noise and vibration and methods for
assessing the degree of impact on people associated with these environments
The technical approaches proposed by NAS underwent several significant
changes during the period of CHABA working result of

group activity as
GRR00008327
working group deliberations public discussions and presentations at national
and international technical meetings Under the constraint that the proce
dures contained within the guidelines must reflect compromise among factors
of practicality economy desired accuracy and specificity the working group
tried to be responsive to the numerous suggestions received from government
agencies industries and the scientific community The proposed procedures
were tried out by several of the working group members and others and short
comings and gaps were identified This led to joint working group research
activities or to efforts by individual members Many of thdse individual
efforts which had their roots in the working group activities were conducted
and sponsored under other government or private industry programs and have
been separately published in the meantime Similarly some agencies faced
with the need for operational decisions used concepts from the proposed
guidelines in their publications those publications are included among the
referen as cited in the guidelines Some of the proposed methods contained
within the guidelines have been officially adopted by several agencies
Further close liaison was maintained between the working group and several
writing groups working on related items under the American Mational Standards
institute ANSI Acoustical Standards Committees In summary the working
group tried to be responsive to all potential users concerned and tried to
reach cousensus wherever possible
During the summer of 1977 EPA distributed copies of the NAB report to
Federal agencies and other interested parties with request for comments
On June 30 1978 request for further comments was published in the Jederal
Register 43 FR 28549 Both of these actions were taken to provide an oppor
tunity for additional viewpoints and expertise to be considered in proposed
11
GRR00008328
revision the NAS report EPA then carried out detailed

of stepbstep
analysis of the issues raised during the comment period in order to improve
the overall accuracy usage and general readability of the document
Conceptually the latest draft version of the guidelines contains the
same basic procedures delineated in the NAS guidelines published in 1977
However because of some refinements in the assessment methodologies EPA in
February 1981 extended to the original conmenters an opportunity to comment
on the final draft version At the same time other Federal agencies were
informed as to the existence of the revised draft and were afforded an
opportunity to comment Comments were also solicited from the National
Academy of Sciences and from other individuals and organizations who speci
ficatly requested an opportunity to review the draft revision to the guide
lines Accordingly revisions have been made to the 1981 dilaft report to
reflect the additional comments received
Finally it is only fair to say that in report as comprehensive and
exploratory as this one not all working group members agreed with all the
details in the report However they all agreed with its essential concepts
and the general approaches and hoped that the details would be worked out1
corrected and fall in place as experience with the proposed guidelines is
gained Similarly not all of those commenting on the report will be satis
fied with the revisions which have been made In the face of concinued gaps
in knowledge honest differences of opinion will undoubtedly remain about the
procedures recommended in this publication Nevertheless it was important
for these guidelines to be published as soon as possible in order to assist
in providing guidance for uniform methods of noise impact assessment It
should be recognized that it may be necessary to update these guidelines in
Li
GRR00008329
the future The guidelines are open to revision as new information becomes
available
These revised guidelines were prepared under the guidance of the Office
of Noise Abatement and Control U.S Environmental Protection Agency EPA
wishes in turn to acknowledge the contributions of the members of Working
Group 69 of CRAM to the development of these recommended guidelines We also
wish to thank the members of CHABA Working Group 84 for their assistance in
the development of the method for assessing human response to highenergy
impulse noise We extend further thanks to all the commentors who provided us
with most helpful comments which led to the revision of the guidelines and
c1io demonstrated noble patience and forbearance during the lengthy revision
process Finally we wish to express our sincere appreciation to Frederick I.
Hall of McMaster University who assisted us in analyzing the comments and
drafting the revision and whose insights and suggestions proved invaluable
to the final issuance of these guidelines
iv
GRR00008330
Committee on Hearing Bioacoustics and Biomechanics
Working Group 69
on
Evaluation of Environmental Impact of Noise
Henning Von Gierke Chairman

WrightPatterson AFB
Clifford Bragdon David Mudarri

Georgia Institute of Technology Environmental Protection Agency
Kenneth Eldred John Reed

Ken Eldred Engineering Sandia Laboratories
William Galloway Paul Schomer

Bolt Beranek and Newman Inc Construction Engineering Laboratory
Jeffrey Goldstein Theodore Schultz

Invironmental Protection Agency Bolt Beranek and Newman Inc
Ira lirsh Sizone Yaniv

Central Institute for the Deaf National Bureau of Standards
Daniel Johnson Robert Young

WrightPatterson AFB San Diego CA
Working Group 54
on
Human Response to Impulse Noise
William Galloway Chairman

Bolt Beraneic and Newman Inc
Daniel Johnson Paul Schomer
WrightPatterson AFB Construction Engineering Laboratory
Karl Kryter Peter Westervelt

SRI International Inc Brown University
GRR00008331
CONTENTS
Section Title
introduction
1.1 Purpose of the guidelines
1.2 Overview of the approach
1.3 Structure of the guidelines
1.3.1 Preliminaries
1.3.2 General audible noise 12
1.3.3 Special noises 13
1.3.4 Vibration 14
1.3.5 Potential changes in population 14
1.3.6 Examples 15
1.4 Other considerations 16
1.4.1 Projects which reduce noise 16
1.4.2 Temporary projects 17

1.4.3 Uncertainties in the analysis 18
General audible noise 19
2.1 Basic screening procedures 20
2.1.1 Measures for the decription of general

audible noise 23
2.1.2 Determining the yearly daynight sound level 25
2.13 Determining the population affected by the

noise of the proposed project 30
2.2 Health and welfare effects 33
2.2.1 Human exposure critria

noise 33
2.2.2 Quantification of the noise impact 41
2.3 Severe health effects 52

2.3.1 Human noise exposure criteria 54
2.3.2 Quantification of the impact 60
2.4 Environmental degradation 62
2.5 Treatment of temporary projects 64
26 Practical Example 66
Special noises 71
3.1 Highenergy impulse noise 71
3.1.1 Description of highenergy impulse noise 72
3.1.2 Human noise exposure effects of highenergy

impulse noise 75
31.3 Structural damage criteria for impulse noise 80
3.2 infrasound 85
3.2.1 Description of infrasound 85
3.2.2 Human noise exposure effects of infrasound 85
3.3 Ultrasound 87
3.3.1 Description of ultrasound 87
3.3.2 Human effects of ultrasound 88

3.4 Noises with information content 88
Vibration 89
4.1 Human effects of vibration 89
vi
GRR00008332
CONTENTS Continued
Section Title
4.1.1 Description of building vibration 90
4.1.2 Human vibration exposure criteria 90

4.1.3 Quantification of the impact 95
4.2 Structural effects of vibration 98
Summary of noise impact analysis 100
5.1 Purpose and structure of the guidelines 100
5.2 Analysis of impacts of general audible noise 101

5.3 Analysis of impacts due to special noises 104
5.4 Analysis of impacts due to vibration 105
References R1
Appendix Acoustical terms and symbols used in the guidelines

and some mathematical formulations for them Al
Environmental noise measures and procedures 31

Environmental noise measures and their purposes
in Federal programs B2
Estimating Ldn from other noise measures 33
Summary of human effects of general audible noise CI
Measurement of and criteria for human vibration
exposure 31
Example application of guideline procedures for
general audible noise El
Fl
vii
--
GRR00008333
LIST OF TABLES
Table Title
Summary of methods for noise impact analysis
Yearly daynight sound level as estimated by
population density 29
Values of the weighting function for general

adverse response 47
Average heating loss as function of 8hour Leq 58
Criterion function for severe health effects 60
Sample data presentation future noise levels
without proposed project 67
Sample data presentation future noise levels of

project alone 68
Sample data presentation future levels from all

sources combined 69
Sample data presentation special scuations 70
10 Values of weighting function for hip energy

impulse noise 79
11 Conversion of Lcdfl to via equal annoyance 81

Ldn
12 Basic threshold acceleration values for acceptable

vibration environments 92
viii
GRR00008334
LIST OF FIGURES
Figure Title
Preparation of noise impact analysis
Flow chart and worksheet
Screening diagram 21
Summary of annoyance data from 12 surveys showing

close agreement 37
Comparison of new annoyance function with previous

functions 39
Suggested descriptors for various situations SO
Comparison of curvilinear function and fractional

impact linear function 53
Potential hearing damage risk for daily exposure to

8hour equivalent sound levels 59
Recommended relationship for predicting community

response to high energy impulsive sounds 78
10 Infrasound criteria 86
11 Weighting characteristic for building vibration

in terms of human responses for the frequency range
to BORn 91
12 Vibration criteria for residential areas 94
13 Percentage of population complaining as function

of peak acceleration 96
14 Types of analyses suggested 103
ix
GRR00008335
levels measured under conditions conditions

represent average or if vary
during the year weighted averages of levels at the different times of year
In some instances rough approximation to annual average conditions or
noise levels will be sufficient in others it will be necessary to be more
precise For example noise levels for some airports are reported for an
average busy day rather than an annual average If the project under analy
sis is landuse development it is quite reasonable to use such existing
noise information even though it is not exactly the annual average The error
in the data is small enough that the cost of more exact estimate of the
annual average is not warranted On the other hand if the project being
analyzed involves change in airport use for example Sunday flights when
there were previouly none the noise level typical of an average busy day mny
lead to nonsensical results the busyday level would be reduced in tie
example if the a...craft noise on Sunday was less than the average on oth sr
busy dayseven thiugh over the year more noise was being produced because of
the added operations Approximations for the annual average can be

lad
very useful shortcuts but need to be applied with careful judgment
Daynight sound level is the primary measure of general audible noise
and is appropriate for noise environments that affect community over an
entire 24hour day There are two kinds of situations where such measuzt
is not appropriate however The first kind consists of those situations
in which it is desirable to assess the effect of noise environment on an
activity of less than 24hour duration An example is the effect of noise
on speech communication in classrooms or in offices In these situations it
ii useful to consider the equivalent sound level over the time

eq CT
period of interest CT for example one hour or eight hours CLeqCl or
t.eqs
24
GRR00008359
The second kind of situation covers those in which the noise is not
for of the to affect the reading but is

present enough day greatly
still subjectively judged as intrusive and disruptive when it is present
Examples of such noise sources may include motorcycle pasabys trains and
specific aircraft flyovers The appropriate sound measure for such an event
is the cumulated sound produced by the single event the Aweighted sound
exposure level L5 ft is measure of accumulated not average sound
energy
Precise mathematical descriptions of all these measures are provided in
All are expressed in Aweighted decibels the reference sound

Appendix
pressure is 20 nicropascals
2.1.2 Determining the yearly daynight sound level
For the screening procedure two yearly Ldn values need to be deter
mined the existing levels and the levels expected to be caused by the
project In addition for the impact assessment it will be necessary

proposed
to estimate the future yearly values in the area if the project is not
Ldn
constructed The total postproject noise level can then be calculated as the
logarithmic sum of the project levels and the future levels in the absence
of the project
Determining direct neasurement To establish the existing

Ldflv by
noise exposure accurately field measurements are oftentimes the preferred ap
Unfortunately such neasuretoents can be expensive and time-consuming

proach
Nonetheless1 measurements nay be warranted For exannple if the present
sound levels are already high so that the noise impact of new
average
for examples on how to calculate logarithmic suns of project

SeeAppenciix
levels and future levels in the absence of the project
25
GRR00008360
project will not be much greater or may be even less than the impact from
the existing noise environment it may behoove the applicant to conduct
measurement program so as to predict the noise impact more accurately
When an existing noise environment is to be determined by direct measure
ment it will be necessary to make measurements at number of locations suffi
cient to establish credible baseline for estimating total impact The number
of measurement locations and their geographic disposition will depend on the
spatial extent of the impact expected to be produced by the project
Measurement periods and the time intervals between them should be deter
mined by the characteristics of the existing noise in order to obtain
reliable estimate of yearly Ldn If the cxisting noise is expected to be
substantially the same from day to day measurements during single typical
24hour period may be adequate Locations where the noise is caused primar
ily by wellestablished motor vehicle traffic patterns are an example In
other situations where strong daily weekly monthly or seasonal effects
occur it may be necessary to measure for number of different daily periods
suitably chosen to account properly for these variations In some particular
situations the .variations may be Large enough to make measurement practi
cally infeasible case in point might be in the vicinity of an airport
with more than one runway which has no on-going noise monitoring program
The most reliable temporal data are obtained by techniques that approach
continuous measurement of the sound level over the time period in question
In some instances it may be reasonable to obtain or sample measurements over
only fractions of the total timee.g several minutes per hour Flow
ever any measurement method used to approximate continuous measurement of
should be justified by adequate technical reasons and data to show the

Ldn
26
GRR00008361
3.1.1.2 Environmental Consequences under Alternative Minor Facilities Modifications
Modifying the interiors of existing facilities including minor changes to room configuration
electrical power routing HVAC mountings for replacement equipment etc would have
minor impact on the ambient or future noise environment which is dominated by aircraft
operations Construction-related noise associated with interior modifications would be
temporary for the duration of the modification projects and localized
Aircraft operations including flight operations and ground engine-maintenance run-ups will
continue to be the primary source of noise at NAS Whidbey Island following replacement of the
EA-6B with the EA-18G With the decreases in the number of aircraft and personnel associated
with replacement of the EA-6B with the EA-18G the annual number of flight operations at NAS
Whidbey Island is projected to decrease even though the primary types of mission training and
readiness requirements for the EA- 8G will remain virtually the same as those for the EA-6B
Ground engine-maintenance run-ups also are projected to decrease an 80% decrease below CY
2003 operations Wyle Laboratories Inc 2004a following replacement of the EA-6B with the
EA-18G because the newer aircraft will require less maintenance due to the decrease in flight
operations and its

younger age Aircraft flight operations of the P-3C/EP-3 C-9 and transient
aircraft will remain the same in CY 2013 however the C-12 has been disestablished and
therefore those operations are not represented
During CY 2013 75987 annual airfield flight operations will be conducted at Ault Field
7% decrease below CY 2003 operations and 6120 annual flight operations will be conducted at
OLF Coupeville 20% decrease below CY 2003 operations Wyle Laboratories Inc 2004a
The distribution of aircraft flight operations arrivals departures and pattern operations and
ground engine-maintenance run-ups by aircraft type in CY 2013 is shown in Appendix The
percentage distribution of daytime and nighttime operations will not change following
replacement of the EA-6B with the EA- 18G
The projected noise contours 65- 70- and 75-dB DNL for annual operations conducted at
Ault Field and OLF Coupeville in CY 2013 following replacement of the EA-6B with the EA
18G are shown on Figure 3-4 and comparison of the CY 2003 and CY 2013 noise contours
65- and 75-dB DNL is shown on Figure 3-5 Operation of the EA-18G in replacement of the
EA-6B results in less noise exposure to the local community This is primarily attributed to the
42
GRR00030968
November2004 Aircraft Noise Study for Naval Air Station Whidbey Island and
WRO4-26 Outlying Landing Field Coupeville Washington
SEL is logarithmic measure of the total acoustic energy transmitted to the listener during the
event Mathematically it represents the sound level of constant sound that would fri one
second generate the same acoustic energy as the actual time-varymg noise event For sound
from aircraft overflights which typically lasts more than one second the SEL is usually greater
than the Lmax because an individual overflight takes seconds and the maximum sound level Lmax
occurs instantaneously SEL represents the best metric to compare noise levels from overflights
Day-Night Average Sound Level DNL and Community Noise Equivalent Level CNEL
Day-Night Average Sound Level and Community Noise Equivalent Level are composite metrics
that account for SEL of all noise events fri 24-hour period In order to account for mcreased
human sensitivity to noise at night 10 dB penalty is applied to nighttime events 1000 p.m to
700 a.m time period variant of the DNL the CNEL level mcludes 5-decibel penalty on
noise durmg the 700 p.m to 1000 p.m time period and 10-decibel penalty on noise durmg the
1000 p.m to 700 a.m time period
The above-described metrics are average quantities mathematically representmg the contmuous
A-weighted or C-weighted sound level that would be present if all of the variations fri sound
level that occur over 24-hour period were smoothed out so as to contam the same total sound
energy These composite metrics account for the maximum noise levels the duration of the
events sorties or operations and the number of events that occur over 24-hour period Like
SEL neither DNL nor CNEL represent the sound level heard at
any particular time but
quantifies the total sound energy received While it is normalized as an average it represents all
of the sound energy and is therefore cumulative measure
The penalties added to both the DNL and CNEL metrics account for the added mtrusiveness of
sounds that occur during normal sleepmg hours both because of the mcreased sensitivity to
noise during those hours and because ambient sound levels durmg nighttime are typically about
10 dB lower than durmg daytime hours
The mclusion of daytime and nighttime periods in the computation of the DNL and CNEL
reflects their basic 24-hour definition It can however be applied over periods of multiple days
For application to civil airports where operations are consistent from day to day DNL and
CNEL are usually applied as an annual average For some military airbases where operations
are not necessarily consistent from day to day common practice is to compute 24-hour DNL
or CNEL based on an average busy day so that the calculated noise is not diluted by periods of
low activity
B-7
GRR0003251
Comment
FAA ELEVATION RULES IGNORED
The Problem Explicit FAA rules address low-level flying over residential
areas which the DEIS touts as being properly followed at OLFC and Ault Field
Actually some of the FAA rules as related to FCLP5 have not been properly
addressed in the DEIS
The Explanation Page 3-41 of the DEIS states that ircraft sfify is based on the physical
risks associated with aircraft flight Military aircraft fly in accordance with .Federai Aviation
.Regaiations .Part 9.1 General Operating and Fiiht Rules which govern such things as operating
near other aircrafi righ way rules aircraj speed and minimum safe altitudes However the
following FAA rule is not addressed in the DEIS
FAA Rule 91.119 Minimum safe altitudes General states that Except when
necessary for takeoff or landing no person may operate an aircraft below the
following altitudes Over congested areas Over any congested area of city
town or settlement or over any open air assembly of persons an altitude of 1000
feet above the highest obstacle within horizontal radius of 2000 feet of the
aircraft Over other than congested areas An altitude of 500 feet above the
surface except over open water or sparsely populated areas In those cases the
aircraft may not be operated closer than 500 feet to any person vessel vehicle or
structure
Growlers are not allowed to actually land at OLFC because they cannot take off due to the
runway being too short Furthermore with touch and go FCLP practice there is no intent to
actually land which involves bringing the plane to stop on land or conversely taking off from
resting position on land Because FCLPs are touch-downs with no actual landing it follows
that true take-off cannot occur since the jet never landed
As shown in Figure 8.1 below the approach to touchdown begins and descends from 400 feet
which puts it at about 400 to 200 feet over many residences within the 2000 foot radius of the
aircraft Furthermore the downwind leg of an FCLP at 600 feet above ground level AGL is
not takeoff or landing approach but is an interim flight between touchdown and approach for
another touchdown nor is the arrival flight at 800 feet AGL landing approach but is circle
OLFC prior to beginning the first FCLP So no part of an FCLP at OLFC complies with the
1000 or 500 foot AGLs stipulated in the above FAA rule Even if the approach and takeoff were
to be accepted as necessary for takeoff and landing and hence excluded the downwind leg
and arrivals are still noncompliant
Citizens of Ebeys Reserve Comments on Draft ETS for NASWI
GRROO1 13597
DEIS Section 6.1 summarizes how the proposed actions comply with applicable laws and
regulations
In accordance wth 40 Code of Feder Reguatons secton 1502J6c anayss of
envftonment consequences shaH ndude dscusson of possbe confhcts between
the Proposed Action and the objectives of federa regona state and oca and use
pans poHces and contros Tabe 61 dentffies the prncpa federa and state aws
and reguatons that are apphcabfle to the Proposed Action and describes briefly how
comphance wth these aws and reguatons woffid be accomphshed/
However compliance with Federal Aviation Regulation Part 9lwas somehow overlooked in the
DEIS and in Table 6-1 The DEIS must discuss and show how its FCLP activity is compliant
with Part 91
In addition FCLP activity at OLFC appears to violate navigable airspace laws As discussed in
https//en.wikipedia.or/wiki/Air rights The navigable airspace in which the public has
right of transit without effecting landowners property rights has been set at the height of500ft
in urban or suburban areas and 300 feet above the surface or tallest structure in rural areas
The exact altitudes at which the airspace over private land becomes ublic airspace or
where the upward bounds of national sovereignty extends is often debated but the Supreme
Court rulings and space treaties are clear Landowner domain extends at least up to 385 feet
in rural areas see ausby US 1946
As noted above both flight paths 14 and 32 require low-level approaches over rural areas and
suburban neighborhoods at altitudes less than 500 feet in some areas as low as 200-300 feet The
FAA however requires no flights below 500 feet over homes or people as codified by the
Supreme Court The court has ruled that property owner controls use of the airspace 500 feet
above their
property and may make any legitimate use of their
property that they want even if it
interferes with aircraft overflying the land This is an FAA rule the Navy claims to honors as
explained by this Oak Ridge National Laboratory Report23
The military services are committed to safety and to minimizing the collateral noise
associated with low-level flight training The Air Force for example has set
23
Ecological RiskAssessment Frameworkfir Low.-i4 ititude Over/lights by Fixed-Wing and RotaryJVing Military
Aircrafi January 2000 Rebecca Efroymson Oak Ridge National Laboratory Winifred Hodge Rose and Sarah
Nemeth Army Construction Engineering Research Laboratory and Glenn Suter II Environmental
Protection Agency Research sponsored by the Strategic Environmental Research and Development Program of the
Department of Defense under Interagency Agreement 2107-N218-S1 under contract DE-ACO5-000R22725
with UT-Battelle LLC Publication No 5010 Environmental Sciences Division ORNL
httDS //wwwrcsearchate.net/Dub1ication/2 52522677
GRROO1 13598
numerous restrictions and tailored its training to reduce noise as much as possible
The DoD in general in addition to following its own flying rules of low-level altitudes
and airspeed also follows those in Federal Aviation Regulation 91.79 which states
that no plane may fly closer than 500 ft from any person vessel vehicle
or structure USAF Fact Sheet 96-17 In addition because of the greater potential
for human annoyance during sleeping hours low-level flying by military fixed-wing
aircraft generally occurs during daylight hours low-level flying near densely
populated areas is prohibited
On approach to and departure from an OLFC touch-down Growlers cannot comply with FAA
rules and must cross over hundreds of residences well-used childrens athletic field dog park
county park trail system crowded recycle center above ground fuel storage tanks and
facility for 100 homeless teens
Conclusion The DEIS failed to consider and explain how it intends to operate at OLFC
without violating very important components of federal law dealing with proximity rules to
persons vessels vehicles and structures or conversely explain how the Navy will appropriately
compensate those impacted by takings
Figure 8.1 Navys schematic of Path 14 FCLP at OLFC The AGL elevations are the about
same for Path 32 Source http//admiralscoveorg/naswiolfhtm
GRROO1 13599
APPENDIX
Extension Commentof
DOD NOISE LIMITS CRITERIA
The following is from Department of Defense Design Criteria Standard Noise Limits MIL
STD-1474D 12 February 1997 SUPERSEDTh1G Available in
AMSC http //www soundmetersource com/upioads/3/0/9/4/3 094346/rn. .iitd 474dpdf

See Section 6.4
4.2 Hearing damage criteria
4.2.1 Time weighted average sound level The 8-hour time weighted average equivalent
sound level shall not exceed 85 dB for any flight member based on aircraft usage and mission
profiles given in The total daily exposure selected in Table 6-I shall be based on flight
members flyingb missions in any given day Hearing protection devices shall be worn
as follows see Appendix This is also equivalent to summing the fractions of the
actual time of exposure to the allowable time of exposure If this value exceeds one the
combined exposure shall then be considered to exceed the standard This is expressed
mathematically as
C1 C2 C3
.. 1.0
TTTT
23n
where the values are the times of exposure to given level and the values are the times
allowed at those levels by Table 6-I All noise exposures above the threshold of 80 dBA shall
be used in the above equation
Table 6-1 Noise limits for unprotected exposures
Time mm Max Sound Time mm Max Sound Time mm Max Sound

dBA2 dBA2 dBA2
No Limit 80 95 92 4.7 105
1440 80 76 93 3.8 106
1210 81 60 94 3.0 107
960 82 48 95 2.4 108
762 83 38 96 1.9 109
605 84 30 97 1.5 110
480 85 24 98 1.2 111
381 86 19 99 0.9 112
302 87 15 100 0.7 113
240 88 12 101 0.6 114
190 89 9.5 102 0.5 115
151 90 7.5 103 115 forbidden
120 91 6.0 104
GRROO1 13628
Allyson Brooks Ph.D Director
State Historic Preservoton Officer
November 29 2018
Captain Matthew Amy

Commanding Officer
Naval Air Station Whidbey Island
3730 North Charles Porter Avenue

Oak Harbor Washington 98278-5000
Re Proposed Increase of EA-1 8G Growler Aircraft and Aircraft Operations
Development of Support Facilities NASWI Log No 102214-23-USN
Dear Captain Amy
As State Historic Preservation Officer will not be signing the current Section 106
Memorandum of Agreement Both the state and local community contend that the
mitigation is not adequate for the adverse effects of the additional Growlers and their
operations
It is most unfortunate that the efforts of our Department the Ebeys Historical Reserve
Trust Board and community all of whom offered other more

the local proportional
mitigation proposals were summarily rejected by the U.S Navy
These impacts from the additional Growlers will adversely affect the setting feeling and
association of Ebeys National Historic Reserve as well as the town of Coupeville
We had all hoped that through some form of operational mitigation or avoidance we
could diminish those effects As we are unable to reach agreement on an appropriate
level of mitigation the State of Washington will not be signing the current Section 106
Memorandum of Agreement
Sincerely
tL4 /L
Allyson Brooks
State Historic Preservation Officer
Aflyson Brooksdahpwa qov

360-586-3066
State of Washington Department of Archaeology Historic Preservation
P.O Box 48343 Olympia Washington 98504-8343 360 586-3065

ww.dahp.wa.gov
GRROO1 63843
Captain Matthew Amy

November29 2018
Page
Jim Baumgart Governors Office
Kendall Campbell NASWI Cultural Resources Program

Kristin Griffin Trust Board of Ebeys Landing NHR
Deborah Stinson Mayor City of Port Townsend
John Fowler Executive Director Federal Advisory Council on Historic
Preservation
Reid Nelson Director Federal Advisory Council on Historic Preservation
State of Washington Department of Archaeology Historic Preservation
P.O Box 48343 Olympia Washington 98504-8343 360 586-3065
ww.dahp.wa.gov
GRROO1 63844
Comments on Expanded Grower Environmenta mpact Statement for
Nava Air Station Whidbey sand
Prepared by Sanford Fidell for Citizens of Ebeys Reserve
December 2018
Adequacy of ES Disdosure of nformation About Aircraft Noise-nduced Annoyance
Section AL3J of the ES Appendix Al page AL23 states that
Schultzs original synthesis included 161 data points Figure A-8 compares revised fits of
the Schultz data set with an expanded set of 400 data points collected through 1989
Fine gold et aL 1994 The new form of the curve is the preferred form in the US
endorsed by F/CAN 1997 Other forms have been proposed such as that of Fidell and
Silvati 2004 but these have not gained widespread acceptance
The Navy is correct that the so-cafled HCON 1992 curve is the dosage-response
reationship preferred for poUcy reasons in the but its ES miseads readers by daiming
that the HCON curve has gained widespread acceptance To the contrary the HCON curve
has been known for

years to be obsoete and demonstraby incorrect The dated boierpate
text of Appendix mis-states and mis-informs readers of the Navys ES about the rationship
between aircraft noise exposure and the prevaence of consequentia degree of aircraft noise-
induced annoyance
Appendix of the Navys ES proffers ony obsoete and incorrect information whie
ignoring the ast quarter century of technica progress in understanding and predicting aircraft
noise effects The cited dosage-response rationship derived from information avaiabe prior
President Fidefl Associates nc formerly Director Environmenta Technoogies Department Boft
Beranek and Newman nc With five decades of professiona experience Dr Fidefl is Feflow of the
Acoustica Society of America and has served as U.S Representative to nternationa Standards
Organization Technica Advisory Group on Community Response Questionnaire Standardization
SO/TC43/SC1/WG49 to SO Working Group 45 on Community Response to Noise and as Acoustica
Society of America Representative to NNCE Technica Study of Metrics for Environmenta Noise
Assessment and ControL
GRROO1 65602
to 1989 and favored by the Navy for seFf-interested policy reasons2 has ong since been
superseded by subsequent research and analysis The atter efforts include recent revision of
an international technical consensus standard the International Organization for
Standardizations SO 1996-12016 about which the Navys dated boilerplate text is silent
An accurate description of the technical iterature on aircraft noise-induced annoyance
more current than that of Appendix would reveal that both the European Unions and SOs
dosage-response relationships demonstrate that the prevalence of high annoyance with aircraft
noise is far greater than FICONs 1992 relationship at noise exposure level of Ldn 65 dB3 In
fact relationship published only year after the U.S Federal nteragency Committee on
Aircraft Noise endorsed the 1992 FICON relationship that of Miedema and Vos 1998 has ong
been European Union standard
The information of which readers of the Navys obsolete boilerplate text are not
informed directly contradicts and makes mockery of the Navys claim that ...this EIS uses the
best available science as required under NEPA to develop an accurate analysis of potential noise
impacts from the Proposed Action The Navys repeated claims on pages M12-13 of the ElS
that
The Federal Interagency Committee on Noise FICON as well as its predecessor and successor
organizations FICUN and FICAN respectively are self-appointed committees of agencies with
administrative interests in transportation noise policy The committees lack direct Congressional
charter to coordinate national policy for aircraft noise regulation FICONs predecessor committee
FICUN was founded primarily to advance the policy interests of its member agencies in part by
supplanting the role of the Committee on Hearing Bioacoustics and Biomechanics of the National
Academies of Science as an authoritative source of information about environmental noise impacts The
Federal Aviation Administration an agency chartered in 1958 specifically to promote the interests of
civil aviation is
prominent member of FICON So is the U.S Department of Defense whose interests
include minimizing potential restrictions on Air Force and Navy flight activity due to adverse community
reaction to aircraft noise exposure
Ln 65 dB is of particular interest because it serves as the Navys definition of significant noise
exposure FICONs dosage-response relationship predicts that 12.3% of the population describes itself
as highly annoyed at level of Ld 65 dB As described later it has long been known that this
percentage is substantial under-estimate of the actual prevalence of high annoyance with aircraft
noise exposure
The definition of threshold of significance of noise exposure is nonetheless useful to the Navy for
reasons having nothing to do with the actual prevalence of aircraft noise-induced in

annoyance
communities By arbitrarily defining Ldn 65 dB as threshold of significance of noise impacts the Navy
can avoid disclosure and description of aircraft noise impacts at lower exposure levels in NEPA
mandated disclosure documents
GRROO1 65603
The EIS analysis was prepared using the best available data available at the time of
preparationand
While the Navy recognizes that best available data have the potential to be updated at
any time the information presented in this analysis is sufficient for decision makers to
accurately assess the impacts for each alternative at this time
are both demonstraby incorrect reaflty the Navys ES is based on outdated 1992-vintage
and incorrect technica information that greaty under-estimates the prevaence of aircraft
noise-induced annoyance associated with the Proposed Action The faiure of the ES to
disdose accurate technica information to decision-makers renders the document unfit for
NEPA purposes
The Navys daim that DNL has been determined to be reliable measure of long-term
community annoyance with aircraft noise. is ako miseading DNL-based predictions of
aircraft noise-induced annoyance prevaence rates in communities are known to account for
ess than haft of the variabiflty from community to community in annoyance prevaence rates
Fidefl et al 2011 The Navys further daim that consistent relationship exists between DNL
and the level of annoyance experienced is

merey dated and seft-referentia truth by assertion
At noise exposure evek ower than Ldn 65 dB the correation between DNL and the
prevaence of high annoyance in communities is non-existent cf Figure of Fidefl 2003
Navy Caims About Average Busy Day Noise Estimates
Section 31221 of the ES asserts that the Average Busy Day measure of operational
levels is highly conservative by accounting for noise only when flight operations occur and
concentrating on those days when flight operations exceed the average number of flights for
that airfield This assertion is ogicafly equivaent to noting that the Annua Average Day
measure of operationa evek is highy miseading by induding noise on days when few flight
operations occur incuding days when flight operations are far fewer than the average number
of flights for that airfied
the context of an environmenta impact discosure document what the Navy refers to
as accounting for noise propedy means disdosing the effects of noise on peope Seep and
speech interference are immediate not cumuative effects of aircraft noise exposure Peope
do not wait for the end of the year to awaken they are awakened by aircraft noise when it
occurs not after the cumuative noise exposure created by years worth of FCLP fight
operations Simiary individua FCLP fight operations interfere with speech in rea time not
during some mathematica fiction of an annuaized noise exposure period
By anaogy pedestrians odds of being struck by car whie crossing busy street
against red traffic ight cannot be meaningfuy reduced simpy by incuding in the cacuation
GRROO1 65604
the odds of being struck in crosswak whie protected by green ight This is because it
makes no sense to combine the probabiities of being struck by car whie pedestrians cross
the street with and against the traffic ight The critica issue is not the tota time pedestrians
spend in crosswaks but whether traffic stops whie they cross
Simiary the probabiity of awakening due to the noise of FCLP operations cannot be
meaningfufly reduced by incuding time periods in the odds cacuation during which no FCLP
operations occur To paraphrase the Navys iflogic in terms of the above anaogy estimating
the odds that pedestrian will be struck by car in crosswalk only while traffic is flowing
through the intersection is highly conservative because it concentrates on those times when
both pedestrians and cars are present in crosswalks is not highy conservative to cacuate
the odds of being struck by car in crosswak ony at times when both cars and pedestrians
are present in crosswak it is the most appropriate way to estimate the odds of being struck
whie crossing street against red ight
Given that the proper goa of an environmenta impact assessment document is to
discose environmenta impacts it is miseading to under-estimate immediate impacts by
averaging them over inappropriatey ong time periods which incude engthy periods when no
aircraft noise is present For exampe it defies ogic to hod that the odds of being awakened
by the noise of FCLP operations can be reduced by incuding time periods during which no FCLP
operations occur the point of this practice is to caution readers of the ES that FCLP practice
does not occur on aM nights of the year it woud be more forthright and ogica for the Navy to
cacuate and discose such noise impacts on nights that FCLP operations actuafly occur and
then point out that ...such operations ony occur smafl number of times year nstead the
Navy chose to misead readers of its ES about major noise impact
Spurious Distinction Between ACUZ and ES Purposes
The Navy seeks to justify its reiance on annua average day estimates of noise exposure
rather than annua busy day noise exposure estimates of noise exposure by drawing an
irreevant distinction between the purposes of ACUZ and NEPA documentation The Navy
maintains that it has adopted Average Busy Day cacuations for routine use in ACUZ
documentation for the purpose of making the most conservative assumptions regarding
projected airfied operations whie the intent of its ES is to support informed decision
making regarding the Proposed Action Such distinction is

egaistic persiflage that
undermines the intent of the Nationa Environmenta Poicy Act
The Navy argues that conservative assumptions about predicted noise exposure eves
are appropriate in the case of ACUZ studies to precude potentia future community
GRROO1 65605
deveopment from encroaching on its airfids simuftaneousy asserts that such assumptions
are somehow inappropriate for preventing the noise of airfied operations from encroaching on
communities The common undedying issue in both cases is encroachment The purpose of an
ES unflke that of an ACUZ study is not to support the Navys flying mission but to disdose
foreseeabe noise impacts of proposed actions
The Navys argument about the inappropriateness of noise modeUng assumptions is
disingenuous one The argument is tantamount to an admission that the Navy adopts
conservative noise exposure assumptions when it wishes to produce aircraft noise exposure
contours that are as arge as possibe but that it prefers other assumptions when it wishes to
produce aircraft noise exposure contours that are as smafl as possibe Decision makers
reviewing environmenta impact disdosure documents require accurate and unbiased
information even when noise modeflng assumptions that the Navy characterizes as
conservative Le average busy day do not suit the Navys preferences for gaming the system
by manipuating the size of aircraft noise exposure contours
The Navys further contention that common measure that is common set of
exposure assumptions is required because of interactions between Auft Fied and OLF
Coupevifle is equafly spurious The Navy coud as reasonaby have based its noise exposure
estimates on average busy day conditions at both airfieds
The Navys conduding argument that US Air Force poUcy currenty favors annua
average day rather than average busy day noise estimates is ikewise unpersuasive Unflke
the Navy the Air Force does not reguady conduct nighttime fied carrier anding practice
exercises at its airfieds The purpose of documentation prepared for NEPA is to disdose to
decision-makers actua noise impacts not to suit Air Force or Navy preferences for under- or
over-statement of noise exposure as may be convenient for various other reasons
Other Mis-Statements of Essentia Technica nformation
Appendix of the ES states that DNL has been determined to be reliable measure of
long-term community annoyance with aircraft noise and has become the standard noise metric
used by the FAA USEPA DoD Federal Interagency Committee on Noise American National
Standards Institute ANSI and World Health Organization among others for measuring noise
impacts.. The statement is partiafly correct but does not begin to inform readers of the
imitations of DNL-based predictions of community reaction to short term intermittent aircraft
noise exposure such as that created by nighttime FCLP operations
For exampe the ES does not inform readers that DNL is ony one of the noise metrics
that HCON considers revant HCON 1992 expUcity states that DNL is sometimes
GRROO1 65606
supplemented by other metrics to characterize specific effects on case-by-case basis.4 This
may include the cumulative metric of Leq Equivalent Sound Level for varying representative
time periods Single event metrics used for supplemental analysis may include SEL Sound
Exposure Level Third Octave Band Sound Pressure Level SPL Lmax A-weighted Maximum
Sound Level and TA Time Above expressed in minutes for which aircraft-related noise
exceeds specified A-weighted sound levels Other DNL-Uke variants such as CNEL and DENL
are commonly used in non-federal U.S jurisdictions and ekewhere for predicting community
response to transportation and environmental noise
More importantly however the boilerplate anguage of the ES misleadingly faik to
inform readers that not of the cited agencies which rely on DNL for measuring that is
predicting noise impacts agree on the same interpretive criteria for assessing noise impacts
The recent Word Heath Organizations Noise Guidelines for the European Region Guski et
aL 2018 WHO 2018 for instance adopts the equation below for estimating the percentage
of the residential population highly annoyed %HA by aircraft noise exposure
%HA -50.9693 1.0 168 Lden 0.0072 Lcien2
At an Lden value of 65 dB an exposure level approximately decibel greater than DNL
value of 65 dB WHO predicts that about 46% of the residential population is highly annoyed by
aircraft noise FICON on the other hand predicts that only 12.3% of the population is highly
annoyed at the same noise exposure level Both the latest revision of the ISO 1996-12016
international technical consensus standard and the European Union predict that about 27%
29% of residential populations are highly annoyed by aircraft noise at the same exposure level
For NEPA purposes forthright defense of reliance on long-term cumulative
measures of noise exposure to predict adverse community reaction would clearly distinguish
between the measure itself and the interpretive criteria that the sponsor of proposed action
applies to the noise metric
The Navys ES misleads readers and fails to meet the requirements of NEPA by
Recall that for NEPA purposes noise exposure estimation is merely means to an end prediction of
noise impacts It is difficult to imagine case that merits closer examination than predicting noise impacts for FCLP
operations on the basis of annual average day noise exposure calculations FCLP operations violate all of the
conventional assumptions of annual average day noise exposure calculations They occur episodically rather than
day-in/day-out are intermittent on long-term basis rather than continuous are often conducted during
nighttime hours and principal noise impact of FCLP flights sleep disturbance is atypical of the effects of the
Navys customary weekday/daytime flight operations
GRROO1 65607
reying on obsoete and incorrect information to define the significance of aircraft
noise impacts in vioation of NEPA requirements for basing impact disdosures on the
best avaiabe scientific information about aircraft noise effects
ignoring that more recent dosage-response reationships indicate far greater
annoyance prevaence rates than the 1992 HCON rationship predicts at the same
aircraft noise exposure eves and
using definition of significant noise impact that is an arbitrary non-technica one
that has nothing to do with any particuar dosage response reationship and in fact
antedates the 1992 HCON reationship by four decades as expained by Fidefl 2015
REFERENCES
European Commission 2002 TPosition paper on dose response relationships between
transportation noise and annoyanceT Luxembourg Office for Official Publications of the
European Communities
Federal Interagency Committee on Noise 1992 Federal Agency Review of Selected Airport
Noise Analysis Issues Report for the Department of Defense Washington DC
Fidell 2003 The Schultz curve 25 years later research perspective Acoust Soc Am 1146
pp 3007-3015
Fidell Mestre Schomer Berry Gjestland Vallet and Reid 2011 first
principles model for estimating the prevalence of annoyance with aircraft noise exposure Acoust Soc
Am 1302 791-806
Fidell 2015 Review of U.S Aircraft Noise Regulatory Policy Acoustics Today 11 26 34
Guski Schreckenberg and Schuemer 2018 WHO Environmenta Noise Guideflnes for
the European Region Systematic Review on Environmenta Noise and Annoyance nt
Environ Res Pubflc Heafth 2017 14 1539 doi1O.3390/ijerphl4l2lS39
International Organization for Standardization ISO 2016 Acoustics Description
Measurement and Assessment of Environmental Noise Part Basic Quantities and
Assessment Procedures Geneva Switzerland
Miedema and Vos 1998 Exposure-response relationships for transportation noise

Acoust Soc Am 104 34323445
Miedema Oudshoorn 2001 Annoyance from transportation noise Relationships with
metrics DNL and DENL and their confidence intervals Environmental Health vol 109
GRROO1 65608
World Health Organization 2018 Environmental noise guidelines for the European region
Copenhagen Denmark WHO Regional Office for Europe
GRROO1 65609
MiIord Wayne Donaldson FAIA
Chairman
Leonard Forsman
Vice Chairman
John Fowler
Executive Director
Preserving Americas Herita9e
Febmary 19 2019
Honorable Richard Spencer
Secretary of the Navy
1000 Navy Pentagon
Washington DC 20350-1000
REF Proposed Increase ofAircraft and Aircraft Operations and Development of Support Facilities

Island County Washington
Dear Mr Secretary
In accordance with Section 106 of the National Historic Preservation Act 54 U.S.C 306108 NHPA and
its implementing regulations Protection of Historic Properties 36 CFR Part 800 am writing to convey to
you the final comments of the Advisory Council on Historic Preservation ACHP regarding the Department
of the Navys Navy proposed increase of EA-18G Growler aircraft and aircraft operations and development
of support facilities at Naval Air Station Whidbey Island undertaking On November 30 2018 the Navy
terminated the Section 106 consultation having determined that further consultation to reach an agreement
was unlikely to be productive In accordance with 36 CFR 800.7 the ACHP is providing these comments
which you must consider before reaching final decision on the undertaking
This has been challenging case for the ACHP as well as the Navy and the numerous consulting parties
Balancing the operational needs of the Navy to meet its paramount national security mission and readiness
requirements with the important historic values present in the Central Whidbey Island Historic District which
embraces the unique National Park unit Ebey Landing National Historical Reserve demands efforts that
transcend mere procedural compliance with the NHPA It is the ACHPs sincere hope that you will accept and
follow the ACHPs recommendations in that spirit
Background
Naval Air Station Whidbey Island NASWI is home to all Navy electronic attack squadrons flying the EA
8G Growler aircraft in the United States The Navys tactical Electronic Attack functions have been
performed almost exclusively at NASWI since 1970 Ault Field provides facilities and support services for
nine carrier squadrons three expeditionary squadrons one expeditionary reserve squadron one training
squadron and an Electronic Attack Weapons School for total of 82 aircraft The Navy is the only U.S
military service to maintain an Electronic Attack aircraft capability and is required to preserve and cultivate
the expertise and knowledge of the Growler community The Navy has indicated that Section 5062 of Title 10
of the United States Code requires it to carry out the undertaking in order to maintain and expand Growler
operational readiness to support national defense requirements
ADVISORY COUNCIL ON HISTORIC PRESERVATION
401 Street NW Suite 308 Washington DC 20001-2637

Phone 202-517-0200 Fax 202-517-6381 achp@achp.gov www.achp.gov
GRROO1 67458
The Navy has determined that Outlying Landing Field OLF Coupeville an integral part of operations at Ault
Field provides the most realistic training for field carrier landing practice FCLP as well as training for
search-and-rescue and parachute operations and has continuously used OLF Coupeville for FCLP since the
late 1960s The altitude above ground at which the BA-18G Growler aircraft fly the landing pattern at OLF
Coupeville closely replicates the altitude of the aircraft carrier landing pattern OLF Coupeville is located on
200-foot ridge surrounded by flat terrain similar to how an aircraft carrier is situated at sea The Navy has
concluded that practicing at an altitude which simulates the carrier environment is essential for pilots preparing
to land on an aircraft carrier because such practice matches the visual cues as well as the required power
settings needed to fly safe approach for an actual landing on an aircraft carrier
In 2013 the Navy began exploring the introduction of additional BA-i 8G Growler squadrons to continue and
expand its existing community in order to provide an increased and flexible electronic attack capability to
address future threats and missions The Navy has determined that maintaining and expanding BA-i 8G
Growler operational readiness supports the Navys national defense requirements under Section 5062 of Title
10 of the United States Code Congress authorized the purchase of additional BA-i8G Growler aircraft in 2015
and 2016 to support the Navys mission
The Undertaking
In order to increase BA-i 8G Growler capacity and meet current and future mission and training requirements
the Navy plans to
Continue and expand existing BA-i 8G Growler operations at the NASWI complex which includes
FCLP by BA-i8G Growler aircraft at Ault Field and OLF Coupeville

Increase tactical Blectronic Attack capabilities by adding 35 or 36 aircraft for grand total of 117 or
118 BA-i8G Growler aircraft to support an expanded Department of Defense mission for identifiying
tracking and targeting in complex electronic warfare environment
Construct and renovate facilities at Ault Field to accommodate and support the additional BA-i 8G
Growler aircraft and
Station additional personnel and their family members at the NASWI complex and in the surrounding
community
Ault Field would support 88000 total airfield operations takeoffs and landings which represents an increase
of 9800 annual operations over current conditions OLF Coupeville would support 24100 annual operations
which represents an increase of 17590 operations per year While there would be an increase in operations at
both airfields Ault Field would still

support four times the number of total aircraft operations than OLF
Coupeville The implementation of this undertaking will result in significantly increased noise impacts from
aircraft operations in some cases with noise levels exceeding 90 decibels dB at number of historic sites
For example operations with 90 dB levels will quadmple at locations such as Reuble Farm contributing
resource to the Central Whidbey Island Historic District
Historic Properties
The Navy has identified numerous historic properties within the Area of Potential Bffects APB for this
undertaking These include the Central Whidbey Island Historic District CWII-ID listed in the National
Register of Historic Places on December 12 1973 which is located partially within OLF Coupeville The
current nomination includes in private and public ownership 103 contributing buildings six sites 286
stmctures and one object The District is significant under National Register criteria and with period
of significance from 1300 to 1945 with areas of significance in agriculture architecture commerce
recreation/tourism ethnic heritage explorationlsettlement education religion military and politics and
government The APB also includes 10 landscapes contributing to the significance of the CWIHD Bbeys
GRROO1 67459
Prairie Crockett Prairie Smith Prairie San de Fuca Uplands Fort Casey Uplands East Woodlands West
Woodlands Penn Cove Coastal Strip and Coupeville The land area of the historic district currently includes
approximately 17400 acres
The Ebeys Landing National Historical Reserve ELNHR or Ebeys Reserve boundary is identical to the
CWIHD boundary Established under Section 508 of the Parks and Recreation Act of 1978 the ELNHR was
created to preserve and protect mral community which provides an unbroken historic record from.. 19th
century exploration and settlement in Puget Sound to the present time The reserve is the only historical
reserve in the National Park System ELNHR was created to be managed through partnership between the
local community and government agencies with administrative management carried out by Tmst Board The
four managing partners of Ebey Reserve are the National Park Service NPS Washington State Parks
Island County and the Town of Coupeville Approximately 85 percent of the land within the reserve is
privately owned with the rest combination of local state and federal ownership
The Section 106 Process
The Navy initiated Section 106 consultation in October 2014 Consulting parties include the Washington State
Historic Preservation Officer SHPO the Island County Commissioners Districts and the Town of
Coupeville NPS the Tmst Board of Ebeys Reserve Washington State Parks Seattle Pacific University Mr
David Day and the Citizens of Ebey Reserve The Navys efforts to identify consulting parties included
outreach and notification to potentially interested Indian tribes that resulted in no requests by any of the tribes
to become consulting parties The ACHP elected to participate in consultation in December 2014
Tn 2016 the Navy proposed an APE to consulting parties Consistent with past practice the Navy proposed to
define the auditory effects component of the APE as those areas on and off the installation within the 65 dB
Day Night Sound Level DNL noise contour that result from air operations at NASWI This DNL is
commonly used by other federal agencies including the Federal Aviation Administration as the metric used to
assess noise effects on communities The 65 dB threshold is typically considered acceptable for most land
uses and it is the ACHPs experience that agencies commonly determine it to be reasonable threshold below
which historic properties are usually not affected
After discussing with the ACHP and the SHPO and taking into account comments made by consulting parties
and those received under the National Environmental Policy Act NEPA that the original APE was too small
the Navy expanded the APE in July 2017 based on an updated noise analysis using the latest approved noise
model for the 65 dB DNL This expansion included all of ELNHR to ensure all potential effects to the CWII-ID
were fully evaluated
Tn October 2017 the Navy informed consulting parties that it was extending its environmental review to
conduct additional analysis to incorporate changes to training requirements that may reduce impacts to local
communities The changes were based on the introduction of new landing technologies that would reduce the
Navys requirement for FCLP and result in fewer operations and personnel than previously projected This
would also result in possible revisions to noise modeling if necessary
Tn June 2018 the Navy determined that the increased frequency of noise exposure would result in adverse
effects to characteristics of the CWIHD that currently make it eligible for listing in the National Register of
Historic Places Although the effects would be intermittent the Navy determined the proposed undertaking
would result in an increased occurrence of noise exposure affecting certain cultural landscape components in
the historic districtspecifically the perceptual qualities of five locations that contribute to the significance of
the landscapes The Navy found no other adverse effects to historic properties from the proposed undertaking
While not accepted by all consulting parties the SHPO concurred with this finding
GRROO1 67460
Tn July 2018 the Navy began consulting on measures to mitigate the adverse effects Consulting parties
considered multitude of mitigation measures ranging from the modification of aircraft engines to quiet the
noise to installing information kiosks regarding the ELNHR During this consultation in September 2018 the
Navy released its Final Environmental Impact Statement FEIS under NEPA By November 2018 the ACHP
was aware that the Navy was concerned it may not be able to reach agreement with the SHPO and execute
Memorandum of Agreement The ACHP worked with representatives from the Navy and the SHPO to identify
set of measures that would be acceptable to required signatories The final set of measures the Navy
proposed were as follows
Providing NPS with funds not to exceed $1 million to support preservation projects that enhance the
landscape integrity of the Ebeys Prairie landscape one of the five identified landscape components of
the CWIHD by preserving and protecting the Ferry House and an associated cluster of outbuildings
and stmctures The Ferry House is an iconic building located at Admiralty Inlet and owned by the
NPS
Seek partnership opportunities through the Readiness and Environmental Protection Integration
REPI Program to support the creation of scenic easements and
Communicate to NASWI personnel that volunteer opportunities exist in ELNHR
The SHPO informed the Navy on November 29 2018 that it would not be signing the agreement with the
mitigation as proposed by the Navy Soon after the Navy determined that further discussions would no longer
be productive and terminated Section 106 consultation through letter conveyed to the ACHP on November
30 2018
As part of developing its comments to the Navy ACHP staff hosted public meeting on December 19 2018
in the Town of Coupeville to solicit public input ACHPs website also provided information on
The the
termination and requested public comment The ACHP received more than 250 comments regarding the
proposed undertaking from consulting parties members of the public and member of Congress The ACHP
was originally required to submit its comments to the Navy on January 14 2019 However due to lapse in
appropriations starting on December 22 2018 all ACHP employees were furloughed and the ACHPs
timeline to provide final comments was suspended until appropriations were approved on January 26 2019
making its deadline for submitting these comments Febmary 19 2019
ACHP Findings
The ACHP has no basis to question the Navy determination that it must meet operational
requirements by expanding existing EA-18G Growler operations at NAS WI
Some consulting parties and many members of the public have expressed concern about the impact of
increased noise on historic properties within and near the APE and urged the Navy to station EA-18G
Growlers elsewhere possibly at multiple installations Recognizing the importance of considering alternative
locations as way to avoid or minimize affects to historic properties from the undertaking as key part of the
Section 106 review process the ACHP sought an explanation regarding the decision and the rationale for
having the EA- 8G Growlers stationed at NASWI during the consultation

process The Navy clarified that the
need and requirements for tactical Airborne Electronic Attack platform can only be met by the EA-18G
Growler and that the relocation of such squadrons away from NASWI and to another installation would incur
significant costs increase operational risk associated with potential timeline impacts of relocation and reduce
operational synergies associated with single-siting the Growler community Additionally the United States
Senate Committee of Armed Services Report for the FY20 17 National Defense Authorization Act references
the EA-18G Growler as the nations only tactical Airborne Electronic Attack platform There is nothing in the
record of the Section 106 proceedings that gives the ACHP basis to contradict the Navys conclusions
GRROO1 67461
regarding these operational requirements and the suitability of NASWI to meet them
Disagreements regarding the APE that complicated the consultation can be resolved through further
monitoring of noise impacts if expanded operations go forward
The ACHP received several comments pertaining to the APE as defined by the Navy as being too narrow in
scope having excluded Port Townsend Fidalgo Island the San Juan Islands Camano Island and the Olympic
Peninsula and having relied on the 65 dB DNL contour line The ACHP provided comments in 2016
recommending that the Navy draw the APE as broadly as possible to take into account both direct and indirect
effects of the undertaking The ACHP understands that using the 65 dB DNL is metric commonly used by
federal agencies to assess noise effects on communities and provide the threshold of noise no longer being
acceptable At the same time rigid adherence to such standard may not provide the most effective way to
address indirect and intangible effects that may in the long mn harm historic properties In response to
comments from the SHPO ACHP and consulting parties the Navy did expand the APE and consultation then
progressed to the resolution of adverse effects
The ACHP recognizes that the use of the 65 dB DNL metric may not effectively measure the human
perception of noise impacts by calculating projected average between the unusually loud single event noise
levels and the unusually quiet ambient noise levels This is particularly true when the potential adverse effects
on historic properties are not direct physical impacts but are dependent upon the perception and resultant
behavior of residents property owners businesses and visitors Predicting and measuring such effects can be
elusive until the expanded operations are actually underway Continued monitoring and evaluation can provide
the necessary information for developing and implementing long-term minimization and mitigation strategies
for the important historic resources
Foreseeable adverse effects were considered by the Navy but further study is advisable the
expanded operations are pursued
Some consulting parties and members of the public expressed concern that the Navy did not adequately
identify and address adverse effects to the economy of Whidbey Island specifically in the agricultural and
tourism industries in its evaluation of increased operations at OLF Coupeville Section 106 requires an agency
to take into account adverse effects to historic properties including those that may be reasonably foreseeable
The Navy considered whether the proposed changes in operations at OLF Coupeville have the potential to
introduce auditory visual and atmospheric characteristics that could cause effects to historic properties Based
on current information other effects such as property owners not investing in rehabilitation or maintenance of
buildings or stmctures or complete abandonment of properties may be possible but are not reasonably
foreseeable at this time While not required to meet the procedural requirements of Section 106 in this case
prior to the approval of the proposed undertaking the ACHP believes further study is warranted to assess
whether these effects on historic properties become probable rather than possible or actually occur if the
undertaking is approved and flight operations are expanded as proposed This will improve the evaluation of
effects of this nature
Mitigation measures negotiated in accordance with Section 106 procedures reached an impasse due
to disagreement on appropriate mitigation and time constraints
The ACHP received numerous comments that mitigation proposed by the Navy was inadequate in relation to
the adverse effects of increased EA- 8G Growler operations Many commented that no amount of mitigation
was adequate and that avoidance i.e not increasing operations at all was the only alternative plausible for
the Navy to consider The Section 106 process requires federal agencies to consider alternatives to avoid
minimize or mitigate adverse effects but does not mandate specific measures or prescribe any substantive
GRROO1 67462
standard to determine the adequacy of such avoidance minimization or mitigation actions After the Navy
proposed providing funding for preservation projects outside of its jurisdiction consulting parties were unable
to agree on which projects could or should be considered for funding or what amount was adequate While
the ACHP did opine on appropriate mitigation measures up to and just prior to termination the
recommendations below contain the ACHPs most current and complete advice on those and other measures it
believes appropriate to resolve adverse effects to historic properties and provide long-term stewardship of the
historic properties it
may affect by this undertaking
Challenges in the coordination of the Section 106 and NEPA review processes complicated timelines
for consultation
The ACHP noted several instances where the continuity and flow of Section 106 consultation was affected by
the decisions made by the Navy as part of its NEPA review Pauses in Section 106 consultation created
confusion among some consulting parties while others were unclear about the scope of Section 106 and
NEPA reviews In October 2017 consulting parties were informed that the Navy was updating the noise
analysis under NEPA to incorporate changes to the Navys operational training requirements and would
consult on changes to the APE and inventory once the update was complete Consulting parties were not re
engaged by the Navy until June 2018 when it issued letter amending the APE and inventory updated the
proposed undertaking and provided its finding of adverse effect for the CWIHD By July 2018 consulting
parties were made aware of the Navys desire to conclude the Section 106 consultation process with an
executed Memorandum of Agreement no later than October 2018 in order to meet its NEPA timeline which
left three months for consulting parties to consider and discuss alternatives to avoid minimize or mitigate the
adverse effect The discussion regarding alternatives to avoid minimize or mitigate was severely limited
given timelines for concluding the NEPA process
Finally the FEIS was released after the Navys findings of effects under Section 106 and therefore was
informed by such findings However the ACHP believes it is preferable for agencies to refrain from issuing an
FEIS until the Section 106 process has concluded Doing so better enables an agency to address both the
effects on historic resources and steps being taken to resolve them in the FEIS
Recommendations
While the Navy used generally accepted modeling and sound impact averages to assess adverse effects the
nature of auditory effects on historic properties is such that they are highly difficult to predict using rigid
standards of decibel noise levels Addressing the actual impacts on historic properties would benefit from
further refinement based on the results of sound monitoring of expanded operations should they commence
The Navys long-term stewardship of historic properties potentially affected by this undertaking would
therefore be well served by collaborating with local stakeholders to monitor how increased noise events
actually end up affecting tourism and investment in preserving historic properties in the area and impact those
characteristics that contribute to the historic significance of the CWII-ID Building such collaborative
relationship is in the best interests of the Navy NPS interested Indian tribes the SHPO local government and
citizens to promote the long-term preservation and vitality of the unique historic resources of the CWII-ID
In order to achieve these and other goals the ACHP provides the following recommendations if the Navy
go forward with expanded operations as proposed

elects to
The Navy working with the stakeholders should undertake additional efforts to monitor and as
needed develop measures for addressing effects to the affected historic properties
The ACHP recommends that the Navy collaborate with identified consulting parties from this Section 106
consultation federally recognized Indian tribes or other organizations or individuals with interest in identified
GRROO1 67463
historic properties to develop noise monitoring program to measure actual direct and indirect effects
including cumulative effects of operations to historic properties namely the CWIHD in order to have fuller
understanding of effects and measures to address them Such monitoring may lead to the finding and
resolution e.g perhaps through possible repairs or sound reduction measures of unanticipated effects on
historic properties during implementation of the undertaking as set forth in the Section 106 implementing
regulations at 36 CFR 800.13b As is the case with almost all Section 106 agreements the last draft of the
Section 106 agreement that was being negotiated for this undertaking included provision for such post-
review discoveries
During this monitoring the Navy should give special attention to physical impacts on historic properties and
effects to the intangible historic and cultural values of the CWIHD to further understand how property owners
and tourists interact with historic properties on Whidbey Island The ACHP also recommends that the Navy
collaborate with NPS the SHPO and the Trust Board of Ebeys Reserve to update the CWIITTID nomination
given the passage of time of both the original nomination with amendments and the designation of ELNHR
in order to best understand character defining features This action should be carried out early enough to refine
the Navys understanding of specific effects to historic properties and put in place appropriate measures to
mitigate them
The Navy should commit to carrying out mitigation measures in further discussions with stake holders
The ACHP recommends that the Navy work with the previously identified stakeholders to develop suitable
mitigation measures based on the results of the recommended ongoing monitoring of impacts on the historic
properties The Navy should be open to providing funds to support such measures with the goal of advancing
the long-term preservation of the historic characteristics of the CWII-ID While consultation just prior to the
Navys termination of Section 106 consultation focused on efforts to provide funding to NPS for rehabilitation
activities at the Ferry House the ACHP believes that broader range of support should be considered The
Navy should also examine creative means of funding and carrying out such measures including exploring
partnerships with the Department of Defenses Office of Economic Adjustment and the ACHP which
possesses potentially useful authorities to achieve these goals including some that may allow the Navy to
provide funds through the ACHP to an organization it

may not otherwise be able to provide funds to
directly
The Navy should pursue innovative partnerships and techniques to promote the long-term
preservation of affected historic properties
The ACHP recommends that the Navy work with the stakeholders to identify future operational and
development plans that may affect historic properties and to explore opportunities through the REPI Program
to support creation of conservation easements possibly in cooperation with the Whidbey Camano Land Trust
The ACHP further recommends that the Navy collaborate with the stakeholders to evaluate the benefits of
designating historic landscapes within the APE as Sentinel Landscapes to enhance the long-term protection
and management of these important resources The Sentinel Landscapes program is jointly managed by the
Departments of Defense Agriculture and the Interior and identifies places where preserving the working and
rural character of key landscapes strengthens the economies of farms ranches and forests conserves habitat
and natural resources and protects vital test and training missions conducted on those military installations
that anchor such landscapes Such added protections may benefit both the Navy mission and the protection of
historic properties
The Navy should pursue additional noise minimization measures and adopt feasible noise-reducing
technologies for EA-18G Growler operations based on the recommended ongoing evaluation of the
nature and extent of effects to hi storic properties from aircraft noise
GRROO1 67464
The ACHP recommends that the Navy work with the stakeholders to continually review operational
procedures to identify potential changes that reduce noise such as restricting hours of flight operations while
supporting mission execution The Navy should evaluate current policies that might impede its ability to
provide support to the local community regarding noise compatibility using the Federal Aviation
Administrations Residential Sound Insulation Program 14 CFR Part 150 Airport Noise Compatibility
Planning as model An example of this is the San Diego County Regional Airport Authoritys Quieter
Home Program The Authority works with property owners within the 65 dB level contour map around San
Diego International Airport to determine if they are eligible for sound insulation treatments to mitigate aircraft
noise Over the longer term the Navy should pursue the development and implementation of new noise
suppression technologies and landing software with the goal of minimizing the impact of aircraft operations on
the affected historic properties
The Navy should better coordinate environmental and historic preservation reviews
The ACHP recommends that the Navy evaluate its efforts in this consultation to coordinate its NEPA and
Section 106 reviews to determine where improvements can be made in the future to reduce confusion about
the scope of each review and ensure that Section 106 determinations and findings have the maximum potential
to inform decisions made under NEPA This review should be informed by the joint handbook issued by the
ACHP and Council on Environmental Quality titled NEPA and NHPA Handbook for Integrating NEPA and
Section 106 Reviews
Conclusion
The ACHP urges the Navy to accept and carry out these recommendations should it determine to implement
the undertaking in location Section 800.7c4 of the Section 106 regulations as the head of
this requires you
the agency to take these comments into account in reaching final decision on the undertaking As required
by Section 1101 of the NTTPA 54 U.S.C 306114 you may not delegate this responsibility summary of
decision regarding the undertaking that contains the rationale for the decision and evidence of
your
consideration of the ACHPs comments must be provided to the ACHP prior to the approval of the
undertaking and shared with the Section 106 consulting parties and the public
You and have an obligation as federal agency leaders to advance the policies that the Congress set forth in
the NHPA directing that the federal government exercise leadership in the preservation of the nations
irreplaceable cultural heritage In that spirit hope you will see these recommendations as wise path
forward can assure you that the ACHP would welcome the opportunity to work with the Navy and the
stakeholders to achieve the accommodation of important historic preservation values as the Navy carries out
its essential mission
look forward to your response
Milford Wayne Donal4tson FAIA

Chairman
GRROO1 67465
THE SECRETARY OF THE NAVY

WASHINGTON DC 20350-1000
March 82019
Mr Milford Wayne Donaldson FATA

Chairman
Advisory Council on Historic Preservation

401 Street NW Suite 308
Washington DC 20001-2637
Dear Mr Donaldson
Thank you for providing the Advisory Council on Historic Preservations

ACHP
comments of February 19 2019 on the Navys proposed increase of EA-l8G Growler airfield
operations at Naval Air Station NAS Whidbey Island Complex greatly appreciate the
ACUPs substantial involvement throughout this complex consultation and your leadership to
develop and provide guidance to all parties
In accordance with Section 106 of the National Historic Preservation Act NHPA and
implementing regulations at 36 800 7c4 have given serious consideration to each
of your comments as well as the concerns expressed by consulting and the public
parties
understand and appreciate your findings and recommendations and have taken them into account
in reaching my decision to move forward with the undertaking to include adopting some of your
recommendations as described below summary of the rationale decision follows
for
my and
also be documented
will in the National Environmental Policy Act NEPA Record of Decision
ROD
In careful consideration of the nature of the proposed undertaking the
Navy consuhed
with the Washington State Histonc Preservation Officer SHPO Indian tribes representatives
of local government the ACHP and other interested individuals and from October
organizations
2014 until
terminating consultation on November 30 2018 As part of that process the Navy
defined the Area of Potential Effect APE to mclude on-installation direct effect
areas on- and
areas and the Ebey

off-installation indirect effect National Historical Reserve
Landing
ELNHR The Navy consulted on the scope of the APE and provided the public and consulting
parties with detailed effects determination The Navy determined that although intermittent
the proposed mcreased Growler operations would result in adverse indirect effects to the Central
Whidbey island Histonc Distnct Histonc District by affecting the perceptual of five
qualities
locations that contnbute to the significance of the landscape The Navy found no other adverse
effects including no potential for direct effects on historic properties
The Navy provided these findings to the consulting parties and the public on June 25
2018 OnJune27 2018 the SHPO concurred with the which
Navys determination restated the
definition of the APE as well as the would have no
Navys determination that the undertaking
direct effects on historic The Navy continued
properties consultation to develop and evaluate
alternatives or modifications to avoid minimize or mitigate the adverse indirect effects to the
perceptual of the five identified locations Between June and November

qualities 2018 the Navy
GRROO1 67574
supported extensive opportunities for public participation in these discussions These
engagements were in addition to the NHPA discussions that had occurred throughout the Section
106 consultation process in coordination with the development of the Navys Environmental
Impact Statement EIS Unfortunately although The parties agreed on the adverse indirect
effects on histonc
properties expected to result from the undertaking an impasse on the type and
amount of commensurate mitigation precluded reaching agreement on mitigation
After reviewing your comments on the Navy termination and relevant consultation
documentation below is my response to the points raised in your letter
The Navy working with the stake holders should undertake additional efforts to
monitor and as needed develop measures for addressing the effects to the affected
historic
properties
The Navy conducted robust analysis of the potential effects to historic properties in the
NHPA Section 106 consultation and as part of the EJS The June 2018 Determination of Effect
documents the finding that the undertaking would not affect

directly historic properties but
would indirectly affect the perceptual qualities of five locations The SI-IPO concurred in this
analysis on June 27 2018 The analysis of potential effects employed noise modeling which is
the commonly accepted methodology for assessing potential noise impacts on communities
Noise modeling incorporates actual noise measurements allows action proponents to assess and
compare vanous operational alternatives and has been validated in court The Navys noise
analysis findings were reinforced by noise measurements taken by the National Park Service
NPS in the ELNHR that closely correlate with results from the Navys noise modeling In
addition operational conditions resulting from the proposed action at ELNHR would be similar
to levels that occurred at the time the Historic District was listed on the National Register of
Historic Places in 1973 and the ELNHR was created in 1978 For these reasons decline to
implement additional noise monitoring efforts also decline the ACHP recommendation to
undertake further study of effects on the Historic District from private property owners
abandomng or not investing in rehabilitation or maintenance of buildings or structures or
complete abandonment of properties which the ACHP acknowledges are not reasonably
foreseeable at this time
Should the Navy modify its undertaking in manner that substantially changes the
effects or should we become aware of significant new circumstances or information relevant to
environmental or historical concerns the Navy will notify the ACH and all consulting parties
and will
prepare supplemental environmental documentation or reinitiate Scction 106
consultation as necessary pursuant to the Navys responsibilities under the NHPA and the
NEPA Further pursuant to your recommendation the Navy will collaborate with the
community on any efforts to update the Historic District nomination and the designation of
ELNHR
The Navy should commit to carrying out mitigation measures in further discussion
with stakeholders
GRROO1 67575
The Navy worked diligently to identify mitigation measures acceptable to all
stakeholders before terminating consultation The impasse we reached with the consulting
parties precludes further productive discussion on identifying mitigation measures As

acknowledged by the ACHP for many stakeholders no amount of mitigation would be
acceptable as avoidance i.e not increasing operations at all is the desired outcome
Accordingly have decided to carry out the mitigation measures contained in the Navys final
offer as discussed below
Prior to termination the Navy received of potential

list Feny House preservation
projects from the NPS Based on the NPS preliminary cost estimate the Navy agreed to fund
up to $1 million worth of Ferry House preservation that meet the Secretary of the
projects
Interior standards for preservation Followmg termination the Navy reviewed and developed
more accurate cost estimate based on detailed descriptions of the projects Consistent with our
internal Navy cost estimate and in the spirit of honormg our previous offer have decided that
the Navy will provide $8 67K to the NPS to

support these Ferry House preservation projects In
addition the Navy will provide up to $20K to the NPS for the design construction and
installation of interpretive historical signs at appropriate locations
The Navy has the authonty to and will fund mitigation for the Ferry House via an
Interagency Agreement with the NPS Accordingly decline the ACHP recommendation to
examine other creative means of funding and carrying out these measures However strongly
support the communitys exploration of partnerships with the Department of Defense DoD
Office of Economic Adjustment OEA to advance the long-term preservation of the historic
characteristics of the Historic District such as through DoD OEAs Compatible Use Program
The Navy should pursue innovative partnerships and to the

techniques promote long-
term preservation of affected historic properties
agtee with your recommendation that innovative partnerships can promote the long-
term preservation of historic properties The Navy will seek partnership
opportunities through
the Readiness and Environmental Protection Integration REPI program by working with the
community to identify potential REP projects and communicating its
support for those projects
to decision-making officials in the DoD Thanks in large part to past Navy advocacy over $1 2M
of REP funds have been spent on Whidbey
Island the majority on projects in the Historic
District In addition the Navy is willing to collaborate with stakeholders to evaluate tIm benefits
of designating historic
landscapes within the APE as Sentinel Landscapes The Navy supports
Whidbey Island joining broader Sentinel Landscape effort combined with ongoing efforts in
the Hood Canal and at Naval Base Kitsap which Federal state and local partners are currently
coordinating for the Sentinel Landscape Committees
Coordinating consideration
The Navy should pursue additional noise minimization measures and adopt feasible
noise-reducing technologics for EA-JSG Growler operations
The Navys efforts to reduce noise impacts on the community are detailed in
Appendix
to the Final ElS and include limiting noise land use planning and management and noise
abatement operational These measures be sumnarized
procedures will in theROD One of our
GRROO1 67576
most significant mitigations is our commitment to employ the Precision Landing Mode a.k.a
Magic Carpet technology which when combined with reduction in the number of pilots per
squadron reduced the number of proposed aircraft operations under the preferred alternative as
identified in the Draft EIS by 30 percent Additionally the Navy remains committed to
implementing the measures identified in Appendix to the Final 1315 to minimize auditory
visual and atmospheric effects of flight operations on the surrounding community Lastly Navy
advocacy resulted in the recent appropriation of over $1 .9M to continue research on chevron
seals potentially viable noise-reducing technology commit to continued pursuit of

innovative technologies that reduce aircraft noise without reducing operational capability
The DoD has noise abatement program that has adopted many of the Federal Aviation
Administration FAA Part 150 strategies Appendix of the Fmal EIS descnbes the Navys
implementation of the DoD noise abatement program at NAS Whidbey Island The Navy does
not however have the statutory authority to implement the FAAs Residential Sound Insulation
Program that ACFIP references That program applies only to operators of public use airports
and is funded by money collected from passenger air fees at those airports that are eligible to
receive Airport Improvement

Program grant funds Those funds are not available to the Navy
The Navy should better coordinate environmental and historic preservation reviews
agree that careful coordination of environmental and historic preservation reviews is
essential and we rely ACHP and SHPO to help ensure

on pubhc stakeholders understand all the
scope of review under NHPA and NEPA The Navy fully

complied with the regulatory
800.8 for coordinating the NEPA
process with the NHPAs
requirements of 36 C.F.R
requirements and sought extensive public engagement throughout the four-year consultation
process The Navy recogmzed the for confusion between the two processes
potential early on
and made every effort to clarify and explain the purpose and scope of each review throughout the
consultation As an example during NEPA re-scoping meetings Fall 2014 the Navy provided
information on both of the Section 106 process in
processes including description relation to
the NEPA process which is allowed under the NIPA regulations
Throughout the NE-IPA consultation process the Navy was fully transparent with the
consulting parties regarding NIPA and NEPA

timehnes communicating updates to the APE and
the undertaking as soon as new information became available From August through October
2018 the Navy conducted consultation
six meetings and participated in numerous conference
calls and visits with consulting parties providing time for the parties to communicate their
unique concerns and discuss proposed resolution options
Although we strive to complete all consultations including NHPA Section 106

consultation before issuing Final EIS Navy policy is consistent with the joint ACHP-Council
on Environmental Quality Handbook which allows the conclusion of the Section
documenting
106 process in the ROD In this
case the Navy felt comfortable moving forward with
publication of the Final EIS without an
agreement onNFIPA mitigation because the impacts of
the undertaking were fully disclosed in the Final EIS and not in
dispute In addition felt it was
important to extend the consultation timeline beyond issuance of the Final LIS to maximize our
chances of reaching agreement on mitigation with the

consulting parties Nevertheless the Navy
GRROO1 67577
continually strives to improve its public outreach and relationships with surrounding local
coinnilunities and will evaluate the subject consultation to determine where improvements can be
made in the future
In conclusion there are number of issues on which we agree and thank you for the
ACHPs assistance in the Section 106
process Historic preservation has been important to the
Navy since the passage of the NHPA more than 50 years ago am committed to that
ensuring
the Navy remains with the local communities
good neighbor surrounding our installations
while at the same time meeting
urgent national defense priorities This concludes the NHPA
Section 106 process
copy of this rationale will be provided to all
consulting parties and to the
public
Sincerely
Richarfy Spencer
GRROO1 67578
DEPARTMENT OF DEFENSE
Department of the Navy
Record of Decision for the Final Environmental Impact Statement

ElS for EA-18G Growler Airfield Operations at Naval Air
Station Whidbey Island Complex Island County Washington
AGENCY Department of the Navy DoD
ACTION Record of Decision
SUMMARY The U.S Department of the Navy Navy after
carefully weighingstrategicthe
operational and environmental
consequences of the
proposed action announces its decision to
implement Alternative 2A the Preferred Alternative which adds

36 EA-18G operational aircraft at Naval Air Station NAS
Whidbey Island stations additional personnel and their family
members at the NAS Whidbey Island complex and in the surrounding
community constructs and renovates facilities at Ault Field
increases airfield operations at both Ault Field and Outlying
Landing Field OLF Coupeville and changes the distribution of
field carrier landing practice FCLP to 20 percent occurring at
Ault Field and 80 percent occurring at OLF Coupeville This
decision does not change the continuation of airfield operations
for other aircraft e.g
P-8A P-3C EP-3 MH-60 and
transients operating from the NAS Whidbey Island complex
The implementation of Alternative 2A includes measures intended

to reduce noise
impacts in the community including the
mitigation measures identified in Appendix of the Final ElS
and the use of Precision Landing Mode PLM a.k.a Magic Carpet
to reduce the overall number of FCLP5 compared to the number
proposed in the Draft ElS The Navy will continue to invest in
new technologies to reduce aircraft engine noise With respect
to mitigating impacts to the perceptual qualities of five
locations that contribute to the significance of the historic
landscape located within the Central Whidbey Island Historic
District the Navy will provide $867000.00 to the National Park
Service NPS to support preservation projects at the historic
Ferry House that meet the Secretary of the Interior standards
for preservation In addition the Navy will provide up to
$20000.00 to the NPS for the design construction and
installation of
interpretive historical signs at appropriate
locations The Navy will also seek partnership opportunities
through the Readiness and Environmental Protection Integration
REPI program by working with the community to identify
GRROO1 67640
potential REPI
projects and communicating its support for those
projects decision-making
to officials in the DoD Finally the
Navy will collaborate with stakeholders to evaluate the benefits
of designating historic landscapes within the Area of Potential
Effect APE as Sentinel Landscapes
With respect to regulatory requirements the Navy has and will

continue coordinate with appropriate federal regulatory and
to
state resource agencies and comply with appropriate permits and
reporting requirements
FOR FURTHER INFORMATION CONTACT U.S Navy Growler ElS Project

Manager Naval Facilities Engineering Command Atlantic Attn
Code EV21/SS 6506 Hampton Boulevard Norfolk Virginia 23508
SUPPLEMENTARY INFORM1TION Pursuant to section 1022 of

the National Environmental Policy Act NEPA of 1969 sections
4321 et seq of title 42 U.S.C Council of Environmental
Quality regulations parts 15001508 of title 40 CFR and
Department of the Navy regulations part 775 of title 32 CFR
the Navy announces its decision to implement Alternative 2A as
described in the Final ElS This decision will enable the Navy
to continue and expand existing EA-18G Growler operations at
theNAS Whidbey Island complex to increase electronic attack
capabilities by adding 36 operational aircraft to support an
expanded U.S Department of Defense DoD mission to construct
and renovate facilities at Ault Field to accommodate additional
Growler aircraft and to station additional personnel and their
family members at NAS Whidbey Island complex and in the
surrounding community The proposed action will enable the Navy
to augment the
Navys existing Electronic
communityAttack at
NAS Whidbey Island complex with additional aircraft in order to
provide Combatant Commanders with expanded electronic attack

capabilities to support our national defense requirements
consistent with the Navys responsibilities under Title 10
United States Code U.S.C Section 8062 In selecting which
alternative to implement the Navy carefully considered number
of factors including strategic the
operational importance and
of augmenting our nations electronic attack capabilities
ensuring quality of pilot training and balancing the impacts of
the proposed action on the human and natural environment
Appropriate mitigation measures consistent with operational
requirements and our Title 10
responsibilities also were
considered in order to potentially lessen the effects on all
surrounding communities
GRROO1 67641
BACKGROUND AND ISSUES NAS Whidbey Island complex has

supported naval aviation for more than 75 years and the Navys
tactical electronic warfare community for more than 45 years
The EA-18G Growler aircraft have been home based andoperating
from NAS Whidbey Island
complex since 2008 As result the
Navy has significant existing infrastructure and training ranges
that support the Growler in the Pacific Northwest In June
2013 the U.S DoD

Appropriations Act of 2014 Public Law No
113-76 added additional EA-18G Growler aircraft and necessary
funding to augment the Growler community In 2015 and 2016
Congress authorized and appropriated money for the purchase of
additional Growler aircraft
There are three types of Growler squadrons supporting DoDs

tactical airborne electronic attack mission carrier squadrons
which deploy from aircraft carriers and conduct periodic FCLP to
requalify to land on aircraft carriers expeditionary squadrons
including one reserve squadron which deploy to overseas land-
based locations and therefore do not normally require periodic
FCLP prior to deployment and the training squadron which is
also known as the Fleet Replacement Squadron FRS which is
responsible for post-graduate training Navy of pilots and

Naval Flight Officers In addition to being the home of the
Growler community Ault Field is the West Coast home of the
Maritime Patrol community operating P-3C and P-8A aircraft and
Fleet Air Reconnaissance squadrons operating EP-3 and three MH
60 search and rescue helicopters Flight operations of these
aircraft are not part of the proposed action but were considered
in this environmental analysis
Purpose and Need
The purpose of the Proposed Action is to augment the Navys

existing Electronic Attack community at NAS Whidbey Island
complex by operating additional Growler aircraft that Congress
has directed the Navy to purchase and operate The Navy needs
to effectively and
efficiently increase electronic attack
capabilities tocounter increasingly sophisticated threats and
to provide more aircraft per squadron to give operational
commanders more flexibility in addressing current and future
threats and missions The need for the Proposed Action is to
maintain expand Growler operational readiness to
and support
national defense requirements under Title 10 United States
Code Section 8062
GRROO1 67642
Public Involvement
Scoping
Notice of Intent to prepare an Environmental Impact Statement

EIS was published in the Federal Register 78 Federal Register
54635 on September 2013 which opened 139day initial
public scoping period from September 2013 to January
2014 15-day extension of the scoping period occurred between

January 13 and 31 2014 see Federal Register on January 17
2014 FR 3188 Following decision by the Chief of Naval
Operations springin request 2014
purchase to the of additional
Growler aircraft the Navy opened new 93-day scoping period on
October 2014 which included publication of revised Notice
of Intent in the Federal Register on October 10 2014 79 FR
61296 and an additional scoping period was announced in the
Federal Register and to local daily and weekly papers on
November 17 2014 79 FR 221 In addition to Federal Register
announcements multiple tools were used to notify the public and

interested parties of the scoping periods including newspaper
and digital advertisements in local daily and weekly papers
press releases publication on the project website as well as
phone calls to elected leaders and direct mailing of letters

and postcards to federal state and local agencies Native
American tribes elected officials and various groups most
likely to be interested in the proposed action Over the two
scoping periods total of
meetings eightin scoping were held
Coupeville Oak Harbor Anacortes Lopez Island and Port
Townsend Washington total of 1307 individuals attended the
eight scoping meetings and 3648 scoping comments were collected
during the open comment periods
Draft EIS
The Notice of Availability of the Draft ElS was published in the

Federal Register on November 10 2016 81 FR 79019 The Draft
ElS public comment period was open from November 10 2016 to
January 25 2017 Following requests from elected officials and
the public the comment period was extended from the initial
deadline of January 25 2017 to February 24 2017 In addition
to Federal Register announcements 82 FR 7822 on January 23
2017 and 82 FR 8185
January on 24 2017 the same tools that
were used to engage the public during the two scoping periods
were used to notify the public and interested parties of the
Draft ElS comment periods Printed copies of the Draft ElS were
also made available for public review at 22 local libraries In
total the public comment period comprised 105 days
GRROO1 67643
Draft EIS open house meetings were held between December and
December 2016 with 1013 individuals attending five meetings
in Oak Harbor Port Townsend Lopez Island Anacortes and
Coupeville Washington During the Draft EIS public comment
period the Navy received 4335 comments
In September 2017 the Navy announced delay in the release of

the Final ElS in order
changes to the proposed
to incorporate
action that could reduce noise impacts to local communities
The announced changes were based upon the accelerated
introduction of new PLM technology that would reduce the Navys
requirement for FCLP
Additionally the Navy announced two new
scenarios to determine how the distribution of FCLP operations
might affect noise impacts on the surrounding communities
These changes to the Final ElS analysis were announced in direct
response publicto comments received on the Draft ElS Because

the Preferred Alternative had not been determined at the time
the Draft ElS was released the Navy announced its Preferred
Alternative on June 25 2018 in advance of the publication of
the Final ElS
Final EIS
The Notice of Availability of the Final ElS was published in the

Federal Register on September 28 2018 83 FR 49089 and in
multiple local daily and weekly newspapers near the NAS Whidbey
Island complex The Final ElS addressed public comments
received during the Draft ElS public comment period It
contained updated information since the release of the Draft ElS
in November 2016 and identified Alternative 2A as the Preferred
Alternative The Navy announced the publication of the Final
ElS using the same public engagement tools used previously
during scopingfollowing the release of the Draft ElS
and The
Final ElS was mailed to all individuals agencies and
organizations that requested copy Printed copies of the
Final ElS were made available for public review at 22 local
libraries and made publicly available on the project website at
www.whidbeyeis.com The Final ElS 30-day wait period ended

October 29 2018
Alternatives Considered
In developing proposed range of alternatives that met the

the
purpose of and need for the Proposed Action the Navy reviewed
requirements for Growler squadrons and unit-level squadron
training in light of Title 10 responsibilities existing
training requirements and regulations existing Navy
infrastructure and Chief of Naval Operations guidance to
GRROO1 67644
support operating naval forces Operational mitigations

including incorporation of PLM and reduced number of pilots
were factored into all alternatives contained in the Final EIS
These factors reduced FCLP requirements by 30 percent when
compared to projections in the Draft EIS In addition the Navy
carefully considered public comments regarding the range of
alternatives and the effects of aircraft noise on the
surrounding community Specifically the Navy considered 10
additional alternatives related to moving some or all of the

Growler community and conducting FCLP practice elsewhere
However no other location has the facilities and functions
necessary to effectively preserve and cultivate the expertise

and knowledge base of the Growler community to support DoD
requirements In all the ElS fully analyzed 15 action
alternative/scenario combinations and for public transparency

carefully documented in Section 2.5 of the Final ElS the
rationale regarding the 10 additional alternatives that were
considered but not carried forward for detailed analysis
No Action
Alternative Under the No Action Alternative the
Proposed Action would not occur this means the Navy would not
operate additional Growler aircraft and would not add additional
personnel at Ault Field and no construction associated with the
Proposed Action would occur The No Action Alternative would
not meet purpose of or need for the Proposed Action
the
however conditions associated with the No Action
the
Alternative serve as reference points for describing and
quantifying the potential impacts associated with the proposed
action alternatives
Alternative Alternative would expand carrier capabilities

by adding three additional aircraft and additional squadron
personnel to each of the nine existing carrier squadrons and
augmenting the Fleet
Replacement Squadron FRS with eight
additional aircraft and additional squadron personnel net
increase of 35 aircraft 335 Navy personnel and 459 dependents
to the region
Alternative Alternative would expand expeditionary and

carrier capabilities by establishing two new expeditionary
squadrons adding two additional aircraft and additional
squadron personnel to each of the nine existing carrier
squadrons and augmenting the FRS with eight additional aircraft
and additional squadron personnel net increase of 36
aircraft 628 Navy personnel and 860 dependents to the region
GRROO1 67645
Alternative Alternative would expand expeditionary and

carrier capabilities by adding three additional aircraft and
additional squadron personnel to each of the three existing
expeditionary squadrons adding two additional aircraft and
additional squadron personnel to each of the nine existing
carrier squadrons and augmenting the FRS with nine additional
aircraft and additional squadron personnel net increase of 36
aircraft 341 Navy personnel and 467 dependents to the region
From purely operational perspective the Navy would prefer to

use OLF
Coupeville for all FCLP5 because it closely replicates
the pattern and conditions at sea and therefore provides
superior training However in an effort to balance the need
for effective training with community impacts the EIS analyzed
five operational scenarios for each force structure alternative
The percentages depicted are used for general description of the
scenarios
Scenario Twenty percent of all FCLP5 would be conducted at
Ault Field and 80 percent of all FCLP5 would be conducted at

OLF Coupeville
Scenario Fifty percent of all FCLP5 would be conducted at
OLF Coupeville
Scenario Eighty percent of all FCLP5 would be conducted at
OLF Coupeville
Scenario Thirty percent of all FCLP5 would be conducted at
OLF Coupeville
Scenario Seventy percent of all FCLP5 would be conducted at

OLF Coupeville
The above five scenarios and in combination

with the three force structure alternatives provide total of
15 action alternatives that are fully evaluated in the ElS
Preferred Alternative
The Navy announced the Preferred Alternative Alternative 2A on

June 25 2018
prior to release of the Final ElS The force
structure under Alternative adding 36 Growler aircraft to the
NAS Whidbey Island complex best meets operational demands by
GRROO1 67646
both establishing two new expeditionary squadrons and adding two

aircraft to each squadron that operates off aircraft carriers
Further Scenario was identified as the preferred scenario for
FCLP distribution because it provides the best training for Navy
pilots results in the least disruption of other aircraft
operations at Ault Field and results in the fewest number of
people being impacted by noise
The primary impact to the community from implementation of the

proposed action is an increase in noise exposure to residents
Therefore the environmentally-preferred alternative is defined
as the one with the smallest increase in number of people as
determined by an estimated percentage increase exposed to
annual noise levels of 65 A-weighted decibels dBA day-night
average sound level DNL or above Alternative 3A is the
environmentally-preferred alternative because it has the
smallest increase in number of people exposed to the 65 dBA DNL
or greater noise levels with an estimated 11.7 percent 1312
people Alternative 2A the Navys Preferred Alternative has
the next smallest increase of 11.8 percent 1316 people four
more than under Alternative 3A within the 65 dBA DNL or greater
noise contour For comparison Alternative 1E has the greatest
increase in number of people exposed to annual noise levels of
the 65 dBA DNL or greater noise contour with an estimated 16.8
percent increase 1879 people 567 more than under Alternative
3A
Environmental Impacts
The focus of the following discussion is on impacts associated

with the Preferred Alternative Alternative which proposes 2A
net increase of 36 Growler aircraft 628 Navy personnel and
860 dependents to the region
Airspace and Airfield Operations
Under Alternative 2A annual airfield operations at the NAS

Whidbey Island complex would increase up to 33 percent over the
No Action Alternative for an estimated total of 112100
operations annually including 88000 operations at Ault Field
and 24100 operations at OLF Coupeville Of the 24100
operations at OLF Coupeville 23700 would be EA-18G Growler
FCLP5 Since each airfield operation is defined as either
takeoff or landing under this scenario about 12000 FCLP
passes would occur annually Coupeville at OLF
change This
amounts to an increase
from approximately 90 hours percent of
total hours per year to 360 hours percent of total hours per
year in aircraft activity at OLF Coupeville
GRROO1 67647
Citizens of Ebey’s Reserve

Revision of October 2018 Comments on:
Residents & National Parks
--Revised February 27, 20191--
Final Environmental Impact Statement for EA-18G "Growler" Airfield Operations at
The following revises Citizens of Ebey’s Reserve (COER) October 2018 comments on
the Final Environmental Impact Statement (FEIS) for EA-18G "Growler" Airfield
Operations at Naval Air Station Whidbey Island (NASWI). They are update and are
additional to comments COER submitted on the draft EIS in February 2017. We have
not to date not found COER’s input on the draft EIS adequately considered or
thoughtfully addressed in the FEIS. Our review of the Navy’s response to all the
comments in Appendix M seemed to pretty much reflect the same talking points made
during the EIS drafting process, which basically messaged, “It’s our way, or your
highway.”
This set of comments on the impacts on residents and national parks (RN) is
accompanied by a separate file on the impacts on endangered species.
Addendum RN.1: Growler Engines
We understand Growlers, existing and yet to be delivered to NASWI, are equipped with
different engines: the F414 enhanced engine and F414-GE-400 series engine and the F404
engine. We further understand there is a significant difference in noise produced by these
different engines. The FEIS does not address which engine or combination of engines was used
in developing the noise contours presented in the FEIS. If the FEIS did not properly account for
the engine noise differences, the contours would not accurately reflect actual DNLs or other
noise metrics. [see, https://www.geaviation.com/sites/default/files/datasheet-F414-Family.pdf]

1
This February 2019 revision of the original October 2018
comment corrects several errors, updates a few areas, and adds two new addendum comments (RN 10 and 11)
GRR 171303

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Case 2:19-cv-01059-RAJ-JRC Document 36-2 Filed 02/13/20 Page 1 of 54

squadrons for several decades

NAS Whidbey Island

Numbers in parentheses denote decrease

1.3 Purpose and Need

out the AEA mission

GZXEDELINES EtR NOISE IMPACT ALYSI$

TECHNICAL REPOflT DATA

REPORT RECIPIENTS ACCESDIOMNO

PERFORMING ORGANIZATION RAME AND ADDRESS IC PHOGRAM ELEMENT NO

74 SPONSORING AGENCY CODE

the purpose of the guidelines proposed in this report is to provide decision-

The quantification lods recarnended for impact assessment in these

guidelines are further developnents of the Practional Impact t4ethaolcgy used

principal tynes of noise and viation environments are considered general

CEY WORDS AND DOCUMENT ANALYSIS

D55CRIPTORS b.IDENtIPIERSIOpSPj ENOED TERMS iCOS4TJ FicldCaup

Noise Lct Noise Effects

sigh-Energy Impulse Noise

WA mailing list tS 20 SECURItY LASSitIriSiJr nPRICZ

EPA ForrIt 22221 1Q72I

intnas ro zcis rcr insIs

Pcs3zcM cnrnz TC rrztt ccrcur tfl azrc

the purpose of the guidelines proposed in this report is to provide

comparative evaluations which constitute noise environment decisions The

procedures contained within the guidelines are applicable to the preparation

of environmental noise assessments Adherence to the procedures within the

guidelines is strictly voluntary The guidelines are neither mandatory nor

regulatory in intent Specific numbers which appear in the guidelines should

not be construed as standards nor are they intended to supplant locally

established community noise level Limits or decisions on envirommental ac

eptability with respect to noise as fostered by certain states municipali

ties or other governmental jurisdictions Instead the guidelines are

ffered here as simply tool to allow decisionmakers to consider tradeoffs

the guidelines are based on the deliberations of the Committee on Hear

ing Bioacoustics and Uiomechanics CHABA Working Group 69 National Academy

of Sciences NAS from 1972 to 1976 in response to request in 1972 by

the U.S Environmental Protection Agency EPA In early 1977 recommended

procedures were published by the National Acadcniy of Sciences in document

entitled Guidelines for Preparing Environmental Impact Statements on Noise

That document provided comprehensive set of procedures for specifying the

physical descriptions of environmental noise and vibration and methods for

assessing the degree of impact on people associated with these environments

The technical approaches proposed by NAS underwent several significant

changes during the period of CHABA working result of

working group deliberations public discussions and presentations at national

of practicality economy desired accuracy and specificity the working group

tried to be responsive to the numerous suggestions received from government

agencies industries and the scientific community The proposed procedures

activities or to efforts by individual members Many of thdse individual

been separately published in the meantime Similarly some agencies faced

guidelines in their publications those publications are included among the

referen as cited in the guidelines Some of the proposed methods contained

within the guidelines have been officially adopted by several agencies

institute ANSI Acoustical Standards Committees In summary the working

group tried to be responsive to all potential users concerned and tried to

reach cousensus wherever possible

Register 43 FR 28549 Both of these actions were taken to provide an oppor

tunity for additional viewpoints and expertise to be considered in proposed

revision the NAS report EPA then carried out detailed

the overall accuracy usage and general readability of the document

Conceptually the latest draft version of the guidelines contains the

same basic procedures delineated in the NAS guidelines published in 1977