Case 2:19-cv-01059-RAJ-JRC: 36-1 - Declaration of Zachary K. Griefen Exhibit 1

Case 2:19-cv-01059-RAJ-JRC Document 36-1 Filed 02/13/20 Page 1 of 122

NAS Whidbey Island Complex Growler FEIS Volume September 2018
Environmental Impact Statement for EA-18G Growler Airfield
Operations at the Naval Air Station Whidbey Island Complex
TABLE OF CONTENTS
ABSTRACT ABSTRACT-i
EXECUTIVE SUMMARY ES-i
NOISE AND HEALTH READERS GUIDE ES-is
OVERVIEW OF THE ENVIRONMENTAL IMPACT STATEMENT ES-23
ABBREVIATIONS AND ACRONYMS xxxix
PURPOSE OF AND NEED FOR THE PROPOSED ACTION i-i
i.i Introduction i-i
i.2 Location i-i
i.3 Purpose of and Need for the Proposed Action i-s
i.4 The Navys Electronic Attack Community at Ault Field and OLF Coupeville i-s
i.5 Scope of Environmental Analysis i-8
i.6 Key Documents i-iO
i.7 Relevant Laws and Regulations i-u
i.8 Agency Participation and Intergovernmental Coordination i-iZ
i.9 Public Participation Scoping 20i3 and Scoping 20i4 i-i3
1.9.1 Scoping Notifications 1-14
1.9.2 Sco ping Meetings 1-15
1.9.3 Scoping Comments 1-17
1.9.4 Summary of Scoping Comment Topics and Commenters 1-18
i.iO Public Participation Draft ElS Review i-2O
1.10.1 Draft Notifications 1-20
1.10.2 Draft Public Meetings 1-21
1.10.3 Draft Public Comments 1-24
1.10.4 Summary of Draft Comment Topics and Commenters 1-25
i.ii Public Participation Comment Themes i-28
1.11.1 General Topics 1-28
1.11.2 Airspace and Airfield Operations 1-30
1.11.3 Noise Associated with Aircraft Operations 1-31
1.11.4 Public Health and Safety 1-38
1.11.5 Air Quality 1-40
1.11.6 Socioeconomics 1-40
i.iZ Other Reports i-42
1.12.1 San Juan County Jet Aircraft Noise Reporting 2014 to present 1-43
1.12.2 Sandford Fidell Public Comment on the Significance Criterion Used for Noise
Impacts 2017 1-43
1.12.3 State of Washington Department of Health Public Comment 2017 1-47
1.12.4 Paul Schomer Public Comment on Aircraft Noise and Hearing Protection 2017 1-48
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1.12.5 Michael Shumans Report on the Economic Costs of the NAS Whidbey Island
Complex 2017 1-49
1.12.6 National Park Service Acoustical Monitoring Report for Ebeys Landing National
Historical Reserve 2016 1-51
1.12.7 Dahlgren Opinion Paper on the Public Health Impact of Aircraft Noise on Residents
in the Vicinity of Whidbey Island 2015 1-55
1.12.8 JGL Acoustics Inc Report on Whidbey Island Military Jet Noise Measurements
2013 1-58
1.13 Clarification and Changes to the Environmental Impact Statement 1-60
1.13.1 Executive Summary 1-71
1.13.2 Chapter Purpose and Need for the Proposed Action 1-71
1.13.3 Chapter Proposed Action and Alternatives 1-72
1.13.4 Chapter Affected Environment and Chapter Environmental Consequences 1-72
1.13 .4.1 Airspace and Airfield Operations 1-72
1.13 .4.2 Noise Associated with Aircraft Operations 1-72
1.13 .4.3 Public Health and Safety 1-74
1.13 .4.4 Air Quality 1-74
1.13.4.5 Land Use 1-75
1.13.4.6 Cultural Resources 1-75
1.13.4.7 American Indian Traditional Resources 1-76
1.13.4.8 Biological Resources 1-76
1.13 .4.9 Water Resources 1-76
1.13.4.10 Socioeconomics 1-76
1.13.4.11 Environmental Justice 1-77
1.13.4.12 Transportation 1-77
1.13.4.13 Infrastructure 1-77
1.13.4.14 Geological Resources 1-77
1.13.4.15 Hazardous Materials and Wastes 1-77
1.13.4.16 Climate Change and Greenhouse Gases 1-77
1.13.5 Chapter Cumulative 1-78
1.13.6 Chapter Other Considerations Required by NEPA 1-78
1.13.7 Chapter References 1-78
1.13.8 Appendices 1-78
PROPOSED ACTION AND ALTERNATIVES 2-1
2.1 Proposed Action 2-1
2.2 Development of the Range of Action Alternatives 2-2
2.3 Alternatives Carried forward for Analysis 2-4
2.3.1 No Action Alternative 2-4
2.3.2 Action Alternatives 2-4
2.3.3 Description of Alternatives 2-11
2.3.3.1 Aircraft and Personnel Loading 2-11
2.3.3.2 Aircraft Operations 2-12
2.3.3.3 Facility and Infrastructure Requirements 2-12
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2.4 Preferred Alternative 2-15
2.5 Alternatives Considered but Not Carried Forward for Further Analysis 2-16
2.5.1 Previously Scoped Alternatives 2-16
2.5.2 Moving Some or All of the Growler Community Aircraft Elsewhere 2-16
2.5.2.1 Single Siting the Growler Community at Ault Field 2-17
2.5.2.1.1 Operational Synergy 2-17
2.5.2.1.2 Proximity to Training Ranges and Special Use Airspace and
Electromagnetic Frequency Availability 2-17
2.5.2.1.3 Efficient Use of Existing Infrastructure 2-18
2.5.2.2 Relocating Growlers Elsewhere 2-19
2.5.2.2.1 NAS Lemoore Kings County and Fresno County California 2-19
2.5.2.2.2 Naval Air Facility El Centro Imperial County California 2-20
2.5.2.2.3 Naval Air Weapons Station China Lake Kern San Bernardino and lnyo
Counties California 2-20
2.5.2.2.4 NAS Oceana Virginia Beach Virginia 2-20
2.5.2.2.5 Marine Corps Air Station Cherry Point Craven County North Carolina 2-21
2.5.3 Conducting FCLP Elsewhere 2-21
2.5.3.1 Regional Military Airfields 2-21
2.5.3.2 Regional Civilian Airfields 2-21
2.5.3.3 Detachment Training Out of the Region 2-22
2.5.3.4 Construct New OLF 2-22
2.5.3.5 Anchor an Aircraft Carrier off the Coast 2-23
2.5.3.6 Exclusive use of Simulators 2-24
2.6 Summary of Alternatives Considered 2-24
AFFECTED ENVIRONMENT 3-1
3.1 Airspace and Airfield Operations 3-1
3.1.1 Airspace and Airfield Operations Regulatory Setting 3-2
3.1.2 Airspace and Airfield Operations Affected Environment 3-3
3.1.2.1 Airspace Classification and Flight Tracks 3-3
3.1.2.1.1 Ault Field 3-3
3.1.2.1.2 OLF Coupeville 3-5
3.1.2.1.3 Military Operations Areas 3-5
3.1.2.1.4 Military Training Routes 3-5
3.1.2.2 Airfield Operations 3-7
3.1.2.2.1 Average Annual Airfield Operations 3-13
3.2 Noise Associated with Aircraft Operations 3-15
3.2.1 Basics of Sound and the A-weighted Sound Level 3-15
3.2.2 Noise Metrics and Modeling 3-17
3.2.2.1 Day-night Average Sound Level 3-17
3.2.2.2 Equivalent Sound Level 3-19
3.2.2.3 Sound Exposure Level 3-19
3.2.2.4 Maximum Sound Level 3-19
3.2.2.5 Number of Events above Threshold Level 3-19
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3.2.3 Noise Effects 3-20
3.2.3.1 Annoyance 3-20
3.2.3.2 Speech Interference Indoor 3-20
3.2.3.3 Classroom/learning Interference 3-20
3.2.3.4 Sleep Disturbance 3-21
3.2.3.5 Outdoor Speech Interference Potential Noise Effects on Recreation and
Outdoor Activities 3-21
3.2.3.6 Potential Hearing Loss 3-22
3.2.3.7 Nonauditory Health Effects 3-23
3.2.3.8 Vibration Effects from Aircraft Operations 3-24
3.2.4 Noise Affected Environment 3-24
3.2.4.1 DNL Noise Contours 3-28
3.2.4.2 Existing Noise Mitigation 3-34
3.2.4.2.1 Noise Abatement Policy 3-34
3.2.4.2.2 Noise Complaint Process 3-35
3.2.4.2.3 Air Installations Compatible Use Zones Program 3-36
3.2.4.3 Supplemental Noise Analyses 3-36
3.2.4.3.1 Single Event Noise and Number of Events Above 3-38
3.2.4.3.2 Speech Interference Indoor 3-44
3.2.4.3.3 Classroom/learning Interference 3-46
3.2.4.3.4 Sleep Disturbance 3-47
3.2.4.3.5 Outdoor Speech Interference Potential Noise Effects on Recreation
and Outdoor Activities 3-49
3.2.4.3.6 Potential Hearing Loss 3-51
3.3 Public Health and Safety 3-53
3.3.1 Public Health and Safety Regulatory Setting 3-53
3.3.1.1 Flight Safety 3-53
3.3.1.2 Bird/Animal Aircraft Strike Hazard 3-55
3.3.1.3 Accident Potential Zones 3-56
3.3.1.4 Environmental Health Risks and Safety Risks to Children 3-57
3.3.2 Public Health and Safety Affected Environment 3-57
3.3.2.1.1 Potential for Aircraft Mishaps 3-57
3.3.2.1.2 Length of Runway at OLF Coupeville 3-59
3.3.2.1.3 Potential for Natural Disasters 3-59
3.3.2.3 Accident Potential Zones 3-61
3.4 Air Quality 3-68
3.4.1 Air Quality Regulatory Setting 3-69
3.4.1.1 Criteria Pollutants and National Ambient Air Quality Standards 3-69
3.4.1.2 General Conformity 3-71
3.4.1.3 Hazardous Air Pollutants 3-71
3.4.1.4 Permitting 3-71
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3.4.2 Air Quality Affected Environment 3-72
3.4.2.1 NAS Whidbey Island Complex Stationary Source Emissions 3-73
3.4.2.2 NAS Whidbey Island Complex Mobile Source Emissions 3-75
3.4.2.3 Chaff 3-77
3.4.2.4 Fuel Dumping 3-77
3.5 Land Use 3-77
3.5.1 Land Use Regulatory Setting 3-78
3.5.2 Land Use Affected Environment 3-79
3.5.2.1 On-station Land Use and Land Use Controls at the NAS Whidbey Island
Complex 3-79
3.5.2.2 Regional Land Use and Land Use Controls 3-81
3.5.2.2.1 NAS Whidbey Island AICUZ Update 2005 3-84
3.5.2.2.2 Washington State Growth Management Act 1990 2005 3-84
3.5.2.2.3 Island County Comprehensive Plan 2011 2016 and Zoning Ordinance
2016 3-85
3.5.2.2.4 City of Oak Harbor Comprehensive Plan 2010 2016 and Zoning
Ordinance 2016 3-87
3.5.2.2.5 Town of Coupeville Comprehensive Plan 2003 and Zoning Ordinance
2016 3-90
3.5.2.2.6 Additional Regional Land Use Controls 3-90
3.5.2.2.7 Readiness and Environmental Protection Integration Program

Conservation Easements and Navigation Easements 3-90
3.5.2.3 Community Character 3-91
3.5.2.3.1 Community Character Island County 3-91
3.5.2.3.2 Community Character Skagit County 3-92
3.5.2.3.3 Community Character City of Oak Harbor 3-92
3.5.2.3.4 Community Character Town of Coupeville 3-92
3.5.2.4 Land Use Compatibility Assessment 3-93
3.5.2.4.1 DNL Noise Contours 3-93
3.5.2.4.2 Accident Potential Zones 3-95
3.5.2.5 Recreation and Wilderness 3-96
3.5.2.5.1 Wilderness 3-96
3.5.2.5.2 Parks and Recreation Areas 3-98
3.5.2.5.2.1 San Juan Islands National Monument 3-101
3.5.2.5.2.2 San Juan Islands National Wildlife Refuge 3-101
3.5.2.5.2.3 Ebeys Landing National Historical Reserve 3-102
3.5.2.5.2.4 Pacific Northwest National Scenic Trail 3-104
3.5.2.5.2.5 State Parks and Recreation Areas 3-105
3.5.2.5.2.6 County and Municipal Parks and Recreation Areas 3-106
3.5.2.5.2.7 Privately Owned and Other Recreation Areas 3-107
3.5.2.5.3 Noise Effects on Recreation 3-108
3.6 Cultural Resources 3-109
3.6.1 Cultural Resources Regulatory Setting 3-109
3.6.1.1 Section 106 of the National Historic Preservation Act 3-110
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3.6.1.2 Area of Potential Effects 3-112
3.6.2 Cultural Resources Affected Environment 3-115
3.6.2.1 Background 3-115
3.6.2.1.1 NAS Whidbey Island 3-117
3.6.2.1.1.1 Ault Field 3-118
3.6.2.1.1.2 OLF Coupeville 3-118
3.6.2.1.1.3 Seaplane Base 3-119
3.6.2.1.2 Island County 3-120
3.6.2.1.3 Central Whidbey Island Historic District and the Ebeys Landing
National Historical Reserve 3-120
3.6.2.2 Archaeological Resources 3-122
3.6.2.3 Architectural Resources 3-122
3.6.2.3.1 On-installation Direct Effect Areas 3-123
3.6.2.3.2 On-installation Indirect Effect Areas 3-124
3.6.2.3.3 Off-Installation Indirect Effect Areas 3-126
3.6.2.3.3.1 Off-Installation Non-Ebeys Landing National Historical Reserve 3-126
3.6.2.3.3.2 Central Whidbey Island Historic District and the Ebeys Landing
3.6.2.4 Cemeteries 3-128
3.6.2.5 Traditional Cultural Properties 3-129
3.6.2.6 Section 106 Consultation 3-129
3.7 American Indian Traditional Resources 3-133
3.7.1 Policy and Regulatory Setting 3-134
3.7.1.1 DoD and Navy Policies Regarding Consultation 3-134
3.7.1.2 Laws Executive Orders and Memoranda Mandating Consultation 3-134
3.7.1.3 Government-to-Government Consultation 3-135
3.7.2 Affected Environment 3-136
3.7.3 Tribal Treaty Rights and Federal Trust Responsibilities Reservation of Rights by
American Indians 3-136
3.7.3.1 Treaties of Point No Point and Point Elliot 3-137
3.7.3.2 American Indian Access and Use at NAS Whidbey Island 3-138
3.8 Biological Resources 3-139
3.8.1 Biological Resources Regulatory Setting 3-139
3.8.1.1 Federal Regulations 3-139
3.8.1.1.1 Endangered Species Act 3-139
3.8.1.1.2 Migratory Bird Treaty Act and Executive Order 13186 3-139
3.8.1.1.3 Bald and Golden Eagle Protection Act 3-140
3.8.1.1.4 Marine Mammal Protection Act 3-141
3.8.1.2 State Regulations 3-141
3.8.1.2.1 Species of Concern 3-141
3.8.1.3 Local Regulations 3-142
3.8.1.3.1 Island County Critical Areas Ordinance 3-142
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3.8.1.3.2 Skagit County Critical Areas Ordinance 3-142
3.8.1.3.3 San Juan County Critical Areas Ordinance 3-142
3.8.2 Biological Resources Affected Environment 3-142
3.8.2.1 Terrestrial Wildlife and Vegetation 3-145
3.8.2.1.1 Vegetation 3-145
3.8.2.1.2 Reptiles and Amphibians 3-145
3.8.2.1.3 Birds 3-145
3.8.2.1.4 Mammals 3-146
3.8.2.2 Special Status Terrestrial Species 3-146
3.8.2.2.1 Federal Threatened and Endangered Terrestrial Species 3-146
3.8.2.2.1.1 Golden Paintbrush 3-148
3.8.2.2.1.2 Taylors Checkerspot Butterfly 3-148
3.8.2.2.1.3 Marbled Murrelet 3-150
3.8.2.2.1.4 Northern Spotted Owl 3-153
3.8.2.2.1.5 Streaked Horned Lark 3-153
3.8.2.2.1.6 Yellow-billed Cuckoo 3-153
3.8.2.2.1.7 North American Wolverine 3-154
3.8.2.2.2 Migratory Birds 3-154
3.8.2.2.2.1 Birds of Conservation Concern 3-155
3.8.2.2.2.2 Important Bird Areas 3-157
3.8.2.2.2.3 eBird Hotspots 3-160
3.8.2.2.2.4 National Wildlife Refuges 3-160
3.8.2.2.3 Bald and Golden Eagles 3-160
3.8.2.2.4 State Threatened and Endangered Species 3-161
3.8.2.2.5 Species of Local Importance 3-163
3.8.2.2.5.1 Island County Species of Local Importance 3-163
3.8.2.2.5.2 Skagit County Species of Local Importance 3-163
3.8.2.2.5.3 San Juan County Species of Local Importance 3-163
3.8.2.2.5.4 Jefferson County Species of Local Importance 3-163
3.8.2.2.5.5 Snohomish County Species of Local Importance 3-163
3.8.2.3 Marine Species 3-164
3.8.2.3.1 Marine Fish 3-164
3.8.2.3.2 Marine Mammals 3-166
3.8.2.3.2.1 Pinnipeds 3-167
3.8.2.3.2.2 Cetaceans 3-167
3.8.2.4 Special Status Marine Wildlife 3-169
3.8.2.4.1 Federal Threatened and Endangered Marine Species 3-169
3.8.2.4.1.1 Green Sturgeon 3-171
3.8.2.4.1.2 Eulachon 3-174
3.8.2.4.1.3 Salmonids 3-174
3.8.2.4.1.4 Bull Trout 3-178
3.8.2.4.1.5 Dolly Varden 3-179
3.8.2.4.1.6 Rockfish 3-179
3.8.2.4.1.7 Humpback Whale 3-181
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3.8.2.4.1.8 Killer Whale Southern Resident 3-181
3.8.2.4.2 State Threatened and Endangered Marine Species 3-183
3.9 Water Resources 3-183
3.9.1 Water Resources Regulatory Setting 3-184
3.9.1.2 State and Local Regulations 3-186
3.9.2 Water Resources Affected Environment 3-187
3.9.2.1 Groundwater 3-187
3.9.2.1.1 Per- and Polyfluoroalkyl Substances 3-188
3.9.2.2 Surface Water 3-189
3.9.2.3 Wetlands 3-190
3.9.2.4 Floodplains 3-191
3.9.2.5 Marine Waters and Sediments 3-191
3.10 Socioeconomics 3-19
3.10.1 Socioeconomics Regulatory Setting 3-192
3.10.2 Socioeconomics Affected Environment 3-192
3.10.2.1 Population Affected Environment 3-193
3.10.2.1.1 NAS Whidbey Island Complex 3-193
3.10.2.1.2 Island and Skagit Counties 3-194
3.10.2.2 Economy Employment and Income Affected Environment 3-195
3.10.2.2.2.1 Agriculture 3-198
3.10.2.2.2.2 Tourism 3-199
3.10.2.3 Housing Affected Environment 3-206
3.10.2.3.3 Housing Affordability 3-211
3.10.2.4 Local Government Revenues Affected Environment 3-213
3.10.3 Community Services Affected Environment 3-214
3.10.3.1 Education Affected Environment 3-214
3.10.3.2 Medical Services Affected Environment 3-217
3.10.3.3 Fire and Emergency Services Affected Environment 3-218
3.10.3.4 Police Protection Affected Environment 3-219
3.10.3.5 On-Base Community Services Support 3-219
3.11 Environmental Justice 3-220
3.11.1 Environmental Justice Regulatory Setting 3-220
3.11.2 Environmental Justice Affected Environment 3-220
3.11.2.1 Environmental Justice Methodology 3-220
3.11.2.2 Environmental Justice Assessment 3-223
3.12 Transportation 3-227
3.12.1 Transportation Regulatory Setting 3-227
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3.12.1.1 State 3-227
3.12.1.2 Regional 3-227
3.12.1.3 Local 3-228
3.12.2 Transportation Affected Environment 3-229
3.12.2.1 Road Network and Access 3-232
3.12.2.1.1 Off-station Road Network 3-232
3.12.2.1.2 On-station Road Network 3-233
3.12.2.2 Traffic Conditions 3-234
3.12.2.3 Transit Pedestrian and Bicycle Facilities 3-237
3.12.2.3.1 Off-station Facilities 3-237
3.12.2.3.2 On-station Facilities 3-238
3.13 Infrastructure 3-238
3.13.1 Infrastructure Regulatory Setting 3-238
3.13.1.2 Local Regulations 3-239
3.13.2 Infrastructure Affected Environment 3-239
3.13.2.1 Potable Water 3-239
3.13.2.1.1 Water Supply and Distribution System 3-239
3.13.2.1.2 NAS Whidbey Island Water Supply and Distribution System 3-240
3.13.2.1.3 Water Supply Capacity and Usage 3-240
3.13.2.2 Wastewater 3-242
3.13.2.2.1 Wastewater Collection and Treatment System 3-242
3.13.2.2.2 NAS Whidbey Island Wastewater Collection and Treatment System 3-242
3.13.2.2.3 Wastewater Supply Capacity and Usage 3-242
3.13.2.3 Stormwater 3-243
3.13.2.3.1 Stormwater Supply and Distribution System 3-243
3.13.2.3.2 NAS Whidbey Island Stormwater Supply and Distribution System 3-243
3.13.2.3.3 Stormwater Supply Capacity and Usage 3-244
3.13.2.4 Solid Waste Management 3-244
3.13.2.4.1 Solid Waste Distribution System 3-244
3.13.2.4.2 NAS Whidbey Island Solid Waste Distribution System 3-244
3.13.2.4.3 Solid Waste Capacity and Usage 3-244
3.13.2.5 Energy 3-244
3.13.2.5.1 Energy Supply 3-244
3.13.2.5.2 NAS Whidbey Island Energy Distribution System 3-245
3.13.2.5.3 Energy Capacity and Usage 3-245
3.13.2.6 Communications 3-247
3.13.2.6.1 Communications Distribution System 3-247
3.13.2.6.2 NAS Whidbey Island Communication System 3-247
3.13.2.7 Facilities 3-247
3.14 Geological Resources 3-247
3.14.1 Geological Resources Regulatory Setting 3-248
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3.14.1.1 State Regulations 3-248
3.14.2 Geological Resources Affected Environment 3-248
3.14.2.1 Topography 3-248
3.14.2.2 Geology 3-248
3.14.2.3 Seismic Activity and Geologic Hazards 3-248
3.14.2.4 Soils 3-249
3.15 Hazardous Materials and Wastes 3-251
3.15.1 Hazardous Material and Wastes Regulatory Setting 3-251
3.15.2 Hazardous Materials and Wastes Affected Environment 3-25
3.15.2.1 Hazardous Materials 3-25
3.15.2.2 Hazardous Wastes 3-252
3.15.2.3 Defense Environmental Restoration Program 3-25
3.16 Climate Change and Greenhouse Gases 3-252
3.16.1 Policies for the Mitigation of and Adaptation to Climate Change 3-253
3.16.1.1 Federal Policies Related to Climate Change 3-253
3.16.1.2 Department of Defense Policies Related to Climate Change 3-253
3.16.1.3 State Policies Related to Climate Change 3-254
3.16.2 Affected Environment 3-254
3.16.2.1 Impacts of Climate Change on Department of Defense Mission 3-255
3.16.2.2 Impacts of Climate Change in Washington State and Puget Sound 3-255
3.16.3 Greenhouse Gas Emissions 3-255
3.16.3.1 Regional and State Greenhouse Gas Emissions 3-255
3.16.3.2 NASWhidbey Island Greenhouse Gas Emissions 3-256
ENVIRONMENTAL CONSEQUENCES 4-1
4.1 Airspace and Airfield Operations 4-2
4.1.1 Airspace and Airfield Operations No Action Alternative 4-3
4.1.2 Airspace and Airfield Operations Alternative 4-5
4.1.2.1 Airspace and Airfield Operations Potential Impacts under Alternative 4-5
4.1.2.1.1 Airspace Alternative 4-5
4.1.2.1.2 Airfield Operations Alternative 4-6
4.1.2.1.3 Alternative Conclusion 4-10
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4.1.5 Airspace and Airfield Operations Conclusion Alternatives through 4-23
4.1.5.1 Airspace Summary 4-23
4.1.5.2 Airfield Operations Summary 4-24
4.2 Noise Associated with Aircraft Operations 4-26
4.2.1 Noise No Action Alternative 4-28
4.2.2 Noise Alternative 4-28
4.2.2.1 Projected DNL Contours Alternative 4-29
4.2.2.2 Supplemental Noise Analyses Alternative 4-46
4.2.2.2.1 Single Event Noise Alternative 4-46
4.2.2.2.2 Speech Interference Indoor Alternative 4-55
4.2.2.2.3 Classroom/learning Interference Alternative 4-59
4.2.2.2.4 Sleep Disturbance Alternative 4-63
and Outdoor Activities Alternative 4-67
4.2.2.2.6 Potential Hearing Loss Alternative 4-72
4.2.2.3 Nonauditory Health Effects Alternative 4-76
4.2.2.4 Vibration Effects from Aircraft Operations Alternative 4-76
4.2.2.5 Noise Conclusion Alternative 4-76
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4.2.5 Noise Impact Comparison Alternatives through 4-165
4.2.5.1 Noise Impact Comparison Alternatives through Acreage and
Population 4-165
4.2.5.2 Noise Impact Comparison Alternatives through Supplemental Metrics 4-168
4.2.5.3 Noise Conclusion Alternatives through 4-168
4.2.6 Noise Mitigation 4-168
4.2.6.1 Fifteen Action Alternatives 4-169
4.2.6.2 Noise-reduction Measures 4-169
4.2.6.3 Noise Abatement Policy 4-170
4.2.6.4 Noise Complaint Process 4-172
4.2.6.5 Air Installations Compatible Use Zones Program 4-172
4.3 Public Health and Safety 4-173
4.3.1 Public Health and Safety No Action Alternative 4-173
4.3.2 Public Health and Safety Potential Impacts Alternatives through 4-173
4.3.2.3 Clear Zones and Accident Potential Zones 4-174
4.3.3 Public Health and Safety Conclusion Alternatives through 4-194
4.4 Air Quality 4-195
4.4.1 Air Quality No Action Alternative 4-195
4.4.2 Air Quality Alternative 4-195
4.4.2.1 Air Quality Potential Impacts Alternative 4-195
4.4.2.1.1 Construction-related Emissions Alternative 4-196
4.4.2.1.2 Stationary Operation-related Emissions Alternative 4-197
4.4.2.1.3 Mobile Operation-related Emissions Alternative 4-198
4.4.5 Air Quality Conclusions Alternatives through 4-215
4.4.5.1 Air Quality Conclusions Average Operations 4-215
4.4.5.2 Air Quality Conclusions High-Tempo Operations 4-217
4.5 Land Use 4-219
4.5.1 Land Use No Action Alternative 4-219
4.5.2 Land Use Alternatives through 4-219
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4.5.2.1 Potential Impacts Land Use Compatibility 4-220
4.5.2.1.1 On-station Land Use 4-220
4.5.2.1.1.1 On-station Land Use Controls 4-220
4.5.2.1.2 Regional Land Use 4-220
4.5.2.1.2.1 Regional Off-station Land Use Controls 4-221
4.5.2.1.3 Land Use in the Noise Environment 4-222
4.5.2.1.3.1 DNL Noise Contours 4-222
4.5.2.1.3.2 Accident Potential Zones 4-259
4.5.2.2 Potential Impacts Recreation and Wilderness 4-260
4.5.2.2.1 Wilderness 4-262
4.5.2.2.2 Parks and Recreation Areas Potential Noise Impacts 4-263
4.5.2.2.2.1 San Juan Islands National Monument 4-263
4.5.2.2.2.2 San Juan Islands National Wildlife Refuge 4-267
4.5.2.2.2.3 Ebeys Landing National Historical Reserve 4-267
4.5.2.2.2.4 Pacific Northwest National Scenic Trail 4-277
4.5.2.2.2.5 State Parks and Recreation Areas 4-279
4.5.2.2.2.6 County and Municipal Parks and Recreation Areas 4-285
4.5.2.2.2.7 Privately Owned and Other Recreation Areas 4-294
4.5.3 Land Use Conclusion Alternatives through 4-297
4.6 Cultural Resources 4-309
4.6.1 Documentation of the correspondence with the tribes is provided in Appendix
Cultural Resources No Action Alternative 4-315
4.6.2 Cultural Resources Alternatives through 4-315
4.6.2.1 Cultural Resources Potential Impacts 4-315
4.6.2.1.1 Direct Effects 4-315
4.6.2.1.1.1 Archaeological Resources 4-316
4.6.2.1.1.2 Architectural Resources 4-316
4.6.2.1.1.3 Cemeteries 4-317
4.6.2.1.1.4 Traditional Cultural Properties 4-318
4.6.2.1.2 Indirect Effects 4-318
4.6.2.1.2.1 Archaeological Resources 4-318
4.6.2.1.2.2 Architectural Resources 4-318
4.6.2.1.2.2.1 Visual Effects 4-319
4.6.2.1.2.2.1.1 On-Installation Indirect Effect Areas 4-319
4.6.2.1.2.2.1.2 Off-Installation Indirect Effect Areas Central Whidbey
Island Historic District and the Ebeys Landing
4.6.2.1.2.2.2 Atmospheric Effects 4-321
4.6.2.1.2.2.3 Noise and Vibration 4-321
4.6.2.1.2.2.3.1 On-Installation Indirect Effect Areas 4-324
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4.6.2.1.2.2.3.2 Off-Installation Indirect Effect Areas and the Central
Whidbey Island Historic District and Ebeys Landing

4.6.2.1.2.3 Cemeteries 4-326
4.6.2.1.2.4 Traditional Cultural Properties 4-326
4.6.3 Cultural Resources Conclusion Alternatives through 4-326
4.7 American Indian Traditional Resources 4-329
4.7.1 Approach to Analyses 4-329
4.7.2 No Action Alternative 4-329
4.7.3 Alternatives and 4-330
4.7.4 American Indian Traditional Resources Conclusion Alternatives through 4-33
4.8 Biological Resources 4-332
4.8.1 Biological Resources No Action Alternative 4-33
4.8.2 Biological Resources Potential Impacts Alternatives through 4-332
4.8.2.1 Effects on Terrestrial Wildlife 4-333
4.8.2.1.1 Habitat Loss 4-333
4.8.2.1.1.1 Endangered Species Act 4-334
4.8.2.1.1.2 Migratory Bird Treaty Act 4-334
4.8.2.1.1.3 Bald and Golden Eagle Protection Act 4-334
4.8.2.1.2 Sensory Disturbances 4-334
4.8.2.1.2.1 Construction 4-336
4.8.2.1.2.1.1 Endangered Species Act 4-336
4.8.2.1.2.1.2 Migratory Bird Treaty Act 4-336
4.8.2.1.2.1.3 Bald and Golden Eagle Protection Act 4-337
4.8.2.1.2.2 Aircraft Operations 4-337
4.8.2.1.2.2.1 Birds 4-337
4.8.2.1.2.2.1.1 Endangered Species Act 4-342
4.8.2.1.2.2.1.2 Migratory Bird Treaty Act 4-344
4.8.2.1.2.2.1.3 Bald and Golden Eagle Protection Act 4-344
4.8.2.1.2.2.2 Mammals 4-345
4.8.2.1.2.2.3 Reptiles and Amphibians 4-347
4.8.2.1.3 Bird/Animal Aircraft Strike Hazard 4-348
4.8.2.1.3.1 Construction 4-348
4.8.2.1.3.1.2 Migratory Bird Treaty Act 4-349
4.8.2.1.3.1.3 Bald and Golden Eagle Protection Act 4-349
4.8.2.1.3.2 Aircraft Operations 4-349
4.8.2.1.3.2.1 Birds 4-350
4.8.2.1.3.2.1.2 Migratory Bird Treaty Act 4-354
4.8.2.1.3.2.1.3 Bald and Golden Eagle Protection Act 4-354
4.8.2.1.3.2.2 Mammals 4-355
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4.8.2.1.3.2.3 Reptiles and Amphibians 4-356
4.8.2.2 Effects on Marine Species 4-356
4.8.2.2.1 Construction 4-356
4.8.2.2.1.1 Endangered Species Act 4-356
4.8.2.2.1.2 Marine Mammal Protection Act 4-357
4.8.2.2.2 Aircraft Operations 4-357
4.8.2.2.2.1 Fish 4-358
4.8.2.2.2.2 Marine Mammals 4-359
4.8.2.2.2.2.1 Pinnipeds 4-360
4.8.2.2.2.2.2 Cetaceans 4-361
4.8.2.2.2.2.2.2 Marine Mammal Protection Act 4-363
4.8.3 Biological Resources Conclusion 4-363
4.9 Water Resources 4-366
4.9.1 Water Resources No Action Alternative 4-366
4.9.2 Water Resources Alternatives through 4-366
4.9.2.1 Water Resources Potential Impacts 4-366
4.9.2.1.1 Groundwater 4-366
4.9.2.1.1.1 Per- and Polyfluoroalkyl Substances 4-367
4.9.2.1.2 Surface Water 4-367
4.9.2.1.3 Wetlands 4-368
4.9.2.1.4 Floodplains 4-368
4.9.2.1.5 Marine Waters and Sediments 4-369
4.9.3 Water Resources Conclusion Alternatives through 4-369
4.10 Socioeconomics 4-370
4.10.1 Socioeconomics No Action Alternative 4-370
4.10.2 Socioeconomic Impacts Alternatives through 4-370
4.10.2.1 Population Impacts 4-370
4.10.2.2 Economy Employment and Income Impacts 4-373
4.10.2.2.1 Short-term Construction-related Impacts 4-374
4.10.2.2.2 Long-term Employee Earnings and Spending Impacts 4-374
10.2.2.3 Impacts to Other Industries 4-375
4.10.2.2.3.1 Agriculture 4-375
4.10.2.2.3.2 Tourism 4-375
10.2.2.3.3 Other Noise-Sensitive Industries 4-378
4.10.2.2.4 Economy Employment and Income Summary 4-378
4.10.2.3 Housing Impacts 4-378
4.10.2.4 Property Values 4-380
4.10.2.5 Local Government Revenues 4-381
4.10.3 Community Services Impacts Alternatives through 4-382
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4.10.3.1 Education 4-382
4.10.3.2 Medical Services 4-384
4.10.3.3 Fire and Emergency Services 4-384
4.10.3.4 Police Protection 4-385
4.10.4 Socioeconomics Conclusion Alternatives through 4-385
4.11 Environmental Justice 4-387
4.11.1 Methodology 4-387
4.11.1.1 Methodology for Identifying Environmental Justice Communities 4-387
4.11.2 Environmental Justice No Action Alternative 4-395
4.11.2.1 Identifying Environmental Justice Communities Analysis under the No
Action Alternative 4-397
4.11.2.2 Identifying Disproportionately High and Adverse Impacts under the No
4.11.2.3 Analysis for Identifying Disproportionately High and Adverse Impacts
under the No Action Alternative 4-399
4.11.2.3.1 Aircraft Noise 4-400
4.11.2.3.2 Potential Increased Risk of Aircraft Mishaps in Clear Zones/Accident
Potential Zones 4-400
4.11.2.3.3 Potential Impacts from Overcrowding at Oak Harbor School District 4-403
4.11.2.3.4 Potential Impacts on Housing Affordability 4-403
4.11.3 Environmental Justice Alternatives through 4-403
4.11.3.1 Identifying Environmental Justice Communities Analysis under Alternatives
lthrough3 4-403
4.11.3.2 Methodology for Identifying Disproportionately High and Adverse Impacts
under Alternatives through 4-433
4.11.3.3 Analysis for Identifying Disproportionately High and Adverse Impacts
under Alternatives through 4-433
4.11.3.3.1 Aircraft Noise 4-433
4.11.3.3.2 Potential Increased Risk of Aircraft Mishaps in Clear Zones/Accident
Potential Zones 4-437
4.11.3.3.3 Potential Impacts from Overcrowding at Oak Harbor School District 4-440
4.11.3.3.4 Potential Impacts to Housing Affordability 4-440
4.11.4 Environmental Justice Conclusion Alternatives through 4-441
4.12 Transportation 4-442
4.12.1 Transportation No Action Alternative 4-443
4.12.2 Transportation Alternatives through 4-443
4.12.2.1 Renovation of Existing Facilities at NAS Whidbey Island 4-443
4.12.2.2 Off-base Operations Trip Generation 4-443
4.12.2.3 Off-base Operations Level of Service 4-449
4.12.2.4 On-base Operations 4-450
4.12.2.5 Transit Pedestrian and Bicycle Facilities 4-45
4.12.3 Transportation Conclusion Alternatives through 4-451
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4.13 Infrastructure 4-452
4.13.1 Infrastructure No Action Alternative 4-452
4.13.2 Infrastructure Alternatives through 4-453
4.13.2.1 Potable Water Impacts 4-453
4.13.2.2 Wastewater Impacts 4-455
4.13.2.3 Stormwater Impacts 4-458
4.13.2.4 Solid Waste Management Impacts 4-458
4.13.2.5 Energy Impacts 4-459
4.13.2.6 Communications Impacts 4-461
4.13.2.7 Facilities Impacts 4-461
4.13.3 Infrastructure Conclusion Alternatives through 4-462
4.14 Geological Resources 4-463
4.14.1 Geological Resources No Action Alternative 4-463
4.14.2 Geological Resources Alternatives through 4-463
14.2.1 Geological Resources Potential Impacts 4-463
14.2.1.1 Topography Impacts 4-463
14.2.1.2 Geology Impacts 4-463
14.2.1.3 Seismic Activity and Geologic Hazard Impacts 4-463
14.2.1.4 Soils Impacts 4-464
4.14.3 Geological Resources Conclusion 4-464
4.15 Hazardous Materials and Wastes 4-465
4.15.1 Hazardous Materials and Wastes No Action Alternative 4-465
4.15.2 Hazardous Materials and Wastes Alternatives through 4-465
15.2.1 Hazardous Materials and Wastes Potential Impacts 4-465
4.15.3 Hazardous Materials and Wastes Conclusion Alternatives through 4-466
4.16 Climate Change and Greenhouse Gases 4-467
4.16.1 Global Climate Change Projections 4-468
16.1.1 Projections for Impacts of Climate Change to Washington and Puget Sound 4-468
4.16.1.2 Projections for Impacts of Climate Change on Department of Defense 4-469
16.1.3 Projections for Impacts of Climate Change at NAS Whidbey Island 4-469
4.16.2 Changes in Greenhouse Gas Emissions from the Proposed Action 4-469
16.2.1 Changes in Greenhouse Gas Emissions from the Proposed Action No

16.2.2 Changes in Greenhouse Gas Emissions from the Proposed Action
Alternative 4-470
Alternative 4-472
Alternative 4-474
4.16.2.5 Greenhouse Gas Summary Conclusions Alternatives through 4-476
4.16.3 Adaptation and Mitigation 4-478
4.16.3.1 Washington State 4-478
16.3.2 Department of Defense 4-479
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4.17 Summary of Potential Impacts to Resources 4-482
CUMULATIVEIMPACTS 5-1
5.1 Definition of Cumulative Impacts 5-1
5.2 Scope of Cumulative Impacts Analysis 5-2
5.3 Past Present and Reasonably Foreseeable Actions 5-3
5.3.1 PastActions 5-11
5.3.1.1 Federal Actions 5-11
5.3.1.2 Non-federal Actions 5-11
5.3.2 Present and Reasonably Foreseeable Actions 5-11
5.3.2.1 Federal Actions 5-11
5.3.2.2 Non-federal Actions 5-13
5.4 Cumulative Impact Analysis 5-14
5.4.1 Airfield and Airspace 5-15
5.4.1.1 Description of Geographic Study Area 5-15
5.4.1.2 Relevant Past Present and Future Actions 5-15
5.4.1.3 Cumulative Impact Analysis 5-16
5.4.3 Public Health and Safety 5-18
5.4.3.4 Combined Impacts from Past Present and Reasonably Foreseeable Future
Actions 5-19
5.4.4 Air Quality 5-19
5.4.5 Land Use 5-22
5.4.6 Cultural Resources 5-23
5.4.7 American Indian Traditional Resources 5-24
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5.4.8 Biological Resources 5-26
5.4.9 Water Resources 5-31
5.4.10 Socioeconomics 5-33
5.4.11 Environmental Justice 5-35
5.4.12 Transportation 5-36
5.4.13 Infrastructure 5-37
5.4.14 Geological Resources 5-39
5.4.15 Hazardous Materials and Wastes 5-41
5.4.16 Climate Change and Greenhouse Gases 5-41
OTHER CONSIDERATIONS REQUIRED BY THE NATIONAL ENVIRONMENTAL POLICY
ACT 6-1
6.1 Consistency with Other Federal State and Local Laws Plans Policies and
Regulations 6-1
6.2 Irreversible or Irretrievable Commitments of Resources 6-11
6.3 Unavoidable Adverse Impacts 6-11
6.3.2 Education 6-12
6.3.3 Mitigation 6-13
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6.4 Relationship between Short-Term Use of the Environment and Long-Term
Productivity 6-13
REFERENCES 7-1
LIST OF PREPARERS 8-1
DISTRIBUTION LIST 9-1
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List of Figures
Figure 1.2-1 General Location Map NAS Whidbey Island Complex 1-2
Figure 1.2-2 General Location Map Aerial Ault Field 1-3
Figure 1.2-3 General Location Map Aerial OLF Coupeville 1-4
Figure 2.3-1 Ault Field Planned Facility Activities under Alternatives and 2-14
Figure 3.1-1 Cross Section of Controlled and Uncontrolled Airspace Classes 3-3
Figure 3.1-2 Aeronautical Chart NAS Whidbey Island Complex 3-4
Figure 3.1-3 Current Aircraft Arrival and Departure Flight Tracks at NAS Whidbey Island
Complex 3-8
Figure 3.1-4 Current Interfacility and FCLP Flight Tracks 3-9
Figure 3.1-5 Current Pattern Operations Flight Tracks 3-10
Figure 3.1-6 Standard FCLP Pattern Altitudes AGL 3-12
Figure 3.2-1 A-weighted Sound Levels from Typical Sources 3-16
Figure 3.2-2 Engine Run-Up Locations at Ault Field 3-26
Figure 3.2-3 No Action Environment for NAS Whidbey Island Overview 3-29
Figure 3.2-4 No Action Environment for Ault Field NAS Whidbey Island Complex 3-30
Figure 3.2-5 No Action Environment for OLF Coupeville NAS Whidbey Island Complex 3-31
Figure 3.2-6 Representative Points of Interest in the Vicinity of NAS Whidbey Island Complex 3-37
Figure 3.3-1 Example of APZ-l and APZ-ll for an FCLP Flight Track with APZ-ll extended 3-57
Figure 3.3-2 2005 AICUZ APZs for Ault Field NAS Whidbey Island 3-62
Figure 3.3-3 2005 AICUZ Clear Zones for OLF Coupeville 3-63
Figure 3.5-1 Island County Adopted APZs 3-86
Figure 3.5-2 65 dB DNL Average Year No Action Alternative Land Use for Ault Field 3-88
Figure 3.5-3 65 dB DNL Average Year No Action Alternative Land Use for OLF Coupeville 3-89
Figure 3.5-4 Parks and Recreation Areas in the NAS Whidbey Island Complex Affected
Environment DNL Noise Contours 3-100
Figure 3.6-1 Area of Potential Effect 3-113
Figure 3.6-2 On Installation Direct Effect Areas 3-114
Figure 3.6-3 Ebeys Landing National Historical Reserve Landscape Character Areas 3-127
Figure 3.8-1 Biological Resource Study Area 3-144
Figure 3.8-2 Taylors Checkerspot Butterfly Designated Critical Habitat within the Study Area 3-149
Figure 3.8-3 Important Bird Areas and National Wildlife Refuges in the Study Area 3-158
Figure 3.8-4 Green Sturgeon and Rockfish Designated Critical Habitat within the Study Area 3-173
Figure 3.8-5 Salmonid Designated Critical Habitat within the Study Area 3-176
Figure 3.8-6 Southern Resident Killer Whale Designated Critical Habitat within the Study Area 3-182
Figure 3.11-1 Census Tracts and Census Block Groups in the Environmental Justice Study Area 3-222
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Figure 3.11-2 Environmental Justice Populations Affected by the No Action Alternative 3-225
Figure 3.12-1 Local and Regional Traffic Circulation Ault Field 3-230
Figure 3.12-2 Local and Regional Traffic Circulation Seaplane Base 3-231
Figure 4.1-1 No Action Alternative FCLP Flight Tracks at NAS Whidbey Island Complex 4-4
Figure 4.1-2 Alternatives 1-3 FCLP Flight Tracks at NAS Whidbey Island Complex 4-8
Figure 4.2-1 Alternative Overview of 65 dB DNL Noise Contours for the NAS Whidbey Island
Complex 4-35
Figure 4.2-2 Alternative 1A DNL Noise Contours for Ault Field 4-36
Figure 4.2-3 Alternative lB DNL Noise Contours for Ault Field 4-37
Figure 4.2-4 Alternative 1C DNL Noise Contours for Ault Field 4-38
Figure 4.2-5 Alternative 1D DNL Noise Contours for Ault Field 4-39
Figure 4.2-6 Alternative 1E DNL Noise Contours for Ault Field 4-40
Figure 4.2-7 Alternative 1A DNL Noise Contours for OLF Coupeville 4-41
Figure 4.2-8 Alternative lB DNL Noise Contours for OLF Coupeville 4-42
Figure 4.2-9 Alternative 1C DNL Noise Contours for OLF Coupeville 4-43
Figure 4.2-10 Alternative 1D DNL Noise Contours for OLF Coupeville 4-44
Figure 4.2-11 Alternative 1E DNL Noise Contours for OLF Coupeville 4-45
Complex 4-84
Figure 4.2-14 Alternative 2B DNL Noise Contours for Ault Field 4-86
Figure 4.2-19 Alternative 2B DNL Noise Contours for OLF Coupeville 4-91
Complex 4-128
Figure 4.2-25 Alternative 3B DNL Noise Contours for Ault Field 4-130
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Figure 4.2-30 Alternative 3B DNL Noise Contours for OLF Coupeville 4-135
Figure 4.3-1 Existing 2005 AICUZ Clear Zones and Conceptual APZs for OLF Coupeville 4-177
Figure 4.5-1 Alternative Overview of the 65 dB DNL Noise Contours and Land Use for Ault
Field 4-253
Figure 4.5-2 Alternative Overview of the 65 dB DNL Noise Contours and Land Use for OLF
Coupeville 4-254
Field 4-255
Coupeville 4-256
Field 4-257
Coupeville 4-258
Figure 4.5-7 Greater than 65 dB DNL Noise Contours in the Vicinity of the San Juan Islands
National Monument 4-266
Figure 4.10-1 Tourism and Revenue and Employment in Island Skagit and San Juan Counties
1997-2014 4-377
Figure 4.11-1 Environmental Justice Populations Affected by Alternative 4-390
Figure 5-1 Cumulative Impact Project Locations 5-10
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List of Tables
Table 1.9-1 Summary of Public Scoping Notifications for the Environmental Impact
Statement for EA-18G Growler Airfield Operations at the Naval Air Station
Whidbey Island Complex 1-15
Table 1.9-2 Public Scoping Meeting Dates and Locations for the Environmental Impact
Table 1.9-3 Libraries and Locations Provided Paper Copies of Scoping Information Materials
2014-2015 Scoping Efforts for the Environmental Impact Statement for EA-18G
Growler Airfield Operations at the Naval Air Station Whidbey Island Complex 1-17
Table 1.9-4 Summary of Comment Methods during Public Scoping for the Environmental
Impact Statement for EA-18G Growler Airfield Operations at the Naval Air
Station Whidbey Island Complex 1-18
Table 1.9-5 Comparison of Comment Topics and Quantities of Public Scoping Comments for
the Environmental Impact Statement for EA-18G Growler Airfield Operations at
the Naval Air Station Whidbey Island Complex 1-19
Table 1.10-1 Summary of Notifications for the Draft Environmental Impact Statement for
EA-18G Growler Airfield Operations at the Naval Air Station Whidbey Island
Complex 1-21
Table 1.10-2 Public Meeting Dates and Locations for the Draft Environmental Impact
Table 1.10-3 Libraries and Locations Provided Paper Copies of the Draft Environmental
Table 1.10-4 Summary of Comments by Submittal Method during the Public Comment Period
for the Draft Environmental Impact Statement for EA-18G Growler Airfield
Operations at the Naval Air Station Whidbey Island Complex 1-25
Table 1.10-5 Comment Topics and Quantities of Public Comment Segments for the Draft
Environmental Impact Statement for EA-18G Growler Airfield Operations at the
Naval Air Station Whidbey Island Complex 1-26
Table 1.13-1 Comparison of the Preferred Alternative Alternative Scenario from Draft
ElSto Final ElS 1-62
Table 1.13-2 Comparison of Certain Resource Areas from Draft ElS to Final ElS 1-63
Table 2.3-1 Total Airfield Operations by Alternative for the Environmental Impact Statement
for EA-18G Growler Airfield Operations at the Naval Air Station Whidbey Island
Complex 2-8
Table 2.3-2 Comparison of FCLPs by Alternative at the NAS Whidbey Island Complex 2-10
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Table 2.3-3 Aircraft Personnel and Dependents by Alternative for the Environmental
Table 2.6-1 Summary of Alternatives Considered in the Environmental Impact Statement for
EA-18G Growler Airfield Operations at the Naval Air Station Whidbey Island
Complex 2-25
Table 3.1-1 Annual Military Training Route Operations in the Affected Environment 3-6
Table 3.1-2 Representative Sound Levels for Growler Aircraft in Level Flight 3-6
Table 3.1-3 Annual Modeled Affected Environment Operations at Ault Field and OLF
Coupeville Average 3-14
Table 3.2-1 Subjective Responses to Changes in A-weighted Decibels 3-16
Table 3.2-2 Estimated Acreage and Population within the DNL Contour Ranges for the
Average Year at the NAS Whidbey Island Complex CY 21 3-33
Table 3.2-3 Percent Difference in the Estimated Acreage and Population within the Average
and High-Tempo FCLP Year DNL Contour Ranges for the NAS Whidbey Island
Complex CY 21 3-33
Table 3.2-4 Maximum Sound Exposure Level dB and Maximum Sound Level dB for
Representative Points of Interest in the Vicinity of the NAS Whidbey Island
Complex CY 21 3-39
Table 3.2-5 Number of Events above Maximum Sound Level of 80 dB 90 dB and 100 dB
for Representative Points of Interest in the Vicinity of the NAS Whidbey Island
Complex No Action Alternative CY 21 3-42
Table 3.2-6 Average Number of Events per Hour of Indoor Speech Interference for
Complex CY 21 3-45
Table 3.2-7 Average Number of Events per Hour of Indoor Classroom/learning Interference
Complex CY 21 3-47
Table 3.2-8 Average Indoor Nightly Probability of Awakening for Representative Points of
Interest in the Vicinity of the NAS Whidbey Island Complex CY 21 3-48
Table 3.2-9 Average Number of Events per Hour of Outdoor Speech Interference for
Complex CY 21 3-49
Table 3.2-10 Average and 10th Percentile Noise Induced Permanent Threshold Shifts as
Function of Equivalent Sound Level at NAS Whidbey Island Complex CY 21 3-52
Table 3.3-1 EA-18G Growler Mishap Data from FY 2009 through FY 2017 for Land-based
Operations 3-58
Table 3.3-2 Percentage of Children Living in Census Block Groups Affected by the NAS
Whidbey Island Complex under the No Action Alternative 3-67
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Table 3.3-3 Number and Percent of Children and Schools Affected by the NAS Whidbey
Island Complex under the No Action Alternative 3-68
Table 3.3-4 Number and Percent of Children Affected by the Clear Zones and APZs at Ault
Field and Coupeville OLF under the No Action Alternative 3-68
Table 3.4-1 National and State Ambient Air Quality Standards 3-70
Table 3.4-2 Northwest Clean Air Agency Jurisdiction Air Emissions Inventory 2014 3-73
Table 3.4-3 NAS Whidbey Island Complex Criteria Pollutant Air Emissions Inventory 3-74
Table 3.4-4 NAS Whidbey Island Complex Reported Annual GHG Air Emissions Inventory
Required Stationary Sources Only 3-75
Table 3.4-5 NAS Whidbey Island Existing Criteria Pollutant Mobile Air Emissions Growler
Operations Only 3-76
Table 3.5-1 AICUZ Land Use Recommendations 3-83
Table 3.5-2 Existing Land Uses within Affected Environment DNL Noise Contours
Surrounding Ault Field and OLF Coupeville 3-94
Table 3.5-3 Parks and Recreation Areas in the NAS Whidbey Island Complex Affected
Environment DNL Noise Contours 3-99
Table 3.5-4 Estimated Total Visitors to State Parks in the Study Area 1987-2011 Every Third
Year and 2011-2016 3-106
Table 3.6-1 Architectural Resources within the APE 3-123
Table 3.6-2 NRHP-Eligible Buildings at Ault Field 3-125
Table 3.8-1 Reptiles and Amphibians Potentially Occurring within the Study Area 3-145
Table 3.8-2 Federally Listed Terrestrial Species and Critical Habitats Potentially Occurring
within the Study Area 3-146
Table 3.8-3 Birds of Conservation Concern Occurring Annually within the Study Area 3-156
Table 3.8-4 Categories of Birds in Important Bird Areas 3-160
Table 3.8-5 State-listed Terrestrial Wildlife Species Their Preferred Habitats and Their
Likelihood of Occurrence within the Study Area 3-162
Table 3.8-6 Marine Fishes by Taxonomic Group that Have the Potential to Occur in the
Study Area 3-164
Table 3.8-7 MMPA-protected Marine Mammals Potentially Occurring within the Study Area ....3-166
Table 3.8-8 NMFS/USFWS-managed Federally Endangered and Threatened Species and
Critical Habitats Identified by IPaC as Potentially Occurring within the Study Area ...3-169
Table 3.10-1 Military and Civilian Personnel Expected to be Assigned to the NAS Whidbey
Island Complex in 2021 3-193
Table 3.10-2 Personnel Stationed and Employed at the NAS Whidbey Island Complex by Place
of Residence 3-194
Table 3.10-3 Total Population Counts Estimates and Projections for Communities in the
Study Area Surrounding the NAS Whidbey Island Complex 3-195
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Table 3.10-4 Civilian Employment by Industrial Sector for Communities within the Study Area
Surrounding the NAS Whidbey Island Complex in 2016 3-197
Table 3.10-5 Selected Economic Characteristics for the Communities in the Study Area
Surrounding the NAS Whidbey Island Complex 3-198
Table 3.10-6 Annual Travel Expenditures Earnings and Employment in Island San Juan and
Skagit Cou nties 1991-2014 3-200
Table 3.10-7 Industry Earnings Directly Generated by Travel Spending by Subsector in Island
San Juan and Skagit Counties 2014 millions 3-201
Table 3.10-8 Government Revenue Directly Generated by Travel Spending by Sector in Island
San Juan and Skagit Counties 2014 millions 3-201
Table 3.10-9 Overnight Visitor Volume in Island and San Juan Counties 2012-2014 3-202
Table 3.10-10 Estimated Visitors to Deception Pass State Park 1987-2008 every third year
and 2011-2016 3-203
Table 3.10-11 2016 Estimated Visitors to State Parks within Ebeys Landing National Historical
Reserve 3-204
Table 3.10-12 Estimated Total Visitors to State Parks within Ebeys Landing National Historical
Reserve for Selected Years 1987-2016 3-204
Table 3.10-13 2016 Estimated Visitors to State Parks in San Juan Islands near the NAS Whidbey
Island Complex 3-205
Table 3.10-14 Estimated Total Visitors to State Parks in San Juan Islands near the NAS Whidbey
Island Complex for Selected Years 1987-2016 3-206
Table 3.10-15 Total Unaccompanied Personnel Housing Needs and Military Family Housing
Needs and Available Assets at the NAS Whidbey Island Complex in 2017 and
2022 3-207
Table 3.10-16 Selected Housing Characteristics for the Communities in the Study Area
Surrounding the NAS Whidbey Island Complex in 2016 3-208
Table 3.10-17 Suitable Rental Housing Located in the NAS Whidbey Island Housing Market
Area 2017 3-210
Table 3.10-18 Vacant Suitable Rental Housing Located in the NAS Whidbey Island Housing
Market Area 2017 3-210
Table 3.10-19 HUD Fair Market Rent by Unit Type Island County 2017 3-212
Table 3.10-20 Available Affordable Housing Units in Island County by Income Level 3-212
Table 3.10-21 Total County Government Revenues by Source for Calendar Year 2014 in the
Area Surrounding the NASWhidbey Island Complex 3-213
Table 3.10-22 Total County Government Expenditures by Category for Calendar Year 2014 in
the Area Surrounding the NAS Whidbey Island Complex 3-214
Table 3.11-1 Comparison of Environmental Justice Populations in Census Block Groups
Affected by the NAS Whidbey Island Complex under the No Action Alternative
to County Totals 3-224
xxviii
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GRR00150192
Table 3.11-2 Environmental Justice Populations Affected by the NAS Whibdey Island Complex
under the No Action Alternative 3-226
Table 3.12-1 NAS Whidbey Island Gate Traffic Counts 3-233
Table 3.12-2 Existing Average Daily Traffic and Level of Service within the NAS Whidbey
Island Complex Study Area 3-235
Table 3.13-1 Water Consumption Data at NAS Whidbey Island 2010 through 2015 3-242
Table 3.13-2 Energy Use Data at NAS Whidbey Island 2009 through 2015 3-246
Table 3.16-1 Washington State Annual Greenhouse Gas Air Emissions Inventory 3-256
Table 3.16-2 NAS Whidbey Island Complex Annual Reported GHG Air Emissions Inventory
Required Stationary Sources Only 3-257
Table 4.1-1 Annual Military Training Route Operations in the Affected Environment 4-6
Table 4.1-2 Comparison of Modeled No Action Alternative and Alternative under All
Scenarios Average Year Aircraft Operations at the NAS Whidbey Island
Complex 4-10
Complex 4-16
Complex 4-21
Table 4.1-5 Comparison of Alternatives under All Scenarios Average Year and No Action
Alternative for Total Aircraft Operations at the NAS Whidbey Island Complex 4-23
Table 4.2-1 Estimated Acreage and Population within the DNL Contour Ranges for the NAS
Whidbey Island Complex Alternative Average Year 4-31
Complex Alternative 4-34
Table 4.2-3 Maximum Sound Exposure Level dB and Maximum Sound Level dB for
Complex Alternative Average Year 4-47
Table 4.2-4 Number of Events Above Maximum Sound Level of 80 dB 90 dB and 100 dB
Table 4.2-6 Average Number of Events per Hour of Indoor Classroom/Learning Interference
xxix
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GRR00150193
Interest in the Vicinity of the NAS Whidbey Island Complex Alternative
Average Year 4-64
Function of Equivalent Sound Level under Alternative at NAS Whidbey Island
Complex Average Year 4-74
Table 4.2-12 Maximum Sound Exposure Level dB and Maximum Sound Level of 80 dB
90 dB and 100 dB for Representative Points of Interest in the Vicinity of the NAS
Average Year 4-110
90 dB and 100 dB for Representative Points of Interest in the Vicinity of the NAS
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GRR00150194
Average Year 4-153
Table 4.2-26 DNL Noise Contour Comparison Overall Increase in the Number of People
within the 65 dB DNL Noise Contour 4-167
Table 4.3-1 Existing Clear Zones and Conceptual APZ Develoment based on Projected
Operations at OLF Coupeville 4-176
Table 4.3-2 Total Populations Aged 19 Years or Younger at NAS Whidbey Island Complex
under the No Action Alternative and Alternative All Scenarios Average Year 4-180
Table 4.3-5 Total Populations Aged 19 Years or Younger at the NAS Whidbey Island Complex
under Alternative All Scenarios High-Tempo FCLP 4-186
Table 4.3-8 Number of Children Residing within APZs for Ault Field and OLF Coupeville
under Each Alternative/Scenario 4-192
Table 4.3-9 Schools and Licensed Daycare Centers within 65 DNL under all Alternatives All
Scenarios Average and High-Tempo FCLP 4-193
Table 4.4-1 NAS Whidbey Island Complex Emissions from Construction All Alternatives 4-196
Table 4.4-2 Stationary Direct and Indirect Criteria Pollutant Emissions All Alternatives 4-198
Table 4.4-3 NAS Whidbey Island Complex Criteria Pollutant Mobile Air Emissions
Comparison with No Action Alternative Scenario 4-199
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GRR00150195
Comparison with No Action Alternative Scenario 4-200
Comparison with No Action Alternative Alternative Scenario 4-201
Table 4.4-18 Total Change in Criteria Pollutant and GHG Emissions All Alternatives 4-216
Table 4.4-19 Total Change in Criteria Pollutant and GHG Emissions High-Tempo All
Alternatives 4-218
Table 4.5-1 NAS Whidbey Island Complex Land Use Acreage 1- within the DNL Contours2
for Alternative Scenario during an Average Year 4-223
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GRR00150196
Table 4.5-16 Land Use Acreage within Conceptual APZs for Runway 32 at OLE Coupeville 4-260
Table 4.5-17 Estimated San Juan National Conservation Area Waters Acres within the Noise
Contours under Each Alternative and Scenario Average Year 4-264
Table 4.5-18 Area of Ebeys Landing National Historical Reserve Encompassed by the Greater
than 65 dB DNL Noise Contours under the Proposed Action Acres 4-269
Table 4.5-19 Number of Events per Hour of Outdoor Speech Interference for Representative
Points of Interest at Ebeys Landing National Historical Reserve Average Year
Daytime 4-270
Table 4.5-20 Number of Annual Aircraft Noise Events with Maximum Sound Level of 100 dB
at Points of Interest in Ebeys Landing National Historical Reserve Alternative
Average Year 4-273
Table 4.5-21 Number of Annual Aircraft Noise Events with the Maximum Sound Exposure
Level or Maximum Sound Level at Points of Interest in Ebeys Landing National
Historical Reserve Alternative Average Year 4-274
Table 4.5-22 Number of Annual Aircraft Noise Events with the Maximum Sound Exposure
Level or Maximum Sound Level at Points of Interest in Ebeys Landing National
Historical Reserve Alternative Average Year 4-275
miii
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GRR00150197
Table 4.5-23 Length of the Pacific Northwest National Scenic Trail Encompassed by the
Greater than 65dB DNL Noise Contours under the Proposed Action Miles
Change 4-278
Table 4.5-24 Number of Events per Hour of Outdoor Speech Interference for Representative
Points of Interest at State Parks Average Year 4-279
Table 4.5-25 Number of Events of Outdoor Speech Interference per Nighttime Hour at
Deception Pass State Park and Fort Casey State Park 4-281
Table 4.5-26 Number of Annual Aircraft Noise Events with Maximum Sound Level above 100
dB at Seleted Park Points of Interest in the Study Area Alternative Average
Year 4-282
Year 4-283
Year 4-284
Table 4.5-29 dB DNL Contour Range at County Parks and Recreation Areas under Each
Alternative and Scenario 4-287
Table 4.5-30 dB DNL Contour Range at Municipal Parks and Recreation Areas under Each
Alternative and Scenario 4-291
Table 4.5-31 Potential Changes to Recreational Levels of Service in Skagit County as Result
of the Proposed Action 4-294
Table 4.5-32 dB DNL Contour Range at Community Gathering Places under Each Alternative
and Scenario 4-295
Table 4.5-33 Total Acreage within the Greater than 65 dB DNL Noise Contours Average Year
Change 4-297
Table 4.5-34 Summary of Impacts on Land Use and Recreation All Action Alternatives 4-298
Table 4.6-1 Definitions of Effects on Historic Properties 4-310
Table 4.8-1 Annual Time of Exposure to Growler Events Greater than or Equal to 92 dBA in
the Study Area 4-34
Table 4.8-2 Annual Time EA-18G Growler Aircraft Altitude is less than 500 feet in the Study
Area 4-351
Table 4.10-1 EA-18G Growler Personnel Loading at the NAS Whidbey Island Complex under
Each Alternative in 2021 4-372
Table 4.10-2 Regional Population Impacts Resulting from the Changes in EA-18G Growler
Personnel Loading at the NAS Whidbey Island Complex Compared to the
Affected Environment Levels 4-373
Table 4.10-3 Total Direct and Indirect Impacts Resulting from Construction Expenditures
under Each Alternative at the NAS Whidbey Island Complex 4-374
xxxiv
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GRR00150198
Table 4.10-4 NAS Whidbey Island Complex Direct Employment and Employee Earnings
Impacts Associated with Each Alternative Compared to the Affected
Environment 4-375
Table 4.10-5 Estimated Increase in Tax Revenues Resulting from the Changes in EA-18G
Growler Personnel Loading at the NAS Whidbey Island Complex Compared to
the Affected Environment Levels 4-382
Table 4.10-6 Projected Number of School-aged Children Relocating to the Region as Result
of Changes in EA-18G Growler Personnel Loading at NAS Whidbey Island
Compared to the No Action Alternative Levels 4-383
Table 4.10-7 Projected Number of School-aged Children Enrolling in the Oak Harbor School
District as Result of Changes in EA-18G Growler Personnel Loading at NAS
Whidbey Island Compared to the No Action Alternatives Levels 4-384
Table 4.11-1 Minority and Low-Income Populations in Census Block Groups Underlying Ault
Field and OLF Coupeville dB DNL Contours either Wholly or Partially Impacted
by the Greater than 65 dB DNL Noise Contour by Any Alternatives or Scenarios
Average Year 4-393
Table 4.11-2 Environmental Justice Populations at NAS Whidbey Island Complex under the
No Action Alternative Average Year 4-396
Table 4.11-3 Environmental Justice Populations at NAS Whidbey Island Complex under Clear
Zones/APZs for Ault Field and OLF Coupeville 4-402
Table 4.11-4 Environmental Justice Populations at NAS Whidbey Island Complex under
Alternative Scenario Average Year 4-403
Table 4.11-10 Environmental Justice Populations at NAS Whidbey Island under the Alternative
Scenario Average Year 4-415
Table 4.11-11 Environmental Justice Populations at NAS Whibdey Island Complex under
xxxv
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GRR00150199
Table 4.11-19 Demographic and Economic Characterstics of the Population Change from the
No Action Alternative for Each Alternative and Scenario under the Average Year
and High-Tempo FCLP Year 4-435
Table 4.11-20 Environmental Justice Populations at NAS Whidbey Island Complex under Clear
Zones/APZs for Ault Field and OLF Coupeville 4-439
Table 4.12-1 NAS Whidbey Island Trip Distribution 4-444
Table 4.12-2 NAS Whidbey Island Projected Average Daily Traffic and Level of Service 4-445
Table 4.13-1 NAS Whidbey Island Water Supply Capacity by District 4-453
Table 4.13-2 NAS Whidbey Island Area Projected Water Consumption Alternative 4-454
per
Table 4.13-3 Projected Annual Water Consumption for New Facilities at Ault Field gpd 4-455
Table 4.13-4 NAS Whidbey Island Area Wastewater Treatment Capacity 4-456
Table 4.13-5 NAS Whidbey Island Area Projected Wastewater Production 4-457
Table 4.13-6 Projected Annual Wastewater Production for New Facilities at Ault Field gpd 4-457
Table 4.13-7 NAS Whidbey Island Projected Solid Waste Production pounds per day 4-459
Table 4.13-8 NAS Whidbey Island Projected Annual Energy Consumption 4-459
Table 4.13-9 Projected Annual Electricity Consumption for New Facilities at Ault Field kWh 4-460
Table 4.13-10 Projected Annual Natural Gas Consumption for New Facilities at Ault Field
MMBTU 4-460
Table 4.16-1 NAS Whidbey Island Complex Annual GHG Emissions Alternative 4-471
Table 4.16-4 Total Change in GHG Emissions All Alternatives 4-477
Table 4.16-5 DoD Strategic Sustainability Performance Plan Objectives 4-480
Table 4.17-1 Summary of Potential Impacts to Resource Areas 4-483
Table 5-1 Other Actions Considered for Potential Cumulative Impacts Associated with the
Proposed Action for the NAS Whidbey Island Complex 5-4
Table 5-2 Total Changes in Criteria Pollutant and GHG Emissions due to Proposed Actions
NWCAA Jurisdiction 5-20
xxxvi
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GRROO1 50200
Table 6-1 Principal Federal and State Laws Applicable to the Proposed Action 6-1
Table 9-1 Distribution List 9-1
xxxvii
Table of Contents
GRROO1 50201
Appendices
Volume
Appendix Aircraft Noise Study
Appendix Air Emissions Calculations
Volume
Appendix Federal and State Agency Coordination
Volume
Appendix Transportation Trip Generation Data
Appendix Land Use Data High-tempo FCLP Year
Appendix Environmental Justice Data High-tempo FCLP Year
Appendix Civilian Airfield Analysis
Appendix Noise Mitigation
Appendix Community Health and Learning Review
Appendix 2013 Scoping Information
Appendix 2014 Scoping Information
Appendix 2016 Draft ElS Public Information Meetings
Appendix Draft ElS Public Comment and Response Key
xxxviii
Table of Contents
GRROO1 50202
Abbreviations and Acronyms
Definition Definition
Acronym Acronym
AAM Advanced Acoustic Model BGEPA Bald and Golden Eagle
Protection Act
AAD Average Annual Day
BLM Bureau of Land Management

AB Afterburner
BMP best management practice

ABD Average Busy Day
BO Biological Opinion
ACHP Advisory Council on Historic
Preservation CAA Clean AirAct
ACRP Aircraft Cooperative Research CCA Carrier Controlled Approach
Program
CEO Council on Environmental
ADT Average Daily Traffic Quality
AEMR Annual Energy Management CFR Code of Federal Regulations
Report
CH4 methane
AESO Aircraft Environmental

Cl confidence interval
Support Office
CNG Cascade Natural Gas

AFFF aqueousfilm-formingfoam
Corporation
AGL above ground level

CNEL Community Noise Equivalent
AICUZ Air Installations Compatible Level
Use Zones
CNO Chief of Naval Operations
ANSI American National Standards

CO carbon monoxide
Institute
COER Citizens of Ebeys Reserve

AOP air operating permit
CO2 carbon dioxide

APE Area of Potential Effects
C02e carbon dioxide equivalent

APZ Accident Potential Zone
CWA Clean Water Act

AQCR Air Quality Control Region
CY Calendar Year
ATC air traffic control
CZMA Coastal Zone Management Act

ATCAA Air Traffic Controlled Assigned
Airspace dB decibel
ATFP Anti-Terrorist Force Protection dBA A-weighted sound level
BASH Bird/Animal Aircraft Strike dBC C-weighted sound level
Hazard
DEIS Draft Environmental Impact
BCC Bird of Conservation Concern Statement
BCR Bird Conservation Region
xxxix
GRROO1 50203
Acronym Acronym
DERP Defense Environmental FY Fiscal Year
Restoration Program
GCA Ground Controlled Approach
DNL day-night average sound level

GHG greenhouse gas
also known as Ldn
HAP hazardous air pollutant

DNWG U.S Department of Defense
Noise Working Hz hertz

Group
DoD U.S Department of Defense IBA Important Bird Area
DoDI United States Department of ICRMP Integrated Cultural Resources
Defense Instruction Management Plan
DPS Distinct Population Segment IFLOLS Improved Fresnel Lens Optical
Landing System
EA Environmental Assessment
IFR Instrument Flight Rule
e.g for example
in/sec inches per second

ElS Environmental Impact
Statement INRMP Integrated Natural Resources
Management Plan
EMS emergency medical service
IPaC Information for Planning and

EO Executive Order
Conservation
ESA Endangered Species Act

IR Instrument Flight Rules
ESU Evolutionarily Significant Unit Military Training Route
FAA Federal Aviation ISO International Organization for
Administration Standardization
FCLP field carrier landing practice JLUS joint land use study
FEMA Federal Emergency lbf pound-force
Management Agency
average sound
Ldn level
day-night
FICON Federal Interagency also known as DNL

Committee on Noise
Leq Equivalent Sound Level
FICUN Federal Interagency

Leq8 8-hour Equivalent Sound Level
Committee on Urban Noise
Leq24 24-hour Equivalent Sound

FMR Fair Market Rent
Level
FONSI Finding of No Significant

Lmax maximum A-weighted sound
Impact
level
FRS Fleet Replacement Squadron

LID low-impact development
FWHCAs Fish and Wildlife Habitat

LOS level of service
Conservation Areas
xl
GRROO1 50204
Acronym Acronym
LSO Landing Signal Officer Navy U.S Department of the Navy
LTO landing and takeoff operation NAWS Naval Air Weapons Station
MAGIC Maritime Augmented NDI Noise Depreciation Index
CARPET Guidance with Integrated

NEPA National Environmental Policy
Controls for Carrier Approach
Act
and Recovery Precision
Enabling Technologies now NHPA National Historic Preservation
known as Precision Act

Landing
Mode
NIPTS Noise Induced Permanent
MBTA Migratory Bird Treaty Act Threshold Shift
MCAS Marine Corps Air Station nm nautical miles
liPa Micropascal nm2 square nautical miles
mgd million gallons

per day NMFS National Marine Fisheries
Service
MLS Multiple Listings Service
NO2 nitrogen dioxide

MMPA Marine Mammal Protection
Act NO nitrogen oxides
MOVES Motor Vehicle Emission NPDES National Pollutant Discharge
Simulator Elimination System
mph miles per hour NPS National Park Service
MoA Memorandum of Agreement NRHP National Register of Historic
Places
MOA Military Operations Area
NRNW FES Navy Region Northwest Fire

MSAT Mobile Source Air Toxics
and Emergency Services
MSL mean sea level
N20 nitrous oxide
MT metric ton
NWCAA Northwest Clean Air Agency
MTCO2e metric tons carbon dioxide

NWR National Wildlife Refuge
equ iva lent
NWSTF Naval Weapons Systems

MTR military training route
Training Facility
NA number of events above

NWTRC Northwest Training Range
specific sound level
Complex
NAAQS National Ambient Air Quality

NWTT Northwest Training and
Standards
Testing
NAF Naval Air Facility

OEIS Overseas Environmental
NAS Naval Air Station Impact Statement
xli
GRROO1 50205
Acronym Acronym
OLE outlying landing field RTPO Regional Transportation
Planning Organization
OPNAVINST Office of the Chief of Naval
Operations Instruction SAR search and rescue
OU Operable Unit SCOG Skagit Council of Governments
PEAS per- and polyfluoroalkyl SDZ Surface Danger Zone
substances
SEL sound exposure level
PEC perfluorinated compound

SH P0 State Historic Preservation
PEOA perfluorooctanic acid Officer
PEOS perfluorooctane sulfanate SIP State Implementation Plan
PHL Potential Hearing Loss SO2 sulfur dioxide
PLM Precision Landing Mode aka SPBHD Seaplane Base Historic District
MAGIC CARPET
SPCC Spill Prevention Control and
PM2.5 particulate matter less than or Countermeasures
equal to 2.5 microns in

SPL Sound Pressure Level
diameter
SR State Route
PM10 particulate matter less than or
equal to 10 microns in STIP Statewide Transportation
diameter Improvement Program
P01 point of interest SUA Special Use Airspace
POV Personally Owned Vehicles TCP traditional cultural property
PSD Prevention of Significant TG touch-and-go
Deterioration
TACAN Tactical Air Navigation
PSE Puget Sound Energy

UA usual and accustomed
PUD Public Utility District

UEC Unified Eacility Criteria
RCW Revised Code of Washington

UIC Underground Injection Control
RDTE Research Development Test

U.S.C United States Code
and Evaluation
U.S United States

REPI Readiness and Environmental
Protection USACE United States Army Corps of

Integration
Engineers
ROD Record of Decision
USDA United States Department of

RTIP Regional Transportation
Agriculture
Improvement Program
USEPA United States Environmental
Protection Agency
xlii
GRROO1 50206
Acronym Acronym
USFS United States Forest Service WAC Washington Administrative
Code
USFWS United States Fish and Wildlife
Service WDFW Washington Department of
Fish and Wildlife

VFR Visual Flight Rules
WGMA Washington State Growth

VOC volatile organic compound
Management Act
VO Fleet Air Reconnaissance

WHO World Health Organization
VR Visual Flight Rules Military

WSDOT Washington State Department
Training Route
of Transportation
xliii
GRROO1 50207
making regarding fixed-wing aircraft Consequently the Navy is

continuing to utilize the latest
version of NOISEMAP for modeling
Wyle Report WR-1304 describes the potential benefits of AAM and limitations of NOISEMAP for
assessing next-generation aircraft primarily differentiated by vectored thrust ability and higher
maximum thrust These factors apply primarily to fifth-generation aircraft such as the F-22 and
F-35 The F-22 is capable of generating more than 35000 pounds of force lbf from each of its
two engines The F-35 produces 43000 lbf of thrust from its single engine The Growler utilizes
two General Electric F414-GE-400 engines with reported thrust of 22000 lbf with afterburner
significantly lower than the next-generation fighter aircraft For comparison of historical aircraft
the maximum thrust for each of the two engines of the F-15C is 23700 lbf with afterburner
while the F-14s two engines were each capable of 28200 lbf with afterburner For comparison
to aircraft that historically operated at NAS Whidbey Island the Prowler engines generated
10400 lbf of thrust
Other Noise Reports Several other noise reports are available that examine both measured and
experiential noise in the areas near and far from NAS Whidbey Island These include the NPS
Acoustic Monitoring Report for Ebeys Landing National Historical Reserve 2016 the Dahlgren
Report on Combat Jet Noise from Landing and Taking Off at Whidbey Island 2015 the JGL
Acoustics Inc report Whidbey Island Military Jet Noise Measurements JGL Acoustics Inc
2013 and the San Juan County Jet Aircraft Noise Reporting 2014 to present and they are
discussed in Section 1.12 The results of these noise reports have not been incorporated into the
ElS because these results have not been peer reviewed and in some cases do not use empirical
data although the results of the NPS Acoustic Monitoring Report dated August 2016 appear to
be consistent with the Navys previous noise analyses Furthermore the National Park Services
NPSs monitoring report demonstrates that while military aircraft are loud military aircraft
operations are highly intermittent with long periods of no military aircraft activity
Nonauditory Health Effects The ElS analysis considers the potential for aircraft noise to impact
ones health as discussed throughout Section 4.2 and Appendix The nonauditory health
effects literature review was expanded using journals and research referred to by the
Washington State Department of Health the USEPA and the public in their comment letters
More complete information added with respect to the following topics includes but is not
limited to hypertension and cardiovascular health lack of sleep stress and anxiety Details can
be found in Appendix
Numerous epidemiological studies and meta-analyses have been conducted on the long-term
health impacts of exposure to noise The basic premise of these studies is that noise can cause
annoyance annoyance can cause stress and prolonged stress is known to be contributor to
number of health disorders such as hypertension myocardial infarction heart attack
cardiovascular disease and stroke
1974 study confirmed that noise can provoke stress but noted that results on its effect on
cardiovascular health were contradictory Some studies in the 1990s found connection
between aircraft noise and increased blood pressure while others did not This inconsistency in
results led the WHO in 2000 to conclude that there was only weak association between long-
term noise exposure and hypertension and cardiovascular effects and that dose-response
relationship i.e the change in effect on an organism based on differing levels of
exposure could not be established WHO 2000
1-37
Purpose and Need for the Proposed Action
GRROO1 50245
focuses on the facilities and functions to support Growler operations at the NAS Whidbey Island
complex
Throughout the NEPA process the Navy sought to provide timely information for public transparency
Because the Draft did not include Preferred Alternative the Navy took steps to announce the
Preferred Alternative as soon as it was determined On June 25 2018 the Navy identified Alternative
Scenario as the Preferred Alternative ahead of the publication of the Final Alternative Scenario
provides the best training for Navy pilots and impacts the fewest number of residents living in the
community See Section 2.4 for more detail on the Preferred Alternative
The next step in the process is Record of Decision which will occur no sooner than 30 days
following the publication of the Final While and Council on Quality
regulations required public comment on the Draft the regulations do not require public comment
period following the release of the Final The Navy considered all
4335 public comments received on
the Draft and refined the Final with updated information that improves the accuracy and
thoroughness of the Final analysis Although the conclusions of the Draft and Final remain the
same the operational changes announced in September 2017 i.e the reduced number of pilots as
defined by the latest information on the enhanced Attack mission and the implementation of
Precision Landing Mode also known as Maritime Augmented Guidance with Integrated Controls
for Carrier Approach and Recovery Precision Technologies CARP had an overall
benefit of lessening the impacts across all alternatives and scenarios The Final provides clarifications
and identifies changes that were made to the Draft see Section 1.13 The Navy response to public
comment is
provided in Appendix
2.2 Development of the Range of Action Alternatives
In developing the proposed range of alternatives that meet the purpose of and need for the Proposed
Action the Navy carefully reviewed important considerations for the Growler community and Navy
aviation training in addition to considering public comments This review included requirements for
Growler squadron training in light of Title 10 responsibilities existing training requirements and
regulations existing Navy infrastructure and CNO guidance to support operating naval forces
Considerations included
The NAS Whidbey Island complex is home to the Navys Growler mission including the training
squadron all U.S.-based squadrons and substantial infrastructure and training ranges that have
been established during the past 45-plus years and as supported by previous analysis
regarding Growler operations
location of suitable airfields that provide for the most realistic training environment
distance aircraft would have to travel to accomplish training
of duplicating capabilities that already exist at Ault Field

expense
operational readiness and synergy of the small Growler community
access to training ranges Special Use Airspace SUA and military training routes
effective use of existing infrastructure
management of aircraft inventories simulators maintenance equipment and logistical support
effective use of personnel to improve operational responsiveness and readiness
2-2
Proposed Action and Alternatives
GRROO1 50290
Table 2.6-1 Summary of Alternatives Considered in the Environmental Impact Statement
for EA-18G Growler Airfield Operations at the Naval Air Station Whidbey Island Complex
No Action No new Growler Total No new personnel
Alternative aircraft 84700 existing personnel
Existing aircraft Ault Field 4104 existing
No new carrier 78200 dependents 5627

Growler squadrons 45 OLF Coupeville
Aircraft aircraft 6500

Expeditionary
squadrons 15
aircraft
Reserve
Squadron
aircraft
FRS 17 aircraft
Alternative new aircraft to Total 335 personnel Scenario 20/80
each existing Scenario 112600 Scenario 50/50
35 carrier squadron Scenario 111200 459 Scenario 80/20
Additional new training Scenario 109800 dependents Scenario 30/70
Growler aircraft for FRS Scenario Scenario 70/30

112200
Aircraft Scenario 110100
Ault Field
Scenario 87300
Scenario 95300
Scenario 103200
Scenario 90000
Scenario 100400
OLF Coupeville
Scenario 25300
Scenario 15900
Scenario 6600
Scenario 22200
Scenario 9700
2-25
GRR00150313
Alternative new Total 628 Scenario 20/80
expeditionary Scenario 112100 personnel Scenario 50/50
36 squadrons 10 Scenario 110700 Scenario 80/20

Additional new aircraft Scenario 109500 860 Scenario 30/70
Growler additional Scenario dependents Scenario 70/30

111800
Aircraft aircraft to each Scenario 110000
existing carrier Ault Field
squadron 18 Scenario 88000

new aircraft Scenario 95500
8newtraining Scenario 103200
aircraft for FRS
Scenario 90600
Scenario 100700
OLF Coupeville
Scenario 24100
Scenario 15200
Scenario 6300
Scenario 21200
Scenario 9300
Alternative additional Total 341 Scenario 20/80
aircraft to each Scenario 111800 personnel Scenario 50/50
36 existing Scenario 110500 Scenario 80/20

Additional expeditionary Scenario 109200 467 Scenario 30/70
Growler squadrons Scenario dependents Scenario 70/30

111400
Aircraft new aircraft Scenario 109600
additional Ault Field
aircraft to each Scenario 87700

existing carrier Scenario 95300
squadron 18 Scenario 102900
new aircraft
Scenario 90300
9newtraining Scenario 100300
aircraft for FRS
OLF Coupeville
Scenario 24100
Scenario 15200
Scenario 6300
Scenario 21100
Scenario 9300
2-26
GRR00150314
Notes
Since the publication of the Draft ElS two new operational scenarios for each action alternative have been
added to the analysis In addition several updates were applied to the noise analysis that included
incorporation of Precision Landing Mode which reduced FCLP requirements by approximately 20 percent
across all scenarios and led to reduction in FCLP operations and updating the number of pilots per squadron
reduction see Section 1.13
Total airfield operations are considered all aircraft operations that occur and these include Touch-and-Goes
Depart and Re-enter Ground Controlled Approaches and FCLPs Total airfield operations include all aircraft for
Ault Field and OLF Coupeville
Total operations may differ between alternative and scenario due to variability in
training requirements and
randomness inherent in modeling
Key
FCLP field carrier landing practice
FRS Fleet Replacement Squadron
N/A not applicable
LF Outlying Landing Field
2-27
GRR00150315
Pattern Operation
An aircraft arrival followed by departure Each pattern is considered two operations the
landing or approach is counted as one operation and the takeoff is counted as another Pattern
operations include the following types
Touch-and-Go
An runway and takes off without

aircraft lands on coming to full stop After
touching down the pilot immediately goes to full power and takes off again
Field Carrier Landing Practice
The required flight training that immediately precedes and qualifies aircrews for
carrier-landing operations These operations are conducted on runway that
simulates an aircraft carrier flight deck FCLP is generally flown in left-hand
closed-loop racetrack-shaped pattern ending with TG landing or low approach
with the Landing Signal Officer present and grading the proficiency of the pilot The
pattern should simulate as closely as practicable the conditions aircrews would
encounter during actual carrier landing operations at sea see Figure 3.1-6
Ground Controlled Approach/Carrier Controlled Approach
An aircraft lands with guidance from ground-based air traffic controllers to practice
and conduct arrivals under actual or simulated adverse-weather conditions Air
traffic controllers provide aircrews with verbal course and elevation information
allowing them to make an instrument landing during IFR conditions Ground
Controlled Approach GCA training is conducted in both IFR and VFR conditions to
provide realistic training for both Navy aircrews and air traffic controllers Carrier
Controlled Approach training is similar to GCA but with the Landing Signal Officer
present
Figure 3.1-6 Standard FCLP Pattern Altitudes AGL
uh rtu rd
urn Lp Hi
trt tur
itt ni
un eef
MN
3-12
Affected Environment
GRROO1 50328
For this the Navy used the Naval Aviation Simulation Model as the best available tool for modeling
operational capacity of the airfield flight operations because it provides operational data input to the
noise model and supports assessment of airspace and airfield operations As part of the noise analysis
flight operations were modeled for an average year at Ault Field and OLF Coupeville An average year
represents conditions that are projected to occur on an annual basis i.e typical operating tempo at
the NAS Whidbey Island complex The number and type of flight operations in the affected
environment for the NAS Whidbey Island complex are those associated with calendar year 2021 which
represents the operations after the transition from the P-3C Orion to the P-8A Poseidon aircraft thereby
isolating the changes in the operational environment for this Proposed Action Therefore the affected
environment is the same as the No Action Alternative in which no additional Growlers are stationed at
NAS Whidbey Island In addition to average year operations high-tempo FCLP year data are provided for
the purpose of qualitative analysis when FCLP activity would be expected to increase over average
conditions The high-tempo FCLP year represents conditions when during the period modeled for this
noise study the most FCLPs were expected to occur
3.1.2.2.1 Average Annual Airfield Operations
The affected environment 2021 for airfield flight operations is reflected in Table 3.1-3 During scoping
some commenters suggested that the noise analysis for OLF Coupeville should use concept found in
the Navys Air Installations Compatibility Use Zones AICUZ Instruction Chief of Naval Operation
Instruction 11010.36C known as Average Busy Day ABD This 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 The Navy believes the ABD
is inappropriate for this document First it should be noted that ABD is an operational-level concept
devised in the AICUZ program and the intent of the AICUZ instruction is to help prevent incompatible
development from affecting the flying mission of Navy airfield The AICUZ program encourages the use
of the most conservative assumptions regarding projected airfield operations in order to prevent future
encroachment even if future operational assumptions may be somewhat speculative Consequently
this underlying goal to prevent incompatible encroachment can result in overstated noise impacts The
intent of this is to support informed decision-making regarding the Proposed Action not to support
the AICUZ programs goals to prevent incompatible encroachment Therefore this uses the best
available science as required under NEPAto develop an accurate analysis of potential noise impacts
from the Proposed Action Moreover because of the interaction between Ault Field and OLF Coupeville
an accurate analysis requires common measure In several alternatives the noise contours of Ault
Field and OLF Coupeville merge and using different units of measure at each airfield would result in
inaccuracy to the noise analysis It would provide two results that are not directly comparable Finally
the alternatives and particularly the sub-alternatives that provide for greater operations at OLF
Coupeville would make the ABD an inappropriate measure based on volume of operations As the
AICUZ instruction notes the yearly average noise level known as Average Annual Day AAD is the
preferred unit of measure that the Navy believes accurately represents the noise impacts that may arise
from the Proposed Action The ABD metric is controversial due to the potential for inaccuracy noted
above Finally the U.S Air Force which first adopted the ABD metric in 1977 has eliminated it from the
Air Force AICUZ instruction Air Force Instruction 32-7063 Air Installations Compatible Use Zones
Program dated December 18 2015 and the Air Force Noise Program instruction Air Force Instruction
32-7070 Air Force Noise Program April 21 2016 specifies the use of AAD The day-night average sound
level DNL noise zones are based on the AAD level in accordance with U.S Department of Defense
3-13
Affected Environment
GRROO1 50329
90 dB and 100 dB for Representative Points of Interest in the Vicinity of the NAS Whidbey
Island Complex Alternative Average Year12
ROl Ivan Rd Above 80dB 57195 60310 63748 58335 62611
8884 11999 15437 10024 14300

Above 90dB 51303 54666 58108 52501 56943
7700 11063 14505 8898 13340

Above 100 dB 34324 38067 41750 35408 40454
4125 7868 11551 5209 10255

R02 SaIaISt.andN Above8OdB 46046 48993 53184 47455 51999
Northgate Dr 7154 10101 14292 8563 13107

Above 90 dB 42152 45574 49955 43774 48683
6094 9516 13897 7716 12625

Above 100 dB 6221 5821 6376 6827 6457
1450 1050 1605 2056 1686

R04 PullandBeDamned Above80dB 6310 6142 5928 5991 5928
Point 1325 1157 943 1006 943
Above 90 dB 444 414 414 418 414
74 44 44 48 44
Above 100 dB
R05 Snee-Oosh Point Above 80 dB 3616 3616 3454 3454 3454

849 849 687 687 687
Above 90 dB
Above 100 dB
R06 Admirals Dr and Byrd Above 80 dB 12206 7642 3061 10689 4594
Dr 9105 4541 -40 7588 1493
Above 90 dB 10798 6770 2709 9462 4064
8349 4319 258 7011 1613
Above 100dB 7712 4703 1908 6665 2863
5485 2476 -319 4438 636

R07 Race Lagoon Above 80dB 4702 3108 1242 4220 1842
3764 2170 304 3282 904

Above 90 dB 3248 2170 842 2941 1263
3018 1940 612 2711 1033

Above 100 dB 2521 1683 653 2282 980
2338 1500 470 2099 797

R08 Pratts Bluff Above 80dB 3663 2448 950 3317 1426
3295 2080 582 2949 1058

Above 90dB 905 607 235 821 353
682 384 12 598 130

Above 100 dB
-65 -65 -65 -65 -65
4-97
Environmental Consequences
GRROO1 50671
RiO Skyline Above8OdB 2164 2090 2337 2341 2337
616 542 789 793 789

Above 90 dB
Above 100 dB
R14 E.Sleeper Road and Above 80dB 47129 51097 54232 48325 53007
Slumber Lane 6613 10581 13716 7809 12491
Above 90 dB 11023 13584 16019 11553 15121
803 3364 5799 1333 4901

Above 100 dB
R15 LongPointManor Above 80dB 4864 3327 1669 4429 2224

2340 803 -855 1905 -300
Above 90 dB 4315 2819 1107 3862 1661
3468 1972 260 3015 814

Above 100 dB 2180 1461 566 1976 849
2139 1420 525 1935 808

R16 Rocky Point Heights Above 80 dB 1976 1879 2026 2047 2026
451 354 501 522 501

Above 90 dB 65 81 65 65 65
-4 12 -4 -4 -4
Above 100 dB
R19 Island Transit Offices Above 80 dB 12271 7722 3126 10755 4659
Coupeville 9099 4550 -46 7583 1487
Above 90 dB 11856 7444 3018 10378 4497
9444 5032 606 7966 2085
Above 100 dB 4315 2819 1107 3862 1661
3468 1972 260 3015 814

R20 South Lopez Island Above 80 dB 147 136 156 157 156
Agate Beach 35 24 44 45 44
Above 90 dB
Above 100 dB
S0i Oak Harbor High School Above 80 dB 635 952 998 796 958
-362 -45 -201 -39

Above 90 dB
Above 100 dB
4-98
GRROO1 50672
S02 Crescent Harbor Above 80 dB 5685 5423 5871 5922 5871

Elementary School
_____________
1249 987 1435 1486 1435
Above 90 dB 5261 4884 5395 5445 5395
1304 927 1438 1488 1438

Above 100 dB
S03 Coupeville Elementary Above 80 dB 2937 1786 726 2534 1091

School 1085 -66 -1126 682 -761
Above 90 dB
-316 -316 -316 -316 -316

Above 100 dB
S04 Anacortes High School Above 80 dB 147 136 156 157 156
35 24 44 45 44
Above 90 dB
Above 100 dB
S09 La Conner Elementary Above 80 dB 400 412 389 392 389
School 48 60 37 40 37
Above 90 dB
Above 100 dB
.on Pass State dB .b 1323 10141 12114

Park 784 1836 4258 1791 3764
Above 90 dB 5741 6709 8943 6620 8477
262 1230 3464 1141 2998

Above 100dB 5558 6587 8895 6455 8406
109 1138 3446 1006 2957

P03 Dugualla State Park Above 80 dB 18577 21094 22329 19029 21650
2299 4816 6051 2751 5372

Above 90 dB
Above 100 dB
P04 Ebeys Landing Above 80 dB 12271 7722 3126 10755 4659

Rhododendron Park 9099 4550 -46 7583 1487
Above 90 dB 12206 7642 3061 10689 4594
9103 4539 -42 7586 1491
Above 100 dB 4315 2819 1107 3862 1661
1595 99 -1613 142 -1059
4-99
GRROO1 50673
P06 Fort Casey State Park Above 80 dB 7476 4544 1847 6451 2770
5287 2355 -342 4262 581
Above 90 dB
-547 -547 -547 -547 -547

Above 100 dB
PlO San Juan Island Above 80 dB 568 556 649 653 649
National Monument 87 75 168 172 168

Above 90dB
Above 100dB
P13 LakeCampbell Above8OdB 183 242 302 305 302
-74 -12 48 51 48
Above 90dB
Above 100dB
P15 PioneerPark Above8OdB 444 414 414 418 414
74 44 44 48 44
Above 90dB
Above 100dB
P17 Reuble Farm Above 80dB 11865 7419 2974 10384 4462
8804 4358 -87 7323 1401
Above 90dB 7476 4544 1847 6451 2770
5835 2903 206 4810 1129
Above 100dB 5606 3408 1385 4838 2078
4913 2715 692 4145 1385
P18 Ferry House Above 80 dB 1869 1136 462 1613 692
689 -44 -718 433 -488

Above 90dB
Above 100dB
4-100
GRROO1 50674
Notes
The difference between the No Action Alternative and Alternative is noted in parentheses for the number of
events above the specified noise
POls that had zero events above an Lmax of 80 dB 90 dB and 100 dB were omitted from the table These included
POls R03 R09 Rh R12 R13 R17 R18 S05 S06 S07 S08 SlO P01 P05 P07 P08 P09 P11 P12 P14 and P16
Key
dB decibel
Lmax maximum sound level
4.2.3.2.2 Speech Interference Indoor Alternative
Conversation or indoor speech is assumed to be interrupted when single aircraft event exceeds the
maximum sound level or Lmax of 50 dB indoors Sharp et al 2009 Normal conversation is about 60 dB
therefore the use of 50 dB indoor level is
very conservative threshold such that soft speaking voice
could be heard For this analysis the model calculated the number of events occurring per daytime hour
700 a.m to 1000 p.m that are greater than the maximum sound level or Lmax of 50 dB at the 20
residential POls and the 10 schools since they are commonly located in residential areas Because the
individual is assumed to be indoors for this analysis noise level reduction factors were applied because
the walls doors insulation and other building features reduce the noise levels inside The analysis was
conducted assuming both windows-open and windows-closed conditions Table 4.2-13 presents the
average daily 700 a.m to 1000 p.m events per hour that exceed an Lmax of 50 dB indoors at these
POls under Alternative all scenarios
Compared to the No Action Alternative Alternative would result in between zero and two additional
events per hour at representative POls during which conversations or indoor speech would be
interrupted The largest change with two additional events per daytime hour would occur at several
POls including ROl R02 R06 R07 R08 R14 and R15 under various scenarios However there are
several POls at which no change would occur under any of the scenarios compared to the No Action
Alternative
4-101
GRROO1 50675
Case 2:19-cv-01059-RAJ-JRC Document 36-1 Filed 02/13/20 Page 57 of 122 01_U SEPA-02
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY .a Thank You

11 .d Per- and Polyfluoroalkyl Substances
1200 Sixth Avenu Suite 900
Seattle WA98101-3140
ENW OFFICEOF 2.c Compliance

4.f
4.r
with the National
Noise Measurements/Modeling/On-Site
Nonauditory Health Effects

Environmental Policy
Validation
Act
March 82017 4.s Health Impact Assessment and Long-term Health Study
Requests
6.b National Ambient Air Quality Standards Compliance
Ms Lisa Padgett 6.c Hazardous Air Pollutant Compliance
EA-18G Growler EIS Project Manager 6.d Air Operating Permit
Naval Facilities Engineering Command Atlantic
6506 Hampton Boulevard

Norfolk Virginia 23508
Attn Code EV2I/SS
Dear Ms Padgett
The U.S Environmental Agency has reviewed the Draft Environmental Impact Statement
Protection for
the U.S Department Navy EA- 8G Growler Airfield Operations at the Naval Air Station
of the
Whidbey Island Complex EPA Region 10 Project Number 13-0030-DOD We are submitting
comments on the DEIS in accordance with our responsibilities under the National Environmental Policy
Act and Section 309 of the Clean Air Act We sincerely appreciate the Navys efforts to prepare this
NEPA analysis conduct outreach and encourage public and agency participation and facilitate the
document review with briefings and an extended review period We honor the courage and commitment
of our armed forces and respect the Navys mission and responsibilities in support of our Nations
defense
The DEIS discusses the Navys proposal to expand the existing BA-i 8G Growler fleet operations at
NASWI complex by adding 35 or 36 aircraft to augment the current electronic warfare capabilities Pilot
training exercises include field carrier landing practices at Ault Field and Outlying Landing Field
Coupeville In support of the Growler fleet expansion the Navy would also construct and renovate
facilities at Ault Field in order to accommodate additional Growler aircraft and station additional
military personnel and their families at NASWI and/or in the surrounding communities The different
alternatives would vary the assignment of additional aircraft among the expeditionary carrier and/or
Fleet Replacement squadrons Scenarios and can be paired with any of Action Alternatives
Scenario would conduct 80% of FCLPs at OLF Coupeville and 20% at Ault Field Scenario would
conduct 50%
OLF Coupeville and 50% at Ault Field and
at Scenario would conduct 20% at OLF
Coupeville and 80% at Ault Field Per Alternative or respectively the Navy would station 371
664 or 377 additional personnel and 509 910 or 894 family members at NASWI and in the
surrounding communities
Based on the information provided the EPA is

rating the DEIS as EC-2 Environmental Concerns with
insufficient information An explanation of the EPA Rating System for the DEIS is enclosed The EPA
acknowledges the use of best management practices referenced in the DEIS for the management of noise
and appreciates the Navys efforts to inform members of the public of the upcoming FCLPs and the
procedures the community can follow for noise complaints However the DEIS does not contain
sufficient information to fully assess the environmental impacts that should be avoided to fully protect
the enviroment and nearby communities and we recommend that additional information and discussion
be included in the final EIS as described below Our recommendations are offered to assist the Navy in
GRROO 151256
completing its environmental review and to help ensure that the overall analysis fully assesses potential
environmental impacts and available mitigation measures to protect human health and the environment
as required by NEPA while also meeting the Navys need to run FCLP drills with an expanded fleet
The EPA recommends that the Navy establish monitoring program to verify that actual noise impacts
are similar to those projected in this EIS As part of this monitoring program protocol should be
established that outlines when or if

adaptive management measures are required The EPA believes this
on-the-ground validation would help provide an assessment of actual noise impacts projected to be
experienced by Whidbey Island and surrounding area residents and wildlife due to the proposed
expansion For example monitoring sensitive receptor sites within each projected DNL noise contour of
65dB and greater may help characterize more fully the actual duration frequency and intensity of
exposures to noise-related impacts within these loudest projected contour zones
We recommend that the noise monitoring discussed above be accompanied by supplemental health
assessment1 of the affected population to characterize baseline conditions and projected health impacts
of the proposed action to inform pathway forward We would be happy to help convene agencies and
organizations for this assessment
In addition according to the EIS these source air pollutant emissions contribute to regional
emission totals and can affect compliance with the NAAQS The final EIS should clarify how this will
or will not affect the attainment status for this region The EPA also recommends that the final EIS
include an assessment of the hazardous air pollutants and as appropriate discussion of the Navys
to mitigate for the additional emissions also be to include in Table 3.4-3 the permit
plans It
may helpful
requirement thresholds for each criteria pollutant
The EPA appreciates the information about the ongoing investigation to remove dispose and replace
legacy aqueous film forming foam that contains perfluorooctane sulfonate and/or perfluorooctanoic acid
As part of the final BIS the EPA requests that the Navy identify measures being taken to prevent further
contamination to the sole source aquifer from legacy or new firefighting chemicals
We have provided list of studies on health effects and wildlife impacts that may be useful in the
analysis of impacts associated with noise.2 The EPA recommends that these studies be considered and
EPAs Health Impacts Assessment page https//www.epa.gov/healthresearch/health-impact-assessments and Minfnum

Elements and Practice Standards for Healih lmpactAssessment September 2014
%203.0.pdf each contain helpful best practices and information about conducting such assessments
Noise Studies
Domes Lisa RN and Hagler Louis MD Noise Pollution Modern Plague Southem Medical Journal Volume
100 March 2007 pages 287-294
WHO 2010 Burden of Disease from Environmental Noise Quantfication of Healthy Lfe Years Lost in Europe
The World Health Organization www.euro.who.mnt at
www.euro.who.mnt/_dataassets/pdf_file/0008/l36466/e94888.pdf
Health effects caused by noise Evidence in the literature from the past 25 years Noise Health
Ising Kruppa
2004 65-13
Stansfeld Stephen and Matheson Mark Noise pollution non-auditory effects on health British Medical
Bulletin 2003 68 243-257
C.D Francis J.R Barber Fromeworkfor Understanding Noise Impacts on Wildlife An urgent Conservation
Boise University Scholar

12013 State Works Department of Biological Sciences
Priority August
GRROO 151257
included in the EIS as appropriate If the Navy becomes aware of new relevant information that can
augment the existing EIS analyses the EPA requests that the new information be included and discussed
in the final EIS Furthermore it

may also be helpful if the information related to health effects from
noise is consolidated into one section in the EIS in order to provide the complete context of the issue
The EPA appreciates the opportunity to review this DEIS We would welcome the opportunity to meet
with the Navy to discuss our comments in greater detail If you would like to schedule such meeting or
have questions regarding our comments please contact Elaine Somers of my staff at 206-553-2966 by
email at
somers.elaineepa.gov or you may contact me at 206-553-2581 or by email at
a1lnutt.davidepa.gov
Sincerely
David Allnutt Director
Office of Environmental Review and Assessment
Enclosure Summary of EPA Rating Definitions
Shannon Graeme at
et synthesis of Iwo decades of research documenting the effects of noise on wildlfe
Biological Reviews 912016982-1005
GRROO 151258
U.S Environmental Protection Agency Rating System for
Draft Environmental Impact Statements
Definitions and Follow-Up Action
Environmental Impact of the Action
LO Lack of Objections
The U.S Environmental Protection Agency EPA review has not identified any potential environmental inspacts
The review have of

requiring substantive changes to the proposal may disclosed opportunities for application mitigation
measures that could be accomplished with no more than minor changes to the proposal
EC Environmental Concerns
EPA review has identified environmental impacts that should be avoided in order to fully protect the environment
Corrective measures of measures can reduce

may require changes to the preferred alternative or application mitigation that
these impacts
EO Environmental Objections
EPA review has identified significant environmental impacts that should be avoided in order to provide adequate
protection for the environment Corrective measures may require substantial changes to the preferred altemative or
consideration of some other

project alternative including the no-action alternative or new alternative EPA intends to work
with the lead agency to reduce these impacts
EU Environmentally Unsatisfactory
EPA review has identified adverse environmental impacts that are of sufficient magnitude that they are unsatisfactoiy
from the standpoint of public health or welfare or environmental quality EPA intends to work with the lead agency to reduce
these impacts If the are not corrected at the final EIS this will be
potential unsatisfactory impacts stage proposal
recommended for referral to the Council on Environmental Quality CEQ
Adequacy of the Impact Statement
Category Adequate
EPA believes the draft EIS adequately sets forth the environmental impacts of the preferred alternative and those of the
alternatives reasonably available to the projector action No further analysis of data collection is
necessary but the reviewer
may suggest the addition of clarifying language or information
Category Insufficient Information
The draft EIS does not contain sufficient information for EPA to fully assess environmental that should be
impacts
avoided in order to fully protect the environment or the EPA reviewer has identified new reasonably available alternatives that
are within the spectrum of alternatives analyzed in the draft EIS which could reduce the environmental impacts of the action
The identified additional information data or discussion should be included in the fmal hIS
analyses
Category 3Inadequate
EPA does not believe that the draft EIS adequately assesses potentially significant
environmental impacts of the action or
the EPA reviewer has identified new reasonably available alternatives that are outside of the spectrum of alternatives analyzed
in the draft EIS which should be analyzed in order to reduce the potentially significant environmental impacts EPA believes
that the identified additional information of such

data analyses or discussions are magnitude that they should have full
public review at draft stage EPA does not believe that the draft EIS is adequate for the
purposes of the National
Environmental Policy Act and or Section 309 review and thus should be formally revised and made available for public
comment in supplemental or revised draft EIS On the basis of the potential significant impacts involved this proposal could
be candidate for referral to the CEQ
From EPA Manual 1640 Policy and Procedures for the Review of Federal Actions Impacting the Environment February
1987
GRROO 151259
Case 2:19-cv-01059-RAJ-JRC Document 36-1 Filed 02/13/20 Page 61 of 122 02_WADOH -05
l.a Thank You
.d General Project Concerns

12.n Quality of Life
2.g Agency Participation
4.b NOISEMAP Model Modeling Methodology and Noise Sources
4.c Advanced Acoustic Model

4.d Day-Night Average Sound Level Metric
4.f Noise Measurements/Modeling/On-Site Validation
4.h C-Weighted Noise Low Frequency Noise and Vibrations

4.j Other Reports
February 24 2017 4.m Supplemental Metrics
4.0 Classroom Learning Interference

EA-18G Growler EIS Project Manager
4.p Sleep Disturbance
4.q Potential Hearing Loss

6506 Hampton Boulevard
4.r Nonauditory Health Effects
Norfolk VA 23508
Attn Code 4.s Health Impact Assessment and Long-term Health Study
EV21/SS
Requests
Subject Comments on the Environmental Impact Statement for EA-1SG Growler Airfield
at Naval Air Station Whidbey Island

Operations
Thank you for the opportunity to comment on the draft environmental impact statement DEIS for the
of EA-18G Growler airfield at the Naval Air Station Whidbey Island

proposed expansion operations
complex As the state health department we are interested in the impact this project will have on the
health and well-being of people in Washington State
As noted in the DEIS this project may result in negative impacts to the publics health from changes in
noise air quality use of hazardous materials and increasing greenhouse gases This project may also
impact social determinants of health such as employment education and transportation Though these
potential impacts are all important to the overall health of the public our comments will focus on the
potential for non-auditory community health impacts from noise associated with the aircraft We have
chosen this focus for our comments because we have received multiple inquiries complaints and
from groups concerned about potential health impacts from

for assistance
requests local community
aircraft noise Current scientific literature that noise at levels similar to those reported on
suggests
Whidbey Island associated with sleep disturbance cognitive impairment and adverse
is
annoyance
cardiovascular outcomes see Appendis We have provided recommendations for better
understanding the potential impact of the planned activities on the health of this community They are
summarized here and explained in more detail below Please contact us if you have any questions or if
you would like to collaborate on solutions
Summary of Recommendations
Provide evidence to assure NOISEMAP model estimates are applicable for use at Naval Air
Station Whidbey Although the NOISEMAP model has been previously validated based on
information obtained from other locations evidence was nat provided to indicate that the
model accurately predicts actual exposure to noise under conditions at Naval Air Station
Whidbey It is also not clear how NOISEMAP has been updated to reflect recent research
findings
GRR00151312
Improve description of current state of science around noise and public health specifically
non-auditory health effects
Describe and conduct comprehensive review of the literature At the request of the
Washington State Board of Health and Island County Public Health Department we
prepared of recently published about the health
summary epidemiological literature
effects of noise exposure We have attached this review Appendix which references
significant number of directly relevant articles that were not included in the DEIS
Do not require definitive causal and significant relationship between aircraft noise
and health prior to including the health outcome in the model This standard is
and resulted health effects excluded from the

unreasonably high in non-auditory being
model
Expand review to include studies examining the health effects of noise from sources
other than aircraft It is unclear why literature from other noise sources which can
result in similar effects were not considered especially since there are limited data on
effects from noise originating with non-commercial aircraft
Conduct Health Assessment Current scientific literature that noise at levels

Impact suggests
similar to those reported on Whidbey Island is associated with annoyance sleep disturbance
cognitive impairment and adverse cardiovascular outcomes whether on

However people
Whidbey Island are octuoly experiencing these outcomes as result of their

exposure to aircraft
noise is question beyond the scope of literature review Therefore we recommend that the
conducts Health Assessment better understand the

Navy Impact to potential impact of the
planned activities on the health of the community
Recommendotion One Provide evidence to ossure NOISEMAP model esfimotes ore ooplicobe for use of
Novol Air Stotion Whidbey

Estimates of noise exposure from noise associated with aircraft operations to the residents within the
surrounding communities were derived from Department of Defense computer modeling software
entitled NOISEMAP The major metric for estimating noise exposure was the Day-Night Average Sound
Level DNL but depending on outcome being investigated other metrics were used For example to
investigate noise effects on recreation metric which estimates the number of noise events per
daytime hour above maximum A-weighted sound level of 65 dB was used NA6S ma For sleep
disturbance the metric was sound exposure level SEL that combines the intensity of sound with its
duration The SEL was estimated for an outdoor environment and converted to an indoor level third
example is the use of an for indoor speech interference as this metric used within the model
identifies the estimated number of events per daytime hour that exceed an instantaneous maximum
sound level of SO dB 50dB Lm4 There are several additional metrics used to evaluate various effects
from noise e.g annoyance classroom/learning interference etc.
The NOISEMAP model has been previously validated based on information obtained from other
locations but has not been validated for this naval air station Due to the involved in
complexities
validating this model along with the cost and time requirements there is no expectation of efforts to
validate this model at the locations addressed in this DEIS However there is an expectation that
evidence be provided to determine if the model is predictive by comparing the modeled estimates to
observed measurements at locations of concern While the authors of the DEIS dismissed the very
limited sound pressure data that have been provided by outside sources for select locations within the
area to be impacted no effort was made to indicate that their efforts of

modeling are predictive
estimates provided It is unclear why efforts were not made to test the multiple estimates provided for
the various metrics
GRR00151313
Each metric for

exposure used for an outcome should be measured under appropriate conditions
scenarios and the model estimates need to be compared against these actual values to identify the
models predictive nature If there are shortcomings these need to be identified and addressed With
many models such as those attempting to identify pollutant dissemination characteristics within ground
water surface water or this can be costly and frequently however

air difficult impossible task in
this case there are ongoing operations so these metrics can be measured in timely manner that is not
cost-prohibitive Without such data there is no means by which to suggest that the model is reflective of
actual exposures and accordingly brings the predicted outcomes into question
In addition the DEll should provide greater detail on how this modeling software has been updated to
address ongoing findings such as within the health outcomes arena as the text indicates the most
recent citation for this frequently updated model to be 1992 Also in 1980 it was determined that 87
percent of the population was not annoyed by sound pressure levels weighted below 65dB Detail
needs to be provided to indicate that no information has been identified in the last 35 years to support
or question the use of 65dB within the model as the lowest range when investigating impacts from
noise discussion also needs be included the remainihg 13

to pertaining to not insignificant percent
of the population that do find these levels and how this of the population was
annoying portion
addressed within the model
Recommendofion Two Improve descriofion of current stote of science oround noise ond public heolth
speciflcolly non-oudif pry heolth effects
In
addressing the effects from noise on those impacted the document divided effects into the
interference disturbance noise-induced non-

categories annoyance speech sleep hearing impairment
auditory health effects performance effects and noise effects on children The model attempts to
address these endpoints directly annoyance speech interference sleep disturbance noise-induced
hearing impairment through the DNL or other exposure metrics indirectly performance effects and
noise effects on children by using metric for interference or excludes them from
classroom/learning
the niodel non-auditory health effects based on the reasoning that no studies have shown definitive
causal and significant relationship between aircraft noise and health
Requiring that definitive causal and significant relationship between aircraft noise and health is
demonstrated to including health outcomes within the model is an unreasonably high standard
prior
that resulted in non-auditory health effects being excluded from the model
In our summary of the literature attached we found evidence of multiple non-auditory effects that
may be attributed to noise exposure including annoyance sleep disturbance cognitive impairment
and adverse cardiovascular outcomes Biological mechanisms of the non-auditory effects of noise
require further study Research to date indicates that adverse health effects are initiated
exposure by
chronic stress and/or sleep disturbance Recent studies also suggest that noise-induced annoyance is
associated with stress response which can affect cardiovascular health
In the review of the literature provided in the DEll odds ratio values are provided without confidence
intervals which are critical to understanding the precision of the estimate and whether the null is
overlapped To provide context of the odds ratios OR the DEll indicates through citation that an OR
of 9.0 is needed for strong relationship to exist between an exposure and outcome As such an OR of
3.5 provides for moderate relationship and the OR values of 1.5 are weak If an odds ratio is shown to
be statistically significant it needs to be considered further Once determined that an odds ratio is
statistically significant the strength of association can be discussed in terms of the percentage of the
GRR00151314
population that could be affected In addition even the effect size

if is small statistically significant
odds ratio from well-defined that has adjusted

study for possible confounding indicate
may that
sensitive population is being affected and this would need be evaluated

to and discussed multitude of
examples exist within the literature in which an odds ratio has small effect size but is found to be
statistically significant and because of the size of the at-risk this

population represents an exposure of
considerable public health consequence
Another issue of note is that this short review was confined to effects from noise originating with
aircraft There increasing evidence noise exposure as defined from
is that
multiple sources including
commercial aircraft is associated with numerous adverse health effects There are likely nuances
associated with noise exposures specific to military aircraft that are not thoroughly understood
However noise levels similar to those reported from NAS Whidbey Island Complex described in all
recent reports pose threat health woutd

to public It seem prudent to include the effects from other
noise sources there are data on from noise
as limited effects
originating with noncommercial aircraft
Recommendotion Three Conduct tieolfh /mpocf Assessment

Current scientific literature suggests that noise at levels similar to those reported on Whidbey Island is
associated with annoyance sleep disturbance cognitive Impairment and adverse cardiovascular
outcomes However whether people on Whidbey are octuolly experiencing these
Island outcomes as
result of their noise

exposure to aircraft is question beyond the scope of literature review Therefore
we recommend that the Navy conduct Health Impact Assessment to better understand the potential
impact of the planned activities on the health of the community Groups that have been described as
susceptible to the effects of noise include the elderly

potentially smokers children shift-workers and
individuals with mental disorders and
sleep disorders physical illnesses
In our of the literature we see increasing evidence

summary that noise exposure as defined from
multiple sources including commercial associated with adverse

aircraft is
numerous health effects
There are likely nuances associated with noise exposures specific to military aircraft that are not
thoroughly understood However noise levels similar to those NAS Whidbey

reported from Island
Complex pose the following threats to public health
Annoyance The scientific literature provides evidence that noise exposure leads to annoyance
which causes decrease in quality of life While definitively quantifying annoyance and its effect
on the population challenging there strong evidence that

is is feeling annoyed has negative
impacts on mental health and cardiovascular endpoints
Sleep Disturbance of measurement

variety techniques have been used to study sleep
disturbance There general agreement that noise associated with sleep
is is disturbance and if
the disturbance is severe and frequent can lead to health

it negative consequences
Cognitive Impairment Studies of noise effects on childrens cognition reveal an increasing trend
that noise exposure results in skills One of the
impaired reading largest studies to date found
that reading comprehension falls below when children are exposed to

average aircraft noise
that is above 55 dB at school
Cardiovascular Disease The extent and underlying mechanisms the

for
relationship between
noise exposure and cardiovascular health are still poorly understood However the scientific
literature has provided increasing evidence of association

positive
Health Impact Assessment is rapidly emerging practice among local state and federal jurisdictions
that helps assess how proposed decision will affect the health of population and whether vulnerable
populations are more likely to be impacted The goal of Health Impact Assessment to
is provide
GRR00151315
recommendations during the decision-making process that will protect health and reduce health
inequities Health Impact Assessment brings potential positive and negative public health impacts and
considerations to the decision-making process for plans pirojects and policies that fall outside
traditional public health such as aircraft use and associated noise Health
arenas military Impact
Assessment can engage community members and stakeholders to provide practical recommendations
to increase positive health effects while minimizing negative ones
If you have any questions please contact lauren Jenks at 360 236-3325 or
Sincerely
Clark Halvorson
Assistant Secretary
Attachment
GRR00151316
Attachment
Summary of the Association Between Noise and Health
Authors Julie Fox PhD MHS Environmental Epidemiologist Washington State Department of Health
Lillian Morris PhD Spatial Epidemiologist Washington State Department of Health
EXECUTIVE SUMMARY
The objective of this document is to summarize recent literature exploring the health effects of noise
exposure and compare our findings to reported noise levels originating from the Naval Air Station NAS
Island Complex The relationship between noise and health has been studied
Whidbey exposure
extensively and the body of knowledge on this topic is rapidly increasing We described noise
measurements taken on Whidhey Island and summarized literature on five of the most studied health
outcomes associated with noise noise induced hearing loss and tinnitus sleep disturbance
annoyance
cognitive impairment and cardiovascular disease in addition to discussion of susceptible populations
While we fuund that noise-induced hearing loss is typically not associated with aircraft noise there is
evidence that noise exposure associated with sleep disturbance cognitive

increasing is
annoyance
impairment and adverse cardiovascular outcomes Groups that have been described as particularly
susceptible to the effects of noise include smokers children the elderly shiftworkers and individuals
with sleep disorders mental disorders and physical illnesses There were limitations associated with this
summary including gaps of knowledge related to exact exposure-response relationships and underlying
pathways for some health endpoints In addition there have been minimal studies specific
to health
effects associated with military aircraft noise exposure More research is needed to understand
differences in risk attributed to susceptible groups compared to the general popelation Despite these
limitations the current body of scientific literature that noise levels similar to those reported
suggests
from the NAS Whidbey Island Complex pose threat to public health
INTRODUCTION
This report was written the of the

by the Washington State Department of Health at request
Washington State Board of Health and Island County Public Heallh Department to summarize recently
literature about the health effects of noise exposure Noise is being evaluated
published epidemiological
concerns on and the area over air noise

in response to community Whidbey Island surrounding traffic
levels originating from the NAS Whidbey Island Complex These concerns are related to historical and
current noise in addition to proposed increases in naval air traffic Our specific objectives were to
summarize recent literature on the most pertinent health effects of noise exposure and relate our
findings to noise on Whidbey Island

exposure
Noise and Health
Noise is generally defined as unwanted sound This definition of noise recognizes the psychological role
impact of noise
of the Auditory effects of noise specifically noise-induced hearing loss and
exposure
tinnitus have been well-established for decades.1 Multiple non-auditory effects may be attributed to
noise including hypertension cardiovascular disease and events diabetes obesity reduced
exposure
declines in and defects.5

cognitive functioning performance birth
GRR00151317
Biological mechanisms of the non-auditory effects of noise exposure require further study Research to
date indicates that adverse health effects initiated

are by chronic stress and/or sleep disturbance.61
Recent studies also that noise-induced

suggest annoyance is associated with stress which
response
can affect cardiovascular health.6
Noise Measurements
Sound is the fluctuation of pressure through medium such as air or water Sound level is measured in
decibels dB on scale that is based on human hearing where 0dB is barely audible and turbojet
engine is approximately 160 cIB Because decibels are based on logarithmic scale when two sounds
are combined the total sound level is much less than simply adding the two sound levels For
together
example if there are two sources that each produce 80dB of noise at single location the resulting
sound level is 83dB nof 160 dO
In addition to differences that determine sound

pressure level sound has varying frequencies measured
in hertz Hz that are heard as pitch The human ear is less sensitive to hearing extremely low and high
frequencies One way of adjusting sound levels to incorporate the varying and
sensitivity perceived
loudness across frequencies an

is to apply A- B- or C-weighted scale The A-weighted scale was derived
from an equal-loudness contour pure tones.1

for Studies indicate that the A-weighted scale provides
better estimate of human hearing threat than the other weightings and the most used
it is
commonly
among human noise impact studies.1 However there is some concern that the A-weighted scale
underestimates the perceived loudness of low frequency noise.1212
While there are over 20 different metrics of sound few are used
typically in studies of health effects
The highest Sound level measured often as an A-weighted Maximum

is reported Sound Level or
Peak Sound Pressure both of which

Level L65 may occur in less than second The sound exposure
level SEL is the total energy of noise measured over specified time period often one second or
single noise event Longer term measurement of noise often

is reported as the Equivalent Sound Level-
A-Weighted L5 which is the A-weighted average sound level based on the equivalent-continuous
sound level over time period The

specified Day-Night Average Sound Level Ld or 0NL is an average
sound level over 24-hour period that incorporates 10-dB penalty for sound events at In studies
night
that focus on sound only during the and

night Lnvst is typically used similarly L5 is typically used for
only daytime noise Thus the duration of sound exposure measurements can range from an
instantaneous event to year
The selection of the sound metric used in studies depends on characteristics of the noise and the type of
health effect studied remains in

being Uncertainty terms of understanding the measurement of noise
such as the number of events or the peak sound level fhat is most relevant for health.1
Noise from Military and Commercial Aircraft
The majority of literature the relationship between

investigating health effects and noise from aircraft is
based on commercial aircraft rather than aircraft.42 The main factors that
military affect ground-level
noise from aircraft are the type of aircraft and engine the
including thrust flap and airspeed
GRR00151318
management procedures and factors that affect sound such as distance to the point of
propagation
concern e.g the receptor topography and weather.22
Noise from aircraft is predominately low frequency approximately 10 to 250 Hz.23 High frequency is
generally defined as up to 5000 or 10000 Hz.51 People may perceive low frequency sounds either with
their ears or by sensing vibrations.24
Different types of aircraft have different acoustic signatures which makes it

possible to distinguish noise
measured from military

and commercial aircraft.25 It is likely that different flight activities e.g takeoffs
field carrier landing practice low-flying and aircraft types alter noise in ways that are determinants of
health outcomes However these distinctions are not evaluated in this summary because of the paucity
of published research on military aircraftnoise
METHODS
We described noise measurements from three publications to understand the noise levels on Whidbey
Island These data included recent measurements by JGL Acoustics Inc.2527 and the National Park Service
Natural Resource Stewardship end Science Office and modeled noise levels in the draft
presented
Environmental Impact Statement ElS prepared by the United States Department of the Navy.ze
There is an extensive body of scientific literature on noise-related health effects We summarized
literature about commercial well as noise from other

aircraft noise as sources because of the limited
peer-reviewed literature on noise from military aircraft Due to time constraints we primarily focused on
peer-reviewed literature reviews with an emphasis on articles published since 2012 This summary
includes detailed description of noise-induced and tinnitus
hearing loss annoyance sleep disturbance
cognitive impairment and cardiovascular disease These effects mental and

impact welfare social
physical health and have been the most thoroughly investigated to date.2
RESULTS AND DISCUSSION
Naval Air Station Whidbey Island Complex Noise
Noise levels HAS Whidbey

originating from the Island Complex have recently been measured by JGt
Acoustics Inc.2627 and the National Park Service Natural Resource end Science Office.25
Stewardship
Modeled noise levels are presented in the draft Environmental Impact Statement EIS prepared by the
United States Department of the Navy7 There are discrepancies in reported noise levels across these
three reports due at least in part to differences in measurement methods and sample locations There
are each approach and challenges comparing the measurements

limitations to to directly that
reported
will not be addressed in this The objective here not evaluate the three
summary is to comprehensively
existing reports but to provide useful reference for gauging possible noise exposure levels under
various conditions on Whidbey Island
JGt Acoustics Inc measured noise originating from military aircraft operations on May 2013 at five
locations in close proximity to one of two landing strips at NAS Whidbey Island
Complex.262 Among
GRR00151319
other measures they reported 24-hr L4 noise measurements ranging from 64.1 dBA to 75.0 dBA and
Max ranging from 81.1 dBA to 119.2 dBA across the sampled sites
The National Park Service took noise measurements National which

at Ebeys Landing Historical Reserve
is located five miles south of NAS Whidhey Island Complex.23 They took multiple measurements for 735
continuous hours from two locations For example they dRA dBA
reported L4 levels of 73.6 and 54.7 at
the two locations with Lama levels of 114 dBA and 85 dRA They also found that levels of lAm 70 dBA
were exceeded by 281 and 125 military aircraft events at the two locations over 31 days
The estimated noise levels for the area surrounding NAS Whidbey NOISEMAP
Island Complex using
modeling software.2 Their models were based on multiple scenarios of predicted flight activity in the
year 2021 which accounts for the proposed increases in flight and estimated changes in
activity
population They estimated that in an average year 3875 people across 7299 acres will live within 65
to 70 cIBA La noise contour 3165 people across 6211 acres will live within 70 to 75 dBA La noise
contour and 3993 people across 6423 acres will live within 75 cIBA L4 noise contour In addition
they estimated LAm levels at multiple points of interest The highest Lama at residential point of
interest was 114 dBA with 267 annual events The highest Ls at school point of interest was 94 dBA
with 178 annual events The highest at park point of interest was 106 dBA with 267 annual
events
Noise Induced Hearing Loss Tinnitus
Noise-Induced hearing loss is defined as an increase threshold level sufficient to affect

in hearing daily
living.4 Hearing loss has more been defined as 10db shift from baseline
specifically hearing involving
multiple frequencies in the same ear.29 Noise-induced hearing loss can be caused by long-term exposure
to steady state sound or one-time exposure to an intense impulse sound.2 cause

Long-term exposures
ongoing degeneration of cells in the inner ear which are irreversible and progressive.2 The
sensory
progression of hearing loss is also affected by the frequency intensity and duration of the noise
exposure.3
There is some debate about the sound that can cause hearing loss The permissible
pressure range
exposure limit set by the United States Occupational Safety and Health Administration OSHA is 90 cIBA
over hours as time-weighted average The National Institute of Occupational Safety and Health
NIOSH recommends an exposure limit of 85 dBA for hours as time-weighted average Research
suggests that an exposure limit of 70 dBA Lxeq over 24 hour period from environmental and leisure
noise could pose risk of hearing impairment.4 Instantaneous peak sound levels of 140 dBA
pressure
can cause mechanical damage to the middle and inner ear and this level of exposure is likely applicable
to occupational and environmental exposures.4
Noise-induced hearing loss generally from exposures higher noise from 3000
is to frequencies ranging
to 6000 Hz43 which are above associated with there

frequencies normally aircraft However is
potentially risk of adverse auditory effects from exposore to low flying aircraft noise characterized by
rapid noise level increases at noise levels exceeding 115 dBA Hearing loss can affect cognitive
performance attention and social interactions and has been associated with accidents and falls
GRROO 151320
Tinnitus has broadly been defined as the to silence35 its and

inability perceive expression etiology
effect on patients variable.36 Tinnitus can be caused by excessive noise exposure and
is is
highly
sometinies associated with noise-induced hearing loss but also be experienced in the absence of
it
may
measureable hearing loss.35 An observed adverse effect level for noise-induced tinnitus has not been
established in the literature but levels for noise-induced loss have been to
protective hearing applied
tinnitus.35 Tinnitus can have significant impact on quality of life and can cause sleep disturbance
cognitive effects anxiety hearing problems irritability and an inability to work
Annoyance
Exposure environmental noise causes subjective discomfort which referred as noise

to is to annoyance
The relationship between noise exposure and annoyance is generally quantified by linking the results
of noise summarized by the percentage of the population highly annoyed and L4

annoyance surveys
noise exposure estimates Measuring subjective outcome is complex and individual annoyance
reactions to the same noise can be variable.38 The in

exposure highly specific wording questionnaire
and how the study is administered can influence how participants rate annoyance.394 Documented
non-acoustic factors that affect how individuals report noise annoyance include demographics
personal social and conditions.394 For attitudes towards the noise source or
situational example
perceived malfeasance related to the noise source can strongly influence results.42 Despite these
survey
complexities curves have increasingly found that the degree of annoyance rises with
exposure response
noise levels from noise.3543

increasing transportation
Noise annoyance is one of the most prevalent effects of environmental noise and can cause feelings of
anger exhaustion and displeasure.SS99A4 There is also evidence of link between noise and
annoyance
neurologic such as headaches and difficulties concentrating.24 studies have

symptoms Multiple recently
analyzed the association between noise annoyance and depression While the statistical significance of
the associations reported in these studies have been inconsistent45 there is growing evidence that noise
annoyance could increase the risk of depression.458 There is also evidence that individuals with higher
noise sensitivity are at greater risk of noise-related psychological disorders.3 Noise annoyance and
specifically the associated stress response is frequently cited as modifier in the association between
noise and cardiovascular heelth.LS
Sleep Disturbance
Sleep disturbance is deviation either measured or perceived from an individuals habitual or desired
behavior.43 characterized several

sleep It is in different ways including awakenings sleep quality
medication to control sleep total sleep time time spent in slow wave sleep sleep stage changes and
arousals.43 Sleep disturbance measurement include standard

techniques polysoninography the gold
that measures brain eye and muscle activity seismosomnogrephy or actigraphy both measure body
movement questionnaires and push button responsesY The effects of noise on sleep are commonly
measured using field studies where participants sleep in their homes with natural noise exposures and
laboratory studies where noise is controlled and participant noise exposures are consistent55 In field
studies another layer of complexity is added by the need to distinguish indoor noises from outdoor
noises.55 On the other hand typical habituation to noise mey not be reflected in studies where
113
GRR00151321
parttcipants sleep in laboratory55 or where sleep disturbance is predicted from exposure-response

models.54 limitation that affects both field and laboratory studies is the difficulty of distinguishing
sleep disturbances that would have occurred without the noise evant referred to as spontaneous
awakenings.5
Sleep is generally thought to play role in and restoration of the body.505556

recuperation There is
increasing evidence that chronic loss associated with obesity

sleep is hypertension diabetes
psychological changes and increased mortality as well and

as impairment in immune endocrine
cardiovascular function.StSSS Low levels of noise lead to minor sleep fragmentation such as shifts to
sleep and movement.58 There broad

lighter is agreement that noise exposure and specifically noise
from related
aircraft is to sleep disturbance and can lead to serious impacts on physical and mental
health if the disturbance is severe end frequent All nine moderate to

enough.tm58 high quality studies
considered in recent review found disturbance

that sleep was linked to aircraft noise events.49 The
estimated degree of sleep disturbance that occurs with different levels of sound is not certain54 For
example the indoor sound esposure levelat which of the estimated

percent population is to
awakenranged between approximately 55 and 85 dB across four different studies that estimated
exposure-response curves50 One study estimated the effect level well above 85 dR.5
Cognitive Impairment
Cognitive impairment is typically measured as the ability to perform task that is assessed with
neurobehavioral tests written questionnaires or interviews Daytime studies of children and adults
performing the same tasks have found that the reletive impact of acute noise on performance is similar
between adults and children.59 In adults there is evidence of chronic noise being associated with
impaired attention and short-term memory.tm6 However there is particular concern about impairment
in children because of the importance of early learning and and the

development effects these have on
subsequent adult health.6263
With respect to noise exposure more information exists for children than
cognitive impairment in for
other health effects Recent research focused on cognitive from chronic noise
impairment exposures in
children indicates that noise does not of cognitive function.1

affect all aspects An increasing treed has
emerged for an association between noise exposure in children and impaired reading skills and memory
and less consistent association with attention1361 has been that noise
It postulated exposure leads to
communication difficulties increased

impaired attention arousal learned helplessness frustration
noise annoyance sleep disturbance and/or psychological of which can result in

stress all impaired
cognition.44
the
In Road-traffic and Aircraft Noise txposure and Childrens Cognition and Health RANCH Study the
most comprehensive study of noise and cognitive children

impairment in to date linear
exposure-
effect relationship was established between aircraft noise and decreased reading comprehension.6
of the RANCH which for

Findings study incorporated adjustment several confounding factors indicate
that reading comprehension falls below average with aircraft noise above 55db L6qjs Further an
increase of 5dB L656 noise exposure to aircraft at school was associated with 2-month in
delay
reading age in the United Kingdom and 1-month delay in reading in the Netherlands
age
11
GRROO 151322
Cardiovascular Disease
There is growing body of literature describing the association between cardiovascular disease and
noise exposure Environmental epidemiological studies are most used the

commonly to investigate
relationship between environmental noise and cardiovascular health effects and include retrospective
cohort cross sectional case-control and meta-analyses The relationship between environmental noise
and cardiovascular disease is complex This complexity has contributed to epidemiological studies
reaching inconsistent conclusions related the

to strength and significance of associations There are
number of variables that potentially influence study outcomes such as source of noise44 selection of
noise metric time of day565 characteristics of the study populationw and study design The
relationship between noise exposure and cardiovascular health is also often confounded by air
pollution and adjusting for this poses challenge.sm
Despite these complexities recent studies have presented evidence of association

increasing positive
between noise and cardiovascular health effects.554455557 Acute noise exposure associated
exposure is
with increased systolic and diastolic blood pressure changes in heart rate and stress hormone release.44
Long-term environmental noise exposure can affect the cardiovascular system and manifest diseases
including hypertension ischemic heart diseases and stroke.4MGS For example recent meta analyses
assessing exposure-response relationships between transportation noise road traffic and aircraft and
cardiovascular effects hypertension and ischemic heart diseases revealed 68 percent increase in risk
per increase L4 with effects

starting at noise levels as low as 50 dB.97 The Hypertension and Exposure
to Noise near Airports HYENA cohort study7277 found general positive association between aircraft
noise and hypertension but the significance of their findings varied by day verses night noise country
and gender.w There is also increasing evidence that nighttime noise is more relevant to cardiovascular
effects than daytime noise65 and men might be at greater risk than women from noise-related
cardiovascular disease
Susceptlhe Populations
Some population groups within the general public are likely at greater risk of developing health effects
from noise exposure However there are few published studies designed to noise
compare susceptibility
of particular subgroup to the general population.65 More often studies effects of varying noise
report
exposure within population that is thought to be at greater risk without comparison to another
population or cite that group is more susceptible based on plausibility Susceptibility may be impacted
by numerous traits including behavior individual circumstances e.g location of residence physical
and mental characteristics and developmental phase For auditory effects smokers may represent
more susceptible population.8 Children the elderly shift-workers and individuals with sleep disorders
mental disorders and physical illnesses are often cited as being more to effects
susceptible non-auditory
of noise.5553
There is evidence of an association between cigarette smoking and hearing lossa79 Co

exposures to cigarette smoke have been found to increase the risk of noise-induced hearing loss
in occupational settings.1
12
GRROO 151323
Children are thought to be at greater risk from the effects of noise exposure because they are
still developing both physically and mentally.1353 There is substantial evidence that noise impairs
childrens cognitive function13 There are inconsistent findings reported for an association
between prenatal noise exposures and low birthweight in two systematic reviewslM and there
is some indication that children exposed in utero to elevated noise have elevated blood
systolic
pressure and stress hormone levels.83
The proposed vulnerability to noise in shift-workers the elderly and people with sleep disorders
may occur through sleep disturbance.5516 In shift-workers both daytime and nighttime noise
pose problem.55 Sleep patterns also change with age and the elderly are generally more prone
to waking up.8
There is evidence that mental health status and personality traits are determinants of noise
perception which is potentially linked to sleep disturbance and subsequent health effects For
example neuroticism has been associated with increased noise and

sensitivity annoyanceP
More generally attitude toward noise sleep sensitivity and personality traits seem to modify
noise impacts on sleep disturbance.12
Individuals with physical illness have been cited as more to

population potentially susceptible
noise exposure.415963 For instance people with prevalent chronic disease could be at an
increased risk of heart diseases associated with noise exposure.82 Pre-existing disease has also
been described as potential effect modifier in the association between noise annoyance and
ischemic heart disease as individuals with chronic illness were more to

likely report higher
levels.76
ennoyance
More research is needed to compare particularly susceptible population groups to the general
population and the degree to which these are more at-risk to harmful effects of noise
groups exposure
CONCLUSION
The primary findings considered in this review are summarized below
Noise-Induced Hearing Loss and Tinnitus There risk of hearing from

is impairment long-term
exposure to steady state noise levels greater than 65 dBA for an 8-hour period and greater than
70 dBA Lseq for 24-hour period at frequencies ranging from 3000 Hz to 6000 Hz This type of
noise is generally not associated with aircraft noise

exposure
Annoyance The scientific literature evidence that noise exposure leads to

provides annoyance
which causes decrease in quality of life While definitively quantifying and its effect
annoyance
on the population is challenging there is strong evidence that feeling annoyed has negative
impacts on mental health and cardiovascular endpoints
Sleep Disturbance variety of measurement techniques have been used to study sleep
disturbance There is general agreement that noise is associated with sleep disturbance and if
the disturbance severe and frequent can health

is it lead to negative consequences
Cognitive Impairment Studies of noise effects on childrens cognition reveal an increasing trend
that noise exposure results in

impaired reading skills One of the largest
studies to date found
that reading comprehension falls belOw average when children are exposed to aircraft noise
that is above 55 dB Laeq
13
GRROO 151324
Cardiovascular Disease The extent and underlying mechanisms for the relationship between
noise exposure and cardiovascular health are still poorly understood However the scientific
literature has provided increasing evidence of positive association
Susceptible Populations Groups that have been described as potentially more susceptible to
the effects of noise include smokers children the elderly shift-workers and individuals with
sleep disorders mental disorders and physical illnesses However more research is needed to
understand differences in risk in these groups compared to the general population
The relationship between noise exposure and health has been studied extensively and the body of
knowledge on this topic is rapidly increasing However there are gaps of knowledge to consider For
instance additional research is needed to thoroughly understand the specific exposure-response
relationship and underlying pathways for some health There are also related to
endpoints complexities
selecting the most appropriate noise measurement for assessing health outcomes For example the L50
metric is commonly used to quantify aircraft noise levels yet this metric does not account for
exposure
loud which could have impacts health such sleep disturbance3

infrequent events on effects as
Different measurements might be more appropriate for specific noise sources or health outcomes and
future work parsing out these relationships will greatly enhance our understanding of the association
between specific noise characteristics and health
In general there is increasing evidence that noise exposure as defined from multiple sources including
commercial aircraft is associated with numerous adverse health effects There are likely nuances
associated with noise to aircraft that are not understood

exposures specific military thoroughly
However noise levels similar to those reported from NAS Whidbey Island Complex described in all
recent reports252628 pose threat to public health
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19
GRROO 151330
Case 2:19-cv-01059-RAJ-JRC Document 36-1 Filed 02/13/20 Page 80 of 122 02_WAGOV-O1
l.a Thank You

2.e Public Involvement Process
2.f Use of Public Comments
January 2017
Lisa Padgett
EA- 8G Growler EIS Project Manager

6506 Hampton Bouieard

Norfolk VA 23508
ATTN Code EV2I/SS
Dear Ms Padgett
There is great deal of Navys proposed expansion of Growler Airfield Operations

interest in the
at Naval Air Station NAS

Whidbey Island The draft Environmental Impact Statement ElS
for the LA-I 8G Growler Airfield Operations at NAS Whidbey Island was released November
10 2016 Thank you for providing such comprehensive and thorough document
Given the volume of the document at more than 700 pages and the technical nature of its
content some local jurisdictions and citizens have expressed concerns about comprehending the
document and providing response within the current public comment period While the Navy
established an extended public comment period of 75 days given the complex nature of the
topic additional time is

necessary to prepare response Thus ask that you please extend the
public comment period an additional 45 days to provide sufficient time for citizens and local
jurisdictions to provide comment
will provide further comment on the draft ElS for the EA- 8G Growler Airfield Operations at
NAS Whidbey Island Complex in subsequent correspondeice
Very truly yours
le rnor
GRR00151331
Case 2:19-cv-01059-RAJ-JRC Document 36-1 Filed 02/13/20 Page 81 of 122 BRIDA000I
also that the SELs recorded by JOL 2013 and 2016 at position and which
It is noteworthy
are directly under the path 32 approach over Admirals Cove are very similar to the approach
SELs for Growlers stated in the 2005 AICIJZ Likewise Table 3.1-2 of the DEN presents
sound levels for Growlers in level flight which shows that Growler SELs under
representative
the flight path are t6 dBA at 200 ft AOL and 109 cIBA at 500 feet AGL for jet speed at 400 kn
and power at 44.5 %NC These too reflect Lillys recorded levels at positions and
Of further relevance the National Park Service during 30 days in July and August 2016
conducted on-site noise recordings at site EBLAOO1 directly between JGL sites and under
the FCLP path The NPS reported6 noise levels within just to dEA of those recorded by JGL
at sites and The DEIS validated that NPS noise study with this statement
National Park Service Report for Ebeys Landing National Historic Reserve 2016
In 2016 the National Park Service performed acoustical monitoring for the Ebeys
Landing National Historic Reserve The conditions measured by this study were
actual aircraft noise over 28-day period in June and July 2016 Although this
differs from the affected environment modeled for calendar year 2021 in this EIS
the results of the study appear consistent with the Navys previous noise analyses
At COERs request JGL revie\ved the NPS study and provided this comment
The NPS report is excellent with lot of detailed acoustic analysis Their finding of
Lmax 113 cIBA is very close to my findings even though their system was located
far from my Position It is important to note that the NPS used the words
extremely loud in the second sentence of the conclusions The NPS report is very
carefully worded document Clearly lot of people spent lot of time preparing this
document doubt that they could find better word than extremely to
characterize the noise from the Growlers
Of further import modeled data does need to be verified with on-site data Although the Navy
asserted was not studies reveal that modeled contours have failed to reflect actual
it necessary
on-site measurements study of 36 sites around RaleighDurham airport7 found the modeled
the actual on-site noise 5-15 that the actual

data consistently underestimated by decibels is
noise levels were roughly 50% to 150% louder than the NOISEMAP 19911998 and NM
19992002 models had indicated
16
2016 National Historical Reserve Acoustical Monitoring Report Natural
Ashley Pipkin Ebeys Landing
U.S of National Park Service Natural
Resource Report NPSJELBAINRR20t6/1299 Department the Interior
and Natural Sounds and Skies Division Fort Collins Colorado

Resource Stewardship Science Night
Technical Report on Preparation of Day-Night Sound Level DNL Contours of Aircraft Noise During 2003
Raleigh-Durham International Airport North Carolina March 2005 HMMH Report 295097.001 Harris Harris
Miller Hanson Inc 15 New England Executive Park Burlington MA 01803

1.1 l9.239/flyrduco/rduaircraftnoise/noiseinfo/downloadsDU 2003 DNLodf
http//l98
Citizens of Ebeys Reserve Comments on Draft EIS for NASWI 30
GRROO1 52230
TABLE OF CONTENTS
ACRONYMS AND ABBREVIATIONS A-li
INTRODUCTION AND EXECUTIVE SUMMARY A-13
STUDY METHODOLOGY A-19
2.1 Data Collection and Validation A-19
2.2 Noise Metrics and Modeling A-21
2.3 Impact and Geospatial Analysis A-22
NAS WHIDBEY ISLAND COMPLEX A-31
3.1 Regional and Local Settings A-31
3.2 Aviation Users A-33
3.3 Climatic Data A-34
AVERAGE YEAR BASELINE SCENARIO A-35
4.1 Flight Operations A-35
4.2 Other Modeling Parameters A-38
4.3 Run-up Operations A-38
4.4 Aircraft Noise Exposure A-41
AVERAGE YEAR NO ACTION ALTERNATIVE A-53
AVERAGE YEAR ALTERNATIVE SCENARIOS A-73
EFFECT OF CONSIDERED HUSH HOUSE A-225
10 LOW-FREQUENCY NOISE A-233
ii REFERENCES A-237
A-3
Appendix
GRROO1 59033
Appendix Al Discussion of Noise and Its Effect on the Environment Al-i
Appendix A2 Annual Flight Operations for School Cases Average Year and High Tempo FCLP
Year Cases A2-l
Appendix A3 EA-18G Runway Utilization Percentage A3-l
Appendix A4 Modeled Flight Tracks and Growler Track Utilization Percentages A4-l
Appendix A5 Representative Flight Profiles for EA-18G P-3C P-8A and Transient Large Jet
Aircraft A5-l
Appendix A6 Point of Interest P01 Event Data A6-l
Appendix A7 Other Modeling Output for High Tempo FCLP Year Scenarios A7-l
Appendix A8 Literature Review Process A8-l
A-4
Appendix
GRROO1 59034
List of Figures
Figure 1-1 Regional Setting of the NAS Whidbey Island Complex and Points of Interest A-14
Figure 2-1 On-Station Buildings for PHL Counts A-24
Figure 3-1 Vicinity of the NAS Whidbey Island Complex A-32
Figure 3-2 Average Daily Weather Data for NAS Whidbey Island and Modeled Conditions A-34
Figure 4-1 Modeled Run-Up Pads For Baseline Scenario A-40
Figure 4-2 Baseline Environment for NAS Whidbey Island Overview A-42
Figure 5-1 Modeled Run-up Pads for Alternatives A-59
Figure 5-2 DNL Contours for AAD Aircraft Events for the Average Year No Action
Alternative A-61
Figure 6-1 Comparison of Baseline and Proposed FCLP Pattern for Runway 14 at OLF
Coupeville A-88
Figure 6-2 Comparison of Baseline and Proposed FCLP Pattern for Runway 32 at OLF
Coupeville A-89
Figure 6-3 DNL Contours for AAD Aircraft Events for the Average Year Alternative 1A A-93
Figure 6-4 DNL Contours for AAD Aircraft Events for the Average Year Alternative lB A-94
Figure 6-5 DNL Contours for AAD Aircraft Events for the Average Year Alternative 1C A-95
Figure 6-6 DNL Contours for AAD Aircraft Events for the Average Year Alternative 1D A-96
Figure 6-7 DNL Contours for AAD Aircraft Events for the Average Year Alternative 1E A-97
Figure 6-8 Comparison of 65 dB DNL Contours for Average Year Alternatives and the No
Action Alternative A-98
Figure 6-9 Estimated Aircraft DNL at POls for the Average Year Alternative A-102
Figure 7-2 DNL Contours for AAD Aircraft Events for the Average Year Alternative 2B A-143
Figure 7-6 Comparison of 65 dB DNL Contours for Average Year Alternative and the No
Figure 8-2 DNL Contours for AAD Aircraft Events for the Average Year Alternative 3B A-193
Figure 8-6 Comparison of 65 dB DNL Contours for Average Year Alternative and the No
A-S
Appendix
GRROO1 59035
Figure 9-1 Modeled Run-up Locations and Considered Hush House A-226
Figure 9-2 Comparison of Single-Event Maximum Sound Level Contours for the High Power
and Considered Hush House Locations A-229
Figure 9-3 Comparison of DNL Contours for the Average Year No Action Alternative for the
High Power and Considered Hush House Locations A-230
Figure 9-4 Comparison of DNL Contours for the High-Tempo FCLP Year Alternative 2B for
the High Power and Considered Hush House Locations A-231
Figure 10-1 Low Frequency One-Third Octave Band Spectral Comparison for the EA-18G and
EA-6B for MIL Engine Power A-234
EA-6B for Approach Engine Power A-234
EA-6B for Traffic Pattern Engine Power A-235
A-6
Appendix
GRROO1 59036
List of Tables
Table 1-1 Summary of Noise Exposure Results for the Average Year A-16
Table 2-1 Numbers of Squadrons and Primary Assigned Aircraft for each Modeled
Condition A-20
Table 2-2 Noise Modeling Parameters A-22
Table 2-3 Points of Interest and Applicable Analyses A-25
Table 2-4 Summary of P01 Analysis Parameters A-28
Table 3-1 Runway Parameters A-31
Table 4-1 Summary of Annual Flight Operations for the Average Year Baseline Scenario A-35
Table 4-2 Detailed Annual Flight Operations for the Average Year Baseline Scenario A-36
Table 4-3 Modeled Run-Up Operations and Profiles for the Average Year and High-Tempo
FCLP Year Baseline Scenarios A-39
Table 4-4 Estimated Acreage and Population within the DNL Contour Ranges for the
Average Year at the NAS Whidbey Island Complex CY 21 for Baseline Scenario A-43
Table 4-5 Estimated Aircraft DNL at POls for the Average Year Baseline Scenario A-44
Table 4-6 Estimated Potential Hearing Loss for the Average Year Baseline Scenario A-46
Table 4-7 Average Indoor Nightly Probability of Awakening at Applicable POls for the
Average Year Baseline Scenario A-47
Table 4-8 Indoor Speech Interference for the Average Year Baseline Scenario A-48
Table 4-9 Classroom Learning Interference for the Average Year Baseline Scenario A-49
Table 4-10 Recreational Speech Interference for the Average Year Baseline Scenario A-50
Table 5-1 Summary of Annual Flight Operations for the Average Year No Action
Alternative A-54
Table 5-2 Detailed Annual Flight Operations for the Average Year No Action Alternative A-55
Table 5-3 Modeled Run-Up Operations and Profiles for the No Action Alternatives A-58
Table 5-4 Estimated Acreage and Population within the DNL Contour Ranges for the
Average Year at the NAS Whidbey Island Complex for No Action Scenario A-62
Table 5-5 Estimated Aircraft DNL at POls for the Average Year No Action Alternative A-63
Table 5-6 Estimated Potential Hearing Loss for the Average Year No Action Alternative A-65
Average Year No Action Alternative A-66
Table 5-8 Indoor Speech Interference for the Average Year No Action Alternative A-68
Table 5-9 Classroom Learning Interference for the Average Year No Action Alternative A-70
Table 5-10 Recreational Speech Interference for the Average Year No Action Alternative A-71
Table 6-1 Summary of Annual Flight Operations for the Average Year Alternative 1A A-73
Table 6-2 Detailed Annual Flight Operations for the Average Year Alternative 1A A-74
Table 6-3 Summary of Annual Flight Operations for the Average Year Alternative lB A-76
A-7
Appendix
GRROO1 59037
Table 6-4 Detailed Annual Flight Operations for the Average Year Alternative lB A-77
Table 6-5 Summary of Annual Flight Operations for the Average Year Alternative 1C A-79
Table 6-6 Detailed Annual Flight Operations for the Average Year Alternative 1C A-80
Table 6-7 Summary of Annual Flight Operations for the Average Year Alternative 1D A-82
Table 6-8 Detailed Annual Flight Operations for the Average Year Alternative 1D A-83
Table 6-9 Summary of Annual Flight Operations for the Average Year Alternative 1E A-85
Table 6-10 Detailed Annual Flight Operations for the Average Year Alternative 1E A-86
Table 6-11 Modeled Run-Up Operations and Profiles for Alternatives through A-91
Table 6-12 Estimated Acreage and Population within the DNL Contour Ranges for the NAS
Whidbey Island Complex Alternative Average Year A-99
Table 6-13 Percent Difference in the Estimated Acreage and Population within the Average
Complex Alternative A-lU
Table 6-14 Average and 10th Percentile Noise Induced Permanent Threshold Shifts as
Function of Equivalent Sound Level Leq under Alternative at NAS Whidbey
Island Complex Average Year A-107
Average Year Alternative A-lb
Table 6-16 Indoor Speech Interference for the Average Year Alternative A-113
Table 6-17 Classroom Learning Interference for Average Year Alternative A-116
Table 6-18 Recreational Speech Interference for Average Year Alternative A-122
Table 7-3 Summary of Annual Flight Operations for the Average Year Alternative 2B A-128
Table 7-4 Detailed Annual Flight Operations for the Average Year Alternative 2B A-129
Complex Alternative A-150
A-8
Appendix
GRROO1 59038
Function of Equivalent Sound Level under Alternative at the NAS Whidbey
Island Complex Average Year A-156
Average Year Alternative A-159
Table 8-3 Summary of Annual Flight Operations for the Average Year Alternative 3B A-178
Table 8-4 Detailed Annual Flight Operations for the Average Year Alternative 3B A-179
Complex Alternative A-200
Complex Average Year A-206
Average Year Alternative A-209
Table 9-1 EA-18G High Power Run-Ups for Hush House Analysis A-228
A-9
Appendix
GRROO1 59039
P-3C low-power run-ups would be conducted on the southwest ramp south of the EA-18G ramp while
the high-power run-ups would be conducted on the active runway near the threshold at Red Label
Foxtrot RLF and Red Label Delta RLD with the aircraft oriented along the runway heading
For the high-tempo FCLP year baseline scenario it was assumed the run-ups would not change
compared to the average year scenario
4.4 Aircraft Noise Exposure
Using the data described in Sections 4.1 through 4.3 NOISEMAP was used to calculate and plot the 60
dB through 90 dB DNL contours in 5-dB increments for AAD events for the average year baseline
scenario Figure 4-2 shows the resulting DNL contours
The 65 dB contour surrounding Ault Field would extend approximately to 11 miles from the runway
endpoints The locations of these lobes would be primarily attributable to the EA-18G on the approach
portion of GCA patterns where aircraft generally descend on 3-degree glide slope through 3000 feet
AGL 10 miles from the runway The 65 dB DNL contour would extend approximately mile past the
western shore of the mainland across Skagit Bay The 80 dB DNL contour would extend approximately
2.5 miles to the east outside the station boundary primarily due to EA-18G GCA and Visual Flight Rule
VFR approaches descending from 1800 feet AGL and also due to the GCA patterns The 90 dB contour
would extend 1300 feet to the east beyond the station boundary
The DNL exposure at the OLF would be attributable to the FCLP operations The 65 dB DNL contours
would extend northward just short of the southern shore of Penn Cove and southward approximately
miles south of the OLFs runway Appendix A7 shows the modeling output for the high-tempo FCLP year
scenarios
Table 4-4 presents the noise exposure in terms of estimated off-station population for each contour
band total of 11171 people are exposed to DNL of at least 65 dB among Ault Field and OLF
Coupeville
Under the high-tempo FCLP year baseline scenario Appendix A7 the totals would increase by percent
at Ault Field percent at the OLF and percent overall compared to the average year baseline
scenario
A-41
Appendix
GRROO1 59071
Table 5-2 Detailed Annual Flight Operations for the Average Year No Action Alternative
Day
0700
2200
Helo
Arrival from Aut
A-55
Appendix
GRROO1 59085
Table 7-2 Detailed Annual Flight Operations for the Average Year Alternative 2A
Day
0700-
2200
Helo
rn Va from Ault
H60 SAR
1239- 244
A-126
Appendix
GRR00159156
Table 7-11 Estimated Acreage and Population within the DNL Contour Ranges1 for the NAS
Whidbey Island Complex Alternative Average Year23
Greater than or
equal to 75 cIB DNL
No Action Alternative
Average Year 3596 3279 3269 2283 5549 3379 12414 8941
Alternative
Scenario 20/80 FCLP 4015 3699 3263 1886 5886 3493 13164 9078
split 419 420 -6 -397 337 114 750 137
Scenario 50/50 FCLP 3899 3595 3266 2423 6370 3763 13535 9781
split 303 316 -3 140 821 384 1121 840
Scenario 80/20 FCLP 3903 3701 3130 2472 6755 3922 13788 10095
split 307 422 -139 189 1206 543 1374 1154

Scenario 30/70 FCLP 3966 3703 3234 2189 6129 3606 13329 9498
split 370 424 -35 -94 580 227 915 557
Scenario 70/30 FCLP 3898 3667 3152 2435 6657 3876 13707 9978
split 302 388 -117 152 1108 497 1293 1037
Alternative
Scenario 20/80 FCLP 1553 539 3380 987 5149 1883 10082 3409
split -2128 -322 292 201 4511 1300 2675 1179

Scenario 50/50 FCLP 2124 583 3470 1065 3784 1447 9378 3095
split -1557 -278 382 279 3146 864 1971 865

Scenario 80/20 FCLP 3442 1059 3148 1018 1287 642 7877 2719
split -239 198 60 232 649 59 470 489

Scenario 30/70 FCLP 1651 518 3443 1027 4793 1774 9887 3319
split -2030 -343 355 241 4155 1191 2480 1089

Scenario 70/30 FCLP 3136 896 3157 1047 2413 968 8706 2911
split -545 35 69 261 1775 385 1299 681
Alternative
Scenario 20/80 FCLP 4238 2873 5376 12487
split 5568 98 6643 -196 11035 1414 23246 1316

-1709 286 4848 3425
Scenario 50/50 FCLP 4178 3488 5210 12876
split 6023 38 6736 419 10154 1248 22913 1705

-1254 379 3967 3092
Scenario 80/20 FCLP 4760 3490 4564 12814
split 7345 620 6278 421 8042 602 21665 1643

68 -79 1855 1844
A-148
Appendix
GRR00159178
Table 7-13 Average and 10th Percentile Noise Induced Permanent Threshold Shifts as Function of Equivalent Sound Level under
Alternative at the NAS Whidbey Island Complex Average Year
1.0 4.L 4/ 24 -3 31
71 16 -7 52
76-77 1.0 4.5 19 4118 165 355 164 90 58 160 63
196 288 42 232 119 45 13 115 18

77-78 1.5 5.0 336 402 310 354 127 75 88 100 57
L3O 103 169 77 121 80 28 41 53 10

78-79 2.0 5.5 148 243 296 175 295 92 65 78 61
98 151 30 150 68 41 -19 54 37

79-80 2.5 6.0 -35 163 241 141 211 75 59 70 76
71 149 49 119 68 52 -7 63 69
80-81 3.0 7.0 78 97 130 85 119 66 59 62
24 57 12 46 66 59 62
81-82 3.5 8.0 53 72 80 68 77 58 84 55
21 29 17 26 58 84 55
82-83 4.0 9.0 48 58 63 48 61 58 64
11 21 26 11 24 58 64
83-84 4.5 10.0 35 36 38 35 37 69 56
69 56
84-85 5.5 11.0 27 26 29 29 28 28
16 15 18 18 17 28
85-86 6.0 12.0 22 26 10 24
13 17 15
86-87 7.0 13.5 10 10
87-88 7.5 15.0
88-89 8.5 16.5
89-90 9.5 18.0
A-is
Appendix
GRR00159186
Table 7-14 Average Indoor Nightly Probability of Awakening at Applicable POls for the Average Year Alternative
Change from Change from Change from hange from

No Action 1o Action Vo Action jNo Action
R02 St and It 9% 35% 8% 6% 52% 38% 11% 6% 1% 12% 50% 36% 7% 55% 0% 14% 11%
\J Northgate
R03 Central uft 19% 10% 3% 2% 21% 11% 3% 23% 12% 7% 4% 20% 11% 3% 23% 12% 7% 1%
Whidbey
R04 Pull and Be ult 25% 12% 6% 3% 26% 12% 7% 3% 27% 12% 3% 25% 12% 6% 3% 27% 12% 3%
Damned Point
R05 Snee-Oosh uft 20% 7% 5% 2% 21% 7% 6% 2% 22% 7% 7% 2% 20% 7% 2% 22% 7% 7% 2%
Point
R06 Admirals Dr OLE 38% 27% 29% 21% 25% 17% 16% 11% 11% 7% 2% 1% 34% 24% 25% 18% 16% 11% 7% 5%
and Byrd Dr
R07 Race Lagoon OLE 18% 13% 6% 13% 5% 3% 7% 2% 2% 17% 7% 12% 3% 3% 1%
R08 Pratts Bluff OLE 13% 9% 6% 9% 5% 3% 2% 12% 6% 6% 3% 2% 1%
R09 Cox Rd and OLE 11% 7% 8% 5% 7% 1% 2% 3% 2% 10% 6% 7% 3% 1% 1%

sland Ridge
Way
RiO Skyline None 3% 3% 1% 8% 3% 3% 1% 3% 1% 3% 3% 1% 3% 3% 1%
Rh Sequim None
R12 Port Angeles None 1% 1% 1% 1% 1% 1%
R13 Beverly OLE 3% 3% 1% 2% 5% 3% 2%
Beach
Ereeland
R14 Sleeper Rd uft 4% 31% 7% 6% 47% 34% 10% J% 1% 37% 14% 12% F5% 32% 7% 50% 36% 13% 11%
Slumber Ln
R15 Long Point OLE 22% 12% 11% 18% 7% F% 14% 3% 21% 10% 10% 6% 15% 1%
Man or
R16 Rocky Point OLE 11% 2% 1% 12% 1% 3% 1% 13% 3% 12% 3% 1% 13% 3%
Heights
R17 Port None 1% 1% 1% 1% 1%
ownsend
R18 Marrowstone None
sland
Nordland
R19 sland Transit OLE 31% 20% 22% 15% 22% 13% 13% 11% 2% 28% 18% 19% 13% 15% 6% 3%
Dif ices
oupeville
A-is
Appendix
GRR00159189
Table 7-14 Average Indoor Nightly Probability of Awakening at Applicable POls for the Average Year Alternative
Change from Change from Change from hange from

No Action 1o Action Vo Action jNo Action
sland Agate
3each
501 Oak Harbor ult 25% 14% 5% 2% 27% 16% 7% 18% 6% 26% 15% 5% 3% 29% 17% 3% 5%
High School
S02 Crescent ult 26% 15% 5% 3% 28% 17% 7% 5% 30% 19% 7% 27% 16% 6% 30% 18% 3% 6%
Harbor
Elementary
School
503 Coupeville OLE 16% 10% 11% 7% 11% 6% 6% 3% 3% 14% J% 6% 7% 2% 1%
Elementary
School
504 Anacortes ult 3% 1% 1% 3% 1% 1% 3% 1% 1% 3% 1% 1% 3% 1% 1%
High School
cc
SOS Lopez Island None
School
506 Friday Harbor None
Elementary
cc
School
507 Siriames None
Douglas
Elementary
School
508 Fidalgo ult 3% 3% 1% 9% 3% 3% 1% 10% 3% 1% J% 3% 3% 1% 10% 3% 1%
Elementary
School
509 La Conner uft 11% 3% 2% 10% 5% 2% 2% 10% 2% 2% 10% 2% 2% 10% 2% 2%
Elementary
School
Sb alger Bay OLE
lementary
Assumes 15 dB and 25 dB of Noise Level Reductions for windows open and closed respectively
R01 and R06 include interior SEL5 greater than 100 dB with windows open
A-160
Appendix
GRR00159190
7.4.4 Residential Daytime Indoor Speech Interference
Table 7-15 presents the average daily indoor daytime 700 a.m to 1000 p.m events per hour for the
applicable POls that would experience indoor maximum sound levels of at least 50 dB with windows
closed and open for average year Alternative Events per hour would be less than one at 12 of the 30
POls and would range between one and 10 for the remaining 18 POls regardless of the window status
Relative to the average year No Action Alternative increases of one or two events per hour would be
experienced by 15 of the POls
For the high-tempo FCLP year Alternative Appendix A7 the above statistics would be the same
A-161
Appendix
GRR00159191
Table 7-15 Indoor Speech Interference for the Average Year Alternative
Change from Change from Change from hange from Change from
Vo Action No Action lNo Action lo Action Vo Action
Rd
R02 Salal St and wIt 10 10 10 10 10
Northgate
Dr
RO3Central wlt5 -i-i -i-i -i-i
Whidbey
R04 Pull and Be wIt
Damned Point
R05 Snee-Oosh wIt
Point
R06 dmirals Dr OLE
and Byrd Dr
R07 Race Lagoon OLE
R08 Pratts Bluff OLE
R09 CoxRdand OLE
Island
Ridge
Way
RiO Skyline None
RilSequim None
R12 Port Angeles None
R13 Beverly OLE
Beach
reela nd
R14 Sleeper Rd wIt 10 10
Slumber Ln
R15 Long Point OLE
nor
R16 Rocky Point OLE
eights
Rl7Port None
ownsend
R18 Marrowstone None
Island
Nordland
R19 Island Transit OLE
Offices
Cou pevil
le
A-162
Appendix
GRR00159192
Table 7-15 Indoor Speech Interference for the Average Year Alternative
Change from Change from Change from hange from Change from
Vo Action No Action lNo Action lo Action Vo Action
Island Agate
Beach
_________ _________ _________ ________ _________ _________ ________ ________ _________ _________ _________ ________ ________ ________ _________ _________ _________ _________ _________
01 Oak Harbor wIt
High School
02 Crescent wIt
Harbor
Elementary
School
03 Coupeville OLE
Elementary
School
04thacortes wIt
High School
cc
05LopezlslandNone
School
06EridayHarborNone
Elementary
cc
School
07SirJames None
Douglas
Elementary
School
08Eidalgo wIt
Elementary
School
09 La Conner wIt
Elementary
School
10 Elger Bay OLE
Elementary
School
With an indoor maximum sound level of at least 50 dB assumes 15 dB and 25 dB of noise level reductions for windows open and closed respectively
The Whidbey General Hospital is located within approximately 1000 feet of the Coupeville Elementary School therefore this location was not modeled individually but similar result for indoor speech interference for P01 S03
would apply
A-163
Appendix
GRR00159193
7.4.5 Classroom Learning Interference
Table 7-16 presents the potential learning interference for classrooms under the average year
Alternative With an Leq8h of 69 dB P01 S02 Crescent Harbor Elementary School would experience
the greatest outdoor Leq8h No other locations would experience Leq8h greater than or equal to the
screening threshold of 60 dB under any of the three alternatives With windows open three or four of
the POls would have more than one event per hour With windows closed two of the POls would have
more than one event per hour P01 SOl Oak Harbor High School would have the most events per hour
with up to seven with windows open POls SOl and S02 would have the most events per hour two or
three with windows closed
All POls would experience between and dB increases in Leq8h and increases of one or two events per
hour
Under the high-tempo FCLP year Alternative Appendix A7 P01 S02 Crescent Harbor Elementary
School would have an outdoor Leq8h of 69 dB Up to four of the POls would have more than one event
per hour with windows open SOl S02 S03 and R03 and up to two POls would have more than one
event per hour with windows closed SOl and S02 P01 SOl Oak Harbor High School would have the
most events per hour with up to seven with windows open and three with windows closed Relative to
the high-tempo FCLP year No Action Alternative POls would experience increases of up to two events
per hour Only one P01 would experience change in indoor Leq8h of greater than dB P01 S03
A-164
Appendix
GRR00159194
Table 7-16 Classroom Learning Interference for Average Year Alternative
Windows Closed Windows Open Windows Closed
Leqeh dB
School R03 Central Whidbey Ault 59 45 45
Surrogate Rh Sequim None 45 45 45
School SOl Oak Harbor High Au It 57 45 45
School
S02 Crescent Harbor Ault 69 54 45

Elementary School
S03 Coupeville OLF 57 45 45

Elementary School
S04 Anacortes High Ault 47 45 45

School
505 Lopez Island School None 45 45 45

S06 Friday Harbor None 45 45 45
Elementary School
S07 Sir James Douglas None 45 45 45

Elementary School
S08 Fidalgo Elementary Ault 50 45 45

School
S09 La Conner Ault 52 45 45

Elementary School
SlO Elger Bay OLF 45 45 45

Elementary School
Numberof Sites Exceeding
One Intrusive Event per Hour
Minimum Number of Intrusive Events
per Hour if Exceeding One
Maximum Number of Intrusive Events
A-165
Appendix
GRR00159195
ri7rnryj YI4 itw

School Oak Harbor High 58 45 45
Ault
School
Crescent Harbor 68 53 45
S02 Ault
Elementary School
Coupeville 45 45
S03 OLF
Elementary School
Anacortes High L5 45
S04 Ault
School

Friday Harbor 45 45 45
S06 None
Elementary School
Sir James Douglas 45 45 45

S07 None
Elementary School
Fidalgo Elementary 50 45 45
S08 Ault
School
La Conner 52 45 45
S09 Ault
Elementary School
Elger Bay L5 45 45
SlO OLF
Elementary School
Number of Sites Exceeding
A-166
Appendix
GRR00159196
WTrnrYL
School SOl Oak Harbor High Ault 58 45 45
School

Elementary School

Elementary School

School

Elementary School

Elementary School

School

Elementary School

Elementary School
A-167
Appendix
GRR00159197
ri7rnryj 7f7
School SOl Oak Harbor High Ault 57 45 45
School

Elementary School

Elementary School

School

Elementary School

Elementary School

School

Elementary School

Elementary School
A-168
Appendix
GRR00159198

School SOl OakHarborHigh Ault 58 45 45
School

Elementary School

Elementary School

School

Elementary School

Elementary School

School

Elementary School

Elementary School
Numberof Sites Exceeding
Notes
Assumes 15 dB and 25 dB of noise level reductions for windows open and closed respectively
Number of average school-day events per hour during 8-hour school day 0800-1600 at or above an indoor maximum single-event sound level Lmax of 50 dB
A-169
Appendix
GRR00159199
7.4.6 Recreational Speech Interference
Table 7-17 lists the AAD daytime NA 50 Lmax per hour for the recreational POls The average NA across
the 11 POls would be four events per daytime hour and one event per nighttime hour Seven POls would
be exposed to less than one event per hour Seven POls would have the most events per hour at 10
under Alternative Scenario Relative to the average year No Action Alternative increases of up to
two events per hour would be experienced at all but nine of the POls These latter nine POls would
experience no change
For the high-tempo FCLP year Alternative Appendix A7 the above statistics would be the same
A-170
Appendix
GRROO1 59200
Table 7-17 Recreational Speech Interference for Average Year Alternative
Increase re increase re increase re increase re
No Action No Action No Action No Action
P01 Joseph Whidbey State Park 10 10
P02 Pass State Park 10 10

Deception
P03 Dugualla State Park 10
P04 Baseball Field Ebeys

Landing National Historical
Reserve
P05 Ebeys Landing State Park
P06 Fort Casey State Park
P07 Cama Beach State Park
P08 Port Townsend
P09 Moran State Park
PlO San Juan Islands National
Monument
P11 San Juan Island Visitors
Center
P12 Cap Sante Park
P13 Lake Campbell
P14 Spencer Spit State Park
P15 Pioneer Park
P16 Marrowstone Island Fort
Flagler
EBLAOO1 Ferry House
EBLAOO2 Reuble Farm
A-171
Appendix
GRROO1 59201
ROl Sullivan Rd 10 10 10 10
R02 Salal St and Northgate 10 10 10 10
Dr
R03 Central Whidbey
R04 Pull and Be Damned Point
R05 Snee-Oosh Point
R06 AdmiralsDrandByrdDr
R07 Race Lagoon
R08 Pratts Bluff
R09 Cox Rd and Island Ridge
Way
RiO Skyline
ci
Rh Sequim
In
ci R12 Port Angeles
R13 Beverly Beach Freeland
R14 Sleeper Rd Slumber Ln 10 10 10 10
R15 Long Point Manor

R16 Rocky Point Heights
R17 Port Townsend -1
R18 Marrowstone Island
Nordland
R19 Island Transit Offices
Coupeville
R20 South Lopez Island Agate
Beach
A-172
Appendix
GRROO1 59202
S01 Oak Harbor High School 10 10
S02 Crescent Harbor
Elementary School
S03 Coupeville Elementary
School
S04 Anacortes High School
S05 Lopez Island School
S06 Friday Harbor Elementary

-c
School
S07 Sir James Douglas
Elementary School
S08 Fidalgo Elementary School
S09 La Conner Elementary

School
Sb Elger Bay Elementary
School
A-173
Appendix
GRROO1 59203
nt tint av
nt ht Un
IIt
db nd
Ru rk
en
ri
L_J
Nt
Wh
it Bu
Figure A4-24 Modeled Average Daily Interfacility Flight Tracks from Runway 07/25 at Ault Field
to the OLF for Numbered Alternatives
A4-28
AppendixA4
GRROO1 59470
TV
nt flnl
fF1
rnFIh rk
-iii
ResidenUat ti.-
Ii vc
Figure A4-26 Modeled Average Daily FCLP Flight Tracks at the OLF for Numbered Alternatives
A4-30
AppendixA4
GRROO1 59472
Allyson Brooks Ph.D Director
State Hjstoic Preservofon Officer
January 25 2017
Gary Mayes
Rear Admiral
U.S Navy
Commander Navy Region Northwest
1100 Hunley Road
Silverdale Washington 98315-1100
In future correspondence please refer to
Project Tracking Code 102214-23-USN

Re Draft Environmental Impact Statement for Proposed Increase of EA-18G Growler Aircraft
and Aircraft Operations and Development of Support Facilities NASWI
Dear Rear Admiral Mayes
Thank you for contacting the Washington State Historic Preservation Officer SHPO with
notification of the availability of the Draft Environmental Impact Statement DEIS for the above
referenced action proposed for Naval Air Station Whidbey Island NASWI The DEIS analyzes
the potential environmental effects that may result from the addition of up to 36 Growler aircraft
at NASWI As result of our review we provide the following comments and recommendations
for your consideration
Based upon our review of the DEIS we reach the opinion that cultural and historic
resources within the area of potential effect APE will be adversely affected by
implementation of the action as proposed In reaching this opinion we note the Criteria
of Adverse Effect from 36 CFR 800.5 and cited in Table 4.6-1 is
found when an undertaking may alter directly or indirectly any of the

characteristics of historic property that qualify the property for inclusion in the
National Register Historic Placesin manner that would diminish the integrity
of the pro pertys location setting design materials workmanship feeling or

association Consideration shall be given to all qualifying characteristics of
historic property including those that may include reasonably foreseeable

effects caused by the undertaking that may occur later in time be farther
removed in distance or cumulative
In addition examples of adverse effect that are relevant to this proposal from 36 CFR
800.5 and Table 4.6-1 include but not limited to
Change of the character of the propertys use or of physical features within the
propertys setting that contribute to its historic significance
Introduction of visual atmospheric or audible elements that diminish the
integrity of the propertys significant historic features
State of Washington Department of Archaeology Historic Preservation
P.O Box 48343 Olympia Washington 98504-8343 360 586-3065
ww.dahp.wa.gov
C-563
GRROO1 60334
We reiterate our concerns that the project APE defined as .the area encompassed by
the 65 dBA DNL noise contour that would exist in 2021 as represented by the No Action
Alternative and drawn on Figure 3.6.1 is too restrictive and does not include portions
of the region that will face comparable effects from visual atmospheric or audible
elements as those areas within the 65 dBA lines as drawn in Figure 3.6-1 We note that
the DEIS states that .APE boundaries will be updated as consultation continues
between the SHPO consulting parties American Indian tribes and nations and other
interested parties Therefore we recommend including in an expanded APE additional
portions of Whidbey Island Camano Island Port Townsend vicinity and San Juan
Islands
In addition we are not convinced that the 65 dBA serves as the best or most appropriate
measure for quantifying and assessing harmful levels of sound and vibrations from
Growler activities Our concern is based upon what appears to be an averaging of sound
levels over long time periods that does not adequately capture the real time experience
of brief but more numerous exposures to higher decibel levels as well as the cumulative
effect of these events
Further we note that the U.S Department of Housing and Urban Development has
posted on Exchange https//www hudexchanqe nfo/proqrams/envftonmenta

revew/nose-abatement-and-controV standards that classify 65 dB as normally
unacceptable and above 75 as being unacceptable Given discussion on page 4-194

of the Kester and Czech 2012 study at NSAWI finding takeoff sounds levels greater than
110 dBC fosters additional concern of noise levels of historic properties receiving
exposure to 75 dB and the need for further perhaps ongoing site specific sound testing
data gathering analysis and commensurate level of mitigation measures
In related comment discussion in Chapter on operational impacts of vibration on
historic properties states No significant physical damage as result of aircraft
operations has been reported to these structures as result of continuous operation of
aircraft for over 70 years 4-195 and sound levels damaging to structural
components of buildings are not likely to occur 4-50 Again our concerns are not
allayed by these statement about the cumulative impacts of vibration and sound waves
on the structural integrity of historic buildings/structures in the APE and beyond in
communities such as Coupeville and Port Townsend

Furthermore and even if consensus were reached that the sound waves and vibration
associated with flight operations have only minor impact on structural integrity there is
concern that historic building owners will take steps to remedy rattling windows and
replace cracking walls and ceilings with inappropriate replacement materials and
methods if not total replacement or abandonment of the structure
Overall our larger concern about this proposal is the long-term and cumulative effects of
increased flight operations on the character and qualities of historic places and
communities that will experience increased levels and frequencies of noise We do not
see firm evidence in the DEIS that the characteristics and qualities that have drawn
generations to the region to live work and recreate will not be significantly diminished if
not eventually lost as result of increased flight operations
ww.dahp.wa.gov
C-564
GRROO1 60335
In summary our review of the DEIS leads us to the opinion that the project implementation will
adversely affect historic properties in the APE We look forward to further consultation with the
SHPO Tribes and other affected parties to avoid minimize or mitigate the adverse effect
Thank you for the opportunity to review and comment If

you have any questions please feel
free to contact me
Sincerely
Allyson Brooks
State Historic Preservation Officer
Aflyson Brooksdahp.wa.qov
360-586-3066
Jim Baumgart Governors Office
Kristin Griffin Trust Board of Ebeys Landing NHR

Deborah Stinson Mayor City of Port Townsend
ww.dahp.wa.gov
C-565
GRROO1 60336
Navy 2016c Two years later in 1973 NAS Whidbey Island was formally established as Functional
Specialty Center responsible for the training and operations of all medium attack squadrons of the
Pacific Fleet and all of the Navys tactical electronic warfare squadrons
The Central Whidbey Island Historic District was listed on the NRHP on December 12 1973 The original
nomination form noted its state significance period of significance for the nineteenth century and
areas of significance including aboriginal historic agriculture architecture commerce and military
The ELNHR Ebeys Reserve boundaries are the same as the Central Whidbey Island Historic District
Established under Section 508 of the Parks and Recreation Act of 1978 the Ebeys Reserve was created
to preserve and protect rural community which provides an unbroken historic record from...l9th
century exploration and settlement in Puget Sound to the present time The reserve is the only
historical reserve in the National Park System The lands included in the historic district today include
approximately 17400 acres including Penn Cove The district consisted of original donation land claims
locations listed in Historic American Building Survey HABS Fort Casey and structures displaying
cross-section of early domestic architecture Cook 1972
By 1980 aviation units based at NAS Whidbey Island included six medium attack squadrons nine tactical
electronic warfare squadrons and three Naval Air Reserve squadrons Navy 2016c In 1980 an
addendum to the NRHP nomination form for the Central Whidbey Island Historic District was developed
to include the Clark House in new location Vandermeer 1980 During the 1980s NAS Whidbey Island
squadrons provided electronic warfare support to U.S naval forces operating around the world NAS
Whidbey Island then functioned as the main homeport for the Pacific Fleet of Prowler squadrons which
began the transition to Growler aircraft in 2008 The Seaplane Base has continued as support facility to
Ault Field Navy 2016c
In 1998 an amendment to the Central Whidbey Island Historic District was completed This amendment
notes the property as district with private and public ownership containing 103 contributing
buildings six sites 286 structures and one object It identifies 79 contributing resources previously
listed in the NRHP The NRHP form notes significance under criteria and period of significance
from 1300 to 1945 and areas of significance in agriculture architecture commerce recreation/tourism
ethnic heritage exploration/settlement education religion military and politics and government The
amendment also identifies key cultural landscape components and characteristics such as land use
patterns circulation systems landscape organization vegetation and farm complexes Gilbert and
Luxenberg 1997
Ten contributing landscape areas were included as part of the 1998 amendment in order to represent
four primary landforms and the Town of Coupeville The ten contributing landscape areas are defined in
the amendment as Ebeys Prairie Crockett Prairie Smith Prairie San de Fuca Uplands Fort Casey
Uplands East Woodlands West Woodlands Penn Cove Coastal Strip and Coupeville The contributing
landscapes possess character-defining qualities including
Patterns of Spatial Organization
Natural Vegetation
Land Use Categories and Activities
Vegetation Related to Land Use
Circulation
C-788
GRROO1 60559
Wyle Report WR-1304 which is the User ManualAdvancedAcoustic Model TechnicalReference and
User Manual SERDEP Project WP-1304 dated May 2009 describes the potential benefits of AAM and
limitations of NOISEMAP for assessing next-generation aircraft primarily differentiated by vectored
thrust ability and higher maximum thrust These factors principally apply to fifth-generation aircraft
such as the F-22 and F-35 The F-22 is capable of generating more than 35000 pounds of force lbf from
each of its two engines The F-35 produces 43000 lbf of thrust from its single engine The Growler
utilizes two General Electric F414-GE-400 engines with reported thrust of 22000 lbf with afterburner
significantly lower than the fifth-generation fighter aircraft For comparison of historical aircraft the
maximum thrust for each of the two engines of the F-15C is 23700 lbf with afterburner while the F-14s
two engines were each capable of 28200 lbf with afterburner For comparison to aircraft that have
historically operated at NAS Whidbey Island the Prowler engines each generate 10400 lbf of thrust
4.d Day-Night Average Sound Level Metric
The day-night average sound level DNL metric is discussed in Section 3.2.2.1 DNL has been determined
to be reliable measure of long-term community annoyance from aircraft noise and has become the
standard noise metric used as federal standard for measuring noise impacts The DNL metric is the
industry standard methodology supported by guidance from the Federal Aviation Administration FAA
U.S Environmental Protection Agency Department of Defense DoD Federal Interagency Committee
on Noise American National Standards Institute and World Health Organization among others and is
the most accurate and valid method for evaluating the impacts of noise under current and future
conditions As federal standard the DNL metric is used by many state and local governments including
Island County in their land-use planning and zoning ordinances In addition the use of 65 decibels dB
DNL is the established federal standard for determining potential for high annoyance This sound level
has been identified in both the FAAs Part 150 Program and the DoDs Air Installations Compatible Use
Zones AICUZ Program including the individual Air Force and Navy programs as threshold for land
use recommendations Land use guidelines for evaluating acceptable noise levels were developed based
upon 365-day averaging and the analysis remains consistent with that standard If
solely active flying
days had been computed the results would not be applicable to the established guidelines based on
365-day averaging and could not be applied directly
Some commenters have noted that the DNL metric is an average metric over the course of an entire
year whereas the airfields at the Naval Air Station NAS Whidbey Island complex do not necessarily
have aircraft operations every day throughout the year therefore noise should be assessed on active
flying days this topic is also discussed in Section 3.1.2 of the Environmental Impact Statement EElS The
DNL metric is not particularly sensitive to the modeled number of days per year meaning the results do
not vary drastically if the aircraft noise is averaged over the entire 365-day calendar year or number of
days less than that number The noise contour results are dictated more by what aircraft are flying the
types of operations they are conducting and their frequency of operations The NAS Whidbey Island
complex typically operates days per week or approximately 260 days per year If the DNL metric for
the analysis were utilized 260 days per year the DNL values would only increase by approximately 1.5
dB beyond those computed for 365 days per year This 1.5 dB adjustment would apply equally to both
the existing condition and the proposed scenarios so the increases reported under the Proposed Action
would not change regardless of the number of flying days used for the analysis Additionally the use of
Average Busy Day ABD would fail to account for the benefit the Navys minimal weekend operations
would have on those days which are days when people are less likely to be away from their homes at
M-29
Appendix
RROO 16 13 18
work Also ABD used for an analysis with multiple scenarios can be misleading For example if an
airfield doubles operations but also doubles its flying days the resulting DNL will not change with all else
being equal
In 1974 the Environmental Protection Agency published Information on Levels of Environmental
Noise Requisite to Protect Public Health and Welfare with an Adequate Margin of Safety March 1974
also known as the Levels Document that reviewed the factors that affected communities DNL still
known as Ldn at the time was identified as an appropriate noise metric and threshold criteria were
recommended Threshold criteria for annoyance were identified from social surveys in which people
exposed to noise were asked how it affected them Surveys provide direct real-world data on how noise
affects actual residents In 1978 noise researcher Schultz showed that the common ground among
studies was the number of people highly annoyed defined as the upper 28-percent range of whatever
response scale survey used Consistent with World Health Organization recommendations the Federal
Interagency Committee on Noise considered the Schultz Curve to be the best source of dose
information to predict community response to noise but recommended further research to investigate
the differences in perception of noise from different sources While more recent research has shown
that people may be more sensitive to todays noise environment the 1978 Schultz Curve is still
recognized in the United States and enacted in land-use ordinances at the federal state and local levels
For additional details regarding the latest analysis related to people highly annoyed by noise and related
noise exposure refer to Appendix Al Section A.3.l of the Aircraft Noise Study Appendix
Because DNL is an average and is often viewed as an inadequate prediction of annoyance to single-event
aircraft noise the analysis includes supplemental analyses The analysis evaluated 48 points of interest
in the community of which 30 representative locations were analyzed for potential indoor speech
interference 30 locations for potential for sleep disturbance 12 locations for potential for classroom
learning interruption and 48 locations for recreation and outdoor speech interference The
supplemental analyses utilize the appropriate single-event metrics that include Maximum Sound Level
Lmax Sound Exposure Level SEL and numbers of events above NA threshold level consistent with
Department of Defense guidance see Sections 4.2.2.2 4.2.3.2 and 4.2.4.2
4.e Day-Night Average Sound Level Contours and Noise
The day-night average sound level DNL metric is discussed in Section 3.2.2.1 Within that discussion it
is noted that the 65 decibel dB DNL is the established federal standard for determining potential for
high annoyance This level has been identified in both the Federal Aviation Administrations Part 150
Program and the Department of Defenses DoDs Air Installations Compatible Use Zones Program
including the individual Air Force and Navy programs as threshold for land use recommendations
Consistent with this guidance 65 dB DNL is used to show areas with potential for high annoyance in this
analysis However aircraft noise does occur outside the 65 dB DNL contour In order to more fully
reflect the noise environment the Draft Environmental Impact Statement ElS included noise contours
of 60 dB DNL as well as detailed noise analysis for specific points of interest In response to public
comments the Navy has expanded the analysis in the Final ElS to show geographic areas subject to
greater than 55 dB DNL and has analyzed 18 additional points of interest
For additional details related to the latest analysis regarding people highly annoyed by noise and related
noise exposure refer to Appendix Al Section A.3.l of the Aircraft Noise Study Appendix Land use
guidelines for evaluating acceptable noise levels were developed based upon 365-day averaging The
M-30
Appendix
RROO 16 13 19
analysis remains consistent with that standard There are increases to the size of the DNL noise contours
under each of the proposed alternatives/scenarios presented in Section 4.2 Under all
alternative/scenario combinations the land area within the DNL noise contours would increase but it
would do so to varying degrees The tables and figures throughout Section 4.2 show the estimated
change in acreage and consequent estimated change in the population within the noise contours
including the 65 dB DNL 70 dB DNL and greater than 75 dB DNL contours and tabulate these data by
Ault Field Outlying Landing Field Coupeville and total Based upon public comments municipal
boundaries for cities and towns around the two airfields have been added to show their location in
relation to the DNL noise contours
Many commenters have noted that the 65 dB DNL threshold is not adequate because it does not reflect
that noise exists outside the 65 dB DNL noise contour See Section 3.2.2 which explains how DNL is
calculated and why it is valuable metric to measure community annoyance The Navy recognizes that
high levels of noise can occur outside of the 65 dB DNL noise contour For this reason the Navy selected
points of interest throughout the community including large number outside of the dB DNL noise
contours and used supplemental metrics to provide more comprehensive presentation of the noise
environment see Sections 3.2 and 4.2
4.f Noise Measurements/Modeling/On-Site Validation
Measuring current noise conditions and/or monitoring future noise conditions as well as collecting
subjective/experiential data are not being considered In addition the results of the National Park
Services noise study affirm the results modeled by the Navy and additional noise monitoring would not
change the results of the impacts presented in this analysis
The discussion of the NOISEMAP model as well as the data inputs into the model that were used for this
analysis can be found in Section 3.2.2 NOISEMAP is the accepted U.S Department of Defense standard
for assessing noise impacts
4.g Average Annual Day/Average Busy Day Noise Levels
Some commenters have stated that the Navy should have used the Average Busy Day ABD
methodology found in the Navys Air Installations Compatible Use Zones instruction The ABD
methodology is not appropriate for this analysis for the reasons stated in Section 3.1.2
4.h C-Weighted Noise Low Frequency Noise and Vibrations
For discussion on noise refer to Section 3.2 and Appendix Aircraft Noise Study A-weighting best
replicates human hearing and is the most appropriate for the assessment of annoyance from aircraft
noise A-weighted sound levels form the basis of the day-night average sound level DNL metric which
is the best available metric to relate aircraft noise to long-term annoyance The Federal Interagency
Committee on Noise found that There are no new descriptors or metrics of sufficient scientific standing
to substitute for the present DNL cumulative noise exposure metric
Commenters have suggested that A-weighted measures may not be as accurate in determining the
disturbing effects of noises with strong low-frequency components However the alternative
measurement methodology using C-weighting increases the emphasis on lower frequencies when
compared with A-weighting C-weighting is most appropriate for impulsive or repetitive sounds such as
blast noise and machine gun fire which contain significant low-frequency noise as well as continuous
M-31
Appendix
GRR00161320
IP/F ME OF NAVY
November 30 2018
Mr John Fowler
Executive Director Advisory Council
on listoric Preservation
401 Street NW Suite 308
Washington DC 20001
Reference Notice of Termination of Consultation for EA480 Growler Airfield Operations
Dear Mr Fowler
After careful find

consideration necessary to noti1 the Advisory Council on Historic
it
Preservation ACHP of my decision to terminate consultation under Section 106 of the National
Historic Preservation Act NHPA to resolve adverse effects to historic properties resulting from
the proposed increase in EA- 8G Growler airfield operations at Naval Air Station Whidbey
Island Complex
Despite our best efforts to reach agreement among the parties there remains
disagreement on the type and amount of mitigation appropriate to resolve adverse effects to
historic properties that would result from the undertaking At this time operational requirements
dictate that the Navy make decision on the undertaking For these reasons have determined
that further consultation is no longer productive have enclosed an Executive Summary

detailing our decision to terminate supporting information is included in Attachments 17
In accordance with 36 CFR 80O7a1 request the ACHP comment on this matter
By this letter also provide notice of termination to the Washington State Historic Preservation
Officer SHPO and other consulting parties
The Navy recognizes its responsibilities to protect the historic district and the
contributing rural landscape and believe the measures that the Navy offered during the
consultation reflect an appropriate response to the effects of the undertaking In

process
addition as member of the Whidbey Island community the Navy will continue to seek ways to
alleviate community concerns related to increased airfield operations The Navys commitment
to its role as community member extends well beyond completion of these NHPA actions
Thank you for your prompt attention to this matter
Karnig Ohannessian
Iepartment of the Navy
Federal Preservation Officer
GRR00164171
Enclosure ExecutiveSuthmary
Attachtneiits
Consultation History to date with key documents
Navys DeterminatiOn of A4rse Effect

ConsultationPian providedto cotisultingpaities oii July24 2018
Navy proposed resolutions in the Draft Memorandum of Agreement MOA of September

27 2018
Navy ptQppsedresQlutions in the Revised Draft MOA of NOveinbei 72018

Operational impacts of Growler consultation timeline
SHPO LetterofNovethbler 29 2Q18 Rejctin the Navy Final Offer
copy tp
Ms MaryOn Attwood Citizens of Fbeys Reserve
Mr Jim Baumgart Offie of the Governor
Dr Allysoit Brooks Wahingon State Historic Preservation Office
Mr Daid Day citien

Ms Jackie ierry Samish Tribe
Ms Kristen Griffin Trust Board of Ebeys Landing National Historical Reserve
Ms Molly Hughes Town of Coupeville
Ms Josóphinë Jefferson Swinomish Tribe
Mr AdaxaLeMieux Office of Congtesman Ltsen

Mr Dennis Lewrch$uquanilsh Tribe
Ms Kerry Lyste Stillguainish Trihe
Ms HelenIPriceJohnson Island County Commissioners

Ms Deborah StinsOn City of Poet TYwisend
Mr Richard Young Tulalip Tribes
Mr Roy Zipp National Park Serye at Ebes Landing National Historical Reserve
GRR00164172

Case 2:19-cv-01059-RAJ-JRC: 36-1 - Declaration of Zachary K. Griefen Exhibit 1

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Case 2:19-cv-01059-RAJ-JRC Document 36-1 Filed 02/13/20 Page 1 of 122

Case 2:19-cv-01059-RAJ-JRC Document 36-1 Filed 02/13/20 Page 2 of 122

Environmental Impact Statement for EA-18G Growler Airfield

Operations at the Naval Air Station Whidbey Island Complex

EXECUTIVE SUMMARY ES-i

NOISE AND HEALTH READERS GUIDE ES-is

OVERVIEW OF THE ENVIRONMENTAL IMPACT STATEMENT ES-23

ABBREVIATIONS AND ACRONYMS xxxix

PURPOSE OF AND NEED FOR THE PROPOSED ACTION i-i

i.i Introduction i-i

i.2 Location i-i

i.3 Purpose of and Need for the Proposed Action i-s

i.5 Scope of Environmental Analysis i-8

i.6 Key Documents i-iO

i.7 Relevant Laws and Regulations i-u

i.8 Agency Participation and Intergovernmental Coordination i-iZ

i.9 Public Participation Scoping 20i3 and Scoping 20i4 i-i3

1.9.1 Scoping Notifications 1-14

1.9.2 Sco ping Meetings 1-15

1.9.3 Scoping Comments 1-17

1.9.4 Summary of Scoping Comment Topics and Commenters 1-18

i.iO Public Participation Draft ElS Review i-2O

1.10.1 Draft Notifications 1-20

1.10.2 Draft Public Meetings 1-21

1.10.3 Draft Public Comments 1-24

1.10.4 Summary of Draft Comment Topics and Commenters 1-25

i.ii Public Participation Comment Themes i-28

1.11.1 General Topics 1-28

1.11.2 Airspace and Airfield Operations 1-30

1.11.3 Noise Associated with Aircraft Operations 1-31

1.11.4 Public Health and Safety 1-38

1.11.5 Air Quality 1-40

1.11.6 Socioeconomics 1-40

i.iZ Other Reports i-42

Impacts 2017 1-43

1.12.3 State of Washington Department of Health Public Comment 2017 1-47

Complex 2017 1-49

Historical Reserve 2016 1-51

in the Vicinity of Whidbey Island 2015 1-55

1.13 Clarification and Changes to the Environmental Impact Statement 1-60

1.13.1 Executive Summary 1-71

1.13.3 Chapter Proposed Action and Alternatives 1-72

1.13.4 Chapter Affected Environment and Chapter Environmental Consequences 1-72

1.13 .4.1 Airspace and Airfield Operations 1-72

1.13 .4.2 Noise Associated with Aircraft Operations 1-72

1.13 .4.3 Public Health and Safety 1-74

1.13 .4.4 Air Quality 1-74

1.13.4.5 Land Use 1-75

1.13.4.6 Cultural Resources 1-75

1.13.4.7 American Indian Traditional Resources 1-76

1.13.4.8 Biological Resources 1-76

1.13 .4.9 Water Resources 1-76

1.13.4.10 Socioeconomics 1-76

1.13.4.11 Environmental Justice 1-77

1.13.4.12 Transportation 1-77

1.13.4.13 Infrastructure 1-77

1.13.4.14 Geological Resources 1-77

1.13.4.15 Hazardous Materials and Wastes 1-77

1.13.4.16 Climate Change and Greenhouse Gases 1-77

1.13.5 Chapter Cumulative 1-78

1.13.6 Chapter Other Considerations Required by NEPA 1-78

1.13.7 Chapter References 1-78

1.13.8 Appendices 1-78

PROPOSED ACTION AND ALTERNATIVES 2-1