Case 2:19-cv-01059-RAJ-JRC Document 41 Filed 02/13/20 Page 1 of 3

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The Honorable Richard A. Jones
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6 IN THE UNITED STATES DISTRICT COURT
FOR THE WESTERN DISTRICT OF WASHINGTON
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AT SEATTLE
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STATE OF WASHINGTON, CITIZENS
9 OF THE EBEY'S RESERVE FOR A
HEALTHY, SAFE AND PEACEFUL NO. 2: 19-cv-O 1062-RAJ-JRC
10 ENVJRONMENT; and
PAULA SPINA,
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DECLARATION OF
12 Plaintiffs, PORT TOWNSEND MAYOR
MICHELLE SANDOVAL
13 v.
14 UNITED STATES DEPARTMENT OF
THE NAVY, et al.,
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16 Defendants.

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Pursuant to 28 U.S.C. § 1746 and under penalty of perjury, I, Michelle Sandoval, declare that the
18 following is true and correct:
19 l. I am over the age of 18 and competent to testify in this matter. The information in
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this declaration is based on my personal knowledge.
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2. I am the Mayor of Pott Townsend, Washington and have been since 2016.
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3. The City of Port Townsend is located at the n01theast tip of the Olympic Peninsula,
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just across Admiralty Inlet from Whidbey Island.
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25 4. There are about 10,000 residents in the City of Pott Townsend. The city is home to

26 Fort Warden State Park. The city is known for its collection of historic Victorian houses. Lt is one

Bricklin & Newman, LLP

i\uornt')'S at Law
1424 Fourth /\vc:nuc.:, Suill' 500
Deel. of Mayor Sandoval Case No. 2: 19-cv-O 1062-RAJ-JRC - 1 Scartlc WA 91\\lll
Tel (206) 264-R600
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 Case 2:19-cv-01059-RAJ-JRC Document 41 Filed 02/13/20 Page 2 of 3

of three Victorian seaports on the National Register of Historic Places. Fort Worden is on the

2 National Register, too, along with approximately 40 individual properties and structures.
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5. The City is impacted by the Growlers that fly out of Naval Air Station Whidbey.
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The planes produce deafening noise throughout the city, including in our dO\vntown tourist area
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and at Fott Worden. The noise impacts visitors and residents alike.
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7 6. The City is concerned that the Growler operations are diminishing the integrity of

8 the setting of the Port Townsend historic districts and the livability of our city. We have expressed

9 these concerns to the Navy in commenting on the Draft Environmental Impact Statement and in
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Section 106 process, specific to protecting historic resources in the city. See Exhibit A and Exhibit
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B hereto. But the Navy has been unresponsive to our concerns. The Navy concluded the Section
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l 06 consullatiun process without entt:ring into a mt::morandum of understanding that might have
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addressed our concerns. Instead, the Navy adopted a Record of Decision that increases the number
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15 of Growler's operating out of Whidbey NAS-and over our city.

16 7. The Navy's implementation of the Record of Decision has resulted in a considerable

17 increase in noisy Growler's impacting our City's residents and visitors. I frequently get phone calls
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or am stopped on the street with complaints about the noise. Visitors and residents complain that
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the noise disrupts their ability to enjoy living in and visiting the city. The noise is damaging the
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integrity of the many historic resources we hold dear.
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8. I understand that the plaintiffs in this lawsuit are seeking a preliminary injunction
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23 to reduce the Growler flights to their pre-ROD levels during the pendency of the litigation. While

24 I assume that would provide many benefits for the persons living and visiting on Whidbey Island

25 close to the airfields, I want the Court to know that a preliminary injunction would also benefit the
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broader public by reducing impacts here in Port Townsend. The thousands of visitors to our historic
Bricklin & Newman, LLP
1\uornq·s :u I.aw
1424 flt1urth l\vcr\<1<, Suite 500
Deel. of Mayor Sandoval Case No. 2:19-cv-01062-RAJ-JRC - 2 Sca<clc W1\ 9HHl1
Tel (206) 264-8600
I 'ax. (206) 2<>4 930ll
 Case 2:19-cv-01059-RAJ-JRC Document 41 Filed 02/13/20 Page 3 of 3

1 sites and downtown area and our residents will benefit hugely from a reduction of Growler
2 operations to their former level.
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I declare under penalty of perjury that the foregoi ng is true and correct.
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Dated this~ day of February, 2020, in Port Townsend, Washington.
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By: /J:b4Rll~
Michelle Sandoval
MAYOR OF PORT TOWNSEND
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Bricklin & Newman, LLP

Attucn~ys at Law
1424 Fourth .'\venue, Suite SOO
Deel. of Mayor Sandoval Case No. 2:19-cv-01062-RAJ-JRC - 3 Scattk WA 9H101
'I'd . (20<>) 2G4-!1(~10
Fox (2L16) 264 9100