Case 2:19-cv-01059-RAJ-JRC Document 41-1 Filed 02/13/20 Page 1 of 5

EXHIBIT A
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Deborah Stinson

Mayor

250 Mathson Suite

Port Townsend WA 98368

360-379-5047
dstinsoncityof pt us

August 162016

Captain GC Moore

Commanding Officer

Naval Air Station Whidbey Island

3730 North Charles Potter Avenue

Oak Harbor Washington 98278-5000

RE Request for Section 106 Comments EA-l8G Growler Operations

Dear Captain Moore

Fhank you for the opportunity you provide in your July 12 2016 letter for the City of Port

fownsend to consult on the proposed Area of Potential Effect APE for the continuation and

increase of Growler operations at NAS Whidbey Island

The City asks that

you expand your area of study as well as your
definition of the indirect

effects component of the APE We also ask that

you consider using different measure of sound

impacts

Area of studyJ too narrow

Your area of study does not include all of the historic areas over which the Growlers fly While

the primary impact areas on Whidbey are affected by take-off and landing operations many
other areas of the Salish Sea area including the City are affected by flight operations The City

was founded in 1851 and contains two US National Historic Landmark Districts our

Downtown and Uptown areas as well as the fort Worden Historic District rhe Districts include

approximately 40 separately-listed properties and structures on the National Register of listoric

J\ NAt IiN ER OI 113

WA

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Places The noise impacts from Growler operations impacts residents visitors and historic

structures in the District therefore the City asks that the APE be expanded to include all

historic areas within the training flight areas

Measure of sound impacts does not take into account rural/naturaHyqjet areas

The City believes that the flight operations may diminish the integrity of the setting of Port

Townsends Historic Districts in that they change the historically-quiet setting of those Districts

within
Also flight operations may have an adverse physical effect on some historic structures

those Districts1

According to your letter your baseline for impacts is noise over 65 decibel dW Day-Night

Average Sound evel DNL This is an average noise level measured over the course of

year While this is the FAA standard FAA policy does not preclude local jurisdictions from

setting lower threshold of compatibility for new land use

developments and the policy allows

for supplemental or alternative measurements2

The average decibel level in the City especially at night is

likely to be very low even below
55dB in certain parts of the City Growler operations are not continuous the noise impacts of the

operations vary based on the exercise but include flights over and near the City for hours at

time frequently at night Therefore the City believes that measuring the noise impacts here

and on Whidbey using an Fffective Perceived Noise Level as provided in lederal Aviation

Regulation Part 36 would be more accurate measure of the effect of flight operations

Finally the DNL uses A-weighting for the decibel measurement It does not take Into account

low-frequency
noise As noted in 2004 article

Regulatory authorities must accept that

annoyance by low frequency noise presents

real problem which is not addressed by the commonly used assessment methods In

particular the A-weighted level is

very inadequate as are the NR and NC criterion

curves Assessment methods specific to low frequency noise are emerging but

limitation of existing methods is that they do not give full assessment of fluctuations

It is possible that application of noise quality concepts in particular fluctuation and

roughness Zwicker and Fast 1999 may be

way forward

See FAA Section 106 Handbook June 2015 Page 27 Section Cla Noise Hasics and the Effect of Aviation

Noise on the Environment Wyle Page 25 Sections 110 Viewed at

flr ii on August 16

2016
Report No DO bAA/AFE/201-02 lechnical Support for Day Night Average Sound Level DNL Replacement
Metric Rcsearch June 142011 Mestre Schomer Fidell l3eriy Authors

114

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3J
Leventhall Low frequency noise and annoyance Noise Health onlinel

2004 2016 Aug Available

from

The City appreciates the need for pilot training and is grateful for the sacrifices made by the

members of our military and their families We ask that the APE be expanded to cover all

historic areas subject to flight operations not just take-off and landing We also ask that you

measure those impacts as precisely as possible and take into consideration low-impact

frequencies

sti
Mayor

EneL

cc Honorable Patty Murray US Senator

Honorable Maria Cantwell US Senator
Honorable Derek Kilmer US Representative

lonorahie James Hargrove Washington State Senator

Honorable Steve Tharinger Washington State Representative

Honorable Kevin Van Dc Wege Washington State Representative

115

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Case 2:19-cv-01059-RAJ-JRC Na0ona
Document 41-1 Filed 02/13/20 Page 5 of 5
Htoric Paces Register

NaonaI Register of HistorL

National Park Service

ILS Department of the Interior

Public nonrestricted data depicting National Register spatial data proce

3000 ft
Disdaimer https/fwwwnps gov/pmap/dsç ine1/

Home https//wwwnpsgov Frequently Asked Questions https//wwwnpsgov/faqshtm

https /www.npsgovImapsfuH hmilmapId7ad17cc9-b8O8/4fa2f8/a99909164

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