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EXHIBIT B
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fl Deborah Stinson

___
C1tyf rr Mayor
250 Mathson Sufte

WA
ownsenu Port Townsend

360378-5047
dstinsoncityofpt us

EA-18G Growler EIS Project Manager

Naval Facilities Engineering Command Atlantic

Attn Code EV2IISS

6506 Hampton Boulevard
Norfolk VA 23508

Dear Sir or Madam

Thank you for the opportunity to comment on the Draft Environmental Impact
Statement DEIS published November 11 2016 on the addition of 36 EA-1 8G
GrowIer jets to the fleet of 82 existing Growlers at Naval Air Station Whidbey
Island NASWI The City previously provided scoping comments on the DEIS in

its letter dated January 2015 It also submitted comments and request for
Section 106 consultation on August 16 2016

The published DEIS does not address our previous comments To summarize
our January 2015 scoping comments addressed

The Navys piecemeal EIS and Environmental Assessment processes for

proposed Navy operations rn the Military Operations Area in the Olympic

National Forest do not comply with NEPAs requirement that the effects of

functionaUyreIated must be assessed together and

activities the

cumulative impacts of those activities addressed

The DEIS does not properly reflect the impacts of jet noise pollution and
other stressors to the health and weIlbeing of our community and our
neighbors on the Olympic Peninsula

Since sending this letter we have discovered other issues that could have direct

impact on Port Townsend and our Olympic Peninsula neighbors

Verbal statements by Navy personnel in public meetings are still not

clearly reflected in written materials As an example the DEIS numbers for

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Growler operations do not include an additional 42 planes as was

discussed at the Navys December open house
There is no mention of weekend training flights in the DEIS but the

Washington State Forest Services Draft Permit does talk about weekend

flights

Additionally our Section 106 consultation letter addressed

request that for noise impacts the Navy expand the area of study as
well as the definition of the indirect effects component of the Area of

Potential Effect APE

request to consider using different measure of sound impacts

request to include an evaluation of all the historic areas over which the

Growlers fly not just the much smaller historic areas affected by takeoffs
and landings

request to enter into formal consultation with the City of Port Townsend
under authority of Section 106 of the National Historic Preservation Act

We remain concerned that the Navy continues to separate the ground air and

sea-based activities on and around the Olympic Peninsula into different public

processes This practice of segmentation has resulted in numerous separate

comment periods between January 2014 and now As we have previously stated
we share the view of some of our constituents who do not view these electronic

warfare testing training and flight activities as separate And that the Navys
segmentation of impacts into numerous distinct public processes continues to

cause confusion and frustration to people who are trying to piece together the full

of impacts
scope

While not directly related to this DEIS we note that this continues practice that

we described in September 2007 letter to the Navy in relation to proposed

actions at Naval Magazine Indian Island

NEPA requires that all

functionally related activities be considered together and
it mandates .. review of cumulative incremental impacts of actions when
following and/or added to other actions regardless of what agency federal

nonfederal private undertakes such other actions 40 CFR 1508.7 The

Navys persistent and chronic segmentation of impacts and its lack of cumulative

effects analyses are cause for serious and long term concerns about public and

environmental health in our own community

Noise Impacts

We incorporate our August 16 2016 Section 106 consultation letter into our

general comments As we mentioned in that letter the DEIS uses an outdated

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noise simulation model that DoD-commissioned study found is not appropriate

for Growler engines

Historic Preservation

As we stated in our Section 108 consuttation letter we believe that the decision

to restrict the APE to areas that rmmediately surround runways and to not take

into account noise from flight operations beyond that narrow scope does not

accurately measure the effect of those operations on our National Historic

Districts

We appreciate the Navys extension of the comment period until February 24

2017 We are aware that many constituent groups have expressed their need for

additional time to prepare comments and believe that granting this extension will

result in the Navy having more specific information that they can use to evaluate
the comments to the DEIS

Additionally while our limited resources constrain our ability to provide you with

more detailed suggestions we commend the detailed analyses and suggestions

of our constituent groups such as the West Coast Action AlUance

We look forward to the formal Section 106 consultation as well as seeing your

responses to our comments The City of Port Townsend appreciates the need for

military training and is grateful for the sacrifices made by the members of our

military and their families

Sincerely

Deborah Stinson

Mayor

cc Honorable Patty Murray U.S Senator

Honorable Maria Cantwell U.S Senator

Honorable Derek Kilmer U.S Representative

Honorable Kevin Van de Wege Washington State Senator

Honorable Steve Tharinger Washington State Representative

Honorable Mike Chapman Washrngton State Representative
Dr AVyson Brooks Washington State Historic Preservation Officer

Reid Nelson Advisory Council on Historic Preservation

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