October 8, 2002

Commander, Atlantic Division
Naval Facilities Engineering Command
ATTN: Mr. Fred Pierson (Code BD32FP)
1510 Gilbert Street
Norfolk, Virginia

Re: OLF Siting in Eastern North Carolina for Training of Super Hornets

Dear Sir:

Below is a summary of our points. Supplementary background material is attached.

1. We find that the Navy does not make a case in the DEIS for an Offsite Landing Field in North Carolina for reasons defined below. The DEIS states:

• No operational need is specifically defined in the document.
• "Important noise mitigation" cited for Oceana does not exist. An OLF does not reduce the area in Virginia Beach that is affected by noise. In fact, no matter what alternative involving Oceana is chosen, the area affected by noise will increase by at least 1750 acres. (DEIS Tables 4-26-29)
• There are virtually no objections from citizens to continuing the use of Fentress as an OLF (two comments in the Tables of Comments). There appears to be so little concern about this issue in Chesapeake that only 150 people attended that hearing.

Based on the statement that existing facilities are adequate, this limited mitigation of noise does not fulfill the purpose and need for action with respect to construction of an OLF that is required by NEPA 1502.10(d).

The omission of an Index makes it almost impossible to navigate the document with reasonable efficiency. The only way to locate items in the text is with lengthy computer searches. (NEPA 1502.10(j))

• Verbosity, lack of coherent writing, superfluous material, lack of tiering, and boiler-plate text add unnecessary length. The document is supposed to be clear and concise, analytical, should provide a clear basis of choice and be little more than a few hundred pages. (NEPA 1502.1; 1502.2(a,b,c); 1502.7; 1502.8; 1502.14; 1502.15; 1502.20 and EO 12898)
• The integrity of information presented in technical discussions throughout the document cannot be verified as to scientific methodology and accuracy. No explicit reference by footnotes is provided. (NEPA 1502.24).

3. We find that the FCLP noise footprint does not appear to be a true representation of the noise that can be expected from training operations and is misleading to the public. Methodology should be corrected and/or clarified. (NEPA 1502.16; 1524)

• Our calculations indicate that values for noise contours on maps were measured from the middle of the airstrip without considering the entire training pattern. This pattern includes a perimeter that extends 1.75 miles out from both sides of the airstrip. Aircraft flying on this perimeter will create a 92 DNL contour directly below the plane and a 60 DNL contour an additional 3.5 miles wider than current projections on maps.
• Maps of noise footprints do not identify the aircraft or the number of operations used to determine the plotted DNL contours. The public must therefore make assumptions about the parameters used to define the contours.
• Flight specifics are presented as a highly impractical 24/7 schedule, not the usual 24/5 schedule flown at Fentress. Using the 24/7 mission profile seems to be a strategy employed by the Navy to artificially lower DNL values. A five-day week is the worse-case but more realistic scenario. If there is even a chance that flight schedules will be 24/5, that set of operations should be reflected in the DNL contours.

• Defense strategies are planned decades ahead. The public has a right to know how military plans will affect long-term productivity and future disruption of the area around an OLF. Super Hornets may be the first aircraft to use an OLF, but they certainly will not be the last.
• Given the discord over noise in Virginia Beach as noise has increased over the years, North Carolina citizens should be informed of such projections. (We are not asking the Navy to reveal defense secrets. We are asking for reasonable projections based on previous experience over the past sixty years.)
• The need to commandeer/control more than 50,000 acres, fully 12,000 more than the area of an OLF noise footprint--34 percent of Perquimans County, 24 percent of Washington County--is not adequately addressed. Nor are the effects of acquisition methods--direct purchase, restrictive easements, or condemnation--discussed with respect to loss of family farms and heritage of the area. (NEPA 1502.1, 1502.16)

5. We find no DNL and SEL readings for churches, schools, and other public buildings for communities in any North Carolina county that will be affected by noise from an OLF. (NEPA 1502.16; 1508.8)

• This data exists in a lengthy Appendix C for Oceana, Fentress, Cherry Point and Beaufort.
• Its omission is an egregious example of the incomplete data that citizens were given to assess impacts on their environment.

• The 55 DNL value is the highest value that the American National Standards Institute (ANSI) considers to be compatible with residential living. Structures within the 55 DNL contour in Tidewater are included in Appendix C.
• Areas being considered for OLFs are rural, where background noise ranges from an imperceptible 0 to a low-key 40dB. Citizens not normally exposed to higher background levels have a right to know what maximum intensity of noise to expect if an OLF is thrust on them.
• Farmers who maintain animal operations need to be aware of the full impacts of extraordinary noise events on their livestock. (NEPA 1502.16(b)
• Historic structures should have noise levels stated in unaltered dB which includes energy produced at low frequencies that can damage structures. (NEPA 1502.16(g))
• Senior citizen population is high in all counties under consideration for an OLF. Please see accompanying charts.
• Heritage- and eco- tourism are major industries in this area. Flight activities at an OLF conflict with expressed state and local policies which support the growth of this environmentally friendly industry. (NEPA 1502.16(c))
• Maps should be clear and easy to read and present all relevant data. The omission of many structures from the maps of OLF noise footprints indicates shaky knowledge and incomplete field investigations of proposed sites. Roads and road names and numbers are absent, challenging residents to judge the effects of noise and accident potential on their neighborhoods.

• An error exists in the equation for calculating DNL which appears in Appendix B. The equation should be restated correctly with explicit footnote references to sources. (NEPA 1502.5)
• Extraneous encyclopedic discussions of, for example, caribou, grizzly bears and manatee, mislead and misdirect attention from relevant issues. (NEPA 1502.2(a)
• Critical information that ANSI considers DNLs between 55 and 65 as only marginal for residential living and above 65 as unacceptable is omitted. (NEPA 1502.9)
• Little to no attention has been given to the fact that there will be hundreds of very loud events during each day and night. The intensity and repetition rate of these events and their impact on human and animal populations is not adequately discussed.
• Discussion of previous complaints about noise from Virginia Beach citizens is omitted, as is a discussion of the pending CCAJN lawsuit, which is a direct result of noise from jet aircraft. (NEPA 1502.12)

• The poorest Tier One counties in North Carolina -- also among the poorest in the nation -- are being targeted for the noise of an OLF.
• These counties will receive only negligible immediate economic benefit.
• Tourism and the ability to attract retirees are two promising avenues of long-term economic growth. With an OLF in place, these prospects will come to a virtual standstill in the affected counties, creating economic stagnation and degradation.
• The DEIS does not provide a balanced projection of long-term economic effects, based on long-term productivity and irreversible commitments of resources. (NEPA 1502.16)
• Beneficiaries of economic growth are Virginia residents with almost twice the median income. Please see accompanying charts.

• It is the responsibility of the federal government to assure for all Americans safe, healthful, productive, and aesthetically and culturally pleasing surroundings. (NEPA Sec. 101)
• That the Navy would consider moving a pollutant -- noise -- out of an affluent area and into the poorest counties in North Carolina, further degrading a marginal economy, is an unconscionable breach of public trust.

8. We find that this document does not address legitimate issues raised by citizens and agencies during the scoping phase. (NEPA 1502.12)

• Approximately 300 categories of issues are listed in 15 pages of tables. While organization of these records appears to be excellent, response to citizen concerns appears to be negligible.
• Almost fifty respondents expressed concerns about fuel dumping, yet no discussion of fuel dumping exists in the document.
• Other issues of importance to North Carolina residents and not addressed include crop dusting, immediate effects of pollutants on crops, and long-term accumulation of pollutants in soil, rivers and streams.
• Without an Index it is virtually impossible to cross reference public concerns with discussions in the document. Nor is there a reference in the Tables as to where a particular issue is discussed in the DEIS. These references should be included in future documents.(NEPA 1502.10(j))

• The table describing risk of bird strike averages severe winter risk with low summer risk to arrive at a meaningless moderate risk all year.
• The manipulation of this data will place pilots in greater jeopardy than predicted during seasons of severe risk.
• This skewed approach does not reduce the severe risk to people, pilot, plane, bird and property during heavy avian populations in fall and winter.

• Data is needed on the effectiveness and kinds of habitat alteration proposed and the acreage that will be affected.
• Methods of mitigation should be delineated and mapped in detail in order to assess their effectiveness and their impact on the environment.
• Reference footnotes should be included. (NEPA 1502.24)

• The potential for accidents during FCLP operations should be discussed more completely, particularly in view of the severe potential for bird strike/ingestion during fall and winter.
• Detailed data from the Navy Safety Center, which has been keeping records since 1980, should be included in the DEIS, particularly since the OLF is a training field.
• Discussion should include a tabulation of all land-based accidents during the past twenty years that required inspections to determine air worthiness of aircraft. Such discussion will provide a more realistic picture of how many aircraft were involved in incidents and at what level of loss.

• Detailed inventories of wildlife are included in discussions of Oceana, Fentress, Cherry Point, and Beaufort, despite minimal construction required on these bases to accommodate Super Hornets.
• Detailed inventories of wildlife in proposed OLF sites, where construction will be far more intrusive, are omitted. This data is readily available from appropriate state and federal agencies and should be included.
• Without a quantitative wildlife population inventory there is no way to estimate the impact of an OLF and its associated operations on various species.
• North Carolina environmental agencies note that pocosins are prime habitat for wildfires, but there is no discussion or substantiating data to show what effect FCLP operations would have on the frequency of wildfires.
• Comments by environmental agencies regarding public use of refuges and effects on refuges are not addressed. Other comments are virtually ignored.
• An analysis of how the degradation of wetlands at the Craven County site would affect the Neuse River is needed.
• Classifying pocosin wetlands in Craven County, however channeled and lumbered, as disturbed is misleading and negates the important role these wetlands play in providing clean water for one of North Carolina's most troubled rivers.
• The State of North Carolina has fine personnel, who can provide site-specific data and define relationships among uplands, wetlands and riverine systems, whether disturbed or pristine. Their input should have been included in assessing environmental damage and discussing mitigation.
• Repetitive, boiler-plate text should be eliminated and replaced with meaningful, site-specific data and analysis for all proposed OLF sites.

OLF siting comes down to five core issues.

• Can the Navy perform its operations without an OLF?
• How much noise will the public have to endure?
• What is the potential for accidents?
• What damage can we expect to the natural environment?
• How will future socio-economic development be affected?

The public has a right to receive complete, coherent, and honest answers to these questions. Yet this document, which took over two years to develop and has cost taxpayers millions of dollars, has answered none of these questions responsibly, concisely, and intelligibly, and with reasonable completeness. Most analyses consist of one-liners that imply "Trust us. We're the government. We have your best interests at heart." There are no references to sources, as required by NEPA.

So, the interminable game of "Which County Will Get the OLF?" is being played out. It has plunged our communities into turmoil. It has already suspended economic growth across a vast area of eastern North Carolina and has cost Tier One counties hundreds of thousands of dollars in lost real estate and business transactions.

According to Section 102(2)(c) of NEPA, the draft statement must fulfill and satisfy to the fullest extent possible the requirements established for the final statement. This document is out of proportion to NEPA guidelines for length relative to project size. The editing that will be required to condense this thousand-page document into the 150 pages suggested in NEPA guidelines will produce a document with little resemblance to the original DEIS. Compared to the complexity of constructing a military base, siting 162 replacement aircraft and laying down tar for an airstrip can hardly be called a major project requiring a voluminous DEIS.

Environmental Impact Statements should be written to be read and understood by the general public. This DEIS is so abstruse that an advanced degree is needed to comprehend it. Putting out a document as verbose and convoluted as this one makes the environmental impact process a sham.

Based on errors, misrepresentation, lack of clarity, excessive length, and omission of basic information that is required by NEPA and that citizens and taxpayers of our counties have a right to know, AEA requests that the DEIS be redrafted to conform to NEPA guidelines and submitted for another round of hearings. (NEPA 1502.9(a)).

In view of the extensive comments AEA and its members have made on this DEIS, we would appreciate receiving future mailings. The street address is: Albemarle Environmental Association, 140 Sunset Circle, Hertford, NC 27944. Thank you.

Sincerely,

The Board of Directors

Georgine Armstrong James Davis Carolyn Hess

Anne Blindt Linda Davis Robert Hess

Jack Blindt Grace Gray Carolyn Jennings

For the Board ____________________ , Vice President
Carolyn M. Hess 

Encs.

CC: The Honorable Gordon R. England
The Honorable Jesse Helms
The Honorable John Edwards
The Honorable Eva Clayton
The Honorable Walter Jones
The Honorable Marc Basnight
The Honorable Michael Easley
The Honorable William Owens
The Honorable William Culpepper
The Honorable John Warner of Virginia
The Honorable George Allen of Virginia
The Honorable Edward Schrock of Virginia
The Southern Environmental Law Center