Letter to the Navy Summarizing AEA's Position on the DEIS


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:

AEA believes it has discovered serious deficiencies in the Draft Environmental Impact Statement prepared by the Navy for siting an OLF in eastern North Carolina. Based on these findings, and under provisions in NEPA, we are requesting that a revised Draft Environmental Impact Statement be published for public comment before the Final Environmental Impact Statement is released -- or that the sections on new OLFs in North Carolina be thrown out for lack of substantiation.

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:

"Existing facilities at NAS Oceana and NALF Fentress were found to meet all the operational requirements to support the FCLP operations of the Super Hornet squadrons. However, the construction and operation of an additional OLF enhances operational flexibility and quality of life and provides important noise mitigation and population encroachment mitigation at NAS Oceana and NALF Fentress. Therefore, construction and operation of an OLF is considered under all alternatives."

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).

2. We find that basic flaws in the construction of the DEIS render it virtually unintelligible to the average citizen.

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))

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)

4. We find that meaningful disclosure of future impacts of the proposed project is missing from this document (NEPA 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)

We call for a full and fair examination of DNL and SEL on churches, schools, public buildings, hospitals, animal operations, senior citizen homes, day care centers, tourist attractions, and historical structures within the 55 DNL contour for each proposed OLF. (NEPA 1502.1; 1502.16)


6. We find that noise pollution, the central issue in OLF siting, is treated with ambiguity in a verbose Appendix in terms that cannot be understood by the public.

7. We find that the Navy's interpretation of the issue of environmental justice entirely misses the spirit and intent of Executive Order 12898 and NEPA.

On this basis alone, eastern North Carolina counties should be removed from consideration for siting an OLF.

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

9. We find the data on risk of bird strike has been unrealistically manipulated to reduce the apparent hazard. Mitigation techniques are not described adequately.

Intelligent discussion of methods and range of habitat alteration to mitigate severe risk of bird strike in fall and winter is lacking.

10. We find the discussion of accident potential to be incomplete and misleading. Reporting only serious accidents gives the public a distorted picture of the number of accidents that have occurred in the past twenty years.

11. We find that analysis of an OLF's impact on the environment in these counties is superficial and ignores the rich and varied wildlife that inhabits these areas.

OLF siting comes down to five core issues.

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)).

We further request that the sections on new OLFs in North Carolina be deleted, since adequate justification for their construction has not been provided.

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.




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 



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