We speak for members of the Albemarle Environmental Association. As an environmental organization we stand for conservation and fairness. We are not opposed to the military. We think you are doing a fine job of defending our country. And we know that you are doing everything possible to take care of the environment on your bases.

What we stand for is preservation of open space and quiet places where animals can raise their young. We stand for preservation of family farms and fresh air and clean water. We stand for opportunities for people to use and enjoy their environment--fishing, strolling, hunting, visiting on front porches and watching fireflies in the quiet of a night.

And we stand for fairness. People make choices in where they live and work and play. Some people make mistakes. We should not have to pay for other people's mistakes.

Again, we urge the Navy to please use available facilities.

In the DEIS the following statement is made:

"Existing facilities at NAS Oceana and NALF Fentress were found to meet all the operational requirements to support the FCLP operations of the SuperHornet squadrons."

This is a very clear and unambiguous statement of fact.

The statement is then qualified with the following:

Lets examine this qualifier:

1. If the "Existing facilities at NAS Oceana and NALF Fentress were found to meet all the operational requirements" why is an OLF needed to " enhance operational flexibility"?
   
   Either the "Existing facilities at NAS Oceana and NALF Fentress were found to meet all the operational requirements" or they cannot meet all the requirements. If enhanced operational flexibility is needed then the statement that the existing facilities "meet all the operational requirements" is incorrect.
2. "An additional OLF enhances... quality of life ...at NAS Oceana and NALF Fentress". True, but only at these two locations. Tthe quality of life will be degraded in any area where an OLF is located. The degradation will take place for the very reason you next state in your qualifier. "...noise...". With the OLF comes NOISE.
   
   Using DEIS figures comparing the noise intensity of various aircraft it can be easily shown that at an altitude of 600 feet the noise intensity of one (1) SuperHornet is equal to that of four (4) Hornet aircraft during FCLP operations
   
   Shall we believe that future aircraft will not continue the trend toward larger engines, greater payloads and even more noise causing escalating degradation of the quality of life near an OLF? Keep in mind that every 3 dB increase doubles the noise level.
3. An OLF "provides important noise ... mitigation at NAS Oceana and NALF Fentress." Why is mitigation needed?
   
   The DEIS states that:
   
   "Although the noise level is slightly higher for the SuperHornet aircraft than for the Hornet, the difference in sound exposure would not be perceptible to most people."
   
   Even though there will only be "slightly" more noise that "would not be perceptible to most people", the Navy still feels that mitigation is needed to help those who live near the runways. Lets keep in mind that most if not all of the people near the runways chose to live there. Oceana was there before the developments and everyone knew it. Granted, the noise is now greater that it was twenty years ago, but did the residents who willingly bought in the area really think the planes would get quieter or that the runway would shut down? Perhaps the Navy should ask the residents to take responsibility for their choices and actions and not suggest that the noise be dumped on northeast North Carolina.
4. "...population encroachment..." What does this mean? Will the OLF prevent future development near Oceana and Fentress? This is a political problem that should have been addressed many years ago by both the Virginia Beach government and the Navy. The Navy has for years supported the Virginia Beach economy and thus could have had great influence on the planning for development near its facilities. It is evident by the proximity of development to the Navy facilities that little to no planning of any consequence was done over the past 50 years.
   
   Now there are outraged citizens demanding that the noise be decreased or eliminated and that their neighborhoods be removed from APZ's . These demands are impossible to satisfy under present conditions, even with an OLF.
   
   Rather than building new facilities the Navy should explore the possibilities of first stopping all new development near the facilities and then relocating neighborhoods away from the existing facilities. Expensive? Very, but it is an alternative to corrupting more of the unspoiled areas throughout America. It is time for the Navy to solve its problems rather that just moving them to another state.
5. "Therefore, construction and operation of an OLF is considered under all alternatives." There seems to be no compelling reasons for this statement except to move the noise that "... would not be perceptible to most people..." out of Virginia Beach to North Carolina. There is no real justification for it since:
   
   "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."

In conclusion, it seems the Navy has existing facilities that can accommodate the Super Hornet squadrons without resorting to defiling more land in North Carolina. We in northeast North Carolina moved here to get away from big city confusion and noise. We chose to live in an unpolluted, rural, agricultural area and will resist any attempts to deface the countryside with exported refuse from other already polluted areas..

The people in Virginia Beach with a noise problem apparently thought they could accommodate the noises from the Navy facilities but it seems they were mistaken. Their mistake should not be rectified by exporting the noise to northeast North Carolina. When the DEIS is examined and all the superfluous sections, tables and jargon are eliminated, it seems that the only supportable reason for an OLF is to placate the Virginia Beach residents and avoid a possible additional lawsuits.

Please do not create more problems by dumping noise on North Carolina. Use existing facilities and correct existing problems instead of creating new ones.

In view of the ambiguities in the areas I have just discussed it would be refreshing if the authors of the final EIS attempted to made the document understandable to the average citizens in the affected area. The citizens have a right to be informed and comment on these documents but they cannot exercise their right if the language of the EIS is on a college level. Writing on this level eliminates about 80% of the population from reading and understanding the document.

We would like to discuss Executive Order 12898, which states that each Federal agency shall make achieving environmental justice for minority and low-income populations part of its mission.

 It also states that public documents should be concise and understandable. Unfortunately, this Draft Environmental Impact Statement is neither concise nor easily understandable. The document should have been written clearly, in sentences of reasonable length, so all people--rich or poor, black or white--could read it, understand it, remember it and not feel intimidated by it.

 Of greater concern is the issue of environmental justice. In this document the Navy compares people in a census tract that will be affected with people in a nearby tract that will not be affected. They do this for all sites where activity will take place. This is standard operating procedure. However, done in this manner, the issue becomes significant only in Bertie County and in Virginia Beach where large African American and low-income populations exist around the base.

This comparison misses the point of the issue. It is proposed that the pollutant--noise--be moved out of Virginia Beach and into northeast North Carolina. In the spirit of environmental justice, we feel that additional comparisons should be made between Virginia Beach and North Carolina counties.

When such comparisons are made, invariably, Virginia Beach comes out on top. Our figures come from the US Census Bureau, based on the 2000 census and their 1997 model-based estimate.

 In eastern North Carolina counties the median household income is about $27,000. In Virginia Beach it is almost $45,000.

African American population here ranges from 25 percent in Craven, to 49 percent in Washington, to 62 percent in Bertie, with only 19 percent in Virginia Beach.

 Senior citizens, over 65, about 16 percent here, versus only 8 percent in Virginia Beach.

And finally, children in poverty here, about 28 percent. Virginia Beach children in poverty, 13 percent.

 This data is critical. With an OLF in the Albemarle, development will stagnate and property values decline. In fact, real estate sales are already sagging. This comes at a time when the area has begun to pull itself up by the bootstraps and, with generous state aid, is developing the unique, unspoiled treasures it has in tranquil waterways, outdoor recreation, cozy waterfront parks and historical homes. In the DEIS the Navy discusses the minimal economic benefits an OLF will bring. It should also discuss the major present and future economic losses that will accompany an OLF.

 We urge the Navy to consider the wider issue of environmental justice that exists here.

 Comment 1:

There seems to be an error in the statement of the equation used to calculate DNL

If the equation you give is solved an incorrect result is produced.

(1) DNL = SEL + 10log(Nday)+ 10log(10*Nnight) - 49.4 dBA,

63.7 dBA = 100 dBA + 10log(5.5) + 10log(10*1.5) - 49.4 dBA.

63.7 dBA = 100dBA + 7.4 + 11.67 - 49.4dBA

63.7 dBA = 69.67 "

This result is incorrect

Equation (1) should be stated as:

DNL = SEL + 10log(Nday + 10*Nnight) - 49.4

= 100dBA + 10log(5,5 + 15) - 49.4

= 100dBA + 13.1 - 49.4

DNL = 63.9 this is the correct solution

Comment 2:

How does the Navy explain the adding arithmetically of dB levels in the equation when they state:

The arithmetic adding in the DNL equation would lead us to believe that we are not dealing with dBs as they are defined in texts on acoustics. What then are we dealing with? The Navy should make it clear that DNL is an empirical value that may have some relationship to community discomfort from sound levels. It is not a measurable level of sound.

Comment 3:

How is it justifiable to label DNL dBA when they are a theoretical calculated metric? They cannot be measured. The Navy definition of dBA is:

The use of the dBA notation when referring to DNL is not only incorrect it is very misleading. DNL is a strictly theoretical value and therefore cannot be measured by equipment designed to measure sound in terms of dBA.

If the Navy discusses a very complicated and confusion topic like DNL noise levels it should be sure it provides complete and correct information. It should not be necessary to go to text books first to find there is an error in a stated equation because it cannot be solved as stated and then to discover the Navy is referring to and labeling an empirically calculated item as if it was a measurable value.

The issues identified during the scoping phase of the DEIS and tabulated in Tables 6-3 and 6-5 cover a wide range of public concerns. The tabulation identifies the topic of concern and the number of statements received regarding the concern but inadequate information characterizing the statements as pro or con the issue is provided. The public is interested how many statements were received, but they are most interested in who is for and who is against the issue. Omitting the characterization of the statements received is a substantial omission from the DEIS and should be corrected in the FEIS so readers will know the public sentiment about the issues.

Also, the reader is challenged to find the Navy's discussion of the issue of concern. The table of identified issues should have, as its last column, a reference to the section and page on which the concern is addressed. This would give the table great value to the reader trying to understand the issues.

This brings me to my next point.

It appears that the Navy has not addressed all the issues tabulated in Table 6-3 and 6-5. For example, there are seven issues under the heading AIR QUALITY that concern fuel dumping,. There were a about forty-six statements received relating to fuel dumping, yet there is no mention of fuel dumping anywhere in the DEIS. This seems to indicate that the Navy (a) Did not wish to discuss the problems related to fuel dumping so it ignored the concerns, (b) Does not feel that the public concern is worthy of an answer or (c) Feels that it is only obligated to answer concerns it wishes to deal with, which makes the scoping phase a sham.

This is but one example of a concern left unanswered. I can only wonder how many other identified issues have been left unaddressed. All but the most frivolous concerns deserve a reply. In the case of the fuel dumping there were about forty-six statements received. Those people deserve the courtesy of an answer to their concerns, even if it is just one line in the DEIS. Only a few additional pages would be required in the DEIS to provide the commentary needed to cover all the legitimate concerns. This will ensure that the public has the information that it is entitled to, and needs, in order to fully understand the issues it has raised and you have tabulated.

We urge you to revise the DEIS to bring the FEIS up to the standard we have come to expect from the United States Navy. Also we request that revisions be made to the document to make it clear, concise and understandable as called for by E.O. 12898.

Bird Strike.The Navy's characterization of the threat of BASH in the Albemarle area is misleading. In Table 12-33, risk of bird strike is averaged over an entire year for all sites. This average is misleading and valueless. Averaging a light summer population of birds with a heavy winter population does not reduce the risk to people, pilot, plane, bird, and property during heavy populations of birds in fall and winter.

After viewing vast numbers of these birds in secluded wildlife refuges, it is difficult to believe that bird strikes would not be imminent if an OLF were sited in the region. The fall and winter population of snow geese and tundra swans on the Perquimans River, in the Mattamuskeet National Wildlife Refuge, in the Pocosin National Wildlife Refuge, and elsewhere in the area runs into the hundreds of thousands. In fact, the area is a mecca for enthusiastic birdwatchers who would not otherwise observe these wildfowl in their breeding grounds in the far north. In addition, tagging studies of tundra swans show that they can be a restless bunch, with individuals roaming over the entire area, thus making predictions of movement more difficult.

A distinction should also be made between migratory patterns and roosting behavior. Tagging studies that we researched did not indicate winter activity in Virginia Beach or Chesapeake, though there may be some. Migration certainly takes place through these coastal areas, but large numbers of birds do not congregate in this congested noisy, suburban/urban location. There is little to offer them in the way of food or habitat. In fact, tt is difficult to believe, from general observation, that the threat of BASH to pilots flying in and around Virginia Beach and Chesapeake is as great as it would be in North Carolina, which is what your bird population maps imply. Migration, though heavy, is transient, with only small populations roosting in suburban/city communities. In North Carolina, these birds roost in secluded, isolated refuges, and they roost by the hundreds of thousands, and this distinction should be made.

 Accidents. As far as we can see, in the DEIS the Navy only discusses the most serious type of accident, one which involves either fatalities or large monetary losses. Commendably, your record on these is stellar, and we thank you for that. But there have been other accidents, as anyone who reads the newspaper or listens to broadcast news knows. The citizens of North Carolina deserve a more thorough analysis of accidents that have occurred at Oceana, Fentress and Cherry Point over the past twenty years, particularly since there is no nearby ocean to ditch a plane, and any mishap may wind up in a farm field, or worse, a dwelling.

In view of the severe hazard level of bird strike in fall and winter, the sketchy information now supplied should be supplemented by full disclosure of past accidents involving aircraft originating in Virginia Beach/Chesapeake facilities. US Air Force data on wildlife strikes would indicate that many accidents occur annually. From this information and media accounts, we must surmise that more than one accident occurs every three or four years. These records should be available to candidate counties for the OLF. We urge the Navy to include these figures in its final document.

 We note from your maps that extensive noise footprints extend into Beaufort County from both the Washington and Craven proposed OLF sites. We understand that no construction will occur in Beaufort, but either the southern or northern sections of this county could very likely be the unhappy recipient of disruptive noise from one of the proposed OLFs.

 Have Beaufort County officials been informed of this impact on their county? Have people in the county been made aware of the proximity of these sites to their county line? In the interests of fair disclosure, we request that a public hearing be scheduled for Beaufort County, and that literature be distributed, if this has not already been done. People across the county, from north to south, can expect extremely high noise levels if one of these sites is chosen, yet they have not been consulted nor has data been included in the DEIS on how these communities will be affected.

 Environmental Justice. This omission reinforces the environmental issue of dumping a pollutant onto a poor county which will receive absolutely no economic benefit, and will, in fact, stand to lose economically. Substantial income is coming into the county from retirees seeking peace and quiet and escape from a hectic life in urban areas.

Chocowinity is an example of a community recently developed around the wonderful natural resources of the area. How many other people who may have considered retiring to this rural county will instead eliminate the county from their consideration and go elsewhere? All the while, economic benefits--and noise abatement--go to the residents of more prosperous Carteret County and southeastern Virginia.

 We urge the Navy to rectify this omission and include the people of Beaufort County in their consideration of all issues. And to please remember that in the DEIS, the Navy states that current facilities meet all operational needs. An OLF is needed primarily because of complaints from residents in Virginia, where training now takes place, who opted to live near a military base, and who now want disruptive noise removed from their own community and thrust on others.

The Albemarle Environmental Association is a fifteen-year-old grass roots group with members on both sides of Albemarle Sound. Past issues we have tackled successfully include a proposed hazardous waste incinerator in Tyrrell County and a proposed landfill for Virginia's trash in Camden County. As you can see, northeast North Carolina has been viewed as a dumping ground for other people's wastes.

On behalf of our members I wish to address the dumping here of yet another unwanted waste: noise from an OLF. Despite the intensity of this issue, major omissions and lack of clarity in the Draft Environmental Impact Statement only serve to confuse and confound instead of enlighten and educate.

 Point Number 1: Appendix C is 230 pages of charts listing schools, churches and public buildings affected by aircraft noise at Oceana, Cherry Point, and Beaufort--including maximum noise events in each location. You can imagine how astonished we were, then, to find that not one church, school, tourist attraction, senior citizen home, day care center, or animal operation near any OLF site proposed in North Carolina was included in these charts.

Is North Carolina such a dumping ground that our children's schools and churches don't count? Out of 1700 pages, couldn't the Navy devote just 5 or 10 pages to projected data that would give us the same working information that our Virginia neighbors have? Shouldn't this environmental impact statement include a careful analysis of what can be expected at the site where dumping is proposed?

Point Number 2 concerns the use of day-night average levels, or DNLs. The Navy says that DNLs are a measure of the true sound level averaged over a 24-hour period. In reality, DNL is merely an indicator of annoyance levels with only a passing mathematical relationship to actual noise levels. Its validity is questioned by numerous authorities.

If DNLs are so reliable, why are people in Virginia Beach complaining? Most of their DNL values are at or below the lowest DNL value, which is 60, of the outermost noise footprint of the proposed OLFs. The Navy would have us believe that this is simply the noise level of an ordinary city street. In reality, at only 55 or 60 DNL, some locations in Virginia experience noise events over 100 decibels.

 Please don't pull the wool over our eyes. If the Navy insists on using DNLs, please call them what they are--an annoyance indicator--and give us the loudest single noise we can expect to hear in public buildings and animal operations near the noise footprint --and how often we can expect to hear this noise. This data already exists, since calculation of DNLs is based on mission profiles. It should have been included in the environmental statement. Our own calculations show that the actual noise events could be more than fifty thousand times louder than your DNLs suggest.

In conclusion: We urge you to work on confronting and solving your noise problems where they exist--in Virginia Beach. Please do not solve your noise problems by placing an OLF in North Carolina. We do not want it.

 The proposed Craven County site needs to be looked at closely as an important recharge area for the Neuse River. Characterizing areas of this pocosin wetland, however channeled and lumbered, as barren is misleading and negates its important role in providing clean water for one of North Carolina's most troubled rivers. It is worth noting that many of the pocosins in our national wildlife refuges have been ditched, yet they are still functioning and attract a wide variety of wildlife.

 Wetland Destruction. Lumbering, though preferably not clear cutting, is compatible with healthy wetlands. The wetlands may be disturbed, but they are not destroyed. Trees will grow back, the wetland can still function, and wildlife thrives because of the variety of habitats and edge effects that are created. Once an OLF is established in the midst of these wetlands, their destruction and the intense activity that will follow will compromise the entire system. We do not pretend to understand the complex interrelations that occur between uplands and wetlands, but we know that tarring over 2,000 acres of this pristine area will disturb it substantially.

 Pollutants. We know that the Navy will do its utmost to contain runoff from the site and the pollutants that go along with it, but no mention is made of how the substantial annual introduction of pollutants from low-level flights will affect plants and animals in the wetlands. The Navy may be able to control runoff from the site, but it cannot control the aerosols from its exhaust. In time, and with intense use, these pollutants will find their way, droplet by droplet, into waterways and wetlands and from there, into the Neuse River. Ten years from now we will be wondering why our environment is no longer wholesome.

 Mitigation. Wetland mitigation has not been shown to be particularly effective. In many cases, unsuitable upland areas are chosen, or plants do not become established properly. For lots of reasons, very few artificial wetlands function like natural wetlands, recharging the water table, buffering against storms and floods, filtering pollutants, and nursing aquatic young. Hurricane Floyd was so devastating to North Carolina communities because development had replaced wetlands. Sponges that had formerly modulated river flows, though not perfectly, were missing.

 We would like to see a more thorough discussion of the impact on the environment if the Craven County OLF site is constructed. Classifying this land as barren, and listing Craven County wetlands acreage at the site as "see footnote" (which few will read, and fewer still may understand), is doing a disservice to an undeveloped area that is rich in wildlife and that has such a beneficial effect on the Neuse River.

 As the Navy goes into its final decision-making mode, we hope that it will consider the economic, environmental, and human losses to North Carolina that will accrue from building an OLF which it does not really need.