ADMIRALTY AUDUBON LETTER: October 22, 2014 Greg Wahl, Environmental Coordinator U.S. Forest Service 1835 Black Lake Blvd SW Olympia, WA 98512 Sent by email: [email protected] To: Greg Wahl Re: Pacific Northwest Electronic Warfare Range Environmental Assessment On behalf of Admiralty Audubon Society, Port Townsend, Washington, I welcome this opportunity to comment on the Pacific Northwest Electronic Warfare (EW) Range Environmental Assessment (EA). Admiralty Audubon recognizes the strategic need to provide our pilots with frequent and advanced training. Nevertheless, we find that the present version of the EA is deficient in several areas and do not agree with the Navys assessment that the environmental impacts are not significant. We recommend that the U.S. Forest Service not adopt or approve the proposed actions. Below are presented several issues that support our recommendation. 1. The western side of the Olympic National Park has a unique soundscape. A location in the Hoh River valley was identified as the quietest place in the lower 48 with respect to anthropogenic sound (see onesquareinch.org for further info). This aspect of the region has been discussed widely in the media, see for example: 1) Americas Vanishing Silent Spaces, Newsweek, by Julia Baird (3 June 2010) or 2) A man speaks up for silence, by Lynda V. Maples, Seattle Times (1 August 2005). In 2005, this unique aspect of the Olympic National Park was noted by the park superintendent at the time, Bill Laitner, who stated It is definitely a priority to maintain that natural quiet. Through the years, Gordon Hempton (founder of onesquareinch and responsible for audio measurements documenting absence of anthropogenic sound), has contacted commercial airlines (flying at much greater altitudes than the planned Navy flights) and has had partial success in convincing them to alter flight routes to avoid this region to help preserved the soundscape. This unique aspect has not gone unnoticed and many of the tourists who come to this region annually do so explicitly to experience this unique natural soundscape. The noise assessment in the EA in general compares the impact of predicted EW range noise to more traditional settings (urban, suburban, rural) which do not represent the rare, natural background conditions of this area. A much lower and documented baseline for ambient anthropogenic sounds should be employed to examine the impacts of the proposed operations on this area. Discussions of construction sounds at building 104 and whether added noise will interfere with sleep or verbal communications miss entirely the questions concerning the degradation of this unique environment. Portable diesel generators required for the mobile emitters and frequent overflights by fighter jets (at 9,000 - 15,000 feet, audible for many miles in all directions) will certainly degrade the soundscape of this location and make it less desirable for tourists - a hardship for an already economically challenged region. A full assessment of the impacts of planned operations on the soundscape should be provided by the Navy to the Forest Service and public. This analysis should be performed relative to the unique soundscape that characterizes this region and not to generic sound baselines established for other, more anthropogenically-impacted areas. 2. The EA assumes no economic impact and therefore categorically excludes this from the analysis. For reasons stated in comment 1, the planned range may alter the attractiveness of this region as a destination for tourists and there is potential for significant economic impact. Since this region is already economically stressed, even small variations in overall economic activity may result in large, relative impacts. The Navy should, therefore, assess the potential economic impact before proceeding. 3. The Navys assessment includes little discussion of indirect impacts of EMR on wildlife and does not incorporate the most recent, best available science. For example, Engels et al. 2014 documents that low levels of EMR interferes with the magnetic navigation systems of migrating birds. The importance and implications of these results have further been discussed by Morrison (2014) and Kirschvink (2014). These articles have been published in Nature, one of the most prestigious, peer-reviewed scientific publications world-wide - this is not internet publishing. The Navys EA does not acknowledge this potential impact. As use of magnetic navigation is widespread in nature, these results may be general applicability. As part of the Pacific Flyway, the Pacific coast is a critical pathway for migratory birds, with an estimated 1 billion birds migrating along the flyway annually. In their five-year strategic plan, the National Audubon Society specifically advocates for the protection of coastal species and habitats with the goal of supporting a healthy Pacific Flyway. In general, taking or adversely impacting migratory birds is prohibited as part of the Migratory Bird Treaty Act. Exceptions are allowed, however, for military readiness training. Nevertheless, as stated on page 3.2-3 of the Navys EA, ... the Armed Forces must confer and cooperate with USFWS on the development and implementation of conservation measures to minimize or mitigate adverse effects of a military readiness activity if it determines that such activity may have a significant adverse effect on the population of a migratory bird species. Since successful migration is critical to the survival of a migrating species, potential navigational impacts must evaluated. However, these potential impacts are not considered in the current EA and hence the potential impacts were not assessed. 4. As has been acknowledged publically, this process was not properly noticed. While the deadline for comments has been extended twice, this remedy has unfortunately resulted in confusion as citizens and organizations have encountered inconsistent deadlines listed in various publications with some erroneously concluding that the comment period had already closed. 5. The EA argues that establishing this new range is environmentally beneficial by reducing the fuel consumption for training missions. While carbon dioxide emissions are of environmental concern, such emissions are only one of many criteria that need to be weighed to assess net environmental impact. As EW training ranges already exist elsewhere, the added impacts of establishing an additional range in this environmentally unique, natural area must be included as well. The present EA does not assess the relative benefits of impacting a greater portion of our remaining natural areas for military training. To conclude, Admiralty Audubon Society recommends that the Navys EA and its associated Findings of No Significant Impacts not be adopted. The deficiencies documented above are significant and must be addressed. For these reasons, the EA does not meet the requirements of law and a full environmental impact statement under NEPA must be prepared. Sincerely, Richard A. Jahnke President, Admiralty Audubon Society References: Engels, S., Schneider, N-L., Lefeldt, N., Hein, C., Zapka, M., Michalik, A., Elberts, D., Kittel, A., Hore, P., and Mouritsen, H. (2014) Anthropogenic electromagnetic noise disrupts magnetic compass orientation in a migratory bird. Nature, v. 509: 353 - 356. (doi10.1038/nature13290). Morrison, J. (2014) Electronics noise disorients migratory birds. (doi:10.1038/nature.2014.15176) Kirschvink, J. L. (2014) Radio waves zap the biomagnetic compass. Nature, v. 509: 296 - 297.
Posted on: Sat, 15 Nov 2014 17:14:26 +0000
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