The Forest Service has inexplicably blocked some substantial comment letters. Heres one from Karen Sullivan: Pacific Northwest Electronic Warfare Range Environmental Assessment #42759 https://cara.ecosystem-management.org/Public/CommentInput?Project=42759 Dear Sir or Madam, On behalf of the National Parks Conservation Association (NPCA) and our 1,000,000 members and supporters, I respectfully submit the following comments on the Pacific Northwest Electronic Warfare Range Environmental Assessment (EA). Many of our members from Washington State and from states around the country travel to the Olympic Peninsula to experience the solitude and wildness of the temperate rainforests, sandy beaches, and alpine meadows offered by Olympic National Forest and Olympic National Park. Our members regularly use areas potentially impacted by this project for hiking, camping, backpacking, cross-country skiing, photography, and fishing. We have several concerns about this project and the process used to develop the Environmental Assessment. We request an extension of the public comment period, additional public meetings before the end of the public comment period, and the completion of a full Environmental Impact Statement (EIS). I. Lack of Adequate Public Outreach The National Parks Conservation Association only learned of this project after receiving an email from one of our members. This occurred only one week before the first and only public meeting regarding the EA. While the EA discusses the Navy’s effort to “ensure maximum participation during the public review period,” we question this assertion and believe the Navy should have employed further efforts of outreach after “no comments were received on the Draft EA.” This statement in the EA is clear evidence of a lack of adequate public outreach. Our own comments would have been much more comprehensive if the Navy had completed proper outreach. We appreciate that another public meeting has been scheduled, but we question its efficacy seeing as this meeting will be held only after the public comment period has closed on October 31st. Again, if the agency was interested in ensuring maximum public participation during the public review, there would have been more than one public meeting and a second meeting would be held before the comment period ended. This would allow the public to comment after having an opportunity to ask questions about the project. We request at least two additional public meetings, preferably in Sequim, WA and Seattle, WA and a further extension of the comment period to December 12, 2014. Finally, due to the controversial nature of this project (as evidenced by the interest and attendance of the single public meeting in Forks, WA), CEQ regulations suggest an EIS is required: “If a federal agency anticipates that … a project is environmentally controversial, a federal agency may choose to prepare an EIS without having to first prepare an EA.” II. Lack of Comprehensive Analysis In reviewing the EA, there was a lack of information and/or ambiguity in certain areas. Due to the lack of proper analysis, an Environmental Impact Statement (EIS) must be completed. – Although the location of the mobile emitters apparently will not be in Olympic National Park, the electronic warfare range will certainly impact park resources (described below). However, the National Park Service and Olympic National Park were never contacted or consulted in regard to this project. According to the map in the EA of the Olympic Military Operations Area (MOA), the entire Pacific coast section of Olympic National Park as well as portions of the Hoh Rain Forest, Queets River Valley, and Quinault Rain Forest that fall within Olympic National Park are included in the MOA. This alone should have required consultation with the park service. Furthermore, according to CEQ regulations, “Responsible officials must bear in mind that more than one agency may make decisions about partial aspects of a major action.” Olympic National Park should have at the very least have been consulted when the project parameters include significant portions of the land they manage. The areas managed by Olympic National Park also includes areas that should be evaluated for the intensity of impact from the project to determine if it is, in fact, significant. CEQ regulations require this evaluation for intensity when projects have, “proximity to historic or cultural resources, parks lands, … wetlands, … or ecologically critical areas.” Olympic National Park contains all of these characteristics. Impacts Analysis – The EA states, “Cumulative impacts of the Proposed Action, in combination with other past, present, and reasonably foreseeable future impacts, were analyzed. Based on the analysis, cumulative impacts within the EW Range Study Area would not be significant.” However, this EA did not analyze the cumulative impact of increased aircraft flights over national forest and national park land that would result from the implementation of this project. According to the EA, up to 2,900 training events per year over the course of 260 days may be conducted, consisting of 2,340 hours of emitter use during which multiple aircraft may be doing maneuvers above Olympic National Forest and Olympic National Park, at altitudes as low as 6,000 feet (according to the Northwest Training and Testing EIS/OEIS). This constitutes a significant cumulative impact. – The EA addresses the noise related to operation of the mobile emitters, but does not take into consideration the impact to national forest and national park visitors and wildlife from the dramatic increase in noise caused by intensified numbers of aircraft overflights during training missions. Many visitors to the Olympic Peninsula enjoy the peace, tranquility, and silence this area provides. The Navy’s own audit found that its jet aircraft emit noise well in excess of the normal human pain threshold. Furthermore, the national park includes “One Square Inch of Silence” - the quietest place in the United States. One Square Inch of Silence was designated on Earth Day 2005 (April 22, 2005) to protect and manage the natural soundscape in Olympic National Park’s backcountry wilderness. This silence may be significantly impacted by increased overflights as a result of this project. The potential negative impacts to soundscape of the National Forest and National Park should be considered carefully in an EIS. Wildlife – Olympic National Park contains important wildlife and migratory bird habitat. The wildlife species and migratory birds in this area may be negatively impacted by the noise and air pollution caused by these operations. While the impact of electronic radiation to wildlife is briefly mentioned in the EA, there is no discussion about the impact of increased jet aircraft traffic on wildlife. The impacts to migratory birds and other wildlife from these operations should be closely analyzed in an EIS. – As mentioned above, many visitors come to Olympic National Park to find opportunities for solitude. Increased overflights resulting from this project would significantly impact these opportunities. Furthermore, the use of pullouts and other public areas by the mobile emitters will impact visitor opportunities negatively. Although the areas used by the mobile emitters will be closed to visitors and may impact transportation avenues, the EA states, “The Proposed Action would not change or alter any transportation and circulation activities of surrounding areas. Therefore, this resource area was not carried forward for detailed analysis.” However, the EA clearly maintains, “mobile emitter sites would be monitored during training activities to ensure that non-authorized personnel remain outside controlled and action level environments at all times.” Not only would these “controlled” areas be closed to transportation, they could significantly impact recreation opportunities in terms of trails in the area or cross-country skiing. Negative impacts to the use and enjoyment of the National Forest and National Park should be considered carefully in an EIS. – – The EA states, “Should an individual/individuals or animals loiter in the area while a training event is occurring, the mobile emitter crews will cease the training (de-energize the emitter) and wait until the area is clear before resuming training.” It is unclear at what point an animal or an individual can be considered loitering. Is there a certain time limit that must pass before the mobile emitter is de-energized? How close to the emitter must an animal be to be considered loitering? This type of ambiguity should be cleared up in an EIS. – III. Conclusion – The National Parks Conservation is concerned with the lack of public outreach and lack of detailed analysis, especially in regard to a lack of consultation with Olympic National Park. NPCA requests additional public meetings before the end of the comment period, which should be extended. In conclusion, a full EIS should be completed to adequately analyze the impacts resulting from this project. – Sincerely, – David G. Graves – Program Manager, NW Regional Office | National Parks Conservation Association – o: 206.903.1645 | c: 206.462.0821 | [email protected] | npca.org – 1200 5th Ave | Suite 1925 | Seattle, WA 98101
Posted on: Fri, 05 Dec 2014 12:38:58 +0000
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