Asserts that noise impacts are affected by “intermittency,” yet it never defines it or explains how or why. Define “intermittency” and why it is not relevant in Navy protection measures for its personnel but is relevant to civilians. Comment 4: JGL STUDY UNDULY FAULTED 28 Claims dismissal of the JGL noise study as “flawed” is unsupportable. Claim is bogus as JGL studies validated. DEIS needs to accept and use that important on-site data in evaluating single noise event impacts. Comment 5: EBEY’S RESERVE 33 Misconstrues an important finding of the National Park Service’s 2015 noise study. Revision called for. Low-frequency (LFN) of the Growler not addressed in the DEIS as an exacerbating impact on Ebey’s Landing Historic Reserve. LFN carriers much further than other noise, and therefore traverses the full Reserve. The impacts of LFN on visitor experience and damage to historic structures needs to be forthrightly addressed. Obfuscates credible understanding of the of the National Park Service’s 2015 noise study as related to impacts on visitor experience. Revision called for. Comment 6: PATH 14 versus 32 39 The 30% use projection for path 14 is unrealistic and greatly understates the DNL noise impacts for path 32. This mistake must be corrected to reflect actual usage potentials of 5% to 10%. Comment 7: SAFETY 44 Actual safety risks are only superficially analyzed for FCLP operations at NASWI and OLFC. An effective solution to dispel the FCLPs risks associated with unchecked encroachment around OLFC is not presented. This shortcoming needs judicious analysis, especially given the Growler is much more likely to crash than the Prowler. Comment 8: FAA ELEVATION RULES IGNORED 52 FAA rules, as related to FCLPs, have not been properly addressed in the DEIS. DEIS needs to explain how it intends to operate at OLFC
Figure 8.1 – Navy’s schematic of Path 14 FCLP at OLFC. The AGL elevations are the about same for Path 32 (Source: ). Comment 9: - DISPROPORTIONATE IMPACTS - The Problem: The DEIS claims the proposed alternatives will not create disproportionate impacts on children or minorities (i.e., “Enviromental Justice”). That claim is neither cogent nor defensible. The Explanation: The DEIS on page 4-121 correctly explains: As described in Section 3.3.2.4, unless there is a place where children congregate within an APZ, such as a school, there is not a disproportionate safety risk to children. As shown on Figures 4.3-1 and 4.3-2, there are no schools located within the APZs at Ault Field and OLF Coupeville under any of the alternatives or scenarios; therefore, there is no disproportionate environmental health and safety risk to children as a result of possible aircraft mishaps. Table 6-1 takes that a bit further a bit further, as extracted from that table: Executive Order 13045, Environmental Health Risks and Safety Risks to Children Navy. The Navy does not anticipate any significant disproportionate health impacts to children caused by aircraft noise, and there no disproportionate environmental health and safety risk to children as a result of possible aircraft mishaps. (Sections 3.3 and 4.3, Public Health and Safety.) The above conclusion is based on important omissions, which once included, render the conclusion unsupportable. Actually, there are three areas of disproportionate aggregation involving children age 19 and under within the proposed APZ -1: (1) The Admirals Cove Swimming Pool is open 4 summer months in the year and there is strong interest in covering the pool so it is open year round. The life guards working there are almost always older teens, and the pool is predominately used by teens and younger children, sometimes but not always accompanied by an adult. In addition, the pool has
Date C or P# 1 Appx. Times2 Estimated3 Notes # of Jets # Bounces Jan 05 tu - Not sure when ? ~30 Not sure of Jan 06wd x - - unsure Jan 08 fr x - - unsure bounces for Jan: ~ 30 Run total for 2016: ~ 30 Feb 02 tu - 1200-1245 = ¾ h 1335-1410 = ¾ h 3 3 75 no wind Feb 03wd x Eve - - 15 knot SE wind Feb 05 fr x Aft - - 20-30 knot SE Wind Feb 08 mo 32 ~1530 to 2000 w/ short breaks = 4.5 h 1-4 150 Calm, mild Feb 09 tu 32 ~1700 to 1900 1-3 40 Calm Feb 10 wd x Eve—Late N - - Rain, varied wind/cloud Feb 11 th x Aft - - “Tailwind” said Navy but was none. So? Feb 12 fr x Morn-Early Aft - - Who knows? Feb 16 tu 32 1600-1800 1-3 100 Fair/mild Feb 17 wd 32 1300-1500 1-3 100 No wind/mild Total bounces for Feb: 465 Run total for 2016: ~ 495 Mar 14 mn x EveLate N ? weather Mar 15 tu 14 1615 - 1830 1-3 100 Mar 16 wd ? Eve Late N Mar 17 th 32 1345-1630 /2000-2145 1-3 225 Mar 18 fr 14 1330-1630 1-3 100 Mar 21 mn x L Eve-N wind Mar 22 tu x Noon-Aft & L Eve-N Not sure ?? Mar 23 wd x L Morn- L Aft & Eve-N Big wind Mar 24 th 32 1345-1545 1-3 Mar 25 fr x All aft ?? Mar 30 wd 32 1410-1630 1-3 100 Sun/0-3 kn