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Indybay Feature
Save U.S. Rainforest - Deadline Nov. 28 to comment re WA State Olympic Peninsula
by Marilyn
Friday Nov 21st, 2014 5:21 PM
The last remaining rain forest in the US is ringed by the Olympic National Forest. The US Navy wants to make the area the "Pacific Northwest Electromagnetic Warfare Range" (PNEWR). The deadline to do something to save this precious fragile place is coming soon. This is a big, permanent, expanding, military project that will change the fragile Peninsula forever. It will likely be a prototype for militarizing more and more National Forests and Parks. We need real wilderness, not more militarizing. The US Forest Service is criminally falling down on its job of protecting the forest.
800_forest-park.jpg
The US Forest Service employee who is somehow the sole person in charge of okaying or rejecting this Electromagnetic Warfare Range (Mr. Dean Millett: please check him out on the videos if you get the chance) has stated publicly that he will be throwing out the thousands of public comments submitted so far (which unanimously reject the PNEWR) using the excuse that "they are not 'substantive'." Below (at ***) are excellent, informative instructions on making "substantive" comments, best made in the form of questions.

For background, an excellent article by Dahr Jamail appears on Truthout.org. A local Peninsula blogger
http://olyopen.com had this to say about that and about the process:
>>
If you care about this issue, you might want to read Dahr’s excellent
article. And then decide whether you want to comment. But my
suggestion is to contact our Senators and Representatives. They hold
the power to slow this and get the right thing done. Our comments are
just wallpaper for the Navy’s process.

http://www.truth-out.org/news/item/27339-navy-plans-electromagånetic-war-games-over-national-park-and-forest-in-washington-state OR http://tinyurl.com/njl7g3y


There is a Facebook page where updates are posted regularly, plus links to informative videos of locals speaking at public meetings.
https://www.facebook.com/protectolypen

---------------------
-see photos of the beautiful Olympic National Park area:
http://www.nps.gov/olym/photosmultimedia/index.htm
-the National Forest borders it on most sides, and is also beautiful:
http://www.fs.usda.gov/detail/olympic/specialplaces/?cid=stelprd3816871
-Olympic National Park is a Biosphere Reserve and a World Heritage site:
http://www.protectedplanet.net/sites/Olympic_Unescomab_Biosphere_Reserve#
-EMF-fragile small animals and birds abound (but not being protected in USN's plan):
http://en.wikipedia.org/wiki/Amphibians_and_reptiles_of_Olympic_National_Park
---------------------
============

***

"SUBSTANTIVE" COMMENTS REQUIRED to SAVE THE FORESTS:


- URGENT UPDATE: ELECTROMAGNETIC WARFARE over OLYMPIC NATIONAL PARK
From Linda Sutton 11/20/14:

We have found out that submitting comments in the form of questions is the
most effective action to take right now. Know that if you have already
submitted objections, you can resubmit your previous comments in the form
of questions, and add additional questions, as long as you do so before Nov
28th. Feel free to copy and paste the following information and share it
widely with friends, including those who don't actually do Facebook

*INTRO*: Citizens have only recently learned of the Navy's plans to turn
large areas of the Olympic Peninsula into an "Electronic Warfare Training
Range". The Navy plans to train pilots in Electromagnetic Warfare tactics
using our National Forests for their land-based emitters, which will be
used in conjunction with squadrons of supersonic Growler jets. The pilots
will be practicing advanced Electronic Warfare tactics in the airspace over
Olympic National Park. Future escalation of the training will most likely
include Growler planes “jamming” --- using electromagnetic radiation to
intercept and disable signals.

The project poses serious threats to public health and to wildlife. More
than three million visitors come to Olympic National Park every year, and
thousands of families make their homes in this area.

The Navy has bypassed doing a comprehensive Environmental Impact Statement
(EIS) for this "project" by claiming there will be "NO SIGNIFICANT IMPACT".
The US Forest Service has accepted this claim and has decided to grant the
Navy a long-term permit to use our National Forest roads for mobile
“emitters” , which will be emitting powerful electromagnetic radiation.

The military already has hundreds of thousands of acres in remote areas
that have been designated for this type of activity with hazardous
weaponry. The Navy has chosen the Olympic Peninsula for their project
because they want their sailors to stay "closer to home" and "save on fuel
costs". However, the costs---and the risks-- of using this location are
exceedingly high, and they have not been adequately considered in the
Navy's plan.

The Forest Service is inviting pubic input on their decision to grant a
permit to the Navy. We have a very short window of opportunity to voice our
objections. The deadline for comments is Nov 28th. Before formulating your
objections, please review the following:

GUIDELINES FOR MAKING COMMENTS

IMPORTANT: If objections are followed by questions, they will be much more
effective. The Forest Service is required to answer each and every
question they
receive.(Statements of objections---regardless of merit---can be more
easily dismissed, but every question you pose must be addressed.) The more
questions, the better.

A suggestion: Formulate your objections/questions in a separate document. Be
sure to save a copy of it. Once you've done that, copy and paste your
comments into the comment box on the Forest Services website. (You can also
attach it as a separate pdf file) Then submit a copy of your objections to
your elected officials. This step is critical for making our voices count.
(See links provided at the end of this post)

“SUBSTANTIVE COMMENTS”

Forest Service officials have stated that only "substantive" comments will
have the power to reverse their decision.

This means that you might highlight where the Navy may have violated
Federal law, which, in this case, is *NEPA.*

NEPA refers to the National Environmental Policy Act of 1969. Through this
Act, the federal government recognized "each generation's responsibility to
act as a trustee of the environment for future generations." The Act
mandates a coordination of all Federal plans, agencies, policies, actions,
puts the protection of our environment as a Federal policy, to "assure for
all Americans safe, healthful, productive and esthetically and culturally
pleasing surroundings...without degradation, risk to health or safety, or
other undesirable or unintended consequences" (42 U.S.Code 4331)

Substantive comments could point out how the Navy's Environmental
Assessment violates the NEPA process. Some ideas are outlined below. Add
more if you can. Remember to pose your objection as a question such as
"Why has the Forest Service not conducted their own independent research?
Why are they choosing to accept the Navy's outdated 'science' ?”

It is not required to include all the legal details of the argument. Just
point out
that the Navy's Environmental Assessment appears to be in violation of
NEPA, and ask the Forest Service why they are allowing these violations?
Consider the following:

1. The Navy violated NEPA procedure by their failure to adequately notify
the public about their project. (tiny notices were placed in obscure
locations, and published in distant newspapers.) The public was not
adequately informed, as Federal law requires.

Sample Questions: Why were the communities where this testing is to be done
not notified? Why were no public hearings held for the Navy’s drafting of
their EA? Why were no local newspapers notified? Why were no local elected
officials notified?

2. The Navy violated NEPA procedure by not notifying or consulting with
Olympic National Park as they drafted their Environmental Assessment (EA).
This project will severely impact the wilderness experience for millions of
visitors to the Park every year. By law, the National Park should have been
consulted when the Navy was drafting their plans.

Sample Questions: Why was the Olympic National Park not notified or
consulted by the Navy during the drafting of this EA? (The Navy has told
the public that they did consult with the Park, but this appears
erroneous.) Do they have any records of their consultation with the Park?
If they do, why isn't it available for the public to see? Isn't if the
Forest Service's responsibility to verify this? Why hasn't the Forest
Service conducted a formal investigation of this violation?

3. The Navy violated NEPA procedure by not addressing future and cumulative
impacts of the project. Federal Law requires that these be fully disclosed
and analyzed. The Navy states that their project aims to "accommodate
growth in future training requirements" , yet they do not specifically
disclose what that growth will include, nor analyze its impacts. According
to the Navy's own briefs, the interception and disabling of signals by
their planes, called Growlers, plays a central role in electronic warfare
training. As such, the Navy must address this very plausible escalation in
their EA. All future phases of the Electronic Warfare Training Project must
be fully disclosed and evaluated in full.This is Federal law. The Navy is
*not* permitted to disclose their plans incrementally or attempt to
disguise their bigger plans by a "piecemeal" approach. USFS Ranger Dean
Millett has stated that he is not considering the larger plan of the
Navy's, but is limiting his "decision space" to just the use of Forest
roads for the emitters. He is not considering the supersonic jets--either
their noise or their radiation--in his decision.

Sample Questions: Why is not only the Navy, but the Forest Service,
narrowing their focus so dramatically, when NEPA clearly states that the
entire project and itimpacts need to be included? Separating out partial
aspects of the bigger project, (which includes many supersonic Growler jets
practicing with active attack radiation), is clearly part of the future
training program and needs to be fully disclosed and analyzed. Exactly how
much radiation will be projected from each of the Growler jets in one day's
training as they practice their warfare tactics? Why is the Forest Service
not demanding full transparency and full disclosure as Federal law mandates?

4. The Navy violated NEPA procedure by not using the most recent and "best
available science" in their conclusion that there will be "No Significant
Impact" from their project. Their supporting science documents are weak and
sorely outdated. Thousands of recent, peer-reviewed studies indicate there
are very real harmful effects---both to humans and to wildlife--- from
man-made electromagnetic fields. The Navy sited only one very dated and
narrow experiment on DNA fragmentation to justify their claim that
electromagnetic radiation is harmless. (See the Navy's EA 3.1.1.2). They
have chosen to ignore thousands of rigorous scientific studies. The Navy's
EA is sorely deficient in this regard, and as such, it violates Federal
law. When the public brought this serious deficiency to the attention of
Ranger Millett, he replied that the Navy's science is "good enough" for him.

Sample Questions: Why is the Forest Service not demanding that the Navy use
the most recent and best available science? Because the project will
include active, focused use of electromagnetic weaponry, pointed down
towards the earth, the damage to living systems will be significant. Why is
the Forest Service not addressing this? Why are they allowing the Navy to
manipulate the NEPA process in this manner when the flaws and deficiencies
of the Navy's EA are so blatant? Isn't it the Forest Service's
responsibility to demand that the Navy fully disclose all impacts of this
project, including the future escalation of the training? Why is the Forest
Service skirting their responsibilities ? Why aren't they protecting the
forest and its visitors from this potentially harmful project? Isn’t that
their responsibility?

5. The Navy violated NEPA procedure by failing to address the impacts this
electromagnetic radiation will have on bees, butterflies, birds and bats as
well as a multitude of other small animals and insects. Because the current
worldwide Bee Colony Collapse is such a threat to our food security, the
President of the United States has called for all government agencies,
including the Department of Defense and the Dept of Agriculture, to make
the protection of pollinators a critical priority. Scientists have found
that man-made ElectroMagnetic Radiation radically disrupts bees' ability to
navigate and find their way back to their hives. Also the Navy's assessment
does not address the harm this radiation causes to amphibians. These
omissions in the Navy's EA renders the document sorely deficient. As such,
it is a violation of NEPA.

Sample Questions: Why is the Forest Service not requiring the Navy to
address the impacts of this project on bees, birds, bats, butterflies, and
other insects as well as amphibians? Numerous scientific studies document
very real harm to these creatures from man-made electromagnetic fields. Why
is this being overlooked? Why is the Forest Service not requiring
comprehensive studies of the flora and fauna in the forests they are
supposed to be protecting?

6. The Navy violated NEPA procedure by not addressing at all the following
areas where impacts will be experienced. Federal Law requires that the Navy
fully analyze and disclose all potential impacts---direct, indirect and
cumulative--- that their project could have. Neither the Navy nor the
Forest Service are permitted to dismiss the following issues. Add as many
questions as you can think about the following issues:

A. Noise from the airplanes: This was completely ignored in the Navy's EA.
The "soundscape" of Olympic National Park and the surrounding wilderness
areas will be severely impacted by squadrons of supersonic jets practicing
overhead most days of the year. This noise will also greatly impact
thousands of citizens' "quality of life" who are forced to live directly
underneath these flight paths.

B. Pollution: The Navy did not address the pollution, both chemical and
electromagnetic, that would be produced from the airplanes.The chemical
pollution alone from just one of these jets is tremendous.

C. Land-use, traditional use, cultural use: Since the early 1900s, these
pristine coastal regions and forests have provided critical habitat and
protected sanctuary for wildlife. This area, long used by millions of
visitors every year for recreation, will radically be altered by the Navy's
project. The noise, the pollution, and the electromagnetic radiation would
destroy any wilderness experience and severely impact recreational use in a
negative way.

D. Economic and social impacts: Visitors to the Olympic National Park are a
driving force of the economies of this region. Degrading the Park, as this
project threatens to do, could have a huge negative impact on the
Peninsula's economy, as families choose to go elsewhere for their vacations
because of the hazards to public health and the disruptive noise. The
Olympic Peninsula would also no longer be a desirable place to live, and
real estate prices could plummet.

Finally, if the Forest Service grants this permit, they are in violation of
their own management plan, and the National Forest Management Act. The
Department of Defense does not have the right to override the Forest
Service's own management plan and this Act. Electronic warfare training is
not consistent with the public purposes for which national forests are
reserved.

According to the US Forest Service's own regulations, military use our
public lands is not permissible if the military has other "suitable and
available" lands for their proposed action.

The military has *hundreds of thousands *of acres of remote lands that are
used for just this kind of hazardous testing and training. Why arent they
being used instead? Every viable alternative needs to be considered. Why
hasn’t the Forest Service required the Navy to use these other lands that
are available?

Finally, the Forest Service's own management policy states that when
considering issuing such a permit,

"*the* interests and needs of the general public shall be given priority
over those of the applicant."

The public has spoken loudly about this issue and have communicated clearly
what their needs and desires are.

Questions: Why are the needs and desires of the general public NOT being
given priority over the desires of the Navy?

Please submit your comments/questions before Nov 28th at the following
website:

https://cara.ecosystem-management.org/Public//CommentInput?Project=42759

*Important:* Please cc your federal and state representatives with your
comment letters:

For local and Washington State:

Contact page for *Sen. Patty Murray:* http://www.murray.senate.gov/public/
index.cfm/contactme
154 Russell SOB Washington, D.C. 20510 (202) 224-2621 (phone) (202) 224-0238
(fax) (866) 481-9186 (toll free); or 915 Second Avenue Suite 2988
Seattle, WA 98174 (206) 553-5545 (phone) (206) 553-0891 (fax) (866) 481-9186
(toll free)

Contact page for *Sen. Maria Cantwell:*
http://www.cantwell.senate.gov/public/index.cfm/email-maria
311 Hart SOB Washington, D.C. 20510 (202) 224-3441 (phone) (202) 228-0514
(fax)

915 Second Avenue Suite 3206, Seattle, WA 98174 (206) 220-6400 (phone) (206)
220-6404 (fax)

Contact page for *Derek Kilmer*: https://kilmer.house.gov/contact/email-me 1429
Longworth HOB Washington, D.C. 20515. (202) 225-5916 (phone) (202) 226-3575
(fax)

950 Pacific Avenue Suite 1230, Tacoma, WA 98402 (253) 272-3515 (phone)


Out of local area: refer to this page for your representatives’ contact
information:

http://www.wsha.org/0311.cfm

Find your State Legislator: http://app.leg.wa.gov/DistrictFinder/
To read what others have said in comments: https://cara.ecosystem-

management.org/Public//ReadingRoom?Project=42759

*Please share this post* with others who may want to submit comments.

Deadline for comments is Nov 28th.
LATEST COMMENTS ABOUT THIS ARTICLE
Listed below are the latest comments about this post.
These comments are submitted anonymously by website visitors.
TITLE AUTHOR DATE
From Olympic Park Associates, FINAL comments:OtterWednesday Nov 26th, 2014 5:05 PM
M-T-W: Calls to Congress, WA State and othersMarilynSunday Nov 23rd, 2014 10:35 PM
Comment from Seattle Audubon SocietySusan NorthSunday Nov 23rd, 2014 6:37 PM
experience speaks re USN War on The Olympic PeninsulaMarilynSunday Nov 23rd, 2014 6:10 PM
More Help for Substantive Comments-As-QuestionsMarilynSunday Nov 23rd, 2014 4:07 PM
Art Project for the ForestMarilynSaturday Nov 22nd, 2014 11:51 PM
send an email to Reta LafordMarilynSaturday Nov 22nd, 2014 11:05 PM
PNEWR includes Eastern WA Nat'l Forest too!MarilynFriday Nov 21st, 2014 6:20 PM
Harper’s Index-­‐Style Scorecard for USN's PNEWRMarilynFriday Nov 21st, 2014 6:14 PM
Culture ClashMarilynFriday Nov 21st, 2014 5:39 PM
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