Save U.S. Rainforest - Deadline Nov. 28 to comment re WA State Olympic Peninsula

It is very instructive to watch some of these videos of the 11/12/14 Port Angeles, WA meeting where the USN condescended to listen to people's questions (but showed their scorn by refusing to make any record of their questions and their --universal -- objections).

the videos can be found here:
http://vimeo.com/raindagger/videos

These people, who have chosen to live in or near the incredible wilderness on the Olympic Peninsula, are individuals well worth hearing and seeing.

And do not miss Crystal Tach in video #8, starting about min. 4. Listen for her information and question to the USN about the "Naval Experimental Zone" that comprises WA, OR, Northern CA, and parts of Idaho. Just a reminder that there is a lot we are not going to be told.


Throughout you can catch glimpses of Dean Millett, the US Forest Service "Ranger" who holds the "decision space" (his term) to okay this USN Electromagnetic Warfare Range. See #9 for plenty of DM. He does not look like he has been doing much ranging or appreciating the wilderness.


Small animals, salamanders, birds, none of these will be guarded from the EMFs the USN admits to emitting, as stated in the video. Large animals and people will supposedly be accommodated by the moving-away of the "mobile emitters" but nobody is going to be beating the bushes or watching the trees for birds.


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there are also more valuable videos there by the same videographer, here is one, with some transcribed quotes:

http://vimeo.com/110384630

"The more you learn, the worse it gets"
from RainDagger Productions

Ken Pickard of Whidbey Island's COER citizensofebeysreserve.com speaks of a discussion he had with USN's John Mosier, Northwest environmental program manager, U.S. Pacific Fleet about the impacts of the U.S. Navy's proposal to conduct electromagnetic warfare training in the Olympic National Forest.

quotes:

Planes may fly as low as 1200 feet over mountainous areas

It's going to completely degrade the soundscape of the west coast

I asked him, "Will there be more flying?" He said there will be up to a 10% increase in the number of operations
BUT
while they are out there, instead of just doing what they currently do, they will be adding this electronic jamming practice -- they will actually be out there longer, so its a deception to say the number of flights will only increase 10% -- maybe, but it will be a longer time.

It's deceptive.

here is a little snip I made from an exchange posted to the Protect OlyPen FB page a few days ago, showing the profound clash of cultures:


     A US Navy pilot who loves to buzz the wilderness says :

Still, to answer your question, yes, it might be possible to find
an aircraft flying "below you" as you hike in the Olympic Forest
mountainous area.

...and to that I guess my question is, So what?


     Debra Wilson replies:

Why... why do lower-flying planes matter???

Have you ever hiked in OUR mountains, heard the deep, calming
quiet that puts your mind body and soul at ease??

Or have you ever heard the nature's sounds of animals or breeze
and sat on a rock up there to soak in the beauty and peacefulness of
it all???

Now imagine your fighter jets flying right in the middle of that scene!!!

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"Thousands of tired, nerve-shattered, over-civilized people
are beginning to find out
that going to the mountains is going home:
that wilderness is a necessity."

--John Muir--



Climb the mountains and
Get their good tidings.
Cares will
Drop off like Fall leaves.
Nature's peace,
storm's energy,
Wind's freshness,
will flow in you
Like sun in tall trees.

--John Muir--

A Public Scorecard for the Navy’s Proposed
Electronic Warfare Training in Olympic National Forest:
A Harper’s Index-­‐Style Evaluation of What We Know and Don’t Know
As of November 11, 2014

by Karen Sullivan

and it is important not to forget that the USN's proposed PNEWR includes another big region in Eastern WA, the National Forest in the Okanogan and Roosevelt area.

from the Protect Olympic Peninsula" FB page today:

" Please share with others that any comments sent to Dean Millet should also copy Reta Laford, the ONF Supervisor. Ultimately, it will be Reta who will review the process and most likely the one who will make the final decision, regardless of what Dean says.

Her email address: rlaford [at] fs.fed.us "

Here is where you should submit your comment ("substantive" of course), directly to the USFS website at:
http://go.usa.gov/785z
[click on "Comment on Project" to the right of that page to get to the web-form]

keep a copy so you can send one to Reta Laford by email. As well as all the government reps you can think of.

Thousands of emotional public comments that were submitted to USFS will be discarded because they "are not substantive." Here is a tribute to people's heartfelt outcries, turning them into art:

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Terra Holcomb added 3 new photos.
https://m.facebook.com/story.php?story_fbid=10152489350428947&id=608623946

Wanna help with a collaborative public art project? We're making "prayer flags" from flannel shirts and writing the emotional public comments people are posting to the Forest Service, in opposition to the Navy's plans to test new radiation war technologies in the Olympics/Okanogan forests. I'll photograph the flags in the forests where testing is planned. You can help by transcribing comments on fabric squares. I believe art is a powerful tool for social change and I promise that you'll be moved by the comments you'll read. Message me or comment and I'll add you to the project page that has more info. Thanks people!

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(some of) the submitted comments can be read at:

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

Navy Electronic Warfare - Supersonic Jets and Radiation Emitters to train on Washington’s pristine Olympic Peninsula
     Quick Summaries With Questions – Comment Period Closes November 28

Comment direct input site: https://cara.ecosystem-management.org//Public//commentinput?Project=42759


1. At least 36 supersonic Growler jets will fly 8 to 16 hours per day for 260 days per year, and will conduct at least 11 “training events” per day on each of 3 mobile radiation emitters rotated through 15 different locations throughout the Olympic National Forest. They will also use airspace over the neighboring Olympic National Park. Each site will be exposed to as much as 468 hours per year, of electromagnetic radiation.

No public notices were placed in any newspapers that directly serve our Olympic Peninsula communities. Why didn’t the Navy notify us in the usual way, about their plans?


2. This training will use a variety of electronic attack weapons carried on each Growler jet, such as lasers, high-powered microwave or EMP or anti-radiation energy in concentrated, directed beams designed, according to a Navy source document “…to attack personnel, facilities, or equipment with the intent of degrading, neutralizing, or destroying enemy combat capability…”

What types of electronic attack will be practiced in our national forest and along our coast, and what are the potential impacts, intended or otherwise, on the local population and the environment?

How can the permit include the use of Electronic Attack weapons if they weren’t even discussed in the Navy’s Environmental Assessment?


3. The Navy claims there will be no significant impacts to the Olympic National Forest, Olympic National Park, State and Indian Reservation lands or communities on the Olympic Peninsula, but the Forest Service has done no independent investigations or scientific research whatsoever, to verify that claim.

Where is the peer-reviewed research to back up the Navy’s claim of no significant impacts? Why didn’t the Navy do its homework?

Why didn’t the Forest Service do its own independent scientific investigations to verify the Navy’s claims?


4. The Forest Service gave the Navy a temporary permit three years ago, to practice with one of its truck and trailer radiation emitters.

Why can’t the public see this permit? It has been asked for.

What did the Forest Service do to make sure that this use was compatible, and what research did it conduct to make sure that there was no harm to birds, plants, trees, animals and human beings in the area of how many tests by the Navy?


5. No studies have been done on additional fire danger during dry seasons that could be magnified by climate change.

Misdirected energy beams from jets or sparks from the trucks or operators’ cigarettes can cause fires. There have also been 6 Navy jet crashes this year in rural and residential areas, including an apartment complex. All of them involved fatalities and fires. With climate change, our forests will be getting drier. Why weren’t these hazards analyzed?


6. A Navy supporting document says, “Friendly Electronic Attack could potentially deny essential services to a local population that, in turn, could result in loss of life and/or political ramifications.”

Why wasn’t this discussed in the Navy’s Environmental Assessment, and what exactly has the Navy done to guarantee this won’t happen?


7. The Navy says its jets will not fly lower than 1200 feet above ground level, but hikers on ridge trails in both the ONF and ONP have seen jets passing beneath them, and report being disturbed by the noise.

Why have jet noise effects not been analyzed on the wilderness soundscape?


8. The Navy is authorized to fly at 300 feet above ground level in a training area near the Canadian border. Nobody knows what would prevent them from authorizing that in the Olympic National Forest, too.

Why does the Navy need to fly so low?


9. Hearing damage occurs at 85 decibels. A Growler jet flying at 1000 feet above ground produces 113 decibels. Residents at Admiral’s Cove on Whidbey Island have had noise levels measured at their homes by a sound professional. Levels have been as high as 134.2 decibels. Residents in Port Angeles and Port Townsend have reported Navy jets flying low over those communities.

How can sound at this level not cause significant impacts?


10. The marbled murrelet, a small seabird threatened with extinction, declined in population by 26 percent between 2002 and 2009. No studies have been done on the effects of loud noise, chronic radiation and electromagnetic disruption on endangered species or migrating shorebirds, geese and ducks.

Why have these studies not been done? Why hasn’t the Forest Service conducted its own research to verify the Navy’s claims?


11. The northern spotted owl, another bird threatened with extinction, has “critical habitat” in the Olympic National Forest, as does the marbled murrelet. Most of the 15 sites where the Navy will place its mobile radiation emitters are in that critical habitat.

Why does the Navy have to further endanger these species when it has already-developed training grounds elsewhere?


12. The Navy already has the use of more than 20,400 square miles of airspace and 356,000 acres of land over training grounds in Fallon, Nevada and Mountain Home, Idaho. By law the Navy must provide the public with substantial reasons and detailed analyses (not just one sentence) of why it cannot find other areas, including private lands, for training. A cost-benefit analysis has not been provided on the savings in jet fuel from not flying the extra 400 miles to Mountain Home, versus the socioeconomic and environmental consequences of intensive warfare training, jet pollution and other hazards, over the Olympic National Forest and over our communities.

Why has the Navy not done these analyses?


13. Not one public comment was received by the Navy on its Environmental Assessment last August, and the Navy has since refused to hold hearings in which public comments would be officially recorded, in affected communities on the Olympic Peninsula. Congressman Derek Kilmer intervened, so the Navy held “informational meetings” but no official hearings. No public comments were recorded. Not one person at any of these meetings in October and November had known about the Navy’s proposed action while the comment period on the Environmental Assessment was still open.

“Informational meetings” are not hearings under the law, and the public was not adequately notified. Why has the Navy not held hearings or accepted public comments at these meetings? Doesn’t public opinion count?


14. The Navy lists these two reasons for why it wants to move the entire electronic warfare program to the Olympic National Park: savings on jet fuel from not having to fly the extra 400 miles to Mountain Home, Idaho, and more time for Navy personnel to spend with their families because of the 45-minute savings in flight-time. At 100 million barrels of oil per year, the US military is the world’s largest user of fossil fuel. 70 percent of that use is jet fuel. While everyone acknowledges saving fuel is a good goal, adding at least 36 jets that burn 1300 gallons per hour hardly qualifies as a fuel-saving event.

How can the navy say it is saving fuel if it is adding at least 36 Growler jets to its fleet? Have the Navy or the Department of Defense done any analyses of the contribution of burning this much fossil fuel to climate change?


15. For the Navy and the Forest Service, the issue is simple: Should the Forest Service grant a Special Use Permit for the Navy to use roads in the Olympic National Forest to run their electromagnetic radiation-emitting truck-and-trailer combinations, which will admittedly cause numerous unannounced forest closures? For the rest of us, the issue is more complex and includes many other problems nobody is addressing in a way that is either fair or makes sense to the public.

Why will issuance of a permit for road use by mobile emitters trigger all of the other activities and impacts, and why are all public concerns being ignored except the ones on road use mentioned in the Environmental Assessment?


No scientific research or investigations have been conducted by either the Forest Service or the Navy on the following list of public concerns:

a. Socioeconomic impacts to communities from increased jet noise and air pollution;
b. Impacts to wilderness values in Olympic National Park;
c. Cultural factors, including traditional uses of land;
d. Analysis of multiple stressors on humans, endangered species, and other wildlife;
e. Analysis of chronic radiation effects on humans, wildlife and habitats;
f. Evaluations of the protection of children, environmental justice, water, land use, and geology;
g. Analyses on population effects on threatened bird species, particularly the cumulative effects of noise and electromagnetic radiation on the northern spotted owl and marbled murrelet, in whose critical habitat areas most of the Navy’s emitter sites will be located;
h. Analysis of the effects of electromagnetic radiation and loud sounds on migrating shorebirds, geese, ducks, and other non-listed birds;
i. Cost analysis for jet fuel savings from not flying an extra 400 miles, versus effects on the environment.
j. Analysis of other sites as alternatives to the Olympic MOA, including private lands.
k. Analysis of the increased fire danger posed by jet and drone crashes, sparks from vehicle transmitters or operators’ cigarettes, or misdirected electromagnetic beams from either the transmitters or from jets, hitting tinder-dry vegetation;
l. Analysis of the interaction and effects of climate change as a potential magnifier of impacts.

Among other areas which include the Gulf of Mexico and the US east coast, the Navy is also planning to conduct training in the Gulf of Alaska just south of Prince William Sound and east of Kodiak Island, that will kill or injure 182,000 whales, dolphins, porpoises, sea lions, seals, sea otters and other marine mammals in one five-year period. This is less than the original prediction of 425,000 marine mammals, but still so astonishing it makes one wonder what parts of our biologically rich coasts will not become war zones with high casualty counts, if the Navy continues to claim them for its own expanded use.

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

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)

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 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)

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/

REMEMBER, the comment period closes November 28. You may comment more than once.
Comment direct input site: https://cara.ecosystem-management.org//Public//commentinput?Project=42759

To read what others have said in comments: https://cara.ecosystem-management.org/Public//ReadingRoom?Project=42759

excerpt from:
http://www.vfpbellingham.org/tipping-the-scale-blog/us-navy-plans-to-wage-war-on-the-olympic-peninsula

I am not an alarmist, but I was trained as an Airborne Electronic Warfare Officer in 1970 and was familiar then with the potential environmental damage these training routes could cause. While the Military Operations Area (MOA) over the Olympic Peninsula has been used for years for readiness training, the Navy's recent Environmental Assessment of this EA18G version is sorely lacking new science regarding possible adverse effects on flora and fauna, with most data at least five years old. Noticeably missing also is adequate information for USFS decision makers to consider regarding daily low-level flights of the noisiest, most polluting aircraft in the Navy inventory. At a minimum the Navy assessment, which also lists alternative locations, cries out for an independent Environmental Impact Statement before the USFS is allowed to unleash these electromagnetic war games on steroids on the Northwest's most pristine wilderness.

Comments Submitted To: comments-pacificnorthwest-olympic-pacific@fs.fed.us

RE: Pacific Northwest Electronic Warfare Range Special-Use Permit Application


Dear Mr. Wahl,

In response to the scoping notice released by the U.S. Forest Service (USFS) Pacific Ranger District on September 26, 2014, the Seattle Audubon Society provides the following comments on the U.S. Navy’s (Navy) application for a special-use permit to conduct the Pacific Northwest Electronic Warfare Range project on National Forest lands.

According to the Pacific Northwest Electronic Warfare Range Environmental Assessment (hereafter EA), the Navy concludes that exposing the federally threatened Northern Spotted Owl (Strix occidentalis caurina) and the federally threatened Marbled Murrelet (Brachyramphus marmoratus) to electromagnetic radiation “may affect, but is not likely to adversely affect” either species. The Navy also concludes that there will be “no effect” on the federally threatened Western Snowy Plover (Charadrius alexandrinus nivosus). We concur with the Navy that Western Snowy Plover will not be affected by this action. However, we disagree with the Navy that the action “may affect, but is not likely to adversely affect” the Northern Spotted Owl and Marbled Murrelet. The Navy has drawn this conclusion without proper analysis of the effects of the action on each species. The Seattle Audubon Society believes that the Navy has been remiss in drawing a “may affect, but is not likely to adversely affect” conclusion without sufficient justification, and we request the development of a full Environmental Impact Statement (EIS) to analyze these effects thoroughly. Furthermore, any “may affect” determination for federally listed species requires concurrence from the U.S. Fish and Wildlife Service (USFWS) (50 C.F.R. 402.14(a)). The Seattle Audubon Society has been unable to confirm such concurrence to date. We request public dissemination of documentation demonstrating that the Navy has consulted with USFWS on the proposed action, and that USFWS has concurred with the conclusions reached in the EA. If such a consultation has yet to occur, we urge the development of a formal Biological Opinion by USFWS.


Summary of Action

Mobile Electronic Warfare Training System (MEWTS) Mobile Emitters

The Navy requests permission from USFS to deploy three Mobile Electronic Warfare Training System (MEWTS) vehicle-mounted electromagnetic emitters along national forest roads leading to 15 sites on Olympic National Forest and Washington Department of Natural Resources (WDNR) lands (12 and 3 sites respectively), during 260 days each year. These emitters will transmit electromagnetic radiation to naval aircraft to mimic conditions pilots might face in combat.

According to the EA, two types of emitters will be included on each mobile unit: (1) Travelling Wave Tube Amplifiers, which emit electromagnetic radiation at 4–8 gigahertz (GHz); and, (2) Magnetron Mobile Emitters, which emit electromagnetic radiation at 6.7–7.4 GHz (U.S. Navy 2014, p. 3.1-2). Each mobile emitter antennae will be mounted 4.2 meters (m) (14 feet (ft)) above the ground (U.S. Navy 2014, p. 3.1-5). The action level environment (defined as public areas where individuals have no knowledge or control of their exposure) of the Traveling Wave Tube Amplifiers is approximately 30.8 m (101.1 ft), while the action level environment of the Magnetron Mobile Emitters is 8.9 m (29.3 ft) (U.S. Navy 2014, p. 3.1-4). A “fixed beam” will be utilized. The dimensions of the beam were not described; therefore, we were unable to calculate the area to be affected. The EA states the mobile emitters will be located on existing cleared open area on ridges and cliffs, with the direction of emissions pointed in a west/northwest direction (U.S. Navy 2014, p. 2-4). In sum, the range of radiation emitted is 4–8 GHz, which is within the microwave portion of the electromagnetic spectrum (300 megahertz (MHz)–300 GHz) (U.S. Navy 2014, p. 3.1-2). The action level environment affected by each mobile unit is within 30.8 m (101.1 ft) of each mobile emitter (area unknown), beginning at a height 4.2 m (14 ft) from the ground.

The three mobile units are to be deployed to three of fifteen available sites during 260 days each year for 8–16 hours per day, with nine hours of actual operating time per vehicle per day (27 total hours per day across the three sites). The three mobile units will rotate daily among the 15 available sites. Thus, 1/5 of sites will be in use each day, meaning every fifth day, the same site will again be in use. According to the EA, mobile emitters will transmit electromagnetic radiation for a total of 2,340 hours per site per year, and 7,020 hours across three sites each year (U.S. Navy 2014, p. 2-6). This provides a total electromagnetic radiation exposure of 35,100 hours across all 15 sites each year (2,340 hrs/site/yr x 15 sites), which is never explicitly stated in the EA. In sum, an undefined area 30.8 m (101.1) ft west of each mobile unit site will be exposed to 4–8 GHz of electromagnetic radiation for 2,340 hours/year, with 9 hours of exposure occurring every fifth day.

Mobile Remote Emitter Simulator (MRES) Magnetron

The Navy also plans to install and operate one fixed (Mobile Remote Emitter Simulator) MRES emitter at Naval Station Everett Annex Pacific Beach. This fixed emitter will be (20 m) 66 ft in height, and can transmit 64 simultaneous pulses at 2–18 GHz (pulsed or in waves) (U.S. Navy 2014, p. 3.1-2). The action-level environment, also undefined in area, will be exposed 217.5 m (713.7 ft) west of the fixed emitter (U.S. Navy 2014, p. 3.1-4). The fixed emitter beam will be pointed in a westerly direction, into the air (U.S. Navy 2014, p. 3.1-15). The Navy failed to clearly identify the hours of operating time expected for the fixed emitter per day and per year, although repeatedly refers to Table 2.1-1 in the EA, which describes hours of operation of mobile emitters (U.S. Navy 2014, p. 3.2-23, 25). We assume this is an error, though we will accept the estimate of 9 hours of operating time per day to determine an annual estimate of 2,340 hours per year (9 hours x 260 operating days) at the fixed emitter site. We encourage the Navy to more clearly identify the hours of operation expected for the fixed emitter. In sum, an undefined area 217.5 m (713.7 ft) west of the fixed MRES emitter will be exposed to 2–18 GHz of electromagnetic radiation for 2,340 hours per year. We are unable to determine the significance of “64 simultaneous pulses” though if this suggests a magnification of emissions by 64 times one pulse, then it would appear that an undefined area 217.5 m (713.7 ft) west of the fixed MRES emitter will be exposed to 2–18 GHz of electromagnetic radiation for an equivalent of 149,760 hours pulsed per year (2,340 hours /year/pulse x 64 simultaneous pulses).


Occupancy of Northern Spotted Owl and Marbled Murrelet

According to a map (Figure 3.2-5) provided in the EA, 7 of the 15 mobile unit sites are within federally designated critical habitat for Northern Spotted Owl (sites 1, 2, 5, 6, 8, 13, and 15) (U.S. Navy 2014, p. 3.2-16). The EA states that a large and virtually isolated Northern Spotted Owl population may be found throughout the Olympic Peninsula portion of the project area (U.S. Navy 2014, p. 3.2-16). Neither presence/absence surveys, nor an evaluation of Northern Spotted Owl nesting sites were provided in the EA.

According to a map (Figure 3.2-6) provided in the EA, 11 of the 15 mobile unit sites are within federally designated critical habitat for Marbled Murrelet (sites 1, 2, 3, 4, 5, 6, 8, 12, 13, 14, and 15) (U.S. Navy 2014, p. 3.2-19). This map also shows that 8 of the 15 mobile unit sites are in close proximity (unknown distance) to areas used by Marbled Murrelet, indicated by subcanopy behavior, above canopy behavior, and downy young or eggshell (sites 3, 5, 6, 8, 9, 12, 14, and 16) (U.S. Navy 2014, p. 3.2-19). The EA concludes that there are no known Marbled Murrelet nesting sites that will be affected by mobile emitters, citing a 2011 habitat suitability model (Raphael et al. 2011) (U.S. Navy 2014, p. 3.2-18). Presence/absence surveys were not conducted. Figure 3.2-6 also shows a cluster of Marbled Murrelet points indicating both sub-canopy behavior and above canopy behavior near the fixed MRES fixed emitter site.


Effects to Northern Spotted Owl and Marbled Murrelet

According to the EA, electromagnetic radiation can affect wildlife depending upon three factors: (1) the type of radiation; (2) the duration of exposure; and, (3) the species receiving the radiation.

Our expectation is that the Navy would carefully review each of the three factors that it stated can cause electromagnetic radiation to affect wildlife, specifically addressing each factor as it relates to Northern Spotted Owl and Marbled Murrelet. Instead, the Navy concludes that exposure of Northern Spotted Owl and Marbled Murrelet to electromagnetic radiation “may affect, but is not likely to adversely affect” either species, presenting three arguments to support this conclusion (U.S. Navy 2014, p. 3.2-26).

First, the Navy states that studies demonstrating a negative effect of electromagnetic radiation on birds were based upon “continual and long-duration” exposure to electromagnetic radiation, and that because units are mobile, exposure will be minimized. Second, the Navy states that both Northern Spotted Owl and Marbled Murrelet will fly through the action area rapidly, minimizing any exposure to flight effects. Third, the Navy states that the directional beam pattern minimizes exposure to radiation. The Navy also states that one of two individuals in each vehicle will be tasked with observing the general training site from inside the vehicle for the presence of people or animals. Thus, if any people or animals are present in an area while training is occurring, the mobile emitter crews will cease operations, and if necessary, relocate. Each of these points attempts to address factor 2 above: duration of exposure.

Duration of Exposure

Unfortunately, the Navy has presented no argument to support its conclusions that the duration of exposure will not adversely affect each species. First, “continual and long-duration” exposure is never defined, and no comparison is made of the amount of exposure time that studies have suggested can cause adverse effects to birds with the expected exposure time of the mobile emitters. We question how the Navy was able to conclude that 9 hours of exposure to electromagnetic radiation (per site per day) does not qualify as continual and long-term. Furthermore, there is no analysis of the planned repeated exposure of 2,340 hours per site per year. As the Navy has not performed surveys to determine presence/absence, but is locating many mobile emitter sites within occupied and critical habitat, we would expect both Northern Spotted Owl and Marbled Murrelet to occur nearby, at least for some portion of time for this action.

With regards to the Navy’s second statement (both Northern Spotted Owl and Marbled Murrelet will fly through the action area rapidly, minimizing any exposure to flight effects), the Navy has ignored each species biology and behavioral patterns as they relate to duration of exposure. Instead the Navy provides a very general assessment of non-soaring bird flight patterns. The time period of electromagnetic radiation exposure should also be compared with the likelihood of encountering either species in a stationary position during the day. Northern Spotted Owl is a mostly nocturnal species that forages opportunistically during the day (USFWS 2011, p. A-9; Forsman et al. 1984, Sovern et al. 1994). Thus, the species is in a mostly inactive, motionless, and cryptic position during the day, maximizing the potential for inadvertent, long-term exposure. Additionally, during the nesting season, both males and female Marbled Murrelets incubate a single egg in alternating 24-hour shifts. Thus, there is ample opportunity for each species to receive a long-term exposure that may adversely affect individuals, as well as nesting success.

Additionally, potential effects to chicks and fledglings should be analyzed. The potential negative effects of electromagnetic radiation on nesting birds and nesting success is acknowledged through citations provided by the Navy (“Effects on birds may include reduced nesting success (Fernie and Reynolds 2005, Balmori 2009) and various behavioral and physiological responses to electromagnetic fields (Fernie et al. 2000, Fernie and Bird 2001), such as disruption of normal sleep-wake cycles through interference with pineal gland and hormonal imbalance.”). However, the Navy does not analyze such potential effects in the context of Northern Spotted Owl and Marbled Murrelet adults, chicks, or fledglings. The Navy limits its analysis to consider only the issue of duration of exposure as it relates to birds in flight, and cites one study (Bruderer et al. 1999) that did not find electromagnetic radiation (in the microwave range) to affect the flight patterns of nocturnal birds. As such, the Bruderer et al. (1999) citation is insufficient evidence to support the Navy’s conclusions that neither Marbled Murrelet nor Northern Spotted Owl will be adversely affected, as this study focuses on the movement of birds and this during nighttime hours. Thus, the Navy has ignored factor 3 above, by failing to thoroughly consider the biology of each species, including diurnal patterns and nesting habits.

The Navy also diminishes the importance of potential effects by stating that mobile unit operations will cease should the single surveyor detect birds from inside the mobile unit. This is no consolation considering that of course, it would be very difficult, if not impossible to detect these highly cryptic species from inside a vehicle. Thus, we disagree that visual surveys conducted from inside each mobile unit would be sufficient to detect Northern Spotted Owl and Marbled Murrelet during emissions activity.

Finally, the Navy states that the directional beam pattern minimizes exposure to radiation, though it is unclear whether the directional beam will intersect with the high forest canopy preferred by these species. Proximity of areas known to be occupied by either species is taken into consideration only generally. Further investigation is needed to evaluate whether adverse effects are to be expected, and the Navy should perform analysis of the likelihood of occupied habitat (particularly nesting habitat) overlap with the directional beams. We are concerned that a lack of regular surveys adjacent to each mobile unit site prior to radiating emissions will repeatedly expose these species to electromagnetic radiation. This issue must be addressed.

Type of Radiation

The Navy attempts to address the question of radiation type through its citation of Bruderer et al. (1999), which did not find negative impacts to nocturnal birds tracked with an electromagnetic beam at 9 GHz. While we do not contest the findings of this study, we suggest that they are not entirely applicable to determine the effects of this action, because flight patterns alone were analyzed, as described above. Additional analysis is needed to determine that radiation from the mobile emitters (4–8 GHz) would not affect other behaviors, the physiology, and the nesting success of each species. Furthermore, the Navy provides no analysis of the expected effects associated with the fixed emitter at a radiation range of 2–18 GHz for 2,340 hrs/year, or 149,760 hours pulsed per year at 64 simultaneous pulses.

Species Receiving the Exposure

As described above, the Navy presented virtually no analysis of potential effects on Northern Spotted Owl and Marbled Murrelet based upon the biology of each species. While information about the status of each species is presented, very little consideration was given to behavioral and life history traits, including diurnal habits, flight patterns, nesting timing and duration, and so on. Most importantly, each species’ biology was not specifically considered with regards to the effects of the action. These and other pertinent questions must be addressed: what is the likelihood that Northern Spotted Owl and Marbled Murrelet individuals will encounter electromagnetic radiation, at what proximity will this occur, for what duration, how might that radiation affect each species’ biology (physiology, behavior, nesting success, etc.) and hence the ability of each species to recover from being threatened with extinction?


Lack of Formal Consultation with the U.S. Fish and Wildlife Service

Any action resulting in a “may affect” determination for federally-listed species requires concurrence from USFWS (50 C.F.R. 402.14(a)). The Seattle Audubon Society has been unable to confirm such concurrence to date. We request public dissemination of documentation demonstrating that the Navy has consulted with USFWS on the proposed action, and that USFWS has concurred with the conclusions reached in the EA.

If the Navy and USFWS have failed to consult on this specific action, we urge such a consultation and the development of a formal Biological Opinion by USFWS. This formal consultation process should result in an analysis of the effects of the proposed action on federally-listed species, as well as the development of reasonable and prudent alternatives and measures to be implemented by the Navy for the purpose of reducing negative impacts associated with this action.


Conclusions

We disagree with the Navy that the proposed action “may affect, but is not likely to adversely affect” the Northern Spotted Owl and Marbled Murrelet. The Navy has drawn this conclusion without proper analysis of the effects of the action on each species, including the three factors considered most important (the type of radiation, the duration of exposure, and species receiving the radiation).

There are significant concerns related to the following points: (1) many mobile unit sites will be placed in occupied and critical habitat for both species; (2) duration of exposure would in fact appear to be long and continual, although the Navy has discounted this point; (3) no analysis of effects was performed to consider each species’ biology (diurnal patterns and nesting habits); (4) no analysis of effects was performed to consider the effects of the radiation range of 4–8 GHz for the mobile emitters on the behavior, physiology, and nesting success of each species; (5) potentially inaccurate information is provided about the hours of operation for the fixed emitter; and, (6) no analysis of effects was performed to consider impacts related to the radiation range of 2–18 GHz from the fixed emitter on either species. We encourage the Navy to develop a full Environmental Impact Statement (EIS) to analyze these effects thoroughly.

Furthermore, any “may affect” determination for federally listed species requires concurrence from USFWS (50 C.F.R. 402.14(a)). The Seattle Audubon Society has been unable to confirm such concurrence to date. We request public dissemination of documentation demonstrating that the Navy has consulted with USFWS on the proposed action, and that USFWS has concurred with the conclusions reached in the EA. If such a consultation has not occurred, we urge the development of a formal Biological Opinion by USFWS.


The Seattle Audubon Society appreciates the opportunity to comment on this EA.

Sincerely,

Susan North
Conservation Manager
Seattle Audubon Society



References Cited

Balmori, A. 2009. Electromagnetic pollution from phone masts, effects on wildlife. Pathophysiology 16:191‐199.

Bruderer, B., Peter, D., and T. Steuri. 1999. Behavior of migrating birds exposed to X-band and a bright light beam. Journal of Experimental Biology 202:1015-1022.

Fernie, K.J., Leonard, N.J., and D.M. Bird. 2000. Behavior of free‐ranging and captive American kestrels under electromagnetic fields. Journal of Toxicology. Environmental Health, Part A:597‐603.

Fernie, K.J. and D.M. Bird. 2001. Evidence of oxidative stress in American kestrels exposed to electromagnetic fields. Environmental Research A 86:198‐207.

Fernie, K.J. and S.J. Reynolds. 2005. The effects of electromagnetic fields from power lines on avian reproductive biology and physiology: a review. Journal of Toxicology Environmental Health, Part B:127‐140.

Forsman, E.D., Meslow, E.C., and H.M. Wight. 1984. Distribution and biology of the spotted owl in Oregon. Wildlife Monographs 87:1–64.

Sovern, S.G., Forsman, E.D., Biswell, B.L., Rolph, D.N. and M. Taylor. 1994. Diurnal behavior of the spotted owl in Washington. Condor 96:200–202

U.S. Fish and Wildlife Service. 2011. Revised Recovery Plan for the Northern Spotted Owl (Strix occidentalis caurina). U.S. Fish and Wildlife Service, Portland, Oregon. xvi + 258 pp.

U.S. Navy. 2014. Pacific Northwest EW Range Environmental Assessment (EA). Final EA. September 2014. 228 pp.




Greg Wahl, Project Lead,
USDA-Forest Service
Olympic National Forest
1835 Black Lake Blvd SW
Olympia, WA 98512


Susan North
Conservation Manager
Seattle Audubon Society
8050 35th Ave. NE
Seattle, WA 98115

Dr Bev Goldie launches the C3 Campaign this morning-- 3 days:3 Congressional Calls--to make sure our elected officials hear our voices. She asks for focused calling by EVERYONE to Kilmer on Monday, Cantwell on Tuesday, Murray on Wednesday. Calls should be short but direct asking that they be recorded (take down name of staffer answering phone). Please forward this list to your contacts so that our efforts will be multiplied. Thank you.

C³ Campaign
3 Days: 3 Congressional Calls

MONDAY- Nov. 24 CALL CONGRESSMAN DEREK KILMER
DC: 202-225-5916 Port Angeles: 360-797-3623
Tacoma: 253-272-3515 Bremerton: 360-373-9735

TUESDAY – Nov. 25 CALL SENATOR MARIA CANTWELL
DC: 202-224-3441 Olympic Peninsula (Tacoma) 253-572-2281
King Co: 206-220-6400 Pierce/Thurston/Kitsap: 253-572-2281
NW (Everett): 425-303-0114 SW (Vancouver): 360-696-7838
Central (Richland): 509-946-8106 Chelan/Douglas Co: 509-946-8106
Okanogan Co: 509-353-2507 E WA(Spokane): 509-353-2507
SE (Richland): 509-353-2507

WEDNESDAY – Nov. 26 CALL SENATOR PATTY MURRAY
DC: 866-481-9186 (toll free) Seattle: 866-481-9186 (toll free)
Tacoma: 253-572-3636 Everett: 425-259-6515
Yakima: 509-453-7462 Spokane: 509-624-9515 Vancouver: 360-696-7797

(Bonus points for going online and also sending e-mails to their offices)

Message: Please register my opposition to the Navy’s proposed electromagnetic warfare training in the Olympic National Forest.

-----
From FB page:

Q: Even if your not in kilmors district?


A: Protect Olympic Peninsula: You can CALL him and register opposition regardless, but you won't be able to do an e-mail unless you know a zip from in the district (like 98368-3058, for instance)

And be sure to call Governor Inslee: 360-902-4111

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Out of WA also call your own reps, see above for link to find reps' info

From Olympic Park Associates, their FINAL comments:
SUBJECT: Pacific Northwest Electronic Warfare Range Environmental Assessment (42759)

Dear Greg Wahl,

Olympic Park Associates (OPA) appreciates this opportunity to comment on the establishment of a permanent electromagnetic warfare training range on the western half of the Olympic Peninsula.

Given the additional time to comment on this EA granting the Navy’s permit application, these comments are a revision of the comments given by OPA on October 10, 2010. OPA asks that this submission is now considered the comments of OPA on this subject.

Olympic Park Associates is an organization of United States citizens living primarily in Washington State. Members live and/or recreate on the Olympic Peninsula. Our organization’s mission is “to protect the wilderness and ecological integrity of Olympic National Park”

OPA strongly opposes the establishment of a permanent electromagnetic warfare training range on the western half of the Olympic Peninsula. The reasons for our opposition are many:

LACK OF INFORMATION
Public notice and information have been limited and sited documents have been deleted from the website. On October 30, 2014, the EA document sited in District Ranger Millett’s Letter of September 26, 2014; File Code: 1950 “The EA is available for review on-line at: http://www.fs.usda.gov/proi…/olympic/landmanagement/projects” was unavailable. The difficulty in finding documentation of this EA has hindered OPA’s ability to make comprehensive comments on the EA. A violation of NEPA procedure.

IMPACT ON PEOPLE & ECONOMY
Aircraft aerial maneuvers and their resulting horrific noise on the western half of the Olympic Peninsula would have an overwhelming impact on citizens living in the area, citizens recreating in the area, and the over 3 million yearly visitors to the area. A National Park Service (NPS) report issued in July of this year showed that in 2013, 3,085,340 visitors to Olympic National Park spent $245,894,100 in communities near the park. That spending supported 2,993 jobs in the local area.

The EA, as quoted below, insufficiently addresses the impacts of the proposed Navy warfare training and its effects on residents, visitors, wildlife, or Navy personnel on the Olympic Peninsula.

PURPOSE AND NEED
The purpose and need given in the Navy EA, while laudable in its intent, is inadequate because of the damage that would done to the people and wildlife on the Olympic Peninsula by its implementation. As stated:

“The purpose of the Proposed Action is to sustain and enhance the level and type of EW training currently being conducted by assets using the NWTRC, to provide the ability to accommodate growth in future training requirements, and to maximize the ability of local units to achieve their training requirements on local ranges. The following list identifies the EW training and needs that will be met by establishing the EW Range: (1) EA-18G and EA-6B Fleet Replacement Squadron (FRS) personnel and Fleet Squadron Personnel training requirements; (2) support of basic and intermediate EW training for all user requirements of the NWTRC, primarily the locally assigned air, surface, and subsurface units; (3) live training, augmented by virtual training; (4) support of unit EW certifications and sustainment
level training; (5) maximization and balance of local unit quality of training with local unit quality of life; (6) reduction in costs of training by conducting more training locally; and (7) reduction in the use of fossil fuel consumption from transit to and from training sites outside the state of Washington.” [PACIFIC NORTHWEST ELECTRONIC WARFARE RANGE
ENVIRONMENTAL ASSESSMENT, abstract prepared by United States Department of the Navy, Final (September 2014).]

OPERATION NOISE
OPA cannot find an analyses of the aircraft noise that will actually be created by these training exercises in the Navy EA.
The Navy EA has limited the discussion of noise to: Vehicle Noise, Generator/Emitter Noise, Fixed Emitter Generator Noise, Mobile Emitter Generator Noise, Temporary Demolition/Construction Noise, and only the following about airplane noise. “(1) aircraft noise exceeds 92 dBA Sound Exposure Level (SEL) at a nest site, or aircraft approach within a distance of 110 yards (yd.), whichever is greater; and (2) ground-based activity occurs during the nesting season within 100 m (110 yd.) of a nest site (U.S. Fish and Wildlife Service 2013).” [BIOLOGICAL RESOURCES 3.2-25]

There is no discussion of the intensity of aircraft noise generated by this project in relation to above standards. There is no reporting of the noise that would be created by the jets while flying in the training range or the noise created by jets flying to and from the training range. OPA argues this is a significant omission in the EA and violates NEPA.

POLLUTION CAUSED
OPA cannot find any reporting on the effects of air pollution that would be created by aircraft, flying up to 12 hours a day and up to 260 days a year, to the people or the environment of the area of the training maneuvers. This seems to be a significant omission and violates NEPA.

WILDLIFE CONCERNS
The environmental consequences of this permit request state:

“3.2.4 ENVIRONMENTAL CONSEQUENCES
• Noise. Noise from vehicle travel, generators/operation of emitters, and temporary demolition/construction (during the renovation of Building 104 and the construction of the MRES tower), may disturb wildlife.”

There is only the following reported:

“As discussed in the Affected Environment section, the ESA-listed bird species that may occur in this portion of the project area are the northern spotted owl, and the marbled murrelet. Critical habitat has been designated for both species, and the Proposed Action overlaps with this critical habitat (Figure 3.2-5 and Figure 3.2-6). The two stressors that could impact the birds are noise and electromagnetic radiation.”

There is no study that demonstrates this project would result in the following conditions or not:

“ESA-Listed Birds
Marbled murrelets and Northern spotted owls in the project area may be temporarily disturbed by noise associated with the Proposed Action. While owls and murrelets may be disturbed by a wide variety of human activities, the USFWS has anticipated that harassment (or “take”) would occur when the species exhibit behavior that suggests that the safety or survival of the species is at risk, or that a reproductive effort is potentially lost or compromised (U.S. Fish and Wildlife Service 2006). These behaviors could include species flushing from the nest during incubation, brooding, or fledging, all of which could lead to egg failure or reduced juvenile survival. Abandonment of the nest during a feeding or delaying a feeding could also lead to reduced survival of the juvenile. Recent biological opinions for forest management activities in the Olympic National Forest have noted that these behaviors are likely to occur when (1) aircraft noise exceeds 92 dBA Sound Exposure Level (SEL) at a nest site, or aircraft approach within a distance of 110 yards (yd.), whichever is greater; and (2) ground-based activity occurs during the nesting season within 100 m (110 yd.) of a nest site” (U.S. Fish and Wildlife Service 2013). [PACIFIC NORTHWEST EW RANGE EA FINAL (SEPTEMBER 2014]

There is no indication in the EA that the permit activities would compromise the conditions as stated above. OPA argues this is insufficient to meet the objectives of NEPA. There is no study or statement of fact that the birds living and flying through this area of the Olympic Peninsula will not be harmed by the activities of jet aircraft using this training range over the years of operation. The stresses of the Navy’s activities in this wildlife rich area could result in adding other birds and animals to the threatened and endangered lists.

• Electromagnetic Radiation. The electromagnetic field created from the operation of the EW emitters during training activities may disturb wildlife that use electromagnetic fields for movement and orientation.” [PACIFIC NORTHWEST EW RANGE EA FINAL (SEPTEMBER 2014]

Not only are there acknowledged threatened bird species in the area of the training range, the coastal area of the Olympic Peninsula is highly important to migrating birds on the Pacific flyway during the spring, late summer, and fall. Migrating birds would be affected by electromagnetic waves and loud sounds of aircraft. These birds would include shorebirds of all types, including geese, ducks, etc. Without additional studies, these could seriously compromise the intent of the Migratory Bird Treaty.

“ESA-Listed Birds
The impact from electromagnetic radiation is expected to be minimal, short term, and recoverable based on: (1) the source of electromagnetic radiation discussed in this EA does not expose wildlife species to constant radiation; in other words, no area of the project area is continuously saturated with electromagnetic fields because six of the emitters are mobile, and the stationary emitter is not constantly running; (2) beams of electromagnetic radiation (e.g., from EW training) may expose birds in flight to increased levels of radiation; however, the birds in flight would be moving through the area and potentially out of the area of the main beam, once again keeping them from continuous or long duration exposure (especially since non-soaring birds have relatively quick airspeeds); and (3) the beam pattern emitted is directional, which minimizes the area exposed to radiation. For these reasons, long term consequences to individual marbled murrelets and northern spotted owls or populations are not expected to result from proposed training activities. The proposed action does not cause direct or indirect changes that would have a considerable impact on the critical habitat in the Study Area. Therefore, electromagnetic radiation from training activities may affect but is not likely to adversely effect the marbled murrelet or northern spotted owl or their critical habitat.” [BIOLOGICAL RESOURCES 3.2-26]

There is no satisfactory indication in the EA on how the aircraft permitted activities would compromise the conditions for these birds. OPA argues this is insufficient to meet the objectives of NEPA.

The sites designated by the plan are on National Forest land. Some of which has been designated as protected areas for spotted owl and marbled murrelet. Marbled murrelets travel up to 50 miles from the forests on the coast to the sea to feed their young. Extensive flight training [up to for 12 hours a day, up to 260 days a year] in this area would disturb, perhaps eradicate, these threatened birds.

OPA argues that the discussion on Environmental Consequences in the EA is insufficient and inadequate for NEPA requirements.

GROWTH IN FUTURE TRAINING REQUIREMENTS
In its application for the Forest Service permit, the Navy EA says,

“1.3 PURPOSE OF AND NEED FOR THE PROPOSED ACTION
The purpose of the Proposed Action is to sustain and enhance the level and type of EW training currently being conducted by assets using the NWTRC, to provide the ability to accommodate growth in future training requirements, and to maximize the ability of local units to achieve their training requirements on local ranges”. [PACIFIC NORTHWEST ELECTRONIC WARFARE RANGE ENVIRONMENTAL ASSESSMENT, abstract prepared by United States Department of the Navy, Final (September 2014).]

In Boeing’s website description of the Growler [18G Airborne Electric Attack Aircraft] it says:
“Full Spectrum: The EA-18G's ALQ-218 wideband receiver combined with the ALQ-99 Tactical Jamming System will be effective against any radar-guided surface-to-air threat.
Precision Airborne Electronic Attack: Selective-reactive technology enables the EA-18G to rapidly sense and locate threats with a significantly higher degree of accuracy than was previously possible. This improved accuracy enables greater concentration of energy against threats.” [Boeing website 10/27/2014]

If the purpose of the Growler aircraft is to find and disable enemy electronic detection, then the proposed permit request, as written, only allows for testing the detection NOT the disarmament of the enemy equipment.

However, the phrase, “…to provide the ability to accommodate growth in future training requirements, and to maximize the ability of local units to achieve their training requirements on local ranges.” [Navy Abstract] This would indicate that further operation enhancement is possible under this permit and the consequences of that have not been included in this EA. OPA argues this is a violation of NEPA because it deliberately excludes activities, already in use by the aircraft, that should be examined as part of the NEPA process.

OPA argues that there is insufficient information being provided to determine that known activities and their consequences have been provided to insure the safety of all people, including Navy personnel, animals, birds, and fish would not be harmed by these enhancements and is therefore in violation of NEPA. The permit operation, as proposed in this EA, would only allow training for the detection NOT the disabling of the enemy equipment.

The public has been told, and the press has repeated, that the emitters from the tower and the mobile emitters would only be pointed straight up and therefore not damaging to people or animals on the ground. It was reported in the Seattle Times, “No threat to wildlife. The trucks would beam the signal upward, not 360 degrees around. The vehicles would be required to shut down if a logging truck stopped near them, or somebody was walking around.” [Seattle Times, Erik Lacitis, Oct 16, 2014]

OPA questions this declaration, as provided, and argues that it is insufficient under NEPA and therefore is in violation of NEPA. If people in the vicinity would require shutting down of the equipment, it would seem there is a perceived danger to those people and the Navy personnel operating the equipment. Further, if training is to include, now and in the future, the disabling of the enemy source of electromagnetic waves, then there would be additional energy waves pointed down from the aircraft. There is no discussion of this possibility and the consequences of such.

NAVY EA ELIMINATIONS FROM CONSIDERATION
The Navy EA states, “Certain resource areas were eliminated from detailed study in the EA because research revealed that the Proposed Action is unlikely to have any potential environmental impacts on these resources, or that impacts would be negligible. The resources that were not evaluated in this EA included geology, water, land use, cultural, transportation, socioeconomics, and environmental justice and protection of children.” [Executive Summary ES-2 SUMMARY OF IMPACTS]

OPA argues that the purpose of NEPA is to evaluate the project and provide proof that NEPA concerns are met. The applicant cannot make that decision by arbitrarily excluding resources. It is not for the Navy or Forest Service to make the subjective decision to exclude NEPA concerns.

The Navy EA has excluded the following important discussions:
• The navy has used socioeconomic reasons for the purpose of this permit but has not provided cost comparisons of the permit activities on the environment verses their claimed cost savings.

• The Navy has excluded discussion of land use of the permit activities verses the current use of the Forest Service lands.

• The Navy has removed cultural factors from the permit applications despite the fact that several tribal lands could be affected by the permit activities. Cultural also applies to traditional uses of an area by people. All people living, working, and touring in the area will be impacted by these activities.

• Protection of children was eliminated. Children are people and all people in the area of the training range will be affected by the activities governed by the permit.

LACK OF INFORMATION TO MAKE EA CONCLUSIONS
Further, OPA argues there is insufficient scientific information available to determine the dilatory effects of electromagnetic waves on humans, animals, and other living organisms. Yearly, millions of people and wildlife use the lands in the Olympic National Forest, Olympic National Park, and Olympic Coast National Marine Sanctuary all having land and waters located on the western half of the Olympic Peninsula. Humans, whales to amebae would be subjected to these electromagnetic waves without discrimination. Therefore, the activities allowed by this permit violate the Marine Mammal Protection Act and could harm humans, birds, vital insects like bees and other pollinators, and other wildlife.

Scientists declare the need for further study on the subject of the impacts of towers and emitting radiation on migratory birds. i.e. “This briefing paper addresses the need to cumulatively assess the impacts of communication towers on migratory birds both from collisions and radiation, especially neotropical migratory songbirds that are most impacted (Shire et al. 2000). The paper discusses some suggested research protocols needed to conduct a nationwide cumulative impacts analysis that would assess effects of tower collisions and radiation on avifauna and on other wildlife pollinators including bats and bees.” [Briefing Paper on the Need for Research into the Cumulative Impacts of Communication Towers on Migratory Birds and Other Wildlife in the United States Division of Migratory Bird Management (DMBM), U.S. Fish & Wildlife Service – for Public Release LAST UPDATED: April 17, 2009]

The travel of electromagnetic waves or noise cannot be stopped at Olympic National Park’s border nor the border of the Olympic Coast National Marine Sanctuary, nor the Washington Islands National Wildlife Refuges which were established by Theodore Roosevelt in 1907. The refuges include 125-acre Flattery Rocks, 300-acre Quillayute Needles, and 60-acre Copalis, stretching off-shore from Cape Flattery all the way south to Copalis, Washington. More than 600 islands, rocks, and reefs comprise the refuges. Together they provide nesting habitat for the majority of Washington’s seabirds.

Because there is insufficient knowledge about the effects of electromagnetic waves on living organisms, we ask that an Environmental Impact Statement (EIS) be provided for this proposal. We also submit that the procedure being followed for this proposal is in violation of the Endangered Species Act because of the admitted possibility of harm to two listed threatened species in the training range area.

OTHER CONCIDERATIONS
Furthermore, Olympic National Park is an International Biosphere Reserve. It was designated a World Heritage Site in 1981. This requested permit allowing these training activities would degrade the status of these designations because of the distraction of jet aircraft maneuvers and their noise that could be seen and heard within Olympic National Park.

DEGRADATION TO PENINSULA WILDERNESS
The activities that would come to the Olympic Peninsula as a result of the establishment of this training warfare range violates the purpose of The Wilderness Act of 1964 by invading the wilderness character of Olympic National Park and the designated Wilderness areas within Olympic National Forest on the west side of the Olympic Peninsula. 95% of Olympic National Park is designated wilderness. Airplane noise generated just outside of the park or the National Forest Wilderness Areas cannot be stopped at their border and therefore destroys their wilderness character.

“A wilderness, in contrast with those areas where man and his own works dominate the landscape, is hereby recognized as an area where the earth and its community of life are untrammeled by man, where man himself is a visitor who does not remain. An area of wilderness is further defined to mean in this Act an area of undeveloped Federal land retaining its primeval character and influence, without permanent improvements or human habitation, which is protected and managed so as to preserve its natural conditions and which (1) generally appears to have been affected primarily by the forces of nature, with the imprint of man's work substantially unnoticeable; (2) has outstanding opportunities for solitude or a primitive and unconfined type of recreation; (3) has at least five thousand acres of land or is of sufficient size as to make practicable its preservation and use in an unimpaired condition; and (4) may also contain ecological, geological, or other features of scientific, educational, scenic, or historical value.” [Wilderness Act 1964]

WILDERNESS VALUES
Wilderness is not a place locked up for the use of few. Wilderness’ multiple uses are invaluable to our nation, our people, our future, and therefore precious to us all. Wilderness makes our earth livable. Many of the wilderness areas on the Olympic Peninsula attracts many more people than can be accommodated without a permitting system for visitation.

In addition, native vegetation pulls pollution from the air and water; soils and plant roots filter the water. Trees and vegetation also serve to sequester carbon by using it -- trading the carbon dioxide in the air for oxygen. This reduces global warming and ocean acidification.

Wilderness holds nature’s storehouse of genes that may someday provide new cures for disease; new and healthier plants and animals for agriculture. Over 50% of medical pharmaceuticals currently come from nature.

Organisms in an ecosystem run the gamut from less than a cell-size to whale-sized mammals. All are necessary to the success of the system.

” …we humans often act as if we are totally independent of our environment, as if our driving thousands of other species to extinction, and disrupting the life-giving services they provide, will have no effect on us whatsoever.

“The fundamental truth is that biodiversity matters profoundly to human health in almost every conceivable way. The roles that individual species, and the ecosystems they make up, play in providing food, fuel and unique medicinal compounds; air, water and soil purification services; and natural regulation of infectious disease, to name a few, are critical to our health and survival. The loss of species as a result of human activity and the degradation of ecosystems ongoing around the world lowers the quality of the planet’s natural resources and destabilizes the physical environment. “[E.O. Wilson, Professor Emeritus and Honorary Curator in Entomology, Harvard University]

Further, “Ecosystems provide goods and services that sustain all life on this planet, including human life. If damaged, we cannot fully restore them, no matter how much money we spend.”

“Changes to the environment—be they from pollution, deforestation, greenhouse gas emissions, or other causes—ultimately affect the living world. Once we lose a gene, species, or an ecosystem, it is gone forever.”

“Wild species, like scientific laboratory organisms, may possess attributes that make them uniquely well suited for the study and treatment of human diseases. If these species are lost, they will take these secrets with them.”
[How Our Health Depends on Biodiversity; Eric Chivian M.D. and Aaron Bernstein, M.D., M.P.H; Harvard Medical School
and the Center for Health and the Global Environment M.D., M.P.H.

Additionally, wilderness provides wildlife habitat far better and less expensive than any zoo.

ALTERNATIVES
Olympic Park Associates argue that there are areas where the planned training could be done that would result in much less damage to the environment, people, and other living organisms.

We will ask that the Secretaries of Agriculture and Interior uphold their mandate under the Wilderness Act to provide protection of the Wilderness Areas on the western Olympic Peninsula from activities that would violate their wilderness character.

“…each agency administering any area designated as wilderness shall be responsible for preserving the wilderness character of the area and shall so administer such area for such other purposes for which it may have been established as also to preserve its wilderness character. Except as otherwise provided in this Act, wilderness areas shall be devoted to the public purposes of recreational, scenic, scientific, educational, conservation, and historical use.” [Wilderness Act 0f 1964]

“(4) Within wilderness areas in the national forests designated by this Act, (1) the President may, within a specific area and in accordance with such regulations as he may deem desirable, authorize prospecting for water resources, the establishment and maintenance of reservoirs, water-conservation works, power projects, transmission lines, and other facilities needed in the public interest, including the road construction and maintenance essential to development and use thereof, upon his determination that such use or uses in the specific area will better serve the interests of the United States and the people thereof than will its denial;” [Wilderness Act 0f 1964]

OPA CONCUSIONS
Olympic Park Associates argues that the stated purpose of this permit does not compare to the damage to the human and wildlife values of the Olympic Peninsula. The value to the people of the United States is far better served by not placing this warfare training range in the proposed location. As proposed it would cause significant economic and environmental harm to the people living on the Olympic Peninsula, and the many tourists that visit this area every year. Because this is federal land set aside for the benefit of all United States citizens, this proposal degrades those benefits to all citizens.

We, as people, have caused considerable environmental damage in the past because of our naive understanding of the effects of our activities on nature. We have introduced plants and animals to areas on earth where they become difficult to impossible to control. (i.e. rabbits to Australia, Kudzu to the Southern United States, African bees escape into the South American environment and spread, becoming “killer bees” in the Americas).

More study is needed before the proliferation of these training ranges are spread across the nation in the laudable attempt to save jet fuel and reduce away time of Navy jet crews from their families. A degrading of the environment could be more costly to all Americans, including the Navy personnel and their families, than the perceived savings of this training range.

Olympic Park Associates asks that the United States Forest Service not issue this permit to the Navy. At minimum, a full EIS is needed before this project proceeds. Our earth’s environment is our home; its degradation gives us all less to defend.

Sincerely,

Donna Osseward, President, Olympic Park Associates
13245 – 40th Ave NE,
Seattle, WA 98125