NOTE: This story includes: links within the text to take you directly to pertinent documents and two side bar stories with additional information.
The time allotted for public comment on the Navy’s proposed electromagnetic radiation warfare exercises in the Olympic National Forest is set to close after November 28th 2014.
The time zone used on the USFS site appears to be Greenwich Mean Time, which is 8-hours ahead of Pacific Standard Time—keep that in mind if you are waiting until the last minute to comment.
In order to have standing to object to the USFS decision on granting the special-use permit, one MUST comment in the current period.
To make your voice heard, file comments online at:
Navy Warfare Training:
Coming to a National Forest Near You?
by Robbie Roberts
It is a dense, ancient landscape of crystal-clear waterfalls and pristine rivers; of trees alive when John Adams was elected the second President of these United Stated. Standing well over 100-feet tall, their broad, moss-covered branches shelter a stunning array of creatures: some endangered species, some endemic and found only in the forests of the Olympic Mountains. Over 300 species of bird are to be found here and an estimated billion birds fly their migratory routes annually along the coastline. Where the forest ends and the great Pacific begins, once locally extinct sea otters frolic in a forest of kelp, and only slightly farther offshore, the once nearly extinct gray whale may be glimpsed from March to May. In 2013, over 3 million visitors from around the world came to the Olympic National Park and National Forest to experience the unique environment of the only temperate rain forest in the continental United States, and the peace, solitude and sanctity it offers.
Today, the United States Forest Service is poised to grant the Navy their request for a special-use permit for war exercises in and above the Olympic National Forest of Washington state in their squadrons of EA-18G ‘Growler’ supersonic warplanes for approximately 260-days-per-year, 16-hours-per-day, flying as low as 1,200-feet above the ground, and working in conjunction with three RV-sized mobile electromagnetic radiation emitters on the forest floor.
While the legal process of application, public notification and deliberation required by the National Environmental Policy Act (NEPA) has been flawed by inadequate, inept and often contradictory communication from the USFS and the Navy–when news of the proposal finally trickled out, the public responded in overwhelming opposition.
Both principals seemed surprised, but unwavering. In Forks, Washington, USFS Ranger Dean Millett, who will make final decision, said, “The project seemed relatively benign and safe to me. I didn’t think anyone would care.” The Navy grasped at an old cliche and said, “They’re making a mountain out of a molehill.”
Is it a benign, fully disclosed project, as Millett believes? Or is the Navy’s Environmental Assessment (http://a123.g.akamai.net/7/123/11558/abc123/forestservic.download.akamai.com/11558/www/nepa/97011_FSPLT3_2346870.pdf) lacking in scope and simply wrong in its conclusions, as the opposition believes? Is it legal? And more broadly, is this a new use of the people’s national forest that will set precedent across the country, introducing an increasing, intrusive militarism into our unique and often fragile national parks and national forests where the public seeks peace?
We’ll examine the facts, offer links to important documents and hear from both sides. Then, you decide.
The History as We Know It
In or around 2011, Ranger Millet granted the Navy a one-year, special-use permit in the Olympic National Forest (http://www.fs.usda.gov/wps/portal/fsinternet/!ut/p/c5/04_SB8K8xLLM9MSSzPy8xBz9CP0os3gDfxMDT8MwRydLA1cj72BTUwMTAwgAykeaxRtBeY4WBv4eHmF-YT4GMHkidBvgAI6EdIeDXIvfdrAJuM3388jPTdUvyA2NMMgyUQQAyrgQmg!!/dl3/d3/L2dJQSEvUUt3QS9ZQnZ3LzZfS000MjZOMDcxT1RVODBJN0o2MTJQRDMwODQ!/?project=42759). “They wanted to see if the sites they’d selected to broadcast from worked,” he said, somewhat fuzzy on his recollections. “And I might have renewed it.”
The Naval Air Station on Whidbey Island, currently home to over 80 Growlers, is potentially adding 36 more, according to U.S. Fleet Forces Command spokesman, Ted Brown.
During the electromagnetic warfare training, trios of jets working together will depart NAS Whidbey, fly over the Olympic National Park and the Olympic National Forest in the Olympic Military Operation Area (MOA) airspace lanes at not less than 6,000-feet Mean Sea Level–which actually translates to 1,200-feet (Actual Ground Level) above the ground. In the MOA there are no speed restrictions on these supersonic aircraft.
The Navy has selected 12 sites in the Olympic National Forest to station their three RV-sized mobile emitters, which will generate electromagnetic radiation beams of various power at 18-GHz frequency. An additional three sites are located on land administered by the Washington state Department of Natural Resources, but to date the Navy has not applied for permission to use them.
In August 2014, Ranger Millett signed a draft decision notice to approve the Navy’s request and announced a 30-day comment period on the Navy’s Environmental Assessment in a newspaper in Aberdeen, Washington. No notices were placed in media in nearby Forks, Port Angeles, Sequim or Port Townsend, the communities beneath the flightpath and adjacent to the Olympic National Forest.
The Navy published notices in Seattle, Montesano and Olympia newspapers, but also neglected to inform the impacted Clallam and Jefferson County populations, who had no idea what was transpiring.
By September 2014 the Navy’s report, titled ‘Pacific Northwest Electronic Warfare Range Final Environmental Assessment’ was submitted. Because the Navy concluded there was a ‘finding of no significant impact’ (FONSI) on people or the environment by their warfare exercises, they were not compelled to produce a complete Environmental Impact Statement. Millett’s pen was poised to sign off on the project.
Then, someone eyeballed the USFS notice describing the Navy’s proposal tacked to a wall in the little Forks’ post office. All hell broke loose.
In short order, Millett canceled his preliminary approval and extended the comment period until October 10th, due to “renewed interest.” The comment period was extended again, until October 31st and then again, to the current end-date of November 28th. Informational meetings were held in Forks, Port Angeles and Pacific Beach.
The Honorable Opposition
Almost without fail, people voicing opposition to the Navy’s plans have noted that their stance is not against the Navy in general–far from it–but against Naval warfare in the people’s national forest. Few epitomize this more than numerous veterans who have spoken eloquently in passionate opposition, including former Naval Aviator Gene Marx. He trained as an Airborne Electronic Warfare Officer, flew sorties in Vietnam and eventually went to work for the Federal Aviation Administration. His son did tours in Iraq. Recently, Marx served on the Board of Directors of Veterans For Peace, a global organization with a permanent seat at the United Nations.
“When I was a young flyer in the 1970s, we were well aware of the potential damage to the environment,” he said. “We flew over the desert near Fallon, Nevada, for good reason. The Navy’s EA is sorely lacking new science regarding possible adverse effects on the environment–this is the noisiest, most polluting aircraft in their inventory. The noise alone at low altitudes would be devastating to wildlife. The Growlers have a lot of juice and are so sophisticated–they can shut down a city. These are electromagnetic war games on steroids above the Northwest’s most pristine wilderness.
“Here’s what they won’t tell you: all of this can be done on simulators, and for much less money and without all the environmental damage that will be done. But the Growler is a cash cow for Boeing and businesses in 44 states. Once the Navy has the aircraft, they’ll say have to use it. But I say: use a simulator!” Shannon Petitjean remembered her grandfather A.L. Petitjean. “He became a Naval Aviator in 1939 and flew missions in WWII. In 1979 he held the rank of Captain, USNR, when he fell to his death, climbing in the Olympic Mountains.
“He loved the mountains and the peacefulness of the forests. I want the Navy to know that I’m grateful for the men and women who serve, as my grandfather did, but that we also need to protect our national forest for generations to come. If this warfare harms small animals, flora and fungal systems–they aren’t in the Navy’s report–once the damage is done, it’s too late!
“My grandfather would roll over in his grave at the thought.”
And About the Noise …
Aircraft noise is not mentioned in the Navy’s EA. Yet the infamously noisy Growlers will fly in groups of three, often as low as 1,200-feet above the ground. They have no muffling system.
Recently, Whidbey Island residents filed a lawsuit after registering noise consistently above 110 decibels, the level where the National Institutes of Health believe permanent hearing damage begins. Realtors in the area must add noise disclosure statements to every real estate transaction. The Seattle Times reported that a Navy 2005 EA made island residents promises they didn’t keep (http://seattletimes.com/html/localnews/2022511067_whidbeynoisexml.html).
At the Port Angeles informational meeting, when asked why aircraft noise wasn’t addressed, Ranger Millett replied it was “not within the USFS’ jurisdiction.” But is that true when activity permitted by USFS on the ground results in the noise? These jets will be interacting with large Navy emitter vehicles stationed on national forest land.
Peter Larson, a private pilot who owns and operates Larson’s Timber Resource Management, said, “Using the working forest, I deal professionally with many governmental organizations and the USFS has absolutely the most stringent noise restrictions of all. Sometimes they’ll shut my operations down for months because they’ve deemed an area habitat–or potential or adjoining habitat–for certain species. Almost every unit of timber has some noise restriction. When I’m at a job site and those jets fly real low overhead, not only can’t I hear my machinery, I can’t hear what someone next to me is saying!
“So, why the double standard? The Navy’s permit opens the door to more flights and much more noise.”
The Fine Print
The Navy’s EA 2-7 states, “The activities of the Proposed Action center on two divisions of the EW, known as electronic warfare support (ES) and electronic attack (EA).”
Former Clallam County Commissioner Ron Richards, both an attorney and commercial fisherman, finds numerous deficiencies with the Navy’s EA, none less pertinent that the electronic attack training mentioned in the Navy’s proposal.
“The EA considers only radiation transmitted upward from their emitters, while the ‘electronic attack’ aspect included in their proposal would probably entail much more radiation directed downward towards the emitters, and thus people, wildlife and any living thing in their path. It’s folly to suggest they won’t test the attack capabilities of the Growlers–and this important issue needs to be addressed.”
At public meetings, the Navy stated that the emitters weren’t currently equipped to receive, however when pressed about future expansion of their project, they stated it was always possible.
In their EA conclusions of ‘so significance’ the Navy also ignored a 1994 UA Air Force report (https://electroplague.files.wordpress.com/2014/09/rf-microwave-radiation-biological-effects-rome-labs.pdf), on Radiofrequency and Microwave Radiation Biological Effects … which on pg. 18 states that “…nonthermal disruptions have been observed to occur at power densities that are much lower than necessary to induce thermal effects… [including] alterations in the central nervous eyetem and the cardiovascular system … exposure to low intensity radiation can have a profound effect on biological processes.” As any ‘google search’ can confirm, there are thousands of published scientific studies examining the negative impacts of electromagnetic radiation on life.
Additionally, at the Pacific Beach meeting, a Navy representative disclosed new information: the emitters will not be manned by Navy crew, instead, they will be operated by two defense contract employees.
The employees would drive the vehicle from the Navy base at Pacific Beach, station it at a site in national forest, construct a perimeter barrier and operate the complicated technology, including the electromagnetic radiation high frequency beam that is deadly if aimed at any living thing.
These non-Navy personnel–presumed armed–are tasked with watching the forest for large animal intrusion (small animals, birds, etc are not included). They will also confront hikers, hunters or anyone visiting the national forest to ‘persuade’ them to leave the area.
The Navy EA 3.1-2 states, “The mobile emitters (MEWTS) have controlled and action level environments in which personnel and the public must not be allowed to loiter, while outside a controlled or action level environment, personnel and the public would receive no harmful levels of electromagnetic radiation … Public safety or health concerns are minimized as the result of Navy precautions and because the general public normally does not have access to Navy-controlled areas.”
“It’s unbelievable that with planes in the air, these hired hands would halt a test and move an emitter elsewhere because a mushroom picker, for instance, wanted to remain,” Richards says. “More likely they’ll say, ‘Do you want to be arrested for interfering with a legally permitted Naval activity?’ There’s great likelihood that the Navy’s proposal will effectively close large areas of the national forest to public use.
“I believe the public has been intentionally deceived on this project by both the USFS and the Navy.”
Richards is planning to create a coalition to fight the project–among them, recreational users, realtors and land owners who face loss of land value and the many businesses that rely on tourists who visit the area.
Is it Legal?
For a quarter century the Forest Service Employees for Environmental Ethics (FSEEE) has worked for responsible stewardship of public land and a future that is both economically and ecologically sustainable. Executive Director Andy Stahl believes the Naval warfare training is an illegal use of national forest land.
“It’s completely inconsistent with the USFS National Forest Management Act, which is a legally binding document. The Memo of Understanding between the Dept. of Agriculture and the Dept. of Defense that Millett uses to support permission is subordinate to the management plan and it also states that if there are other military or private lands available for these exercises, the USFS must refuse. The Navy has not said that other lands are ‘unsuitable or unavailable’ only that it takes a bit more fuel to get there.
“Furthermore, Congress has never authorized the USFS to permit military use of national forests. Millett should deny the permit because it’s inconsistent with the forest plan and not a congressionally authorized national forest purpose, but will he? No.”
How will the FSEEE respond? “Sue.”
Impacts? Let Us Count the Ways
Karen Sullivan, a retired US Fish and Wildlife Service employee, has articulated many concerns.
“The Navy failed to fully analyze and disclose all potential impacts–direct, indirect and cumulative–on the public and the environment. There have been many violations of the NEPA procedure, beginning with lack of public notice to the entire Olympic Peninsula. The Navy also based their ‘no significant’ impact conclusions on old science, when many recent studies addressed the effects of electromagnetic radiation beams on everything from flora and fauna to migratory birds in flight. It’s a violation of NEPA for the Navy to dismiss environmental considerations it considers not meaningful or foreseeable during a NEPA process.”
Sullivan list of possible affects include socioeconomic impacts to communities from increased jet noise and air pollution, impacts to wilderness values in nearby Olympic National Park, analysis of multiple stressors on humans, endangered species, and other wildlife and analysis of chronic radiation effects on humans, wildlife and habitats.
The local Sierra Club and the Admiralty Audubon Society have both issued statements finding the Navy’s EA deficient and disagreeing strongly with their environmental impact ‘findings of no significance.’ At this date, there are 2440+ letters on the USFS NEPA comment website, almost all voicing opposition (https://cara.ecosystem-management.org/Public//ReadingRoom?Project=42759).
Comments will be accepted through the 28th November. (https://cara.ecosystem-management.org/Public//CommentInput?Project=42759)
Shawn Mcallister has lived on Lake Quinault for nearly two decades and works at a nearby resort. “People come from all over the world to experience our beautiful rain forest, to hike here–and to allow the peace and quiet surround them. Our ecosystem is unique and fragile.
“We won’t have jobs if people think this is a war zone. What about the resort owners, fishing and hunting guides and businesses that depend on tourism? This could change our lives forever. I just cannot understand why the USFS would allow it.”
And the Final Word
Our national forests are the people’s lands, set aside by Congressional Act for their benefit and recreation, for water, timber and other itemized uses, but Congress never authorized military use.
And while the Navy has sought to minimize the public’s perception of this project, their own EA tells another story about the scope of their intent. Once they’re on the ground with men and machinery, what precedent will this set for national forest lands across the country?
Thousands of letters on the NEPA comment website testify to the passion the public feels. Millett said he’s never seen anything like it. The public is speaking, but will the USFS listen?
At the Pacific Beach meeting, someone stood and said, “I guess we need to decide if we want our national park or we want another military training ground. Don’t they have enough? Do they really need this, too?”
Copyright Robbie Roberts 2014
The Big Picture
The Navy’s proposal to conduct warfare exercises on Olympic National Forest land is only a part of their plan for expanded war-training activities in the area the Navy calls their Northwest Training and Testing Study Area.
The Navy plans an increased use of explosives, sonar and mine warfare in Puget Sound and Hood Canal, the Strait of Juan de Fuca, off Indian Island near Port Townsend and in the Pacific off Washington’s northwest coast. Also included is the Olympic Coast National Marine Sanctuary, home to 29 species of sea mammal, which extends as much as 40 miles offshore along 135 miles of Washington’s Pacific shore.
Last January, the Navy issued a draft Environmental Impact Study (http://nwtteis.com/Portals/NWTT/DraftEIS2014/EIS/Northwest%20Training%20and%20Testing%20Draft%20EIS-OEIS%20Volume%201.pdf) And a final EIS is expected in December of this year.
Included are an increase of ‘sonobuoys’, of which there are 500+ already in local waters; some emit sonar signals, and some contain charges which, when exploded, emit loud acoustic signals.
The Navy’s EIS concluded that the sonobuoys might affect–but “not likely adversely”–our resident killer whale population, as well as several other species of whales, sea otters and harbor seals that call these waters home.
However, their conclusion flies in the face of a plethora of scientific studies the Natural Resources Defense Council cites, which state that “numerous mass strandings and whale deaths across the globe have been linked to military sonar use … By the Navy’s own estimates, even 300 miles from the source, these sonic waves can retain an intensity of 140 decibels–a hundred times more intense than the level known to alter the behavior of large whales.” (http://www.nrdc.org/wildlife/marine/sonar.asp)
Sea mammals use their complex hearing systems to communicate, navigate and seek food. Recent research has proven that whales abandon their feeding grounds in the attempt to flee sonar noise. (http://www.theguardian.com/environment/2013/jul/03/whales-flee-military-sonar-strandings)
In the Gulf of Alaska near Prince William Sound, the Navy plans five years of summer-long warfare exercises that involve two Carrier Strike Groups using high-frequency sonar, live missiles, bombs, guns, heavyweight torpedoes, new weapons systems and sinking ships.
The rich waters of that region nourish a wide variety of sea mammals: whales, dolphins, porpoise, sea lions, seals and otters. Some call it home, others migrate there each summer to feed, breed and shelter. The sea populations in the Gulf are at their peak precisely when the Navy will practice war in the same waters.
Initially, the Navy predicted almost 100,000 marine mammal “takes” there each of the five years.”Takes” is the Navy’s sanitized word for “kill” or “disrupt behavior to a point where behavior patterns are abandoned or significantly altered.”
When that number was met with a certain horror, the Navy went back to their computers, deleted a few zeros, and now predict approximately 50,000 sea mammal “takes” in the Gulf per year. (http://goaeis.com/Documents/SupplementalEISOEISDocumentsandReferences/DraftSupplementalEISOEIS.aspx)
On the USFS NEPA website, many comments on the electromagnetic radiation warfare proposal for the Olympic National Forest refer to something a five-star general said over 50 years ago, as he gave his farewell address as the 34th President of the United States:
“We must guard against the acquisition of unwarranted influence, whether sought of unsought, by the military-industrial complex.”
-Dwight D. Eisenhower