Asserts that noise impacts are affected Define and why it “intermittency” by yet it never defines it is not relevant in Navy protection “intermittency,” or explains how or why. measures for its personnel but is relevant to civilians. Comment 4: JGL STUDY UNDULY FAULTED 28 Claims dismissal of the JGL noise study Claim is bogus as JGL studies as is unsupportable. validated. DEIS needs to accept “flawed” and use that important on-site data in evaluating single noise event impacts. Comment 5: EBEY’S RESERVE 33 Misconstrues an important finding of the Revision called for. National Park Service’s 2015 noise study. Low-frequency (LFN) of the Growler The impacts of LFN on visitor not addressed in the DEIS as an experience and damage to exacerbating impact on Ebey’s Landing historic structures needs to be Historic Reserve. LFN carriers much forthrightly addressed. further than other noise, and therefore traverses the full Reserve. Obfuscates credible understanding of the Revision called for. of the National Park Service’s 2015 noise study as related to impacts on visitor experience. Comment 6: PATH 14 versus 32 39 The 30% use projection for path 14 is This mistake must be corrected unrealistic and greatly understates the to reflect actual usage potentials DNL noise impacts for path 32. of 5% to 10%. Comment 7: SAFETY 44 Actual safety risks are only superficially This shortcoming needs judicious analyzed for FCLP operations at NASWI analysis, especially given the and OLFC. An effective solution to dispel Growler is much more likely to the FCLPs risks associated with crash than the Prowler. unchecked encroachment around OLFC is not presented. Comment 8: FAA ELEVATION RULES IGNORED 52 FAA rules, as related to FCLPs, have not DEIS needs to explain how it been properly addressed in the DEIS. intends to operate at OLFC
Asserts that noise impacts are affected by “intermittency,” yet it never defines it or explains how or why. Define “intermittency” and why it is not relevant in Navy protection measures for its personnel but is relevant to civilians. Comment 4: JGL STUDY UNDULY FAULTED 28 Claims dismissal of the JGL noise study as “flawed” is unsupportable. Claim is bogus as JGL studies validated. DEIS needs to accept and use that important on-site data in evaluating single noise event impacts. Comment 5: EBEY’S RESERVE 33 Misconstrues an important finding of the National Park Service’s 2015 noise study. Revision called for. Low-frequency (LFN) of the Growler not addressed in the DEIS as an exacerbating impact on Ebey’s Landing Historic Reserve. LFN carriers much further than other noise, and therefore traverses the full Reserve. The impacts of LFN on visitor experience and damage to historic structures needs to be forthrightly addressed. Obfuscates credible understanding of the of the National Park Service’s 2015 noise study as related to impacts on visitor experience. Revision called for. Comment 6: PATH 14 versus 32 39 The 30% use projection for path 14 is unrealistic and greatly understates the DNL noise impacts for path 32. This mistake must be corrected to reflect actual usage potentials of 5% to 10%. Comment 7: SAFETY 44 Actual safety risks are only superficially analyzed for FCLP operations at NASWI and OLFC. An effective solution to dispel the FCLPs risks associated with unchecked encroachment around OLFC is not presented. This shortcoming needs judicious analysis, especially given the Growler is much more likely to crash than the Prowler. Comment 8: FAA ELEVATION RULES IGNORED 52 FAA rules, as related to FCLPs, have not been properly addressed in the DEIS. DEIS needs to explain how it intends to operate at OLFC
All-COER-Comments.docx