
The Navy has released its 2025
Draft Amended Analysis to Environmental Impact Statement for EA-18G “Growler” Airfield Operations at Naval Air Station Whidbey Island Complex, Washington, September 2018
From the Navy:​
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"The Navy prepared this amended analysis consistent with the U.S. District Court’s findings. Specifically, the amended analysis (1) updates GHG emissions calculations and explains the basis for those calculations; (2) clarifies and expands on the analysis of species-specific impacts on birds; (3) refines the analysis of the impact of increased operations on childhood learning and attempts to quantify the degree of impact to the extent supported by the best available science; and (4) reassesses whether relocating some or all of the “Growler” community to Naval Air Facility (NAF) El Centro is a reasonable alternative and provides a fuller explanation of the Navy’s reasoning for eliminating the alternative from detailed study."
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Read the Draft Amended Analysis here:
SDA Comment Suggestions for Members
April 18, 2025
Talking Points
1. Community Participation
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Opportunities for community participation, in all forms, were extremely limited by the Navy. The time frame for comments was too short. The time frame for communicating to the public from our groups about this process was sorely inadequate. The “meeting” options offered were inadequate with 2 “public meetings” held as open houses, both on Whidbey Island, and only one online “meeting” which appeared to be pre-recorded. The submission of comments has been the only true means of public input. Requests were made by both the Attorney General’s Office and the attorney for COER to add two more public meetings and to extend the comment period. There was no response by the Navy to these requests.
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2. Greenhouse Gas (GHG) Emissions
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What proactive measures can the Navy implement to prevent jet fuel contamination in our community, and what resources are available to support environmental cleanup if contamination occurs?
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Has the Navy conducted a cost analysis comparing the long-term environmental and health impacts of jet fuel contamination with the investment needed for improved fuel management systems, spill prevention technologies, and cleanup efforts?
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What measures are being taken to reduce GHG emissions and minimize the environmental footprint of Growler jet training exercises?
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Has the Navy explored sustainable aviation fuel (SAF) alternatives that could reduce GHG pollution without compromising performance?
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The operations at the OLF are largely <3,000 feet, as they are flight carrier landing practices (FCLPs). Alternative 2 increases the annual GHG emissions by 44%. What justification is there for adding the >3,000 feet emissions to the baseline? This reduces the increase to 25%, but does not represent the impact on the environment in question. It is a distortion of reality.
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What quantities of formaldehyde, phosphorus and other toxic additives are being released into the air during OLF operations? What is the impact of those releases on the population? What are the long term impacts of those releases? What does the Navy plan for mitigation of those releases?
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3. Particulates
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The Navy needs to estimate particulate emissions from Growler jet aircraft during practice at OLF and determine potential harm to Whidbey citizens. See report by TransportEnvrionment.org: “Can living near an airport make you ill?” Particulate emissions from low flying aircraft are an increasing concern and need to be addressed.
4. OLF/Ault Field and the 80/20 split
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The Navy estimates 80% of flights at OLF and 20% at Ault Field as a result of their latest ROD. What is the actual percentage difference between Growler practice flights at OLF versus Ault Field during the last year? What can be done to ensure that at least 20% of Growler practices occur at Ault Field?
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The splitting of operations 50/50 between Ault field and OLF would go a long way in mitigating – or at least spreading out the noise impacts of operational increases.
5. Safety Concerns
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There is concern for the potential of a Growler accident in the populated areas under flight paths 14 and 32 when the Growlers are practicing at OLF, especially with the two most recent Growler crashes in the past six months. OLF is directly neighbored by homes, farms, forest, and Whidbey Island’s main highway. This is not a safe training area and puts both pilots and civilians at risk of a deadly accident.
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The Growler’s F-18 airframe is one of the most accident-prone military airframes in existence. Between 1980 and 2014, the F-18 sustained 39 accidents; 22 crashes of the EA-18G and F/A-18 have occurred since 2000. Most recently, there have been two Growler crashes in the past six months - one which was deadly and both pilots were lost. Training over populated areas only increases risk and safety concerns.
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See a partial summary of incidents and accidents. Note that this partial summary does not include the two recent Growler crashes in eastern Washington State (Rainier) and California (San Diego). The F-18 Super Hornet platform has a mishap rate well above the average of all military aircraft. Given this history, Growler practice flights endanger schools, hospitals, homes, parks/play fields, and highways located near OLF.
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Most airplane crashes occur as a result of a near vertical descent. While the damage is extensive, it is usually confined to an area with a diameter of a few hundred yards. The Growler situation is quite different, as the damage can extend much further. Combine this with the Growlers’ high accident rate and pilots in training, and you have a significant possibility of a serious accident with major loss of life and risk of forest fire due to the surrounding trees at OLF.
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To provide an actual safety example, a malfunctioning Navy jet raised community safety concerns in Coupeville, WA, on May 31, 2023. Mid-afternoon, an EA-18G "Growler" jet, operating out of Naval Air Station Whidbey Island, was conducting FCLPs at the OLF when it developed engine trouble, creating an emergency situation. A resident waiting to turn onto Route 20, just north of the OLF runway, heard a loud and alarming metal-on-metal noise and looked up to see a Growler that appeared to be struggling in flight as it headed north from the OLF in Coupeville. Directly in its path were the county’s fuel storage tanks for its bus transit center. Nearby was Whidbey General Hospital, the only hospital on the island. Further, a West Beach Road area resident observed smoke billowing from the plane's engine. Fortunately, the pilot was able to get the jet back to Ault Field in Oak Harbor without crashing.
Another resident explained that when this jet began its practice session, it was the loudest jet she had ever experienced over the town and phoned the base about the noise level. Upon learning of the incident, this resident emailed the Navy asking, "Why would a Growler in trouble fly over the town, risking the two schools, the hospital and the County seat? Why did a pilot’s emergency procedures bring the plane over the most densely populated area in Central Whidbey?”
Citizens of Ebey's Reserve (COER) has previously revealed numerous shortcomings of the OLF. Had the OLF runway met the Navy’s own contemporary longer length requirements, the imperiled Growler pilot would have been able to land right there rather than put the town of Coupeville and the pilot at risk. The pilot would not have had to fly 20 more miles further to land at Ault Field in a disabled aircraft. This real example of jet training risks only increases concerns about the consequences of a crash.
The Navy owes people and the communities a detailed explanation as to how exactly and with what equipment and manpower the Navy has to respond quickly to an emergency of this type.
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Yet another safety problem is that a portion of SR 20 loops into the OLF’s Primary Surface (a protected area surrounding the runway), and the northern portion of the Clear Zone (extended protection area) is bisected by Patmore Road and Keystone Road which violates Navy requirements. These violations of the Navy’s own safety requirements puts civilians in harm's way and pilots in danger by causing them to make risky decisions in order to avoid the surrounding communities in the case of an emergency.
6. Birds
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As quoted in the Navy’s 2025 Draft Amended Analysis, successful breeding of the American white pelicans in nearby Padilla Bay has not been documented since 2017. The Navy made the decision to increase Growler jet operations by four-fold in 2018. Similarly, the Navy writes that “Over the years, many [tufted puffin] breeding sites formerly present in this area have been abandoned.” Has the Navy communicated with local Tribes, environmentalists, and ornithologists to consider possible changes to avian migration, presence, choice of breeding locations, and behavior in correlation to the Navy’s and Growler arrival and operational increases to the area?
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The Navy’s study only looks at state-listed birds, which represent a very small population of the birds in the area. The study appears to draw assumptions and conclusions from such old studies which seem to be not very relevant or at least limited in being able to apply to current conditions and draw meaningful conclusions. More current and relevant research must be done to provide a proper study of the bird populations in the area.
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The Navy cites studies from the 1970s and 1980s which are outdated. The personal computer industry did not begin until 1977 and monitoring equipment used for studies during this time period was extremely primitive compared to modern equipment available today. Throughout the Draft Amended Analysis, the Navy draws conclusions from old studies, but then states there is a lack of information. Additional taxpayer-funded studies with state-of-the-art monitoring and data collection equipment would likely provide meaningful and relevant, updated data allowing for informed decision making.
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The study used chickens to compare damage to hair cells and regrowth in a footnote. Domestic versus wild birds with potential for different physiologies provides a poor comparison of how they adapt to noise levels and apparent threats. A true study on the wild birds of focus and their actual reactions, impacts, and recovery abilities is needed to make this a proper Amended Analysis.
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The Navy’s conclusions regarding the American white pelicans are incorrect. The pelicans are known to strongly dislike people and noise such as fireworks and jets. At the Swinomish Channel, about 40 pairs of American white pelicans were breeding and nesting. They had established a colony, but 4th of July fireworks scared them off and they abandoned that colony for the rest of the breeding season. The Navy’s study is amiss in thinking the pelicans would not form a colony at Crockett Lake. If conditions were appropriate at Crockett Lake, as in no jet noise - there would be a good chance a colony would be established there. American white pelicans are not rare in this area of North Whidbey, as the study suggests, and like many other birds they are moving northward due to climate change. The pelicans are now being observed regularly in Skagit County. Using eBird, as the Navy did, has problematic issues as it is dependent on citizen scientists to be present in the area for sightings as well as inclined to report their sightings to the eBird site.
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Does the Migratory Bird Treaty Act (MBTA) not protect all birds in the area? Almost all birds except a few are protected from harassment and more under the MBTA. The Washington Dept of Fish and Wildlife has protection for most birds as well. Why are their laws not applicable in this situation? Some of the birds on the WA state “candidate species” list for consideration for listing are in the subject area(s). These birds should be studied now instead of waiting until their populations decline to the point of being endangered or sensitive. We need preventive rather than reactionary actions and the Navy has a duty to support these preventative measures as an environmental steward.
7. Childhood Learning
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The Navy claims the impact on childhood learning and reading comprehension on Whidbey Island can be mitigated through building insulation and closing windows. How is the Navy addressing the impacts on children’s health and focus during recess and at home while doing homework?
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What alternative flight paths or altitude adjustments could be implemented to reduce noise impact on residential and school areas?
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Can quieter flight maneuvers or modified training schedules be introduced to minimize noise during school hours and other sensitive times?
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How can the military collaborate with local schools to mitigate learning disruptions caused by jet noise?
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The Navy writes that “ongoing Growler operations have not to-date led to student performance dropping” and “at least some anecdotal data supports the conclusion that Growler operations have not caused detrimental learning effects at local schools.” Between 2018 when this data was gathered and 2025, has the Navy assessed the student performance changes since the increase in Growler operations? How does the Navy take into consideration the anecdotal data from students, parents, and teachers sent bi-monthly from Quiet Skies Over San Juan County which contains countless reports of disrupted learning and focus?
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The Navy should acknowledge that childhood learning is not limited to the classroom only, and should alter their training accordingly to foster a healthier learning environment for children. The Navy does acknowledge that childhood learning may be impacted within school buildings, but this analysis lacks any research acknowledging that childhood learning occurs outside of the classroom, including during recess time, extracurricular activities, and homework (American students spend 6.8 hours on homework a week on average). Growler jet operations can begin earlier than 9am, continue throughout the entirety of the day, and not end until past midnight. On days like this, there is no opportunity for children to learn in a distraction-free environment. According to two 2023 studies, it takes an average of 23 minutes to recover after a distraction. The Navy should acknowledge that childhood learning is not limited to the classroom and alter their training accordingly to foster a healthier learning environment for children.
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The Navy acknowledges that Alt 2A will increase the odds of negative impacts on students reading by 24% at Coupeville Elementary school. Both Navy and local families have children attending this school. The WHO recommends schools should not be located near airports, but in this case the Navy is bringing the negative impacts to the school. How can this be justified?
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The only study in the Navy’s document referencing military aircraft near an elementary school (S. Korea) showed significantly lower reasoning score results. The cited Ranch study showed increases in hyperactivity. Basner showed negative memory impacts. The Navy’s amended analysis points to much broader negative impacts than just reading on the students at Coupeville Elementary school. Since the implementation of Alt 2A, these impacts have been manifesting. Have the Navy contacted the school to inquire about changes in student learning and behavior since operations have increased? If not, are these children just considered collateral damage?
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8. Relocation
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The Environmental Impact Statement (EIS) or Development of Facilities to support basing US Pacific Fleet F/A-18e/f Aircraft on the West Coast of the United States was completed in May, 1998. Lemoore and El Centro were the preferred locations. NASWI was considered but eliminated. See image:

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What other options exist for the Navy to decrease the impacts on the Pacific Northwest region that have not been explored? For example, can Navy pilot trainees be deployed, short term, from NASWI to multiple bases for EA-18G Growler training?
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The Navy writes that by maintaining the single-siting of the Growler jets on Whidbey Island, service members and their families are not forced to relocate, their financial costs and relocation burdens are minimized, and, therefore, they have reduced stress and improved quality of life. How can the Navy equally prioritize consideration of the local community members, many of whom lived here before the Growlers arrived, who have been forced to relocate, endure their own financial costs and relocation burdens, and have increased stress and lower quality of life due to the Growler jet operation expansion and related impacts?
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What resources are available to support military families who face relocation due to base expansions or changes? Are there resources to support local community members who face relocation due to Growler impacts?
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Have alternative training locations with lower population density and environmental sensitivity been considered? If so, what are the barriers to utilizing those sites?
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Are there opportunities for regional cooperation where training exercises could be shared among multiple bases to reduce concentrated noise impacts in one location?
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Growler jet noise has been a concern of the community for some time and it has been formally acknowledged that the noise is disruptive. In an effort to protect our community, prevent the disruption of childhood learning, and have a viable Navy, what options are available for relocating the Growler training exercises to a less vulnerable area while maintaining local housing stability for military personnel and their families?
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What other training sites provide realistic carrier landing and takeoff conditions in a way that does not needlessly endanger pilots, civilians, schools, homes, hospitals, protected parks, and more?
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Is the Growler repair facility in California? If so, this should be factored into the cost of relocation. El Centro would be closer and require less fuel and perhaps increased efficiency.
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On page 62 of the Draft Amended Analysis, the Navy writes that El Centro is in a Clean Air Act non-attainment area (an area that exceeds pollution limits for one or more criteria pollutants), and home-basing the AEA community or any number of EA-18G Growler jets at NAF El Centro would have a greater impact to that region’s air quality and contribute to public health concerns. If basing any number of EA-18G jets at El Centro would contribute to unacceptable levels of air pollution then it can be certain that basing the entire AEA community at NASWI has a damaging effect to the air quality in Washington State. Rather than put this state at risk of becoming a non-attainment area as well, preventative measures should be implemented now to protect the safe air quality Washington currently has. Not only will this lead to healthier communities, it will also allow for NASWI to utilize the base more sustainably and be in compliance with air quality policies for longer.
9. General
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Is the Navy open to establishing a community advisory board to ensure ongoing dialogue with residents, educators, and environmental groups?
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Can environmental assessments be conducted more frequently to evaluate the impact of training on ecosystems?
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What data does the Navy currently have on noise pollution levels in affected areas, and how frequently is this data reviewed to assess changes or improvements?
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Are there updated noise-reducing technologies available for Growler jets that could be integrated to mitigate the noise impact?
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Can advanced flight simulators be used more extensively to reduce the need for live exercises in noise-sensitive areas?
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What is the Navy’s long-term strategy for balancing pilot training needs with community health and environmental stewardship?
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How can the Navy collaborate with independent experts to assess noise, pollution, and environmental risks — and share those findings publicly?
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How can the Navy work with local governments, environmental groups, and schools to develop proactive solutions that address community concerns?
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According to the Navy’s own safety standards, the OLF runway itself is unsafe. The 5,400-foot strip, built prior to 1943 to accommodate aircraft built in the 1940s, is nearly 3,500 feet too short for Growler jet FCLP operations, which require 8,800 feet. Given that the runway cannot be extended, why does the Navy continue to put its own pilots in danger by training them on an inadequate runway?
10. Navy Funding
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The Navy has been quoted saying it would cost $800 million to relocate the Growler jets? Is this still accurate? If so, how does this compare to the Navy’s annual funding at NASWI?
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How does the Navy plan to use funding towards monitoring their impact on the environment?
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How does the Navy plan to prioritize the health and safety for the environment and the communities they are training over in their funding plans?
The Navy only scheduled two in-person public meetings in Oak Harbor and Coupeville and one online meeting. They allotted an extremely short period of only 18 days to review the document before the first public meeting.
Please make CALLS TO our elected officials to:
1. Ask for a 1-month extension of comment period (to May 28)
2. Add Navy public meetings in Port Townsend & Lopez Island
WASHINGTON DC. CALL NUMBERS in order of priority:
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Sen. Cantwell 202) 224-3441
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Sen. Murray (202) 224-2621
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Rep. Larsen (202) 225-2605
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Rep. Adam Smith (202) 225-8901
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Rep Emily Randall (202) 225-5916
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Rep. Kim Schrier 202) 225-7761
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Rep. DelBene (202) 225-6311
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Rep. Marilyn Strickland (202) 225-9740
Additional details:
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A paper copy of the Draft Amended Analysis may be reviewed at 22 public libraries in the northern Puget Sound region. The full list of libraries may be found at the project website.
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The Navy prepared the Draft Amended Analysis to the 2018 Final Environmental Impact Statement and 2019 Record of Decision for EA-18G Growler Airfield Operations at Naval Air Station Whidbey Island in compliance with the National Environmental Policy Act and the orders of the U.S. District Court for the Western District of Washington.
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The Navy has announced two in-person and one online public meetings to inform the public about the contents of the Draft Amended Analysis, answer questions, and provide the opportunity to submit official written comments. All comments must be submitted electronically or postmarked on or before 11:59 p.m. PDT on April 28, 2025 to be considered in the Final Amended Analysis.
We are requesting a comment period extension for May 28.
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Thank you for taking ACTION with us
by making calls, reviewing the new draft, sending questions, attending the public meetings, and making comments!