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

April 18, 2025

Talking Points

 

1. Community Participation

 

• 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?

 

• 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?

 

• What measures are being taken to reduce GHG emissions and minimize the environmental footprint of Growler jet training exercises?

 

• Has the Navy explored sustainable aviation fuel (SAF) alternatives that could reduce GHG pollution without compromising performance?

 

• 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.

 

• 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

 

• 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 

 

• 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?

 

• 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

 

• 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.

 

• 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.

 

• 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.

 

• 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.

 

• 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.

 

• 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

 

• 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?

 

• 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.

 

• 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.

 

• 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.

 

• 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.

 

• 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

 

• 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?

 

• What alternative flight paths or altitude adjustments could be implemented to reduce noise impact on residential and school areas?

 

• Can quieter flight maneuvers or modified training schedules be introduced to minimize noise during school hours and other sensitive times?

 

• How can the military collaborate with local schools to mitigate learning disruptions caused by jet noise?

 

• 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?

 

• 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.

 

• 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?

 

• 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

 

• 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: