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Statement of Opposition to Outlying Landing Field

by Ernest Marshall |

Statement of opposition by Sierra Club, Cypress Group, as entered into the Public Comments for the DEIS

Commander, Atlantic Division
Attn: Mr. Fred Pierson - Code BD32FP
Naval Facilities Engineering Command
1510 Gilbert Street
Norfolk, VA 23511-2699
Re: Navy Outlying Landing Field, Washington County, NC

Dear Mr. Pierson,
I wish to submit the following comments on the Draft Environmental Impact Statement for the proposed "preferred alternative" Outlying Landing Field (OLF) in Washington County. These comments are made on behalf of the North Carolina Chapter of the Sierra Club, including the Cypress Group region which incorporates Washington County. The 15,000 members of the North Carolina Chapter and especially the 1000 members of the Cypress Group of Sierra Club would be quite negatively impacted by the OLF. We regularly (almost every weekend) conduct outings in such areas as the OLF location. The noise generated by constant take-offs and landings by FA-18 Superhornets (conservatively estimated at 50-60 decibels) would utterly undermine the outdoor experience sought through these outings and render our program impossible. The EIS has not adequately addressed such an issue.

Sierra Club is only one of many groups who have come to rely upon the area for the proposed Washington County OLF for education, recreation, and as an economic resource. These uses are basically incompatible with the Washington County OLF. In recent years the economy of eastern North Carolina (the very region where your interest in OLFs now centers) has shifted to eco-tourism, guided/non-commercial hunting and fishing, retirement communities made up of those seeking a clean, noise-free environment, etc. These are resource uses that depend upon retaining an unspoiled natural environment. The OLF undermines quality of life and livelihoods in the area. The EIS does not sufficiently address these issues

The EIS does not sufficiently acknowledge the importance of the area (referred to loosely as "the East Dismal Swamp") impacted by the OLF is as a natural area. The site of the landing field is designated wetlands, and therefore quite sensitive to ground water pollution from jet fuel and exhaust and other environmental impacts. There are several land use areas which have been omitted from the Site 7 Map and the text. I will mention only some of the more important omissions. The OLF would be located in the Van Swamp Game Land, administered by the N. C. Wildlife Resources Commission. This is an important wildlife preserve. Also the OLF borders the Pungo Unit of the 111,000 acre Pocosin Lakes National Wildlife Refuge. The EIS discusses only impacts on deer and small mammal populations, neglecting the fact that the Pocosin Lakes National Wildlife Refuge is one of the most important areas for wintering Tundra Swan, Snow Geese and other waterfowl in the mid-Atlantic region. Furthermore, barely off your map to the north is 18,000 acre Pettigrew State Park, North Carolina¹s largest state park and the location of the state¹s second largest natural lake.

The environmental impacts on all of these areas as well as others would be significant. The Van Swamp Game Land is an important area for hunting Black Bear (18 bear taken last season). Black Bear hunting is big business in the Pamlico-Albemarle Peninsula. The area¹s economy, heavily dependent upon hunting, fishing, and eco-tourism, is extremely sensitive to adverse environmental impacts. Wildlife impacts not addressed by the EIS include Endangered and

Threatened Species. Bald Eagles are known to nest in the area, and Red-cockaded Woodpeckers can be presumed to nest there since they do so in similar habitats nearby. The Red Wolf is know to be in eastern Washington County. With an estimated 51,000 take-offs and landings per year serious impacts are to be expected on the wildlife at Pocosin Lakes National Wildlife Refuge, the Van Swamp Game Land, and elsewhere. The impacts of the noise level created by the OLF on human activity as well as wildlife is not sufficiently addressed by the EIS. This will hamper many activities even beyond the "noise footprint". As one of numerous examples, Public Schools in surrounding counties depend upon environmental education provided by Pettigrew State Park. For example, for an entire week every September about 1000 4th graders go through a nationally recognized program on Native American Culture which has to be conducted outdoors. The jet noise from the nearby OLF would be a major adverse impact. Because of these errors, omissions, and weaknesses in the EIS the North Carolina Chapter of Sierra Club strongly opposes the Washington County OLF.

Sincerely,

Ernest Marshall
Public Lands Coordinator Sierra Club, (Cypress Group)