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 w. L. Jones
1208 N.E. Parker Road
Coupeville, WA 98239

January 9, 1991

Admiral Frank Kelso

Chief of Naval Operations
Washington, D.C. 20370-2000

Dear Admiral Kelso:

The Town of Coupeville has passed a Resolution requesting

that NAS Whidbey move its accident potential zone outside the
city limits of Coupeville. Recent developments at NAS Whidbey
now make this request more urgent. These include:

1. Admiral Bremner has increased the accident potential

over the Town by 42% in 1990 as compared with 1989.

2. MAS Whidbey has resumed low altitude (300-500 ft.) fuel

dumping on Town residents.

3. The promised Environmental Impact Study is now over a

year late, $500,000 has been expended, and the Base
Commander says the quality of the study is so poor that
it cannot be released to the'public. The release
schedule has been pushed forward another 6 months.

The high accident potential over the Town of Coupeville and

a probable tragic accident can be prevented by suspension of
operations on runway 14 of the Coupeville Outlying Field. CNO
Priorities for Safety, and DOD policies for the environment would
support a decision to stop flying off runway 14. The needs of
the fleet do not dictate use of this runway.

Please review operations at NAS Whidbey with the objective

of improving safety by immediate suspension of low level training
flights going over the Town of Coupeville and into runway 14.

I look forward to your response to my concerns for the

safety of the historic.Town of Coupeville and all of its
residents. r -

Sincerely,

fa.
- a;

Councilman, Town of CoupRV&LFiia'

 DISCUSSIOH OF OPERATIONS
AT HAS HHIDBEY

V T .
H
was pas sed by the Coupeville Town Counc il
ti n 87-6
This Resolution
o
si ned
nd olu
Res b the hayor in April of 1987.
accident potential zones
.
req uestsO thaYt NAS H hidbey move all noise
of Coupeville and reduce the
outside the city limits n.
idential use within the Tow
consistent with full res Hay of 198 8, and
by the Tow n in
Resolution 88-2 was passed 6 and req ues ted
Resolution 87-
this Resolution reaffirmed Stu dy for
ironmental Impact
that the Navy perform an Env 8, the Base
0n Hay 10, 198
operations over Coupeville.
ised the Hayor of Coupeville
Commander, Capt. Sehlin, adv
ld be performed.
that an Environmental Study wou
rations over
Als oin 1988, Admiral Jackson reduced ope
96 in 1989, thus re-
Coupeville from 30,082 in 1988 to 22,5
by about 25%. Admiral
ducing accident potential and noise
ts follo w the cour se
Jackson also took action to make pilo
patterns.
rules and stay within the designated flight

REQUESTED ACTION.
August of
Since Admiral Bremner took command of the Ring in
eville from
last year, he has increased operations over Coup
sed the
22,596 (1989) to 32,080 (1990), which has increa
the
accident potential to the Town by about 42% and degraded
noise environment by a similar amount.

The promised Environmental Impact Study is now over a year

behind schedule, $500,000 has been spent, and the study is
reported to be of such poor quality that the Base Commander,
Capt. Waggoner, has accepted another 6 month delay for more
work. flany in the community have lost hope that the study
will ever be released, or if released, that it will be of
any value to the Navy or the Town of Coupeville.

On December 21, 1990, one of Admiral Bremner’s pilots flew

over the Town at about 300 feet altitude and dumped toxic
fuel on the Coupeville Animal Inn, endangering the Inn
residents and an "AS Whidbey instructor pilot who happened
to be at the Inn picking up his dog. It is clear that under
the current command, the risk of accidents and environmental
damage to the Town is becoming unacceptably high, and it is
time to respond to the Town's Resolutions by removing the
accident potential zone from the city limits. Suspending
operations on runway 14 would produce this result and this
action is requested beginning immediately. '
 '\ ' ‘ .
.u 3 av H
l. .| . At .| .l I \La '
.l l‘

Secretary of Defense Report to Congress (1990):

“The Administration is committed to protecting

the environment. and the Department of Defense
not only promotes. but seeks to be a leader in
environmental compliance and protection"

The Code of Federal Regulations. Part 775.3. Department

of the Navy:

“The Department of the Navy must act with care

to ensure, to the maximum extent possible, that
in carrying out its mission of providing for the
national defense. it does so in a manner consis-
tent with national environmental policies”

CNO Letter Dated 7 August 1990:

"Safety remains the number one peacetime

priority for Naval Aviation"

NAS Nhidbey AICUZ Report:

The East side of the Town of Coupeville has been desig-

nated by the Navy as Accident Potential Zone II and
Noise Zone III. Under accident potential the report
recommends not more than 2 dwelling units per acre.
Under Noise Zone III the report recommends no dwelling
units due to incompatibility with the noise.

Coupeville is a 100 year old historical town and a part

of the Ebey's Landing National Historical Reserve.
Many homes existed in what are now noise zones before
the Navy came to Whidbey Island. Therefore, it is the
Air Operations that are incompatible with the Town.

Island County Health Officer:

"People who live in the noise zones under the

flight patterns are definitely being adversely
affected by the noise"

"High levels of noise exact a toll on healthgwetfi_

by damaging hearing and by causing a vicious "
cycle of stress-related illnesses"
' ‘ *“ ~- ,i; .sr-ggyé
F. Accident Potential:
The National Transportation Safety hoard documents a l0”
' year fatal accident rate for the commercial Boeing
Model 737 aircraft as 0.04 fatal accidents per 100,000
hours flown. Commander Rich Wais of NAS Whidbey docu-
ments a fatal accident rate of 4.0 fatal accidents per
100,000 hours for the A-6, which is 100 times the
civilian rate for the Boeing 737.

I'USA Today” reports that there have been 2 crashes of

the Air Force C-S aircraft during its 22 year life and
a million flight hours. Commander Rich Wais documents
237 crashes of the A—6 during 2,100,000 flight hours
with 168 being non-combat.

Capt. David Waggoner reports that student A-6 pilots

are starting to practice night carrier landings over
Coupeville at 500 feet altitude with as little as 50
hours experience flying the aircraft.

While Admiral Bremner may consider the A-6 to be a

safe airplane because it only crashes a little less
than twice as often as an F-18, the civilian residents
of Coupeville, which are over flown almost every night,
consider the A-6 a very unsafe airplane because it
crashes 100 times more frequently than a reasonably
acceptable rate for civilian transport aircraft.

Reduced Demand for Runway 14 Operations:

During the calendar year 1990, a total of 33,833 FCLP

operations were flown including Ault Field and
Coupeville OLF. Approximately 16,000 of these were
flown off runway 14 at Coupeville 0LF. During 1991 it
could be expected that the number of required opera-
tions would be reduced and that this reduction would
support de-activation of runway 14. Some of the
factors that could reduce the tempo of FCLP operations
are as follows:

1) End of the Cold War;

2) Longer deployments for project Deaart Shield;

3) Reduced Marine pilot training;

4) Aircraft Carriers Coral Sea and Midway da-

commissioned;

5) De-activation of aquadrona VA-lSS and VAOfl142;

6) Poaaible da-activation of VA-128;

 7) Reduced funding for steaming time;

8) 300 student pilots to be dropped from the

Navy's pilot program.

RESPONSIBILITY FOR ACCIDENTS.

Given the CND's statement that "Safety remains the number
one peacetime priority for Naval Aviation", together with
the AICUZ accident potential and noise abatement assess-
ment for Coupeville, and the NAS Whidbey Safety Officer's
assessment of the A-6 accident rate potential, it is clear
to me and I hope to you that suspension of operations on
runway 14 is a reasonable and prudent action for prevention
of a terrible accident in the Town of Coupeville. If you
conclude otherwise, then I believe the Community and
possibly the Navy would hold Admiral Bremner personally
responsible for fuel dumping and any aircraft that crash
into the Town.

Copies to:

Mayor Bette Coyne

Admiral Bruce Bremner
Congressman Al Swift
Congressman Norm Dicks
Senator Brock Adams
Senator Slade Gorton
Vice Admiral Rudy Kohn
Vice Admiral Charles R. Larson
Congressman Tom Foley
Congresswoman Patricia Schroeder
Secretary of Defense, Richard Cheney
Mr. Arnold Punaro
Mr. Rudy de Leon
Secretary of the Navy, H. Lawrence Garrett III
KIRO TV - Attn: Military Affairs Editor
KDMO TV - Attn: Military Affairs Editor
KING TV - Attn: Military Affairs Editor
CBS Sixty Minutes - Attn: Don Hewitt
Seattle Post-Intelligencer - Attn: Ed fley
Whidbey News-Times — Attn: Gretchen Young
 tumult W
ATTACHMENT #2

nt30Lurzou as -‘:L

A RESOLUTION dealing with aircraft noise intensity and aircraft

accident potential zones within the Town of Coupeville.

ion 87 6
UHEREAS. the Town of Coupeville passed and approved Resolut
mitiga ting measures
on the 27th hr Npril.1987 requesting that the Navy adopt
limits and to limit noise
to reeove all accident zones from within the Town
f“"
uninhibited full residential
over Coupeville to Noise Zone I values consistent with
It," ‘

use.
ing
' UHEREAS, one year later. the Navy has not adopted any mitigat
ons over Coupeville by 37%
measures and in fact has increased flight operati
in 1988.
in 1987 and is further increasing operations by 17%
the
NHEREAS. the current level of flight operations exceeds by 59%
er. 1986.
level projected in the Navy AICUZ study dated the 30th of Septemb

HHEREAS. the current level of flight operations and associated noise

of a
and safety concerns are having a severe impact on the health and welfare
put no limit
number of the residents of the Town of Coupeville. and the Navy has
on further increases lin operations.

now THERFORE. be it RESOLVED ‘that the Town of Coupeville reaffirms

Resolution 87--6 and further requests that the Navy perform an Environmental
s
impact Study of Navy decisions leading to the increases of flight operation

over the Town of Coupeville and including projections of.the environmental

impact of further increases.

PASSED by the Town Council and APPRO VED by its Mayor this ZTA day

of May, 1988.

i ' .
. THE TONN or COUPEVILLE
'

£3v
. '" Mayor

/ Council Member

Ma:- / €074.41? Council Member

Lflm Z/éérdfi Council Member

Council Member

Council Member

ATTEST:
'
per

W fliri/WL Treasurer-Clerk
.
.
 ATTACHMENT #3

FUEL DUKPING REPORT

DATE: 12-21-90

TIHE: 3:00 P.H.

LOCATION: Town of Coupeville

Animal Inn of Coupeville
2451 Parker Road

DESCRIPTION:
to the Animal Inn on 12-21-90 to
A Navy Instructor pilot came Inn
pick up his dog. At that time an A-6 aircraft flew over the
e
The engine exhaust was visibl
very low at tree top level.
and
and he was tr ying to gain altitud
e and was out of the pattern.

"Run inside, he'

The Navy Instructor said to the Animal Inn owner,
is dumping fuel on us".

They went inside and later returned to the yard and could smell
kerosene fumes. The Navy Instructor tried to get the tail number
of the aircraft but could not see it. The incident was reported
to HAS Hhidbey.
 ill-£74m...—
ATTACHMENT if 4 7
ources
Part III Defense Res
ENVIRONMENT 2
____

EVIRONMENT es that en-

the subject of intense - Implementing management procedur
the
Environmental issues are iety and
t our soc sure the Department has the right peOple at
ncern among leaders throughou right place with the right training.
AdminiSt ration lS committed to
CE: world. The t
nt, and the Departmen Success
trotecting the'environme to be a These goals will not be easy to achieve.
tes, but seeks t fo-
of Defense not only promo tec-
nce. and pro will depend primarily on a multifaceted effor
Wenviron-mental complia cusing on seven critical elements: cultural
chan ge,
, DOD is working to
—iiron. Consistent with that aim C into all defense compliance, people, budget, training, com mun ica-
TriEorporate an environmental CthJ tions/public affairs, and improving relations
with
activities. regulatory agencies.
effort: pro-
Two primary objectives underlie this ter Major actions already under way include
an ex-
access to the air, land, and wa
tecting long-term tensive audit of environmental complianc e. Some
ability, and enhanc-
needed to sustain mission cap
ment. Toward 900 installations have been surveyed to date, and
ing the quality oflife and the environ more-than 8,000 potentially contaminated sites
of Def ens e has estab-
those ends, the Department have been identified. Another 7,000 sites on for-
:
lished six Specific goals merly used DOD prOperties are being reviewed.
and The Department seeks to correct all of these prob-
. Performing environmental impact analyses lems, but those that pose the greatest risk to public
the
conducting environmental planning early in health and the environment must receive priority
acquisition prOCCSS; for cleanup. The Department also is working to
.. Identifying resources to meet environmental re- reduce the use of hazardous materials and avoid
quirements using established programming and the generation of hazardous waste, as part of an
budgeting procedures; ongoing effort to achieve significant reductions in
.. Maintaining internal communication programs hazardous waste generation by 1992. Continued
that ensure DOD leaders and managers are emphasis in all other areas, such as air, water, and
aware of environmental requirements and exter- toxic substances, will enhance our total posture and
nal programs that provide communities infor- reaffirm our resolve to serve as a model of compli-
mation on DoD’s environmental activities and ance within the regulated community.
compliance efforts;
- Minimizing pollutants from DOD installations Environmental protection is an important part
and Operations worldwide; of the defense mission. As steward of nearly 25
. Maintaining feedback systems that ensure each million acres of public lands and billions Of dollars
organizational level has sufficient information to worth of facilities, the Department of Defense has
comply With DOD environmental requirements; a responsibility to conserve and restore the natural
and ' resources entrusted to it.
 ATTACHMENT #6

THE NAVY
DEPARTMENT OF ATIONSNAVAL OPER
OF THE CHIEF OF
OFFICE
20350-2000
WASHINGTON. DC IN neptv atria to

Bar SS4G/0U605037
7 August 1990

D. Burns
Mr. James ders
hidbey Islan fif“ ‘
President, W vironment “‘i T J.
En
for a Sound .
t O ff ic e B ox 773 9
\t ,.
Pos 9823
Washington
Coupeville,
Burns:
Dear Mr.
s at OLF
our letter conc erning flight op eration d to this
u for miral Kelso was
forwarde
ggzggviile. Ygur letter to Ad
ply.
office for re
concern in addressing
appre ciate your expression of Coupeville.
We sincerely ted with operations at OLF
asso cia this
problem ar ea s sued involving
issues actively being pur
are many
While there conducted with the
erat ions continue to be
facility, fli gh t op
safety 0 f our crews and
the surrounding
re ga rd fo r th e rt environment,
utmost h hazards exist in any airpo
Alth oug
com m un ity . tors associated with
t is ma de to minimize the risk fac
eve ry eff or
and requirements. Safety remains the
our tra ini ng op era tio ns
ion;
iority for Naval Aviat
number one peacetime pr
ntually be based
to the type of aircraft to eve
a5
A determination will be
and the training syllabus that
at NAS Whidbey Is land . The pro ces s use d to reach
required have yet to be determined lved and takes into account
invo
this determination is extremely on
the impact flight operations have
many factors, among which is all fac tors
the surrounding community. Careful consideration of
which is best for the Navy and
will, we trust, lead to a decision
the community.
interest in this
Thank you again for your comments and sincere
matter.

Sincerely,

0......”
DAVID N.
Rear Admi , U.S. Navy
Deputy As~ tant Chief of
Naval Operations (Air Warfare)
By direction of the
Chief of Naval Operations
 ’.

KW (
DEP ART MEN T or THE NAV .‘
no
NA VAL, All STATION wHIDOtY I‘Lg
TON 9.37..5m° v
04! MARIOI.VA§H1NO
11010 ' 3”
Ser AICUZ:St/ , 039
2 (“MW 1990 -

_
n Alexander
ent
uilding Departm
itiagg County B
9.0. Box 5000
Coupaville, WA 98278-5000

Dear Mr. Alexander:

Center
to the . ter
let from the Island County Permit
This respo nds of ‘ and
posal
.
of May 7, 1990, regarding the pro
nce on Parcel
for establishment of a re51de WA.
The site address is 11
63 5. -Dr., Coupeville,
(Ill!
Use Z ones (AICU
' Z) Update '
was
The Air Installation Compatible ava ilable at that time.
completed in 1986 and is based on data 'se
N01 Zone 3 and .
Accide nt
ty is in
Based on the study, this proper re51dential
Potential Zone II (APz-II). The AICUZ study suggests
hibited because it is not
develo ment in Noise Zone 3 be pro
IeveI§7'-"
compatible WIEE aircraft n01se
.
of resid ential . development in
With regard to the general issue ll-
APZ-II the AICUZ stud su gests a max1mum den51ty of 1-2 dwe
1nq units per acre, which may 5e increased under a FIannea Unit
Development (PUD).
on, including
Please advise if we may provide further informati
information on noise attenuation.

Sincerely,

STEPHEN ROTHBOECK
Deputy AICUZ Officer
By direction of the Commanding Officer

Copy to:
Island County Health Department
H. F. and Virginia Soderling
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 ATTACHMENT #9
_ 15

-
REVIEW OF lO-YEAR PERIOD
1968 THROUGH 1977
U.S. CERTIFICATED ROUTE AIR CARRIERS

Tge acciden
ears 196t 8record of the certificated route air carriers for the
through 1977, has been summa
rized in the following
aSt 1 iZS' E1) Accident rates by make and model, (2) types of accidents,“
c§;eg;:5es-of operation’ (4) causes or factors, and (S) sche
duled compared
£0 ngnscheduled revenue service .

Accident Rates by Make and Model

Accidents and accident rates by aircraft make and model used in 311
- operations of the U.S. certificated route carriers are shown in the fol—
,“ lowing table for the years 1968 through 1977. All aircraft makes and
models are not represented; however, the makes and models which appear
in the table accounted for 91 percent of the acc1dents and 97 percent of
the total hours flown in the 10-year period.

Accidents, Rates By Aircraft Make and Model

U.S. Certificated Route Air Carriers
1968 through 1977
C Accident Rates Per
3
100,000 Aircraft
Aircraft _ Accidents Aircraft Hours-Flown
Make and Model T0ta1 Fatal Hours-Flown Total Fatal
3-747 27 2 2,434,648 1.11 0.08
l 3-707 1/ 66 14 2] 10,319,643 0.63 0.11
-
B—7zo" 10 1 1,914,354 0.52 0.05
r 3-727 87 9 17,830,157 0.49 0.05
' 5-737 11 _;g ,__g,§26.640 0.44 0.04
L DC-8 54 4 6,086,927 0.89 0.07
00-9 42 11 2/ 8,419,724 0.50 0.11
00—10 10 1 " 1,589,693 0.63 0.06
L-lOll 10 1 , 812,405 1.23 0.12
L-188 6 2 546,881 1.73
_ 0.58
cv-sso, 600, 640 30 7 3/ 2,573,959 1.26
3' cv-880 0.25
‘5 1 687,067 0.75 0.15
% BAC 1—11 6 0 964,318
1 0.62 0.00'
DHC—6 5 2 168,872
’ F-27, FH—227 2.96 1.18
15 9 1,242,356 1.21 0.72
I YS-ll 5 0 449,111
t 1.11 0.00
M-404 2 1 385,809
; 5-61 0.52 0.26
__J§ _43 63,724 9.42 4.71
. '
_ .~

Total 454 70 60,697,599

.'**.w.

0.71 0.11
l] A sabotage accident which occurre
d September 8, 1974, is included in
-.-u

all computations except rates.

.
e 3/ Includes mid
. air collision accidents nonfatal to air
excluded 1n fatal accide carrier occupants,
nt rates.
 ATTACHNENI 410 ‘ ~

REST CONCERNING DAVIA TION SAFETY V

FACTS or INTETHE NNIDBEY ISLAN AREA
IN

. .mmy area military mishap rate (mishap: per 100,000 ilight

In
}fiuh:3 steadilv decreased over the last 10 years, from 8.0 in
now5
we, to 9 in 193?. The average rate for this period is 4.6.
.km-military aviation in the U S. for the same period had an
average mishap rate oF 6. a. decreasing {rpm 7. a in 1981 to 5.0
si:z months oi 1989.
throught the first

:3 Only 3 non-military personnel have been kill-d in an Ame

unshap, and only 1 in an EA-bB mishap. This cover: a period of
over 30 years. There has never been a civilian killld in an A-é
or EA 68 mishap in the whidbey area or by any aircraft flown out
of NAS whidbey. Nor has there ever been any personal property
damage due to an aviation mishap at Nhidbey.

3. Fatal accident rate for AélEAb for thl last {iVI yIarI was 3.3
'(I. fiz¥o§§§_6f 3.3 ior 5968). Civil aVian Han mainfainoa a 1.1
?a Ea I mishap rate *0 Efie same period.

T‘L 5. M;

_ ”*3"k
1;.

~ 3%\
‘I' It;_.. . .