From: WEE

To: W; W520; W
Co: _
Subject: Email to Wayne and our approach to the Growler termination
Date: ' Tuesday, December 04, 2018 3:18:00 PM
Importance: High

John,

I met with Reid this morning to discuss our initial next steps regarding the Growler termination. Our
immediate first step is to send Wayne an email with our approach and request for his approval. I
have drafted this text below in discussion with Reid, for your review; you should then finalize the
email and send to Wayne. Reid and Tom are at BLiVi this afternoon so l’m sending this to everyone.

Naval Air Station Whid bey Island (NASWI) is home to all Navy electrOnic attack (VAQ) squadrons
flying the EA—18G Growler aircraft in the U.S. The VAQ mission—related Navy functions have been
performed almost'exclusively at NASWI. in June 2013, the U.S. DoD Appropriations Act of 2014
added additional Growler aircraft and the necessary funding to- augment the Growler com_munity._ To
meet current and future mission and training requirements, the Navy has been analyzing numerous
scenarios since 2014, with the purpose and need relating to the:

o continuation and expansion of existing EA—lBG Growler operations at the NASWI, which
includes flight carrier landing practices by Growler aircraft Ault Field and Out Lying Field
Coupeville;
0 increase ofelectronic attack capabilities by adding.35 or 36 aircraft to support an expanded
DoD mission for identifying, tracking, and targeting in a complex electronic warfare
environment; I '
0 construction and renovation of facilities at Ault Field to accommodate additional Growler
, aircraft; and I I
«- stationing additional personnel and their family members at the NASWI and in the
surrounding community. - _ '

The ACHP elected to participate in December 2014 after the Navy announced it would need
additional Growlers in order to address current and future threats. Since that time, we have been
consulting with NASWI, the SH PO, the Trust Board of Ebey’s Landing National HiStorical Reserve
(Trust Board), NPS, island County Commissioners, Town of Coupeville, City of Port Townsend,
Washington State Parks, Seattle Pacific University, the Citizens of Ebey’s Reserve'(COER), and Mr.
David Day.

NASWI made its finding of effect in June 2018, that the increased, freq uentness of noise exposure
results in adverse indirect effects to characteristics of the Central Whidbey Island Historic District.
Although the effects are intermittent, the proposed undertaking would result in an increased
occurrence of noise exposure affecting certain cultural landscape components in the historic district
“specifically, the perceptual qualities of five locations that contribute to the significanceof the A
landscapes. The Navy finds no other adverse effects to historic properties from the propo'sed
undertaking.

Since June 2018 we have been in discussion on measures to mitigate the adverse effect since
avoidance and minimization are not an option due to the nature ofthe undertaking. There has been
tremendous pushback from the consulting parties (most notably the SH PO, Trust Board, Town of
Coupville, and COER) which resulted in the Navy thinking beyond traditional mitigation measures as
the historic property affected is outside the installation boundary. Even with the creative mitigation
being proposed by the Navy, the SHPO was unable to agree to a MOA nor was it willing to terminate
consultation. Due to contracting requirements, timelines established by the U.S. DoD Appropriations
Act of 2014, and the fact that it has stretched its mitigation capabilities to the limit, the Navy
decided to terminate consultation in order to bring this four year consultation to a close.

It is our recommendation that the ACHP address this termination through Chairman Comment by
developing comments on the undertaking and then circulating these comments to the Membership-
for consideration. This will be exactly like the process we undertook for the termination of the
Providence Viaduct PA. You shall consider any comments received from the Membership in
preparing the final comment document, which will then be transmitted to the agency official and to
the Membership. --

We are making this recommendation on the fact that:

s the ACHP has been involved in this consultation since the very beginning;
0 we have provided continual guidance and recommendations to NASWI and the SHPO;
. we would have signed a two-party agreement if the SHPO had terminated;
9 our thoughts on the undertaking and mitigation measures are well developed;
0 the holiday season is upon us and we are facing budget constraints.

It is my intention to send Reid and Kate to Whidbey island the week of December 17’Eh to conduct a
site visit and to hold a public meeting on your behalf. We will accept public comments via email
through the new year. 'And we anticipate a draft letter going to Membership no later than Monday,
January 7, 2019. The comments must be submitted back to the Navy no later than Monday, January
14,2019.

Again, this is based onwhat Reid envisioned forthe email.

Thanka

Kate

******************$***********************i*************

Katharine R. Kerr
 Program Analyst
Advisory Council on Historic Preservation
' Office of Federal Agency Programs

401 F Street, NW
Suite 308 _
Washington, DC 20001-2637
Phone: (202) 517-0216
Fax: (202) 517-6384
Email: kkm@aclmgox