JOE A.

KUNZLER COMMENTS ON THE SECTION 106 MEMORANDUM

OF AGREEMENT (MOA) RE: EA-18G GROWLER AIRFIELD OPS EIS

[Word to the wise: Document is written to be printed double-sided and lay flat. Thanks.]

JOE A. KUNZLER SECTION 106 ON THE EA-18G GROWLER AIRFIELD OPS

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COMMENT LETTER - SUBMITTING FOR CONSULTATION 2018-10-25
 25 October 2018

Commanding Officer Captain Matthew Arny, USN,

NAS Whidbey Island,
Attn: CRPM
1115 W. Lexington Dr
Oak Harbor, WA 98278
NAVFACNWCR@navy.mil

Dear Captain Arny;

Attached is my commentary on the Memorandum of Agreement (MOA) regarding security
EA-18G “Growler” Airfield Operations. Thanks to you and your Cultural Resources Manager Kendall
Campbell for the opportunity to comment on this draft. Please accept these comments to have
your staff address and get back to me please as appropriate. We have a post-COER world to shape
– and time is acute as we feel the hand of history upon our shoulders while Team Whidbey works.
I also read, “The Navy will update the draft as consultation continues to provide the public
opportunity to express their views on resolving the adverse effects of the undertaking.” Good, I
hope these comments trigger more than one update.
Very respectfully;

Joe A. Kunzler
growlernoise@gmail.com

JOE A. KUNZLER SECTION 106 ON THE EA-18G GROWLER AIRFIELD OPS

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 TABLE OF CONTENTS
Joe A. Kunzler Comments on the Section 106 Memorandum of Agreement (MOA) RE: EA-18G Growler
Airfield Ops EIS ........................................................................................................................................................................ 1
Table of Contents .................................................................................................................................................................... 3
Introduction .............................................................................................................................................................................. 4
Some General Acute Thoughts ............................................................................................................................................ 4
General Thoughts on the Draft MOA ................................................................................................................................ 4
Need A New Whereas for History of OLF, Please.................................................................................................... 4
Stipulation For Landscape Preservation......................................................................................................................... 4
Cultural Landscape Inventory .......................................................................................................................................... 5
Southern Gateway .............................................................................................................................................................. 5
Historic Preservation Easements .................................................................................................................................... 5
Navy Volunteer Collaboration ........................................................................................................................................ 5
Boilerplate Signature Pages ............................................................................................................................................... 5
Concluding Thoughts ......................................................................................................................................................... 5
What If This Agreement Requires More Resources? ..................................................................................................... 5
Museum Quality Exhibit Why OLF................................................................................................................................. 5
Sign on OLF Coupeville Property Advertising the OLF ............................................................................................ 5
Up the Investment in Easements and Eminent Domain? ........................................................................................... 6
Concluding Thoughts .............................................................................................................................................................. 6

JOE A. KUNZLER SECTION 106 ON THE EA-18G GROWLER AIRFIELD OPS

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 INTRODUCTION
I appreciate very much the opportunity to comment on the Draft Memorandum of Agreement
(MOA) on an expansion of EA-18G “Growler” Airfield Operations, Naval Air Station Whidbey Island, Island
County, Washington to traditional Field Carrier Landing Practice (FCLP) levels. I am going to be acute and I
need to mention at the outset, I am on the outside looking in with a very limited timetable to comment so I
cannot expect a timely response to a public records request of discussions to clarify things so please be
patient with me consulting parties and concurring parties – you may know something I do not. Ultimately, I
perceive this MOA is being done by to Paul McCartney’s “Band on the Run” with limited resources, and my
comments will reflect this.

SOME GENERAL ACUTE THOUGHTS

Below thoughts do not pertain to the MOA document itself. Therefore, posting here for discussion:

• Very happy to see collaboration between the US Navy, DAHP and Ebey’s NHR leadership
• Displeased neither Oak Harbor Navy League nor PBY Memorial Foundation are concurring
parties while COER is a concurring party. Also pleased Ebey’s NHR leadership is at the table.
• Feel the final MOA could have the Island County Commissioners vote on to approve; there’s
your public hearing COER/Sound Defense Alliance assuming your members can behave. My issue
is security for all participants, period.
• Again, I am on the outside looking in with a very limited timetable to comment so I cannot expect
a timely response to a public records request of discussions to clarify things so please be patient.
There you go.

GENERAL THOUGHTS ON THE DRAFT MOA

Need A New Whereas for History of OLF, Please
Moving forward into the MOA itself, I went over the “Whereas” intro of the MOA and was displeased
at the lack of reference to the history of Outlying Field Coupeville (OLF). So, I am going to suggest one
based on my historical research1:
WHEREAS, Navy has been using OLF for Field Carrier Landing Practice (FCLP) since
1943 and jets such as all version of the A-6 Intruder, variants of the A-3 Skywarrior,
all versions of the EA-6B Prowler, and all versions of the EA-18G Growler since
January 5, 1967 as documented in the January 26, 1967 Whidbey News-Times. The
Navy intends during the Undertaking to increase to historical norms of FCLP use at
OLF, an increase with effects on Ebey’s Landing National Historic Reserve (ELNHR).
My point being: Using OLF for jet FCLP is 100% normal. Please document in your MOA. Thanks.

Stipulation For Landscape Preservation

As to the stipulation for landscape preservation, I am not too sure this is really going to be helpful. I
do not feel having watched many beautiful Field Carrier Landing Practice (FCLP) periods at OLF Coupeville
that FCLP is going to do anything to the terrain of Central Whidbey. If this is to retrofit historic buildings,
then I support this gift of peace to that specific end.

1
One can review the 1967 Whidbey News-Times article at https://bit.ly/2OMlwuo.

JOE A. KUNZLER SECTION 106 ON THE EA-18G GROWLER AIRFIELD OPS

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 Cultural Landscape Inventory
This quite frankly from the outside looking in I perceive as an Ebey’s NHR responsibility, so if Ebey’s
NHR is so under resourced as to require this level of NAS Whidbey Island help – I have an expectation as a
taxpayer paying for this that the tone towards NAS Whidbey Island please change from Ebey’s NHR
supporters. Thank you.

Southern Gateway
I am very happy with the current draft MOA as to, “The design, construction, and installation of a
southern gateway entry sign to the ELNHR”. I feel having, “The gateway exhibit referencing Navy history
and/or current aviation use at Outlying Field Coupeville with the goal to provide context to visitors explaining
the presence of Navy lands and aircraft in the ELNHR” is a means of healing between Ebey’s NHR & Navy
supporters by presenting and publishing historical truth.

Historic Preservation Easements

I feel historic preservation easements is a very relevant effort at genuine mitigation and should be
eagerly supported. This is a good tool of land use reform alongside Accident Potential Zones or APZs. I
hope this element will also receive Ebey’s NHR support, Congressional support and such please.

Navy Volunteer Collaboration

No comments on this for personal reasons. Thank you.

Boilerplate Signature Pages

Uh um, the boilerplate signature pages all date back to Barriergate days. As in, “THE SECURITY
ENHANCEMENTS AT OUTLYING LANDING FIELD COUPEVILLE, NAVAL AIR STATION WHIDBEY
ISLAND, ISLAND COUNTY, WASHINGTON”. Seems worth prompt fixing, eh?

Concluding Thoughts
I generally am happy with the Draft MOA. Seems to strike the right balance. But…

WHAT IF THIS AGREEMENT REQUIRES MORE RESOURCES?

After reading a story published late on 23 October 2018 on the Whidbey News-Times website2 and
some additional research, it seems some seek to acquire more resources for mitigation. OK then, I am happy
with the current agreement as it stands – and documented why. But if the other parties – some neutral,
some anti-OLF – seek more resources… this is my response to making investments to reward the pro-OLF
community for some balance:

Museum Quality Exhibit Why OLF

For pro-OLF balance to those new resources to appease Ebey’s NHR; let’s start with having NAS
Whidbey Island prepare by 2021 a museum-quality exhibit why OLF to take on tour. Seems only appropriate.

Sign on OLF Coupeville Property Advertising the OLF

No seriously. Stick a big laminated sign saying, “Please enjoy A sound of freedom – EA-18G Growlers
doing Field Carrier Landing Practice for all the other sounds of freedom like news, debate and family.” Then
post the schedule and squadron bouncing below it. Make sure there is a community consultation process!
There. I do not expect any more noise disclosure litigation after that.

2
www.whidbeynewstimes.com/news/navy-seeking-public-comments-on-ea-18g-growler-impact-on-historic-properties/

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 Up the Investment in Easements and Eminent Domain?
Furthermore, the Navy could always up the investment in easements and eminent domain. Why?
Let’s start with one of the consulting parties in the Town of Coupeville who wrote earlier this year our local
Congressional Delegation among other requests;

• A commitment from the Department of Defense and the Department of the Navy to work with
Congress and Washington State to obtain mitigation funding for sound retrofits to existing
buildings in Central Whidbey.
• A similar commitment for mitigation funding to purchase property from existing property owners
who need to leave the Central Whidbey area because of significant noise increases.
I agree with these requests, obviously. In part because I lobbied the Washington State Board of Health and
the Island County Board of Health to really take a hard look at land use reforms in the wake of COER’s
complaints about health issues. Well, Island County Commissioners serving on the Island County Board of
Health in their deliberations explored land use reform ideas but decided not to do much. Since COER was
unsatisfied with the Island County Board of Health’s rejection, they went to the State Board of Health. Only
to find the State Board of Health was unable to act and two Board Members on their own recognizance
recommended the following according to a transcript made of the August 2017 meeting:

• I want to point out that the Island County Board of Commissioners and Island County Board of
Health have it within their power to address some of these issues if they so choose to do that.
Their decisions to allow building to occur around aircraft have contributed to this. So, I'm not
going to let them off the hook for that.
• The plan B and C are not health regulation but growth management, what do we do with growth
management and engaging the representative and senators who represent Island County to work
with Department of Defense to move this up in their priority.
My point being: The world would be a better place with more Central Whidbey easement investment, period.

CONCLUDING THOUGHTS
A day like today, it’s not a day for sound bytes really. We can leave those at home. But I
feel the hand of history upon our shoulder in respect to this, I really do. I just think we
need to acknowledge that and respond to it.
Tony Blair, Former British Prime Minister
Somehow the above Tony Blair quotation seems appropriate. This MOA is hopefully being negotiated
to bring Ebey’s Reserve and OLF Coupeville together, not to further divide supporters of both. I generally
support the current Draft MOA as I consider me a lukewarm supporter of Ebey’s NHR and hearty supporter
of OLF Coupeville – and feel a balance must be struck.
I ask all consulting parties and all concurring parties – hereafter you – please be serious, recognize
you can make peace with Kendall Campbell or you can abuse this process to keep waging community conflict.
I ask you take those longstanding conflicts regarding FCLP at OLF elsewhere as Kendall’s ally and as someone
who should be more on the receiving end of your anger as I am a dirtbag political activist and not a career
professional public servant with kids at home who may or may not know their mom IS a hero. I suggest you
make peace and understand if you ask for more so will I. If some of you want to roll the dice; then the stakes
will up for the Ebey’s NHR we all seek to protect… and I do not seek that. Thank you.

JOE A. KUNZLER SECTION 106 ON THE EA-18G GROWLER AIRFIELD OPS

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COMMENT LETTER - SUBMITTING FOR CONSULTATION 2018-10-25