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Over the course of the past six years, the primary focus of Citizens Concerned About
Jet Noise (CCAJN) has been the widely-acknowledged adverse impacts
of jet aircraft noise and accident risk. While these two issues
remain a primary focus of CCAJN, the Navy's Environmental
Impact Statement clearly indicates that increased aircraft air
emissions that will result from siting Super Hornet aircraft
at NAS Oceana is a cause for equal concern and demands equal
attention.
Unfortunately, neither CCAJN, nor the media or elected
officials have, to this point, satisfactorily addressed this
issue. For its part, CCAJN will be working to correct this
awareness deficit and hopes that the media and elected officials
will soon treat Super Hornet generated air pollution in a responsible
manner.
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Jet aircraft exhaust contains
high levels of Volatile Organic Compounds (VOCs) and Oxides of
Nitrogen (NOx). These
two air pollutants, when acted upon by sunlight, chemically react
over time to produce ozone. Prevailing winds disperse these pollutants
and often cause areas as far away as Hampton, Suffolk, and the
Eastern Shore to be as severely ozone-impacted as areas near
NAS Oceana and NALF Fentress.
The Environmental Protection Agency (EPA) describes area ozone
generation and migration at its website: http://www.epa.gov/airnow/mapselect.html.
For example, on July 17, 2002, the Virginia Department of Environmental
Quality (VDEQ) recorded the highest unhealthy ozone level for
the year in this area. When you open this link you will see red
areas indicating unhealthy air quality. Note that an area of
unhealthy ozone originates over Virginia Beach and, over time,
expands to include areas remote from Virginia Beach.
Ozone, itself, has both a good and bad character. In the
upper atmosphere, ozone protects us from harmful solar radiation.
However, when it is produced near ground level, it is recognized
as a potentially serious health hazard by the EPA.
Ozone is a respiratory tract and lung irritant. Symptoms
range from nose and throat irritation to coughing, breathing
difficulty, and chest pain. Other toxic effects include
changes in blood chemistry, liver function, nervous system response,
visual acuity, and susceptibility to infection. EPA-recognized
studies show that high levels of ground-level ozone are associated
with 10-20 percent of summertime respiratory-related hospital
admissions.
Further, EPA has concluded that ozone can aggravate pre-existing
respiratory conditions such as asthma, and long-term exposures
to ozone can cause repeated inflammation of the lungs, impairment
of lung defense mechanisms, and irreversible changes in lung
structure, which could lead to premature aging of the lungs and/or
chronic respiratory illnesses such as emphysema and bronchitis.
Children and the elderly are most at risk. See: http://www.epa.gov/ttn/oarpg/naaqsfin/o3fact.html.
The VDEQ is the state agency responsible for ensuring that
the public is adequately protected from ozone pollution by monitoring
the emission of primary pollutants, restricting emissions to
levels that will maintain a healthy environment, and for enforcing
appropriate EPA regulations. Ozone concentrations are measured
in parts per million (PPM). Two federal criteria establish maximum
air quality ozone threshold conditions above which air is considered
unhealthy. These are: 0.12 PPM of ozone for a one (1) hour period
and 0.08 PPM of ozone for an eight (8) hour period.
According to the VDEQ, in 2002 to date (Note: before the arrival
of any Super Hornets), one or both of these threshold criteria
were exceeded a total of 41 times resulting in unhealthy ozone
levels in this area in violation to federal and state regulation.
http://www.marama.org/ozone/2002/browsePA.idc?area=Hampton+Roads.
In 2001 there were 9 such violations.
The Hampton Roads Region was an EPA-designated non-attainment
air quality region until 1997 when it was re-designated as an
"attainment area subject to a Maintenance Plan" after
demonstrating that measures taken to improve air quality had
been effective. The VDEQ prepared the Maintenance Plan that established
air emission budgets for NAS Oceana, effective through 2008.
To accommodate the anticipated arrival of 156 Hornet aircraft
from NAS Cecil Field, the VDEQ authorized an increase to the
NAS Oceana air emissions budget for VOCs.
Specifically, NAS Oceana was permitted to increase VOC emissions
by 200 tons from 319 tons per year to 519 tons per year.
The 519 ton per year allocation was to remain constant through
2008.
After the arrival of Hornet aircraft in late 1998, however, Clean
Air Act violations have become increasingly frequent.
In October 2001, the EPA advised the VDEQ that the Region
failed to meet EPA air quality standards and directed the
VDEQ to prepare a Contingency Plan by October 2002 that would
implement measures to bring the Region into compliance with the
Maintenance Plan.
And, as can be seen by the data for 2002, the situation is getting
much worse.
Thus, it is clear that instead of ensuring that public health
was adequately protected, the VDEQ short-sightedly authorized
increases in pollutant budgets at NAS Oceana that virtually ensured
that the quality of the Region s air would become increasingly
unhealthy.
Even more alarming, the Navy acknowledges that siting all
the Super Hornet aircraft at NAS Oceana, even with an Outlying
Landing Field, will increase VOC emissions by more than 136 additional
tons (total 951 tons/year) annually relative to a new 2000 Baseline
of 815 tons per year. This new Baseline itself, however,
exceeds the VDEQ authorized emissions budget for VOCs by an astonishing
296 tons per year.
This enormous increase is explained in the DEIS as a result of
differing computational methods employed by the Navy and the
VDEQ. The establishment of a new baseline, however, may indicate
that the Navy has routinely exceeded its VOC emission allocation
for several years and therefore been a significant factor in
the inability of the Region to meet the clean air objectives
of the VDEQ Maintenance Plan.
Further, it appears that despite the fact that the VDEQ limited
the Navy in 1997 to a VOC emission budget of 519 tons per year
level thru 2008, the Navy apparently is prepared to ask the
VDEQ to increase its budget, not by 136 tons per year, but by
432 (136 + 296) tons per year..
The DEIS indicates that the Navy would exceed the de minimis
level for VOCs by 36 tons per year (36%) under the "Bring
em All" scenario(Alternative 1) and using the 2000 Baseline
emissions budget. [Note: The de minimis level for VOCs for Oceana
is 100 additional tons per year.] In actuality, however, the
alternative that would site all the East Coast Super Hornets
at Oceana appears to exceed the VOC de minimis level by
332 tons per year or by 332%.
These facts beg several questions:
Why has this information been concealed from the public and
why has the VDEQ, the agency responsible for protecting us, not
contributed to this discussion?
How can the navy and elected officials responsibly consider
bringing all the Super Hornets to NAS Oceana under the current
conditions of the Region s unhealthy air quality?
How can responsible elected officials and Chamber of Commerce
officials promote single-siting knowing full well that North
Carolina will successfully obstruct the building of an OLF if
that state gets none of the aircraft?
How can the VDEQ reverse itself and grant the Navy an
increase in its budget of ozone-producing air emissions when
the Navy has apparently exceeded its VOC budget for the past
three years?
Why doesn't the VDEQ require the Navy to demonstrate clearly
that it is not comparing "apples with oranges" when
it uses a new air emissions baseline.
Who is looking after the interests of local residents? Apparently,
not the VDEQ.
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