Proposed Navy Fighter Exercises Threaten Pocosin Lakes NWR Birds

The National Wildlife Refuge Association (NWRA) needs your help to prevent a proposed Navy fighter landing field adjacent to 113,000-acre Pocosin Lakes National Wildlife Refuge in North Carolina, a vital migratory stopover for waterfowl and songbirds.

Please contact North Carolina Congressional representatives listed below, and urge them to oppose the Navy's proposal to place the "OLF" (Outlying Landing Field) near Pocosin Lakes NWR in Washington County. Instead, ask that they support an alternate location.

Background

In September 2003, the Navy announced its decision to construct an outlying landing field (OLF) in Washington County, NC. The OLF will provide simulated aircraft carrier landings for F/A 18 Super Hornet jets, stationed in Oceana, VA, and Cherry Point, NC. The Navy estimates 31,650 practice aircraft landings and take-offs annually at the proposed OLF, equal to about one every 15 minutes. The majority of these practice landings will occur at night in an area with few heavily lighted areas nearby.

The proposed landing field would be constructed within 3.5 miles of the Pungo Unit of Pocosin Lakes NWR. Approach, departure and holding patterns of the jets would routinely occur over the refuge at low altitudes. Noise from the jets will disturb resting and feeding waterfowl, which could potentially lead to their abandonment of the area and harmful impacts on the approximately 100,000 tundra swans, snow geese and other waterfowl that winter on Pocosin Lakes NWR. The Pungo Unit of Pocosin Lakes NWR was established in 1963 as a sanctuary for migratory waterfowl and includes diverse wildlife, such as the endangered red-cockaded woodpecker, bald eagles and the endangered red wolf, among others.

The Refuge and many surrounding private lands are managed to provide habitat and food for waterfowl and other wildlife. Pocosin Lakes NWR is identified as an internationally important waterfowl area by the U.S. Fish and Wildlife Service and is an integral part of the Atlantic Flyway, and the South Atlantic Migratory Bird Initiative has designated Pocosin Lakes an "Important Bird Area." Most of the tundra swans and snow geese that exist on the Refuge feed in the surrounding agricultural lands, including the site of the proposed OLF.

The possibility of birds colliding with jets is a real danger, especially to the pilots, at times resulting in crashes. The Air Force Bird Avoidance Model (BAM) rating system classifies the bird collision hazard at the proposed Washington County site as "severe" for 50 percent of the year. Further, Ronald Merritt, a former Geo-Marine employee during the time of the company's study for the Navy and former Chief of the Air Force's Bird/Animal Strike Hazard (BASH) Team, has stated, "It's not if a bird strike is going to occur [at the Washington County OLF site]. It's when the bird strike will occur and how severe it will be when it occurs." (See the full text of his letter to the Navy following this alert.)

On April 20, 2004, U.S. District Court Judge Terrence Boyle ordered the Navy to stop work on the planned OLF by issuing a preliminary injunction prohibiting any further direct or indirect action associated with the project. The injunction is a temporary victory for opponents of the landing field; however, the threat remains and the Navy will continue its efforts to develop an OLF next to Pocosin Lakes NWR in Washington County.

What You Can Do:

Call, email or fax the offices of North Carolina Senators Elizabeth Dole (R) and John Edwards (D).

Call, email or fax the offices of Congressman Walter Jones, Jr. (R) and Senate Candidate Erskine Bowles (D) and Congressman Richard Burr (R).

In your communications, include these 3 points:

• You oppose the Navy's proposal to place an Outlying Landing Filed (OLF) adjacent to the Pocosin Lakes NWR

• You believe such activity will pose not only a threat to the wildlife that thrive at Pocosin Lakes refuge, but also to the pilots that will be asked to risk flying through airspace known to be crowded with 20-pound swans and other waterfowl

• You encourage the Senator and Congressman to work with the Navy, Governor Easley and other state and local officials to identify alternate sites.

Call, email or fax Senator Elizabeth Dole at:
Phone: 202-224-6342
Fax: 202-224-1100
http://www.senate.gov/~dole/index.cfm?FuseAction=ContactInformation.ContactForm

Call, email or fax Senator John Edwards at:
Phone: 202-224-3154
Fax: 202-228-1374
http://edwards.senate.gov/mailform.html

Call, email or fax Representative Walter Jones at:
Phone: 202-225-3415
Fax: 202-225-3286
http://jones.house.gov/html/contact_email.html

Call, email or fax Senate Candidate Erskine Bowles at:
Phone: 919-834-7080
Fax: 919-834-0626
info@bowles2004.com

Call, email or fax Congressman Richard Burr at:
Phone: 202-225-2071
Fax: 202-225-2995
richard.burrNC05@mail.house.gov

Thank you for taking action on behalf of the Refuge System. Please feel free to contact Michael Woodbridge, Assistant Director of Government Affairs, at 202-333-9075 or mwoodbridge@refugenet.org.

Ronald L. Merritt's Letter:

October 13, 2003

Gordon R. England
Secretary of the Navy
1000 Navy Pentagon
Washington, D.C. 20350-1000

Dear Secretary England,

I am writing to you to express my concern with the US Navy proposal to construct and operate an outlying landing field (OLF) near Pungo Lake in Washington County, North Carolina. The recent signing of the Record of Decision (ROD) underscores my conclusion that the bird strike issue was minimized in the Final Environmental Impact Statement. I know that there are many elements that are considered in site selection and that there will always be impacts that cannot be avoided. However, the potential for a catastrophic bird strike at the proposed site near Pocosin Lakes National Wildlife Refuge has not been fully addressed. The following should be considered:

• The Bird Avoidance Model (BAM), a risk model developed by the US Air Force, forecasts severe bird strike potential for the Washington County site for 50% of the year. There are very few places in the United States where this level of threat exists.

• The radar study at the proposed site near Pungo Lake was conducted late in the wintering season when bird populations would be declining. Even so, over a 12-day survey period, the vertical scanning radar detected over 450,000 birds moving through the 24-degree beam. Of these targets, over 40,000 were flocks of large birds, and over 70,000 were identified as large birds. This represents a serious threat to aircraft safety during a twelve-day period at the end of the winter.

• The ROD suggests that bird detection radar would be considered as part of the bird strike mitigation program. This OLF cannot be operated safely without the use of a sophisticated bird detection system - yet nowhere in the United States is such a radar system operational on a daily basis. The US Navy does not have operational procedures to integrate bird detection radar into air traffic control.

I have been aware of the severe bird strike hazards facing military pilots flying in this region since 1988 when I was assigned as Chief of the Bird Aircraft Strike Hazard (BASH) Team at the Environmental Engineering Division, Headquarters United States Air Force, at the Pentagon (my resume is attached). To address this concern I worked with the Air Combat Command to conduct a two-year study at the Dare County Bombing Range in 1994. The results of that study resulted in an area-specific bird avoidance model (BAM) to assist aircrews in identifying periods of time when bird activity at the range could be hazardous. During that study, the biologists who were assigned the task of tracking birds and developing the risk model became familiar with many of the factors that contribute to the complex dynamics of bird movements in the region. Daily changes in weather patterns as well as the seasonal and yearly changes in agricultural practices made forecasting daily bird movement patterns nearly impossible. The Dare County Bombing Range BAM assisted Air Force pilots in planning periods of time when the range would be safe, but long periods of time still were identified when the range could be plagued with unacceptably high concentrations of birds moving through the area.

In January 2003, I was an employee with Geo-Marine, Inc., an environmental services company that was contracted by the US Navy to review BASH issues at each of the six proposed OLF sites. We also were contracted to conduct a radar survey of birds at Site C, near Pungo Lake, part of the Pocosin Lakes National Wildlife Refuge. It was my group that designed and built the mobile radar system that was deployed to the site in February 2003. Additionally, I was responsible for developing the survey protocol for the radar study and preparing the draft report. When initially contacted about this study by the Geo-Marine staff at Newport News, Virginia, I was concerned with how late in the wintering period the study was to be conducted, as well as the short duration of the surveys (4 weeks). I explained that the study would not be indicative of bird numbers or movement patterns throughout the winter and would serve only to show that the radar system was capable of detecting bird movements in the region.

The project also included a detailed review using the US-BAM as well as on-site evaluations. The BAM study indicated that Site C was severe 50% of the year. Only Site D, near Lake Mattamuskeet, had longer periods of severe ratings (58% of the year). Sites A and B each were severe 49% of the year, while the two sites that were not located in the immediate region indicated a dramatically lower bird strike risk with Site E being severe only 1% of the year, and Site F never reaching a severe rating. The ROD suggests that a severe rating 58% of the year was unacceptably high, and yet considered the 50% severe rating at Site C comparable to the severe ratings at NAS Oceana (31%) and NALF Fentress (36%).

The purpose of the on-site assessments was to identify potentially hazardous conditions that would further exacerbate the bird and wildlife strike hazard concerns. Site D (deemed unacceptably risky) is situated close to Lake Mattamuskeet. Site C is situated within five miles of Pungo Lake (a major wintering area for tundra swans and snow geese). None of the other sites in the study were situated close to such habitats. And yet, only Site D was determined to have unacceptable bird strike risk potential.

The Record of Decision (ROD) and the Environmental Impact Statement (EIS) for the Introduction of the F/A 18 E/F (Super Hornet) to the East Cost of the United States on which it was based concern me greatly. The written decision suggests that the bird strike risk at the Washington County field site (Site C) is similar to other sites in the area and that a standard Bird Aircraft Strike Hazard Plan can be developed to mitigate this concern. This conclusion is erroneous. It completely ignores the data that show that Sites A, B, C, and D are forecast as Severe at almost half of the year and that two sites (D and C) are situated extremely close to areas known to support large populations of wintering waterfowl. The decision also ignores the recommendation that radar should be used if Sites A, B, C, or D are selected and that the use of radar for real-time bird avoidance is still in development and not currently part of naval air operations anywhere in the world.

I understand that there are many factors that are considered in selecting a new OLF and that BASH concerns are only one. I do think, however, that in light of the extraordinary concentration of large flocking birds in close proximity to the Washington County site, and the very limited studies that have been conducted there, that the bird strike risk should be revisited and that a safer location considered. Additionally, a detailed assessment of bird detection radar systems should be conducted to determine the capability and reliability of the systems commercially available.

Sincerely,

Ronald L. Merritt
President, DeTect Inc.

cc: Governor Michael F. Easley