Item I1 BOARD OF COUNTY COMMISSIONERS
AGENDA ITEM SUMMARY
Meeting Date: February 19, 2014 Division/Department: Growth Management
Bulk Item: Yes _ No x Staff Contact Person/Phone#: Christine Hurley 289-2517
AGENDA ITEM WORDING: An update on the Navy's issuance of the Record of Decision on October 31, 2013,
for the Final Environmental Impact Statement for Naval Air Station Key West Airfield Operations, which did not
include a requirement to conduct a noise study to establish a baseline.
ITEM BACKGROUND: On June 29, 2012, the Department of the Navy published a notice of availability of the
NASKW Draft EIS in the Federal Register. On August 15, 2012, the County responded to the NASKW Draft EIS with a
letter stating 41 specific comments and concerns. On August 2, 2013, the Navy published the NASKW Final EIS and
selected "Alternative 2" as the preferred alternative, including annual airfield operations equaling approximately 52,000
operations, the transition to next generation aircraft (F-35) and carrier air wing Field Carrier Landing Practice (FCLP) at
NAS Key West which may impact the County. While the Navy addressed some of the County's comments, all major
substantive recommendations were rejected in the Final EIS.
On August 21, 2013, the BOCC authorized the County Administrator, staff and Keith & Schnars (K&S) to meet with
senior Navy policy officials, members of the Florida congressional delegation and County lobbyist to discuss the County's
continuing concerns with the FEIS,including:
• The establishment of absolute maximum limits on all types of flight operations, including FCLP and night flights. The
current FEIS language does not clearly establish limits for the Navy operations;
• The proper evaluation of the baseline condition for existing operations at NASKW. Specifically,the impacts associated with
the FA-18E/F Super Hornet were included in the FEIS baseline notwithstanding the fact that the impacts to the surrounding
community by this aircraft were not properly evaluated in past NEPA documentation. The Navy's inclusion of the FA-
18E/F Super Hornet has the effect of reducing the magnitude of impacts between the baseline operations and the operations
included in the preferred alternative;
• The recommendation that the Navy contract with an independent consultant to conduct a noise study to establish an actual
noise baseline with actual noise sampling based on industry accepted protocols;and
o Should the Navy choose not to conduct a noise study, as requested by the EIS Committee, request authorization for the
County to contract an independent consultant to conduct a noise study to establish an actual noise baseline with actual
noise sampling to document the full impacts to surrounding community and the necessary mitigation by the Navy to
alleviate the impacts.
• The full mitigation by the Navy for the impacts associated with the proposed increases in flight operations included in the
preferred alternative and as a-result of the FA-18E/F Super Hornet to ensure the impacts on existing surrounding community
are minimized. This includes,but is not limited to:
o Navy request for statutory authority, where necessary, to provide mitigation to the surrounding community impacted by
the proposed increases in flight operations included in the preferred alternative and as a result of the FA-18E/F Super
Hornet. Mitigation including,but not limited to:
■ Soundproofing(noise attenuation)
o The use of alternative runways(i.e., 13/31,03/21)to alleviate impacts to the surrounding community.
o Modification of operational procedures and full enforcement of course rules (e.g., altitudes, flight paths) to minimize
impacts to the surrounding community.
On October 3, 2013, Congressman Joe Garcia, Roman Gastesi (County Administrator), Bob Shillinger(County Attorney),
Lisa Tennyson (Director Legislative Affairs and Grants Acquisition), Mayte Santamaria (Assistant Director of Planning
and Environmental Resources) and Michael Davis (Vice President of Keith and Schnars, P.A.) met in Washington, DC
with the Assistant Secretary of the Navy Dennis McGinn. Monroe County staff and K&S briefed the Assistant Secretary
on the County's key concerns (described above) with the FEIS and the Navy's operations at NASKW. The Assistant
Secretary did not take a position on the substance of any of the four issues but did note that he understood the County's
concerns and that he would consider them fully before he made a decision on signing the Record of Decision(ROD).
The ROD issued by the Navy on October 31, 2013, does include a response to the County's four remaining concerns;
however, it does not include any revisions or additional conditions relative to the County's four remaining concerns(pages
15-18 of Attachment 1).
As noted above, on August 21, 2013, the BOCC approved the recommendation that the Navy conduct a noise study to
establish an actual noise baseline with actual noise sampling based on industry accepted protocols; and if the Navy
chooses not to conduct a noise study, as requested by the EIS Committee (EIS Committee Resolution 001-2013 —
Attachment 2), authorization for the County to contract an independent consultant to conduct a noise study to establish an
actual noise baseline with actual noise sampling to document the full impacts to the surrounding community and the
necessary mitigation by the Navy to alleviate the impacts.
At its Dec. 13,2013 meeting, the EIS Committee recommended again that the BOCC conduct a noise study to establish the
noise baseline(as described in EIS Committee Resolution 001-2013: authorization for the County to contract with Keith&
Schnars to conduct a noise study to establish an actual noise baseline with actual noise sampling to document the full
impacts to surrounding community).
K&S is providing support to the BOCC, County Administrator and the County's Environmental Impact Study Oversight
Committee (EIS Committee) in the review and comments in response to FEIS documents. Since the ROD does not
include a condition for the Navy to conduct a noise study and the BOCC already directed staff to develop a contract to
conduct a noise study, staff is working on a separate BOCC agenda item for an amendment to the Agreement for
Professional Services with K&S and its noise sub-consultant to collect noise data for the establishment of baseline data.
PREVIOUS RELEVANT BOCC ACTION: On August 15, 2012,the BOCC authorized the mayor to sign the County's
comment letter on the DEIS, drafted by Keith and Schnars, P.A. The County responded to the DEIS with a letter stating 41
specific comments and concerns.
On August 21, 2013, the BOCC authorized the mayor to sign the County's comment letter on the FEIS outlining the four
remaining concerns and authorized the County to meet with senior Navy policy officials to discuss the County's continuing
concerns with the FEIS.
CONTRACT/AGREEMENT CHANGES: N/A
STAFF RECOMMENDATION: N/A
TOTAL COST: INDIRECT COST: BUDGETED: Yes No
DIFFERENTIAL OF LOCAL PREFERENCE:
COST TO COUNTY: SOURCE OF FUNDS:
REVENUE PRODUCING: Yes No AMOUNT PER MONTH Year
APPROVED BY: County A OMB/Purchasing Risk Management
DOCUMENTATION: Included X Not Required
DISPOSITION: AGENDA ITEM#
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DEPARTMENT OF DEFENSE
Department of the Navy
Record of Decision for the Final Environmental Impact
Statement (EIS) for Naval Air Station (NAS) Key West
Airfield Operations, Florida
AGENCY: Department of the Navy, DOD.
ACTION: Record of Decision.
SUMMARY: The Department of the Navy (DoN) , after carefully
weighing the strategic, operational, and environmental
consequences of the proposed action, announces its decision
to support and conduct airfield operations at NAS Key west
by accomplishing the proposed action as set out in
Alternative 2 . Alternative 2 will provide for the
transition from legacy aircraft to next generation
aircraft, alteration of existing facilities as necessary to
meet requirements for next generation aircraft, and will
potentially accommodate carrier air wing detachment
training events in the event that primary carrier air wing
training locations on the U.S. East Coast are unavailable.
Total annual airfield operations could equal up to
approximately 52 , 000 operations.
FOR FURTHER INFORMATION CONTACT: Greg Timoney, Naval
Facilities Engineering Command Southeast, P.O. Box 30,
Building 903, NAS Jacksonville, FL 32212; phone : 904-542-
6866; email: gregory. timoney@navy.mil.
A. SUPPLEMENTARY INFORMATION: Pursuant to Section
102 (2) (c) of the National Environmental Policy Act (NEPA)
of 1969, sections 4321 et seq. of Title 42, U.S .C, Council
on Environmental Quality regulations (parts 1500-1508 of
Title 40 CFR) , and DoN regulations (part 775 of Title 32
CFR) , the DoN announces its decision to support and conduct
aircraft training operations at NAS Key West. The proposed
action will be accomplished as set out in Alternative 2,
described in the Final EIS as the Preferred Alternative.
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The implementation of this alternative will result in the
gradual transition from legacy aircraft to next generation
aircraft and alteration of existing facilities to meet
requirements for next generation aircraft. In addition,
Alternative 2 provides the DoN with flexibility to
accommodate carrier air wing detachment training events
when primary carrier air wing training locations on the
U.S. East Coast are unavailable. Additional carrier air
wing Field Carrier Landing Practice (FCLP) operations would
vary annually based on availability of the primary training
locations, but could total up to 4, 500 additional annual
operations (aircraft conducting up to 2,250 FCLP patterns;
each pattern consists of two flight operations [a take-off
and a landing] ) . As there would be no increase in other
flight operations, total annual airfield operations could
equal up to approximately 52, 000 operations.
This decision will enable the DoN to sustain fleet training
conducted at and associated with the NAS Key West airfield
by DoN tactical aviation and its use by other DOD and
federal agencies.
B. BACKGROUND AND ISSUES: NAS Key West' s weather/climate
supports year-round fleet training, and its location
provides quick and efficient access to the nearby Key West
Range Complex, a key training venue for jet aircraft with
fighter or attack missions.
Purpose and Need
The purpose of the proposed action is to sustain fleet
training conducted at, and associated with, the NAS Key
West airfield by DoN tactical aviation and its use by other
DOD and federal agencies, while introducing next generation
aircraft . The proposed action is needed in order to
maintain the level of readiness mandated in Title 10
U.S.C. , part 5062 . Specifically, the use of NAS Key West
enables DoN to achieve and sustain required aviation
training, thereby supporting the timely deployment of naval
units; achieve and sustain readiness of squadrons to
quickly surge significant combat power in the event of a
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national crisis or contingency operation consistent with
the Fleet Response Training Plan. The Fleet Response
Training Plan implements the DoN' s Fleet Response Plan at
the U.S . Fleet Forces Command level and is essential to the
readiness of U.S. Naval forces. The NAS Key west airfield
is also needed to support required flight operations by DoD
and other federal agencies .
Public Involvement
The Notice of Intent to prepare this EIS was published in
the Federal Register on May 12, 2010 (75 FR 26739) _
Notification of public scoping was also made through local
media outlets and letters sent to government agencies,
local organizations, Native American tribes, and interested
private citizens. Two public scoping meetings were held on
May 26 and 27, 2010 in Key West, Florida.
The Notice of Availability (NOA) for the Draft EIS was
published in the Federal Register on June 29, 2012 (77 FR
38801) and a Notice of Public Meetings was published in the
Federal Register on July 3, 2012 (77 FR 39489) . Public
meetings were conducted in Key West, Florida August 1 and
2, 2012 . The public comment period ended on August 28 ,
2012 . This 60-day public comment period included a 15-day
extension granted by the DoN in response to a request from
the Monroe County Board of County Commissioners . The
extension was announced in the Federal Register on July 24,
2012 (77 FR 43275) . A total of 37 individuals and
organizations provided 101 separate comments on the Draft
EIS.
The NOA for the Final EIS was published in the Federal
Register on August 2, 2013 (78 FR 46940) . Notices
published in newspapers in Key West, Florida also announced
the release and summarized the results of the Final EIS.
The Final EIS addressed all oral and written comments
received during the Draft EIS public comment period. The
Final EIS was mailed to all individuals, agencies, and
organizations that requested a copy of the final document;
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the Final EIS is publicly available on the project website
at www.keywesteis.com.
Alternatives Considered
The DoN identified and evaluated the environmental
conditions associated with current airfield operations and
compared these with the potential environmental conditions
under a reasonable range of alternatives that would satisfy
its purpose and need. Alternatives considered in the Final.
EIS were identified as the No Action Alternative and
Alternatives 1 through 3 .
The No Action Alternative would continue annual airfield
operations at a level similar to present (approximately
47, 500 annual operations) , and continue to support existing
capabilities . Because of year-to-year fluctuations, a 10-
year average was used to represent existing airfield
operations from 2000 through 2009. When the EIS analysis
began in 2010, operational data from Fiscal Years (FY) 2010
and 2011 were not available. However, when these data
became available, annual airfield averages were found to be
within the 10-year average used in this EIS. Under the No
Action Alternative, next generation aircraft would not be
introduced and no facilities would be altered to support
next generation aircraft training operations. While the No
Action Alternative does not meet the purpose for and need
of the proposed action, it does serve as a baseline for
describing and quantifying the impacts associated with the
various alternatives analyzed in the Final EIS .
Alternatives 1 through 3 are described as follows:
s Alternative 1 - annual airfield operations would
continue at a level similar to present (approximately
47, 500 annual operations) . Legacy aircraft would
gradually transition to next generation aircraft . In
addition, existing facilities would be altered to meet
requirements for next generation aircraft.
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• Alternative 2 - builds on Alternative 1, by providing
the flexibility to accommodate additional carrier air
wing FCLP training at NAS Key West when primary
carrier air wing training locations on the U.S. East
Coast are unavailable. Additional carrier air wing
FCLP operations would vary annually based on
availability of the primary training locations, but
could total up to 4, 500 additional annual operations
(aircraft conducting up to 2,250 FCLP patterns) .
Under Alternative 2 total annual airfield operations
could equal approximately 52, 000 operations.
s Alternative 3 - the same as Alternative 2, and
additionally provides operational capacity and
flexibility to effectively meet DoN training
requirements under the Fleet Response Training Plan
with up to an approximately 10 percent increase in
other annual airfield operations . Under Alternative 3
total annual airfield operations could equal
approximately 57, 000 operations.
Alternative 2 is identified in the Final EIS as the
Preferred Alternative since it best meets mission and
foreseeable training. Factors that influenced selection of
Alternative 2 as the Preferred Alternative included the
results of the impact analysis in the EIS, and the
strategic and additional training capability provided by
establishing NAS Key West as a contingent location for
carrier air wing FCLP training when primary carrier air
wing training locations on the U.S. East Coast are
unavailable in accordance with requirements identified by
Commander, Naval Air Forces Atlantic. Carrier air wing
training is essential to maintaining the higher levels of
readiness required by the Fleet Response Plan and Fleet
Response Training Plan, in particular, maintaining the air
wings associated with the six aircraft carriers that are
required to be available for deployment within 30 days.
Regulations implementing NEPA require the identification of
the environmentally preferred alternative. The
environmentally preferred alternative for this EIS is
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Alternative 1. When compared to the other action
alternatives, there are potentially less flight operations
associated with Alternative I as this alternative does not
include the accommodation of carrier air wing detachment
training events in the event that primary carrier air wing
training locations on the U.S. East Coast are unavailable.
Consequently, over the long-term, Alternative 1 would
result in less estimated noise and land use impacts as
compared to the other action alternatives. Additionally,
as with the other action alternatives, reductions in heavy
metal use and some air emissions would be expected with the
transition from legacy aircraft to next generation
aircraft .
Environmental Impacts
The EIS analyzed environmental impacts and the potential
magnitude of those impacts relative to the following
environmental resource categories: noise; air quality;
safety; land use; transportation; infrastructure;
socioeconomics, environmental justice and protection of
children; cultural resources; geology, topography, and
soils; water resources; biological resources; and hazardous
materials, hazardous waste, toxic substances, and
contaminated sites. The EIS provided an examination of
potential future conditions associated with NAS Key West
airfield operations . The geographic scope of this analysis
was defined by the extent of the effects of the subject
airfield operations and includes NAS Key West and the
surrounding community.
The environmental effects of existing aircraft operations
were analyzed in detail as part of the No Action
Alternative, which served as baseline for comparison for
the future conditions identified in the other alternatives
under consideration. Many impacts were common among the
action alternatives . A detailed discussion of the
environmental consequences for each resource is provided in
Chapter 4 of the Final EIS. The discussion below
identifies resource categories for which the potential for
significant impacts were identified or for which
substantial public comments were made. The focus of this
discussion is on the impacts associated with the Preferred
Alternative (Alternative 2) , to transition to next
generation aircraft while providing additional FCLP
capability when other training locations are unavailable.
Noise: The noise environment at the NAS Key West airfield
was modeled using the NOISEMAP software suite. NOISEMAP
utilizes a library of actual aircraft noise measurements,
adjusted to local meteorological conditions, to produce
noise contours based on an average annual day of
operations . NOISEMAP is approved for use by DOD to model
noise exposure at and around military air stations .
NOISEMAP has been validated through extensive study.'
Although a newer aircraft noise model called the Advanced
Acoustic Model (AAM) is under development for aircraft
noise modeling, AAM has not yet been approved For use by
the DOD. Per OPNAVINST 11O1O .36C, NOISEMAP is to be used
for developing noise contours and is the best noise
modeling science available today for fixed-wing aircraft .
The analysis in the Final EIS addresses noise associated
with aircraft flight operations, aircraft engine run-up
activities, and on-ground testing. Based on the results of
NOISEMAP, the estimated off-station population exposed to
ILundberg, W.R. (June 1991) . Analysis of Measured Environmental Noise Levels: An
Assessment of the Effects of Airbase Operational Model Variables on Predicted
Noise Exposure Levels. Final Report for Field Measurement July 79-March BO and
Analysis June 89-December 90. AL-TR-1991-007.
Speakman, Jerry D. (July 1989) . Lateral Attenuation of Military Aircraft Flight
Noise. Final. Report for Field Test and Analysis: April 1984-September 1988.
AAMRL-TR-89-034.
Lee, R.A, (March 1982) , Field Studies of the AF Procedures (NOISECHECK) for
measuring Community Noise Exposure from Aircraft Operations. AFAMRL-TR-82-12.
Seidman, Harry and Ricarda L. Bennett. (June 1981) . Comparison of NOISEMAP
Computer Program with and without the SAE Lateral Attenuation Model.
Rentz, Peter E. and Harry Seidman. (May 1980) . Development of Noisecheck
Technology for Measuring Aircraft Noise Exposure.
Bishop, Dwight E. , Thomas C. Dunderdale, Richard D. Horonjeff, and John F.
Mills. (April 1977) . Further Sensitivity Studies of Community-Aircraft Noise
Exposure (NOISEMAP) Prediction Procedures. AMRL-TR-76-116.
Dundordale, Tom C., Richard D. Horonjeff, and John F. Mills. (March 1976) .
Sensitivity Studies of Community-Aircraft Noise Exposure (NOISEMAP) Prediction
Procedure.
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noise levels greater than or equal to 65 decibels (dB)
using the standard noise exposure metric of Day-Night
Average Sound Level (DNL) will potentially increase by 366
people (15%) to 2, 782 people . The estimated housing units
within the 65 DNL or greater noise zone will potentially
increase by 184 units (14%) to 1,457 units on off-station
lands (excluding water) . The estimated on-station land
acreage within the 65 DNL or greater noise zone will remain
at 3, 920 acres and the off-station land acreage within the
65 DNL or greater noise zone will increase by 92 acres to
1, 886 acres. Estimated changes in noise exposure at
representative receptors (analyzed in terms of average
noise levels, single event noise, speech interference, and
sleep disturbance) will be imperceptible to slight. No
population affected by NAS Key West airfield operations
would be at risk for long-term hearing loss as no
population resides within the 80 DNL or greater noise zone.
occupational noise exposure at NAS Key West will continue
to be managed with hearing protection and monitoring in
accordance with all applicable regulations.
Air Quality: There will be no air emissions associated with
the minor infrastructure upgrades. The transition from
legacy aircraft is estimated to result in a reduction in
volatile organic compounds (VOCs) , carbon monoxide (CO) ,
and particulate matter emissions, and a modest increase in
oxides of nitrogen (NO,) and sulfur dioxide (SO2) emissions
that will not approach the Mobile Source. Comparative
Threshold. Infrastructure upgrades and aircraft operations
emissions are estimated to result in negligible impacts to
area air quality.
Safety: There will be no changes to existing runways or
Accident Potential Zones (APIs) , and no new construction to
add new risks with implementation of the Preferred
Alternative. All regulations, plans, and safety protocols
that pertain to runways, APIs, mishaps, Bird/Wildlife
Aircraft Strike Hazard (BASH) , and other flight safety
considerations will continue to be followed. The slight
increased risk of BASH potential associated with the
increase in annual airfield operations at lower altitudes
where there is more bird activity will be minimized through
adherence to the air station' s BASH program, flight
operations standard operating procedures, and best
management practices that use all available resources to
minimize exposure during higher risk times of day, and
migration seasons .
As there is some uncertainty about mishap rates for next
generation aircraft, the DOD and DoN will continue to place
a high priority on safety programs for introducing next
generation aircraft, including increased modeling,
simulator training, ground tests and ensuring that each new
aircraft meets required standards prior to certification.
Even though the likelihood of an aircraft mishap will
remain remote, the increased annual airfield operation
levels will result in the potential for slight increased
risk of mishap. However, due to safety mishap program
advances it is expected that overall mishap rates will
remain below historical mishap rates for NAS Key West .
Land Use: The land use analysis is focused on off-station
lands and the land area within the 65 DNL or greater noise
zones and airfield safety zones . The total off-station
acreage within 65 DNL and greater associated with
implementation of Alternative 2 would be 1, 886 acres, an
increase of 92 acres compared to No Action Alternative, an
approximate five percent increase. Within these zones,
residential land use is not recommended by the DoN.
However, local land use is not controlled by the DoN; the
local government of Monroe County has jurisdiction for land
use controls. Historically, Monroe County has allowed
residential development within the DoN' s 65 DNL or greater
noise zones. The areas where existing incompatible
residential land use will increase with implementation of
the preferred alternative are primarily in the Big Coppitt
Key, Geiger Key, and Key Haven areas. Existing county
zoning prohibits or restricts new incompatible land uses
for all of these areas except for Key Haven and a small
portion of Stock Island. The DoN will continue to work
with Monroe County elected officials, planners, and
citizens to encourage compatible use adjacent to the Air
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Station consistent with the Air Installations Compatible
Use Zones Program.
Off-station noise exposure within the 65 DNL or greater
noise zone will continue. Based on the Monroe County Year
2010 Comprehensive Plan Future Land Use Map, areas within
the 65 DNL or greater noise zone designated as residential
will increase by 59 acres (includes 46 acres Residential
and 13 acres Residential Conservation) to 596 acres, an 11
percent increase from the No Action Alternative. On-
Station incompatible land uses within the noise and safety
zones are addressed in the NAS Key West Masten Plan. There
will be no change to safety zones (accident potential
zones) and therefore no change to associated land use
impacts. The DoN will continue to work with Monroe County
to address compatible use of privately owned land within
APZ I in the northwest portion of Boca Chica Key and APZ I
and 11 on Geiger Key.
Transportation: Transportation impacts related to the
proposed action are associated with the temporary increases
in personnel at NAS Key West as a result of units that
travel from their respective homebase to NAS Key West for
training (i .e . , detachment training) . The peak number of
personnel that would travel to NAS Key West at any one time
for such training is estimated at 920 and this would occur
during carrier air wing training events for up to 10 days
twice per year. This change represents an increase of up
to 139 persons as compared with existing conditions.
Although minor increases in personnel during peak times
will result in more in-bound and out-bound vehicular
traffic to NAS Key West properties, the potential impacts
could be reduced with carpooling and other traffic
management measures, as needed. No disruption to current
transportation patterns or changes to existing levels of
traffic safety are anticipated. Construction traffic will
be negligible given the scale of infrastructure
improvements to be implemented. Collaboration with local
and regional transportation planning will continue
consistent with Executive Order 13514, Federal Leadership
in Environmental, Energy, and Economic Performance.
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Socioeconomics, Environmental. Justice, and Protection of
Children: The implementation of the minor facility upgrades
will not result in noticeable regional socioeconomic
impacts. Direct and indirect beneficial local economic
impacts associated with the additional up to 18,400 inan
days by transient personnel will not result in changes to
long-term population, employment, income, or housing
trends. Implementation of the Preferred Alternative will
not result in disproportionately high and adverse human
health or environmental effects on minority and low--income
populations and there will be no environmental health or
safety risks that would disproportionately affect children.
Biological Resources: The implementation of facility
upgrades are proposed to occur along the flight line within
developed areas of NAS Key West, which will not result in
loss of marine and terrestrial communities or wildlife
habitat .
While it is possible that migrating birds could react to
construction noise, any reaction would likely be slight,
temporary, and not significant as research suggests
migratory birds acclimate to noise and visual disturbance.
Because flight operations are military readiness
activities, impacts to bird populations protected by the
Migratory Bird Treaty Act have been analyzed under 50
C.F.R. Section 21.15 (Authorization of take incidental to
military readiness activities) and found that impacts will
not cause significant adverse effect to populations of
migratory birds . Therefore, further consultation with the
U.S. Fish and Wildlife Service (USFWS) was not required.
Increases in aircraft noise exposure levels will not
significantly impact terrestrial wildlife as in-air noise
would be temporary, short in duration, and dissipate
quickly once an airfield operation is completed_ Resident
species within terrestrial habitats near the airfield
likely have acclimated to the existing noise and visual
disturbance generated by overflying aircraft and
maintenance run-up activities. NAS Key West will continue
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to manage wildlife and carry out conservation and
protection of biological resources (including migratory
birds) in accordance with the installation' s Integrated
Natural Resource Management Plan (INRMP.) (and associated
BASH program) and per agreements with the USFWS, National
Marine Fisheries Service (NMFS) , and Florida Fish and
Wildlife Commission (FWC) .
Marine wildlife at the surface or submerged could
experience exposure to aircraft noise, However, aircraft
sound is refracted upon transmission into water because
sound waves move faster through water than through air. in
addition, in-air noise from aircraft operations will be
temporary, short in duration, and dissipate quickly once
the airfield operation is completed. Furthermore, the
sound exposure levels will be relatively low to marine
wildlife that spend the majority of their time underwater,
constantly move, and are presently exposed to aircraft
noise under existing conditions. Therefore, it is unlikely
that exposure to aircraft noise from increased annual
airfield operations will injure or disturb natural
behavioral patterns of any marine mammals in the area to
the point where such behaviors are abandoned or
significantly altered that would rise to harassment under
the Marine Mammal Protection Act.
The Lower Keys marsh rabbit, nesting loggerhead sea turtle,
and Florida manatee are already subject to aircraft noise
under existing conditions . Based on available research
regarding reactions to aircraft overflights, the DoN
determined and USFWS concurred, that implementation of the
Preferred Alternative may affect, but is not likely to
adversely affect the Lower Keys marsh rabbit, nesting
loggerhead sea turtles, or Florida manatees. Designated
critical habitat for federally listed species does not
occur within the area of potential biological resource
effect; therefore, the implementation of the Preferred
Alternative will have no effect on critical habitat. NAS
Key West will continue to manage threatened and endangered
species in accordance with the installation' s INRMP and
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subsequent annual updates, and per agreements negotiated
with USFWS, NMFS, and FWC.
Mitigation► Measures
The management actions included in the Final EIS consist of
existing best management practices (BMPs) and standard
operating procedures (SOPs) that will continue to mitigate
potential environmental effects associated with
implementation of the Preferred Alternative. The DoN has
determined that the practices and procedures, detailed in
Chapter 7 of the Final EIS, provide all practicable means
within; the DoN' s ability to avoid or minimize significant
environmental impacts from implementation of the Preferred
Alternative. In summary, these practices and procedures,
which are all related to noise abatement, specify:
o High performance/unrestricted climbs are prohibited.
o Northeast departing aircraft are directed to fly over
the Boca Chica Road Bridge before turning.
e Pilots avoid overflying Key Haven, Stock Island, East
Rockland Key, Big Coppitt, and Geiger Key.
e In the pattern for Runway 13, aircraft remain within 2
males on the downwind leg.
m Aircraft do not overfly Key West or any key below
3, 000 ft unless instructed by ATC or for safety of
flight .
o The arrival to Runway 07 is south of Key West and
Stock Island and is adjusted to remain over water (the
Boca Chica Channel) near the final approach to the
runway.
s Runways 03 and 13 are designated as the primary FCLP
runways . Runway 03 is utilized to the maximum extent
practicable for noise abatement .
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• NAS Key West typically operates from 7 am to 10 pm
daily.
• The majority of engine maintenance run-ups occur on
the interior of NAS Key West .
• All arriving squadrons are briefed on the course rules
and pilots are made aware of noise concerns associated
with airfield operations.
• NAS Key West Air Operations receives noise complaints
by a hotline.
While the DoN cannot commit to mitigation measures outside
its jurisdiction, the DoN is required to identify all
relevant and reasonable mitigation measures that could
minimize potential adverse impacts identified in the EIS.
Accordingly, the Final EIS identified that neighboring
communities could adopt the land use compatibility
recommendations outlined in the OPNAVINST 11010. 36C, Air
Installations Compatible Use Zones Program, to ensure the
impact on existing and future land use compatibility is
minimized.
Agency Consultation and Coordination
The results of agency consultation and coordination is
summarized as follows:
• The DoN determined the Proposed Action is consistent
to the maximum extent practicable, with the
enforceable policies of the Florida State Coastal
Management Program and submitted a Coastal Consistency
Determination to the Florida Department of
Environmental Protection (FLDEP) . In a letter dated
August 28, 2012, the FLDEP concurred with the DoN' s
federal consistency determination.
• In accordance with Section 7 of the Endangered Species
Act, the DoN consulted with the USFWS regarding
potential impacts to threatened and endangered
14
species . In a letter dated August 8, 2012, USFWS
concurred with the DoN' s determination that
implementation of the Preferred Alternative may
affect, but is not likely to adversely affect the
Lower Keys Marsh Rabbit, nesting loggerhead sea
turtles, or Florida manatees and will have no effect
on critical habitat .
* Because the Navy determined these flight training
activities are military readiness activities under 50
C.F.R. Section 21 .15 (Authorization of take incidental
to military readiness activities) and found that
impacts will not cause significant adverse effect to
populations of migratory birds, further conference
with USFWS was not required.
® In addition, National Historic Preservation Act
consultation was not required for this EIS.
Responses to Comments Received on the Final EIS
The DoN reviewed and considered all comments that were
received during the 30-day wait period following
publication of the NOA for the Final EIS. During the wait
period, two comment letters were received One comment
letter was submitted by a local citizen supporting the
DoN' s proposed action, and the other from the Monroe County
government, in which four primary concerns were raised.
Monroe County representatives and Congressman Garcia also
met with the Navy to discuss their concerns. Monroe
County' s concerns were similar to comments received on the
Draft EIS that were previously considered and addressed in
the Final EIS. The DoN has again carefully reviewed the
Monroe County comments and provides the responses
summarized below.
Concern #1: Consideration of the establishment of absolute
maximum limits on all types of flight operations, including
carrier air wing FCLPs and night flights . The current
Final EIS does not clearly establish limits for DoN
operations .
15
Response #1: This EIS evaluated the potential maximum
number of annual airfield operations under each of the
alternatives based on a careful assessment of both historic
use levels and reasonably foreseeable factors potentially
influencing future annual airfield operation levels at NAS
Key West . Approximately 52, 000 total annual airfield
operations could occur with implementation of the Preferred
Alternative, including additional carrier air wing FCLP
operations that would vary annually based on availability
of the primary training locations, but could total up to
4, 500 additional annual operations (aircraft conducting up
to 2,250 FCLP patterns) . A NEPA analysis does not result
in an absolute limit on the number of operations that can
be conducted as part of the action, however, to the extent
that DoN makes a substantial change in the proposed action
relevant to the environmental concerns or there are
significant new circumstances or information relevant to
environmental concerns bearing on the impacts evaluated in
this EIS, the DoN would evaluate whether supplemental
analysis was warranted in the future.
Concern #2 : Proper evaluation of the baseline for existing
operations. Specifically, impacts associated with the F/A-
18E/F Super Hornet were included in the FEIS baseline,
notwithstanding the fact that the impacts to the
surrounding community by this aircraft were not properly
evaluated in previous NEPA documents. Including the Super
Hornet has the effect of reducing the magnitude of impacts
between the baseline operations and the preferred
alternative operations.
Response #2: The 2003 Environmental Assessment (EA) for
Fleet Support and Infrastructure Improvements at NAS Key
West analyzed potential impacts to the human environment,
including noise and flight paths resulting from all
transient aircraft operations, including F/A-18E/F
operations. As a result of that analysis the DoN reached a
Finding of No Significant Impact on April 14, 2003, which
completed and satisfied the NEPA requirements associated
16
with the introduction of F/A-18E/F aircraft at NAS Key
West.
This EIS is an examination of potential future conditions
associated with NAS Key West airfield operations. The
environmental effects of existing aircraft operations,
(including the F/A-18E/Fs) , are analyzed in detail as part
of the No Action Alternative, which serves as baseline for
comparison for the future conditions or alternatives under
consideration. F/A-18E/Fs are part of the current
inventory of aircraft operating at NAS Key West and
comprise approximately 25 percent of the existing annual
airfield operations.
Concern ##3; Previous recommendation that the DoN contract
with an independent consultant to conduct a noise study
with actual noise sampling based on industry accepted
protocols .
Response #3 : As part of the EIS, the DoN conducted a
detailed examination of the existing and potential noise
conditions associated with NAS Key West airfield
operations. NAS Key West airfield operations were modeled
using the DOD-approved NOISEMAP program. The NOISEMAP
program utilizes a library of actual aircraft noise
measurements, adjusted to local meteorological conditions,
to produce noise contours based on an average annual day of
operations . NOISEMAP represents the best noise modeling
science available today for military airfields. NOISEMAP
has been validated through extensive study and is used by
DOD and other federal agencies to model noise exposure at
and around military air stations for noise associated with
aircraft flight operations, aircraft engine run-up
activities, and on-ground testing.
Concern #4 : Request appropriate mitigation by the DoN for
the impacts associated with the proposed increases in
flight operations included in the Preferred Alternative,
and as a result of the F/A-18E/F Super Hornet, to ensure
the impacts on the existing surrounding community are
minimized. This includes but is not limited to: 1)
17
providing mitigation to surrounding Communities impacted by
the proposed increases in flight operations, including, but
not limited to soundproofing. That the DoN request
statutory authority, if necessary, to undertake such
mitigation; 2) Using alternative runways (i.e. , 13/31 and
03/21) to alleviate impacts to surrounding community; 3)
Modification of operational procedures and full enforcement
of course rules (e.g. , flight paths, altitudes) to minimize
impacts to the surrounding community.
Response #4 : As described above, with the implementation
of the Preferred Alternative there will continue to be no
population at risk for long-term hearing loss as no
population resides within the 80 DNL or greater noise zone.
In addition, the estimated changes in noise exposure at
representative receptors (measured in terms of average
noise levels, single event noise, speech interference, and
sleep disturbance) will be imperceptible to slight . The
DoN recognizes the importance of and makes every effort to
balance noise abatement with the need to train DoN pilots.
The DoN will continue tO make every attempt to minimize its
noise impacts to nearby communities through the continued
use of designated flight paths, procedures, and noise
abatement measures for military aircraft operating from NAS
Key West.
In response to the specific recommendations listed above,
Congress has not given the military services the authority
to install soundproofing in homes and buildings that are
not owned by the federal government . The alternate runways
(Runway 03/21 and/or Runway 13/31) are already used 33
percent of the time. Selection of which runway is to be
used at any given time is primarily determined by the local
winds. Aircraft performance, particularly during takeoffs
and landings, is safer and more efficient when aligned into
the wind. Since the prevailing wind conditions favor Runway
07/25, there is a limitation in the volume of operations
that could be shifted to the alternate runways. And as
detailed in the EIS, all practicable procedures are already
in place to minimize aircraft noise to the local community.
18
C. Conclusion
In determining how best to support and conduct existing and
future aircraft training operations at NAS Key West, I
considered the following factors : operational and readiness
requirements; potential aircraft mix and types of airfield
operations; manpower requirements and costs; the analysis
of environmental and socioeconomic effects within the Final
EIS; relevant federal and state statutes and regulations;
and the comments received during the EIS process . After
carefully weighing all of these factors, and analyzing the
data presented in the Final EIS, I have determined that the
Preferred Alternative (Alternative 2) best meets the needs
of the DoN while minimizing potential environmental impacts
to the greatest extent possible. The Preferred Alternative
allows for the gradual transition from legacy aircraft to
next generation aircraft and alteration of existing
facilities to meet requirements for next generation
aircraft, while also providing the DoN with flexibility to
accommodate carrier air wing detachment training events
when primary carrier air wing training locations on the
U.S. East Coast are unavailable.
w-
Date Roger M. Natsuhara
Principal Deputy Assistant
Secretary of the Navy
(Energy, Installations & Environment)
19
11 V.1
Environmental Impact Study Oversight Committee
RESOLUTION No. 001-2013
A Resolution of the Environmental Impact Study Oversight Committee of Monroe County,
Florida authorizing the County Administrator and Keith and Schnars (K&) to represent the
County in conversations and meetings regarding the Final Environmental Impact Statement
(FEIS). Specifically, the Administrator and K&S shall attempt to meet with Senior Navy policy
officials, the White House Council on Environmental Quality, White House Intergovernmental
Affairs and members of the Florida congressional delegation to discuss the County's continuing
concerns with the FEIS, including existing and proposed operations at NASKW. The
Administrator and K&S shall discuss the following County concerns and issues:
• The establishment of absolute maximum limits on all types of flight operations, including FCLP
and night flights. The current FEIS language does not clearly establish such limits for the Navy
operations;
• The proper evaluation of the baseline condition for existing operations at NASKW. Specifically,
the impacts associated with the FA-18E/F Super Hornet were included in the FEIS baseline
notwithstanding the fact that this aircraft was not properly evaluated in past environmental
documentation. The Navy's inclusion of the FA-18E/F has the effect of reducing the magnitude
of impacts between the baseline and the preferred alternative;
• The recommendation that the Navy contract with an independent consultant to conduct a noise
study to establish an actual noise baseline with actual noise sampling based on industry accepted
protocols;and
o Should the Navy choose not conduct a noise study, the Environmental Impact Study
Oversight Committee recommends the Board of County Commissioners consider
contracting its own independent consultant to conduct a noise study to establish an actual
noise baseline with actual noise sampling to document the full impacts to surrounding
community and the necessary mitigation by the Navy to alleviate the impacts.
• The full mitigation by the Navy for the impacts associated with the proposed increases in flight
operations to ensure the impacts on existing surrounding community are minimized. This
includes,but is not limited to:
o Navy request for statutory authority, where necessary, to provide mitigation to the
surrounding community impacted by the proposed increases in flight operations included
in the preferred alternative and as a result of the FA-18E/F Super Hornet. Mitigation
including, but not limited to:
■ Soundproofing(noise attenuation)
o The use of alternative runways (i.e., 13/31, 03/21)to alleviate impacts to the surrounding
community.
o Modification of operational procedures and full enforcement of course rules (e.g.,
altitudes,flight paths)to minimize impacts to the surrounding community.
PASSED AND ADOPTED BY THE ENVORONMENTAL IMPACT STUDY COMMITTEE
OF MONROE COUNTY, FLORIDA, at a meeting of said Committee held on the 141h day of
August, 2013.
Roman Gastesi, County Administrator Yes
Kim W igington, Community Representative Yes
Commander John Hammerstrom, Community Representative Yes
Don Riggs, M10 Coalition Yes
Richard Shetzer, M10 Coalition, Alternate Yes
Environmental Impact Study Oversight Committee
9"a d R. De.Saq*4
Secretary