Comments on proposed helicopter landings on our mountains. Summary first for busy people; details for insomniacs. Cory

Comments on April 2011

Environmental Assessment (EA) for High-Altitude Mountainous Environment Training (HAMET)

for the 25^th Combat Aviation Brigade, Hawai’i

by Cory Harden, PO Box 10265, Hilo, Occupied Hawai'i 96721  808-968-8965  mh@interpac.net

The Army is to be commended for responding to community concerns by re-doing the December 2010 EA. The April 2011 EA covers subjects more thoroughly, includes additional surveys covering wider areas, and clearly identifies LZ (landing zone) locations. However, serious concerns remain.

The need for high-altitude landings in Afghanistan and HAMET in Hawai’i is questionable.

Public involvement, consultation, and distribution for the April 2011 EA were not adequate.

Impacts from transporting helicopters and soldiers between O’ahu and Pohakuloa and increasing helicopter flights at Pohakuloa are not evaluated.

Safety analysis is inadequate for aircraft maneuvers so difficult they require three weeks of specialized training. The EA does not mention two high-altitude helicopter crashes in Colorado (one fatal), nor two fatal helicopter crashes and one forced landing in Hawai’i. It does not analyze causes or environmental impacts for the 2003 Hawai’i HAMET landing over three miles away from the LZ.  The EA does not describe methods for finding LZs at night. It does not say whether lights will used to avoid aircraft collisions, nor evaluate any impacts to people and wildlife from lights.

The EA describes the process and timeline for transporting trainees and aircraft to Colorado or Texas, but does not do so for Pohakuloa.

Some biological surveys only cover about one-tenth of the area around LZs where helicopters may descend to 200 feet.

The illegal takeover of the Kingdom of Hawai’i by the U.S. is not mentioned in the cultural overview.

Noise analysis is inadequate. Noise maps contradict written information, and show levels at some LZs as quieter than locations farther away. Day-night and even annual averages, and a method that under-estimates low-frequency noise, are used. The only study quoted re. noise impacts on wildlife was done by the Army. Inadequate data is presented re. HAMET training-day noise levels. Three helicopters at a time may fly on one mountain, but it is unclear whether noise analysis considers more than one. Vibration is not evaluated.

Instead of analyzing cumulative aircraft visual and noise impacts with HAMET added, the EA uses existing aircraft impacts as a rationale for generating more.

Details follow. Thank you for considering these comments.

1.4 - NEED FOR THE PROPOSED ACTION

There is “little need” for helicopter landings at high elevations in Afghanistan, per an Army investigation of a high-altitude helicopter crash on Pikes Peak in Colorado last year. [ Damage to Army helicopter in Colo. Crash: $25.8M, Associated Press, 3-9-11, quoting an Army crash investigation] This contradicts the EA statement of “..the need for well-prepared aviation brigades to conduct combat operations in Afghanistan…” [EA, p. iii]

It appears pilots could be trained in Colorado or Texas.

“Flight time is estimated to be approximately 2 hours for each pilot…” [EA p. 2-1]

It appears a few pilots at a time could be sent to Colorado or Texas for this 2-hour training.

For high-altitude helicopter training, a New York unit travelled to Colorado, and a Kentucky unit was scheduled to travel to Texas. [Helo pilots learn to fly at extreme altitudes, Army Times,

7-5-10]

If Hawai’i units went to either site, travel times would be similar.

It appears only one or two weeks of travel is needed for HAMET in Colorado or Texas.

“In HAMET, students perform classroom and flight simulator work at their home base, followed by a week of individual pilot training at Fort Carson or Fort Bliss, and then a week of multi-aircraft and nighttime training.” [Helo pilots learn to fly at extreme altitudes, Army Times, 7-5-10]

Pilots have been trained in Colorado while EA is being revised.

“[Col.Frank] Tate said he’s already sent roughly 30 of approximately 260 pilots to Colorado, which serves as another stie for high-altitude helicopter training.” Tate called it a “ ‘family saving issue’ “ [Airborne warriors put skills to test, Hawai’i Tribune-Herald, 4-1-11]

Training may be more realistic in Colorado, where mountains seem to have multiple jagged peaks like the mountains in Afghanistan. Mauna Kea and Mauna Loa have gentler slopes.

1.7 - AGENCY AND PUBLIC INVOLVEMENT, OUTREACH, AND CONSULTATION

The Army did not consult with Sierra Club, although it made extensive comments, including concerns about the lack of consultation with us, on the December 2010 EA.

The Army did not consult with other interested and affected parties named in Sierra Club comments on the December 2010 EA, namely--

District administrator of Hawai’i Island Natural Area Reserve System

Hawai’i Volcanoes National Park

Department of Hawaiian Homelands

Hawaiian civic clubs

This may violate CFR: “a plan to include all interested or affected parties should be developed…[and] will include the following…3) Consultation with appropriate persons and agencies. [32 CFR V 651.36 (e)]

The Army did not send notice of the April 2011 EA to Sierra Club or Cory Harden, though both made extensive comments on the December 2010 EA, and CFR says  “Distribution of the draft FNSI should include any agencies, organizations, and individuals that have expressed interest in the project, those who may be affected, and others deemed appropriate.” [32 CFR V 651.35 (f)]

Ron Terry and Barry Taniguichi are incorrectly identified as Mauna Kea Management and Observatories.

Both are volunteer members of the Mauna Kea Management Board. [EA, April 2011, p. 7-2]

1.8 - Regulatory Framework (and 6.2 Conclusions from Alternatives 1-3)

Federal law says any EA longer than 25 pages may indicate the need for an EIS. The EA cites this law but appears to disregard it.

“Any analysis that exceeds 25 pages in length should be evaluated to consider whether the action and its effects are significant and thus warrant an EIS.” Cited in EA references [32 CFR V 651.32 (b)]

Public involvement was inadequate, despite years of public interest in military actions.  “ where impacts are… suspected to be of public interest, public involvement should be initiated early in the EA (scoping) process. [32 CFR V 651.39(c) \4\]

Requirements for public meetings may not have been met—several commenters called for meetings open to the general public, but none were held.

“The proponent shall also ensure appropriate public and agency meetings, which may be required to facilitate the NEPA process in completing the EA.”  [32 CFR V 651.35 (h)]

2 - DESCRIPTION OF THE PROPOSED ACTION AND ALTERNATIVES

Helicopters and soldiers will need to be transported between PTA and O’ahu, and HAMET will generate more helicopter flights within PTA. The EA does not describe these actions, nor evaluate the impacts.

2.6 - 25th CAB Safety Record (and 4.13 Human Health and Safety Hazards)

The EA says “[t]he CAB has an excellent safety record, including during past HAMET flights.” [EA p. 4-63] But the EA does not say why one helicopter landed 3 ½ miles off its LZ in November 2003. KAHEA (the Environmental-Hawaiian Alliance) says the Army called it a “hard landing”. The Army also called the June 2010 crash in Colorado a “hard landing” though two pilots were injured and damage was $26 million (see below.)

The EA says HAMET “is considered a low-risk mission according to the 25th CAB Risk Assessment Worksheet” [EA p. 4-63] But the EA also says “[h]igh altitudes and mountainous terrain…greatly affect the performance of a helicopter engine and the handling characteristics of an aircraft” [EA p. 1-2] to the point that several weeks of specialized training are required. 

The EA says HAMET involves different maneuvers than the 2001 air-assault training crash and 2009 general maintenance test flight crash. But it should analyze other relevant factors.

The EA says there is a “low potential for future accidents.” [EA p. 4-63] But a high-altitude trainee in Colorado said “ ‘I’m not going to lie, I was nervous and scared…It wasn’t just training; it was if you screw this up, it could end badly.’ “ [Helo pilots learn to fly at extreme altitudes, Army Times, 7-5-10] And one Army officer called the training “demanding.” [1st Air Cav set to reach new heights, www.army.mil, 1-26-11]

Information on crashes is insufficient. The December 2010 and April 2011 EA cite two past CAB helicopter crashes. But it’s only two sentences, and there is no mention of the fatalities, nor the causes of the crashes.

Nor are these incidents mentioned. Two involve Black Hawks, which would be used in HAMET. The 1996 crash was cited in Cory Harden’s comments on the December 2010 EA.

·        One Marine died and two were hospitalized after an April 1, 2011 Sea Stallion helicopter crash in Kaneohe Bay.

[Man killed in copter crash is identified, Hawai’i Tribune-Herald, 4-1-11]

·        There was a forced landing of a 25^th CAB Black Hawk helicopter at Koko Head Elementary School on February 7, 2011.

[Army helicopter lands in Hawai’i Kai field, Hawai’i Star-Advertiser, 2-7-11]

·        Two pilots were injured in an Army high-altitude Apache helicopter crash on Pikes Peak in Colorado on June 30, 2010. “The Army called it a ‘hard landing’ and has never admitted how badly the aircraft was damaged” according to a March 2010 report by The Denver Channel TV news.

[ Damage to Army helicopter in Colo. Crash: $25.8M, Associated Press, 3-9-11; Army: Helicopter Crash on Pikes Peak Caused $26M In Damage, ABC 7 News/ The Denver Channel.com, 3-9-11; Army Pilot, Training Cited in PIkes Peak Chopper Crash, http://www.thedenverchannel.com/news/2704326/detail.html]

·        Four soldiers died in an August 2009 Army Black Hawk helicopter crash on Mount Massive in Colorado.

[Human Error Cited in Army Helicopter Crash on Colo. Mountain, http://www.thedenverchannel.com/news/22314889/detail.html]

·        Two people died in a March 5, 1996 Cobra helicopter crash at Schofield. 

[Six die in crash of Army copters, Honolulu Star-Bulletin, 2-13-01]

The EA says “Army training procedures as well as standard operational and emergency procedures minimize any impact to human health and safety in the LZ during HAMET.” [EA p. 4-60] But an Army investigation of the June 2010 Colorado crash “said the rescue took so long that the more seriously injured pilot’s condition became critical before he was airlifted to a hospital…”

[ Damage to Army helicopter in Colo. Crash: $25.8M, Associated Press, 3-9-11]

The EA says pilots will do reconnaissance flyovers before landing. It does not say

·        If the landing will be cancelled if people are nearby

·        How the pilot will see the LZ at night—with lights that may disturb people and wildlife, with night vision devices, or with other means.

The EA does not state whether the helicopters will use lights to avoid collisions with other aircraft.  If they will use lights, the EA does not evaluate the impacts on people and wildlife.

2.7 – ACTION ALTERNATIVES

The EA describes the process and timeline for transporting trainees and aircraft to Colorado or Texas, but does not do so for Pohakuloa, nor compare the time, effort, and cost. [EA p. 2-30]

3. 6 and 4. 6 - BIOLOGICAL RESOURCES

Helicopters will fly 200 feet about ground level in a 6560-foot (1 ¼ mile) diameter circle around the LZs  [EA p. 2-9].

But surveys conducted by the Pohakuloa Natural Resources Office were within a square only one-tenth that size for plants, bat habitat, and wekiu bugs. Surveys were within a circle only two-thirds that size for birds. [EA p. A-4 to A-5]

The 6560-foot circle for 200-foot altitudes means potential low-flying helicopters over the nene sanctuary and over about 6 square miles of ‘io range. In addition, three LZs are inside ‘io range.

Surveys conducted by the Pohakuloa Natural Resources Office were only conducted during one season.

Wekiu bug populations vary widely over time depending where the wind blows bugfall

The surveys cited on p. 3-22 are not readily available to the public.

The EA does not evaluate impacts from noise disrupting communication between mates and family groups, masking predator noise, and other impacts short of causing animals to flee, for threatened and endangered species. [EA p. 4-13]

3.7 – CULTURAL RESOURCES

The illegal takeover of the Kingdom of Hawai’i by the U.S. is still not mentioned in the cultural overview, though Cory Harden mentioned the omission in comments on the December 2010 EA.

3.11 and 4.11 - Noise

One would expect more noise around LZs from helicopters landing and taking off, but the noise contours in Figures 4-5 to 4-9 show relatively less noise around the Mauna Kea LZs.

The figures also show no noise over 80 dB, which seems to contradict a later EA statement:  “…the highest noise levels [will be about]…100 dB within [about] 100 feet of the geographic center of the LZ.” .” [4-15-11 Memorandum, EA Appendix A, p. 6]

The EA noise assessment method under-represents low-frequency noise—the type helicopters generate.

“Noise from transportation sources…is assessed using the A-weighted DNL…[which] significantly reduces the measured pressure level for low-frequency sounds…” [EA p. 4-35]

The EA mentions special methods for evaluating noise impacts on wildlife, but does not say whether these methods were used. 

“L max The maximum sound level of a noise source is useful in anticipating impacts on wildlife. Maximum sounds levels are used in conjuction with the proximity and duration of the noise source to examine potential effects on wildlife (Noise Quest 2011)” [EA p. 4-35]

The EA does not specify which studies were used to evaluate noise effects on wildlife, and whether the studies were done by the Army. The only study quoted is not a peer-reviewed study--it was done by Peter Peshut, a biologist who works at Pohakuloa. The EA gives no details to support the study’s conclusions.

“Army Regulation 200-1 (U.S. Army 2007a)…specifies that potential impacts of noise on wildlife shall be assessed through studies ‘on individual species’ response or a surrogate response to noise.’ In accordance with this approach, published studies on wildlife responses to helicopter noise were utilized in assessing potential effects on wildlife…” [EA p. 4-36]

“Potential impacts of noise on wildlife within the ROI [region of influence], including threatened and endangered species, are considered less than significant due to the nature of the species habitat and range as well as established conservation measures.(Peshut 2011).” [EA p. 4-47]

The EA uses inadequate data to back up its statement that “…maximum noise levels on flying days are similar to non-flying days; therefore, this preliminary assessment indicates HAMET activities do not significantly alter the existing maximum noise levels at each sample location.” [EA p. 4-47 and 4-49]

 “[T]he maximum number of helicopters training on any mountain at one time would be three.” [EA p. 2-9] 

But the EA does not say how many helicopters were flying during the noise test. And it only gives maximum sound levels for one helicopter. [EA p. 4-35]

Half the test locations had higher maximum noise levels on flying days—about 14 dBa at #5, 8 dBA at #1, and 5 dBa at #4. [EA Table 4-10, p. 4-48] 

Readers can only estimate levels since the EA does not disclose the numbers used to generate the table.

The EA does not describe what other noise sources were present on test days (military and civilian aircraft, weapons firing, traffic, construction, wind, etc.]

A knowledgeable person told me the wind was blowing the opposite direction from normal while the noise testing was done.

Army use of day-night and even annual averages does not seem like an appropriate way to evaluate the  impacts of intermittent helicopter noise, as many Hawai’i residents subjected to tour and military helicopters would probably testify. 

“Chapter 14 of Army Regulation 200-1…states… the primary metric should be the DNL [day-night average sound level] [EA p. 4-36] 

“…the Hawai’i SONMP [US Army Hawai’i Statewide Operational Noise Management Plan] includes an informal land use planning zone…intended to account for seasonable variability in increased operations that may dilute noise impacts averaged over a 1-year period.” [EA p. 3-68] 

Vibration is not evaluated at all, though it is cited in Sierra Club comments on the December 2010 EA.

The EA does not describe how the noise of nighttime flights may affect wildlife.

The EA does not state whether HAMET will occur during nesting season for certain species, nor evaluate the impacts.

The EA does not specify what type of sound level meters were used.

Hawai’i Administrative Rules, Title 11, Chapter 46, Community Noise Control, does not apply to aircraft. But it is worth noting that maximum noise levels allowed for some other noise sources, for conservation, preservation, and open spaces lands , are 55 dBA by day and 45 dBA by night. HAMET helicopter noise would range from 69 dBA at a slant distance of 2,000 feet to 98 dBA at 200 feet. 

It is unclear whether the EA uses noise evaluation methods described in two articles listed in

9. REFERENCES--

Article 1-- Pater, L.L., et. al., Recommendations for Improved Assessment of Noise Impacts on Wildlife, Journal of Wildlife Management, 73 (5),pp. 788-795; July 2009.

“ An appropriate metric will measure sound stimulus characteristics in a way that can be related to responses by an animal. For example, a sound metric that does not account for frequencies within the hearing range of a species cannot meaningfully characterize sound stimuli for that species. As a further example, a metric that is designed to measure continuous sound cannot adequately describe a brief transient event such as a gunshot. Animal responses to sound can depend on sound level, rate of onset, duration, number of events, spectral distribution of sound energy, presence of pure tones, and relative level of background noise…[p. 789]

For highly variable or transient noise events, a simple measurement of SPL [sound pressure level] or LEQ [metric equivalent average sound level] is not adequate. For transient noise events of a few to several seconds duration, such as a pass-by of a vehicle or aircraft, measuring average noise level is problematical because the choice of the measurement period duration affects the magnitude of the metric measured. A better method is to divide the event duration into short (typically 1 sec) time increments, measure LEQ during each increment, and report the maximum value that occurs in any time increment. For such a sound-stimulus measurement, total duration of the event should also be described and reported, for example the period that 1-second LEQ values were measured to be within 10 dB of the maximum value…[p. 789]

For aircraft and helicopter flyby noise events, 2 metrics are sometimes measured and reported, both the SEL and the maximum 1-second equivalent average (LEQ) level discussed previously, because both are good candidates to be related meaningfully with an animal’s response. These metrics will typically be quite different in magnitude, even though they are expressed as decibels and describe the same event…[p. 790]

Spectra…Characterizing a noise stimulus adequately often requires not only the value of …[greater than or equal to] 1 overall sound-level metric(s), but also a spectrum that shows how magnitude of a sound metric varies with frequency (pitch)…. [p. 790]

Audiograms…An audiogram of the study species is useful to guide interpretation of noise-response data…animal perception of sounds cannot generally be inferred based on human perception…[p. 790]

Frequency Weighting…A sound stimulus can be more meaningfully characterized by considering how it is perceived by the animal…Applying frequency weighting for owls to a helicopter spectrum has a different effect than applying human A-weighting to the same spectrum…Weighting systems developed for humans are not appropriate for animal species that have substantially different audiograms…]p. 790]

Air flow (wind) over a microphone can introduce spurious very-low-frequency noise into a measurement…[p. 792]

…sources rich in low frequency energy, such as helicopter noise…can travel long distances efficiently.. helicopter noise level does not depend only on the distance of closest approach, but also on aircraft speed, power settings, rotor pitch, and maneuvers.. Weather can cause sound level to vary by as much as 50 dB...[p. 792]

Immediate [animal] responses, such as alert and flushing behavior at nests or roosts and changes in activity patterns, are of special interest when associated with foraging and rearing offspring… Sound, both anthropogenic and natural, can also affect nest-site selection…and can mask biologically important sounds, including mating call behavior and predator and prey sounds… [p. 792]

Researchers should also consider whether an animal is responding to noise or to some other aspect of a potentially disturbing activity, because many potential disturbances include both auditory and visual stimuli…[p. 793]

Article 2— Delaney, D.K., L.L. Pater, T.J. Hayden, L. Swindell, T. Beaty, L. Carlile, and E. Spadgenske, 2000, Assessment of Training Noise Impacts on the Red-cockaded Woodpecker: 1999 Results]

“Few researchers have directly compared differences in bird responsiveness between aerial and ground-based disturbances (Bowles et al. 1990). Studies that have examined the effects of aircraft activity on nesting birds (e.g., Platt 1977; Windsor 1977; Ellis 1981; Anderson et al. 1989) have often noted a slight but nonsignificant decrease in nesting success and productivity for disturbed versus undisturbed nests. Anderson et al. (1989) noted a slight decline in the nesting success of experimental Red-tailed Hawk (Buteo jamaicensis) nests versus control nests (80 percent experimental versus 86 percent control success) after helicopter disturbances.” [p. 13]

“Anderson et al. (1989) reported that 2 of 29 Red-tailed Hawk nests were abandoned after being flushed by helicopter flights, compared with 0 of 12 control nests.” [p. 14]

“Two metrics, the SEL and the maximum 1-second equivalent average (LEQ) level, were used for helicopter noise, airplane noise, and vehicle pass-by noise, since both are meaningful in terms of correlation with response (Environmental Protection Agency [EPA] 1974, 1982; Federal Interagency Committee on Urban Noise [FICUN] 1980; Fidell et al. 1991; Schomer 1994; Schultz 1978; U.S. Code of Federal Regulations 1980).” [p. 25]

“No significant difference in nesting success was found between experimentally disturbed and relatively undisturbed nest sites. [but] The second year data are limited in number and statistical power and are not sufficient to make strong conclusions or to establish reliable noise doseresponse relations or thresholds.” [p. 42]

[my note: for an endangered species, losing even a few nests could be a tipping point]

The EA should evaluate impacts based on the following article--Noise: A Health Problem,United States Environmental Protection Agency, Office of Noise Abatement and Control,Washington,DC 20460, August 1978 [http://www.nonoise.org/library/epahlth/epahlth.htm#mental]

Mental and Social Well-Being

"The Noise, The Noise. I just couldn't stand the Noise." Suicide note left by a desperate homeowner.

The most obvious price we pay for living in an overly noisy world is the annoyance we frequently experience. Perhaps because annoyance is so commonplace, we tend to take our daily doses of it for granted - not realizing that the irritability that sometimes surfaces can be a symptom of potentially more serious distress inside us. When noise becomes sufficiently loud or unpredictable, or if the stress imposed is great enough, our initial annoyance can become transformed into more extreme emotional responses and behavior. When this happens, our tempers flare and we may "fly off the handle" at the slightest provocation.

Newspaper files and police records contain reports of incidents that point to noise as trigger of extreme behavior. For instance, a night clerical worker upset about noise outside his apartment, shot one of the boys causing the disturbance after he had shouted at them, to no avail, to "Stop the noise." As other examples, sanitation workers have been assaulted, construction foremen threatened, and motorboat operators shot at -all because of the noise they were producing.

Such extreme actions are not the usual responses to noise and stress. Some people cope with loud noise by directing their anger and frustration inward, by blaming themselves for being upset, and by suffering in silence. Others resort to a denial of the problem altogether, considering themselves so tough that noise does not bother them. Still others deal with noise in a more direct manner: they take sleeping pills and wear ear plugs, increase their visits to doctors and keep their windows closed, rearrange their sleeping quarters and spend less time outdoors, and write letters complaint to government officials.

Most of the time these ways of contending with noise are not likely to eliminate the noise or any underlying annoyance. Short of taking extreme action - which is unlikely to solve the problem either - most people who cannot cope with noise in these ways typically direct their anger and frustration at others and become more argumentative and moody, though not necessarily violent. This noise-induced, anti-social behavior may be far more prevalent than we realize.

Indeed, noise can strain relations between individuals, cause people to be less tolerant of frustration and ambiguity, and make people less willing to help others. One recent study, for example, found that, while a lawnmower was running nearby, people were less willing to help a person with a broken arm pick up a dropped armload of books. Another study of two groups of people playing a game found that the subjects playing under noisier conditions perceived their fellow players as more disagreeable, disorganized, and threatening. Several industrial studies indicate that noise can heighten social conflicts both at work and at home. And reports from individuals suggest that noise increases tensions between workers and their supervisors, resulting in additional grievances against the employer.

Although no one would say that noise by itself brings on mental illness, there is evidence that noise-related stress can aggravate already existing emotional disorders. Research in the United States and England points to higher rates of admission to psychiatric hospitals among people living close to airports. And studies of several industries show that prolonged noise exposure may lead to a larger number of psychological problems among workers.

5 - CUMULATIVE IMPACTS 

Table 5-1 -  Summary of past activities

Table 5-2 -  Summary of current and anticipated activities

5.8 -  Noise

The tables do not list existing aircraft noise sources. The EA does not analyze cumulative impacts with HAMET added. Instead, the EA uses existing aircraft noise as a rationale for generating more.

“For the military, hundreds of helicopter flights and thousands of hours of flight time are logged at Pohakuloa each year. Moreover, commercial helicopters plying the tourist trade on Hawaii [sic] Island transit palila critical habitat regularly throughout the year, with no restrictions on flight paths or elevation.” [4-15-11 Memorandum, EA Appendix A, p. 4]

5.9 -  Visual and Aesthetic Resources

The tables do not list existing aircraft activities, though they are described (very briefly) elsewhere in the EA.. The EA does not analyze cumulative impacts with HAMET added.

“…aviation training currently occurs within PTA, and commercial and private aircraft operate outside of PTA.” [EA p. 3-72]