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Secretary Gordon R. England <br />November 2 l, 2003 <br />Page 2 of 3 <br /> <br />By letter of October 7, 2002, I informed the Navy that the State could not disagree with <br />the Navy's consistency determination. The State's position was conditioned, however, <br />upon there not being any significant changes in the types of aircraft, number of sorties, <br />nature of training exercises or other activities described in the DEIS. (Copy attached.) <br /> <br />The Final Environmental Impact Statement (FEIS) notes the 2002 consistency <br />determination and State response: <br /> <br />The Navy has determined that the proposed OLF would be undertaken in a <br />manner conslstem to the maximum extent practicable with applicable, enforceable <br />coastal zone management policies of Washington County. The North Carolina <br />DEN-R, Division of Coastal Management has concurred with this determination. <br /> <br />The project as described in the FEIS and selected in the Record of Decision is <br />substantially different, however, from the proposal that the State reviewed for <br />consistency in 2002. The differences include: <br /> <br />Introduction of "surge operations" that could result in "a concentrated period of <br />higher operational tempo", including increased flight operations at the OLF. <br /> <br />Potential imroduction of other aircmf~ in addition to F/A-18 E/F in response to <br />base closings at other training facilities such as Vieques, Puerto Rico. <br /> <br />A decision to control impacts on surrounding property by acquiring 30,000 acres <br />around the OLF in fee simple rather than obtain easements on the property. <br /> <br />The final selection of the Washington County OLF site (out of the six potential <br />locations identified in the DEIS and consistency determination) over sites that <br />could be developed with less damage to coastal resources. <br /> <br />All of these changes have the potential to significantly increase impacts on coastal <br />resources. <br /> <br />I also recently received a copy of a letter fi'om Ronald L. Men'itt to the Secretary of the <br />Navy. Mr. Men'itt participated in a study of bird str~e risks commissioned by the Navy <br />for each of the six proposed OLF sites. Mr. Men'itt believes that the bird strike risk at the <br />Washington County site is unacceptably high because of the extremely large populations <br />of waterfowl that winter around Pungo Lake. Mr. Merritt felt compelled to write the <br />Secretary of the Navy because he believes the FEIS fails to accurately reflect the severe <br />risk of bird strikes around the Washington County site. Apart fi'om the risk to Navy <br />pilots, the situation described by Mr. Merritt represents a threat to the wintering swans <br />and snow geese and to the fundamental purpose of Pocosin Lakes National Wildlife <br />Refuge. <br /> <br /> <br />