[audubon-news] Audubon/Navy Whistleblower Object to Navy Jet Field Plan

  • From: "BIANCHI, John" <JBIANCHI@xxxxxxxxxxx>
  • To: <Audubon-news@xxxxxxxxxxxxx>
  • Date: Wed, 15 Oct 2003 17:37:03 -0400

Contact: Chris Canfield


Whistleblower Finds His Research on Severe Safety Issues
Was 'Minimized' and Conclusions Are 'Erroneous' in Final Study

Chapel Hill, North Carolina, Wednesday, October 15, 2003 - An expert on bird 
and aircraft safety issues, contracted by the US Navy to perform studies at a 
site proposed for a new F/A 18 E/F Super Hornet jet training field, has 
revealed serious concerns about the use of his research in the Navy's final 
decision-making.  The revelations corroborate National Audubon Society 
objections to the plan to construct a field within a few miles of the Pocosin 
Lakes National Wildlife Refuge in Washington County, North Carolina. 

Ronald L. Merritt, former head of bird aircraft strike hazard (BASH) programs 
for the US Air Force worldwide, worked for the consulting firm contracted to 
conduct safety studies as part of the Navy's Environmental Impact Statement 
(EIS).  In addition to personal visits to the six finalist sites, Merritt's 
team also did a one-month radar survey at the Navy's preferred site in 
Washington County.  This preferred location had received wide criticism among 
knowledgeable wildlife managers for its proximity to the refuge, winter home 
for some 100,000 swans, geese, and other large waterfowl.

On September 10, 2003, the Navy issued its decision to base new squadrons of 
Super Hornet jets at bases in both Virginia and North Carolina and to share 
training runs at the remote field in between.  Audubon, numerous other national 
conservation organizations, federal and state wildlife experts, and political 
leaders consistently objected to the Washington County location as destructive 
to the environment and dangerous for pilots.

In a letter sent to the secretary of the Navy, Merritt notes, "the bird strike 
issue was minimized in the Final Environmental Impact Statement. ... There are 
very few places in the United States where this level of threat exists."  The 
text of the letter is attached.

When Audubon and others raised similar concerns, the Navy responded publicly 
that the research conducted by Merritt and others assured safe operations at 
the chosen outlying landing field (OLF).  Merritt calls that conclusion 
"erroneous."  "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."

In his letter to the secretary, Merritt says 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...the bird strike risk should be revisited and...a safer location 

"It is clear that, unfortunately, the Navy secretary based his decision on 
incomplete and misleading information," said Audubon COO Bob Perciasepe.  
"Given these revelations, Audubon is asking the secretary to review the data 
and look for a more suitable location for the landing field."

The National Audubon Society is considering legal action to contest the 
decision.  Lawyers from Audubon and the Southern Environmental Law Center 
(SELC) are already developing arguments in the case.

"The Navy has a duty to fairly characterize the risks and impacts of its 
decisions, and to honestly disclose those to the public," said SELC Senior 
Attorney Michelle Nowlin.  "The Navy has failed in the exercise of this 
essential duty."

"While a legal case is bolstered by this new information, we'd much rather have 
the Navy work with our governor and congressional delegation to find a safer 
field site," said Chris Canfield, executive director of Audubon North Carolina. 
 "Audubon continues to support necessary training for our troops - just not 
under such a risky and destructive plan."

Audubon is dedicated to protecting birds and other wildlife and the habitat 
that supports them.  Our national network of community-based nature centers and 
chapters, scientific and educational programs, and advocacy on behalf of areas 
sustaining important bird populations, engage millions of people of all ages 
and backgrounds in positive conservation experiences.

#   #   #


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 

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.


Ronald L. Merritt
President, DeTect Inc.

Cc:  Governor Michael F. Easley

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