Without actually performing an Environmental Impact Statement (EIS), the U.S. Navy has decided to use the National Forests on the Olympic Peninsula for electronic war games. The U.S. Forest Service (USFS) is poised to give the green light to this proposal.
The Navy has acquired some fancy jets that are equipped with electronic combat equipment. The mission is to detect, locate and destroy or disable enemy radar installations. But the pilots need training to operate the electronic gadgets. They already have a radio frequency (RF) emitter tower in Coupeville, but they’ve decided they need to install another emitter tower at their Annex at Pacific Beach on the coast. But the training would be much better if the “enemy” targets could move around and the pilots didn’t already know exactly where they were. So some genius dreamed up the idea of putting mobile emitter units all around the National Forests. Proposed are 15 sites on the Olympic Peninsula, 12 on National Forest land and 3 on Washington State Department of Natural Resources land. An additional 8 sites are proposed on National Forest land in Eastern Washington.
The Navy has performed an Environmental Assessment (EA) for these mobile emitters. In this assessment, they have determined that there will be no significant impact to: Public Health and Safety; Biological Resources; Noise; Air Quality; and Visual Resources. Since they have determined that there will be no significant impact, they use this to then claim that a full EIS is not necessary. Translation: we don’t think there are any problems; therefore there are no problems and we don’t have to prove it. Trust us.
The people who performed the EA have no expertise in electromagnetic radiation, so the EA is heavy on noise and light on the impact of high energy RF radiation. In the section on Noise, they only take into account the noise from the generators supplying power to the mobile units. These would be operating an average of 9 hours per day, 260 days per year for a total of 7,020 hours per year in Olympic National Forest. Double that if you count the proposed mobile units in the Okanogon and Roosevelt National Forests in Eastern Washington. Curiously, they don’t take into account the noise of the aircraft because they claim that they are not increasing the current number of training flights, they are only adding electronic warfare to the training during the flights. But it seems clear, even to the casual observer, that the current training flights would not be directly over the Olympic National Forest. The flight path must change to reflect the new training requirements, mustn’t it? Aircraft noise has certainly diminished the peace and quiet of Deception Pass State Park.
The authors of the EA admit that the noise and the electromagnetic radiation may disturb wildlife, but they always conclude with these oft-repeated phrases: “It is unlikely that a single transit by a mobile emitter would evoke anything other than a short-term behavioral response.” [e.g., p. 3.2-25, EA] and “Electromagnetic radiation may have an impact on vegetation, invertebrates, amphibians, reptiles, and non-listed birds and mammals… however, it is unlikely that [all of the above] would be constantly exposed to electromagnetic radiation, and therefore negative effects are less likely to occur.” [e.g. p. 3.2-26, EA]
Their claim that the noise and the RF radiation will not impact the flora and fauna is entirely based on the premise that the mobile emitters are moving around the forest, so no long-term effects are expected. This despite the fact that 3 mobile units will be in operation for 9 hours per day 260 days per year. Curiously, they state “Dense vegetation can reduce noise levels by as much as 5 dB for every 100 ft. (30.5 m) of vegetation, up to a maximum reduction of 10 dB over 200 ft. (60.9 m).” [p. 3.2-24, EA] And yet, with regard to the RF radiation, they cite the lack of dense vegetation as a reason why the flora won’t be harmed. “Furthermore, these sites have been preselected because, in general, they are on a cliff or ridgeline and/or currently provide an open area to the west of the pull-out that enables the mobile emitter a clear line of sight to the west. [p. 2-4, EA]. A study by Haggerty implicates low-level RF background in the decline of aspen trees in the U.S. Do we want to find out what high-level RF will do to cedars, firs, moss, ferns and such?
The only wildlife taken into account in the EA were those on the endangered or sensitive species list. They determined that there may be harm done to some individual animals or birds but that would not affect the overall population, therefore they issued the finding that some species may be affected but not adversely affected. “Impacts to wildlife are determined significant if the fitness of individual animals were affected directly or indirectly to the extent that populations would decline or become unstable. For an outcome to be biologically significant to a population, it must have a measurable impact on the population and/or its habitat which could reasonably be expected to affect its stability, and as a result influence a population’s viability.” [p. 3.2-22, EA]
In the section on Visual Resources they only take into account the tower at Pacific Beach. They do not take into account the mobile units. In the EA, the mobile units are portrayed in an artist’s rendition as looking like a camper with an antenna on top. This is presumably why they didn’t bother; how many campers are already in the park? But the mobile unit that was tested in 2012 at Pacific Beach bears no resemblance to a camper. The mobile Joint Threat Emitter, made by Northrop Grumman, looks more like something out of Star Wars. Perhaps the artist’s drawing is what the Navy hopes the mobile unit will look like when they finally get this project going.
The EA is light on details concerning the electromagnetic radiation of the fixed and mobile emitters. There is not enough information to really determine the known effects. The frequencies given are in the microwave range. The missing details are probably classified, but here is what they give:
The transmitter tower at Pacific Beach
A fixed emitter at Pacific Beach on a tower would have a total height of about 66 ft. above ground level. The fixed emitter is capable of generating an electromagnetic wave at frequencies ranging from 2 to18 gigahertz (GHz). It can emit up to 64 simultaneous signals and can transmit in pulses or a continuous wave. [p. 2-1, EA]
In the EA, reference is made several times to the transmitter tower already having been through the Environmental Impact process, giving the impression that the environmental impact of the tower need not be further assessed. For example: “The NWTRC EIS/OEIS [Northwest Training Range Complex Environmental Impact Statement/Overseas Environmental Impact Statement] has an October 2010 Record of Decision that approved an alternative that included EW training activities associated with the establishment of a fixed emitter in the Pacific Beach area.” [p. 2-8, EA]
The Northwest Training Range Complex Environmental Impact Statement is a massive document in three volumes (2,713 pages) covering all aspects of land, sea and air operations by the Navy in the Pacific Northwest. In this document, mention is made of possibly installing a fixed emitter at Pacific Beach or some other coastal location. “Pacific Beach, Washington is one potential location for a fixed land based electronic warfare (EW) emitter. This location, or a similar site on the Washington coast, would allow EC training at sea for ships, submarines, and aircraft…].” [p. 2-29, NWTRC EIS; emphasis added]
There was no real environmental assessment done for this possibility other than to acknowledge that the RF radiation could be hazardous, but it was up high on a tower, aimed to the west over the ocean, appropriate warning signage would be employed keeping people and flammable materials at a safe distance. It is also inside of a secure, Navy-owned area, so is of no further concern. Pacific Beach Elementary School, near the tower-mounted emitter is located approximately 2,000 ft. from the proposed tower location. According to the EA this “is well outside any controlled or action level environment where there might be hazardous exposure levels.” [p. 3.1-6, EA]
The US Fish and Wildlife Service Biological Opinion on the NWTRC EIS does not mention the emitter at Pacific Beach or radiation.
The environmental impact of the tower wasn’t adequately addressed in the NWTRC EIS. The environmental impact of the tower is not addressed in the EA, as the claim is made that it was addressed in the NWTRC EIS. They are sliding the tower in sideways.
The mobile emitters
There are two types of vehicle-mounted mobile emitters that are being proposed. One utilizes a Traveling Wave Tube Amplifier (TWTA) capable of generating an electromagnetic wave at frequencies ranging from 4 to 8 GHz. The other is a Magnetron capable of generating an electromagnetic wave at frequencies ranging from 6.7 to 7.4 GHz. One of these (it is unclear which) operates at an approximate peak transmit power of 100 kW and the other at 3 kW. [p. 3.2-26, EA]. Folks, these are high power microwave emitters, by definition. Low power microwaves, in cell phones and such, are generated with transistors and/or diodes. In the NWTRC EIS/OEIS, the tower emitter is likened to cell phones and such, which is totally disingenuous.
Mention of “peak transmit power” implies that these emitters are pulsed. What they are not telling us is the pulse width, the pulse repetition rate, the duty cycle and the average power. These parameters are needed to determine the full hazards. Nevertheless, these emitters can produce electromagnetic hazards. Someone has determined that the minimum distance for safety is about 100 ft. But this only takes into account safety from thermal (heat) effects (burning of skin and eyes). Other known effects are not taken into account. The authors of the EA brush this off with the following: “There are no conclusive direct hazards to human tissue as a result of electromagnetic radiation. Links to DNA fragmentation, leukemia, and cancer due to intermittent exposure to extremely high levels of electromagnetic radiation are speculative; study data are inconsistent and insufficient at this time (Focke et al. 2009).” [p. 3.1-1, EA]
This paper by Focke et al. deals with extremely low frequency radiation (50 Hz) and is therefore completely irrelevant to the GHz radiation proposed (1 GHz = 1 billion Hz). Maybe they should have consulted with the Army. This de-classified Army report on RF weapons outlines several ways that RF radiation can harm mammals. One is thermal: burning and hyperthermia (heat stroke) inducing disorientation. “In prolonged hyperthermia, with temperatures over 40º C to 41º C, the brain suffers severe damage that usually leads to death.” The size of the animal and the wavelength of the radiofrequency are most important. In the Rhesus monkey a frequency of 0.225 GHz at 10 W/kg of body weight caused the body temperature to increase to 42º C within 10-15 minutes. A lower dose of 5 W/kg caused the temperature to increase to 41.5º C in less than two hours. The convulsive threshold for rats is estimated to lie between 22-35 W/gm for one second.
A second method of incapacitating mammals with RF radiation is called “microwave hearing.” Microwave hearing is the sensation of buzzing, ticking, hissing or knocking sounds that originate within the head from pulsed microwaves. There is no sound present. The threshold energy of the microwave auditory response in humans is a function of pulse width and frequency but also varies from individual to individual. For a frequency of 2.45 GHz. the incident energy density per pulse must equal or exceed 20 mJ/kg body weight with pulse widths between 0.5-32 microseconds. Not enough information is given about the mobile emitters to make a determination of this effect. The threshold for animals and birds is not known. The onset is immediate but only lasts as long as the exposure. In addition to disrupting hearing, there might also be an adverse psychological effect.
A third method for incapacitating mammals with RF radiation is disruption of neural control. The neurons are electrically stimulated in a synchronous manner. Electronic stimulation of neural synchrony can be achieved. At just the right frequency, pulse repetition rate and energy, seizure can result. “The condition thought to be necessary to produce [this effect is] an overall [pulse] repetition rate of 15 Hz. Such a field may be developed using a radar-like, high-peak-power, pulsed source…The effective range could be hundreds of meters.” This would vary from individual to individual. Not enough information is given about the mobile emitters to make a determination of this effect.
In addition to these RF weapons outlined by the Army document, the American Academy of Environmental Medicine warns against the cumulative bio-effects of RF background radiation above and beyond thermal effects. The long list of references includes effects in the 2-8 GHz range including oxidative damage to DNA (Xu et al., 2010) and altering gene expression (Lee et al., 2005). Other effects are: motor and cognitive impairment, sleep disorders, behavioral and neurological disorders, pre-natal development disorders and chromosomal instability.
The plan is for the Navy crew to drive the mobile unit to a designated pull-out and set up the 100 ft. radius with warning tape and warning signs (wouldn’t this block all other traffic on the road?). During operation, one of the crew members would be monitoring the site for human or animal intrusion while the other operates the equipment. Should an animal or human enter the “unsafe” zone, the equipment would be turned off and the animal or human would be induced to leave the area. Should the animal or human refuse to leave, the Navy crew would pack up and move to another location.
The authors of the report admit that the radiation can affect the wildlife in various ways: disruption of nesting, behavioral and physiological responses, disruption of sleep-wake cycles, interference with the pineal gland and hormonal imbalance, changes in alarm and aversion behavior and overall deterioration of health and reproductive problems. However, they reassure us that this will not be a problem because they will relocate if they see any animals. [p. 3.2-5, EA]
Besides claiming that there will be no long-term effects because the mobile units are moving around, they also state in many places that the RF beam is directional and pointing at the sky. Birds will fly through it rapidly and will not be exposed for long enough to bother them. Animals on the ground will be outside of the beam, will probably not be around anyway because of the noise or will be deliberately scared off. [p. 5-3, EA]
There is one aspect that is conspicuously missing. Recall that the mission is to identify, locate and destroy or disable the RF source. They do not address this third part: destroy or disable. The NWTRC EIS/OEIS makes a brief mention of simulating the firing of a HARM [High-speed Anti-Radiation] missile. This missile has an inbuilt detector to home in on the RF source. But, presumably, these jets are also equipped with RF weapons, bursts of RF radiation designed to scramble or fry the electronics of the source emitter. Will these be used in the training exercises? If so, they will be pointing downward, toward the source and the forest.
Finally, as stated in the EA: “The Proposed Action would occur on government-owned lands, either operated by the Navy or the USFS. The nature of activities for the Proposed Action would not differ from current uses of these areas.” [p. 5-4, EA]
Oh, yeah. We zap microwaves around the forest all the time.
The USFS has extended the comment period to10/31/2014. Submit your comments online or via e-mail to: firstname.lastname@example.org
Update 11/1/2014: The public comment period has been extended through November 28, 2014.