Over the course of the past six years, the primary focus of Citizens Concerned About Jet Noise (CCAJN) has been the widely-acknowledged adverse impacts of jet aircraft noise and accident risk. While these two issues remain a primary focus of CCAJN, the Navy’s Environmental Impact Statement clearly indicates that increased aircraft air emissions that will result from siting Super Hornet aircraft at NAS Oceana is a cause for equal concern and demands equal attention.
Unfortunately, neither CCAJN, nor the media or elected officials have, to this point, satisfactorily addressed this issue. For its part, CCAJN will be working to correct this awareness deficit and hopes that the media and elected officials will soon treat Super Hornet generated air pollution in a responsible manner.
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Jet aircraft exhaust contains high levels of Volatile Organic Compounds (VOCs) and Oxides of Nitrogen (NOx). These two air pollutants, when acted upon by sunlight, chemically react over time to produce ozone. Prevailing winds disperse these pollutants and often cause areas as far away as Hampton, Suffolk, and the Eastern Shore to be as severely ozone-impacted as areas near NAS Oceana and NALF Fentress.
The Environmental Protection Agency (EPA) describes area ozone generation and migration at its website: http://www.epa.gov/airnow/mapselect.html. For example, on July 17, 2002, the Virginia Department of Environmental Quality (VDEQ) recorded the highest unhealthy ozone level for the year in this area. When you open this link you will see red areas indicating unhealthy air quality. Note that an area of unhealthy ozone originates over Virginia Beach and, over time, expands to include areas remote from Virginia Beach.
Ozone, itself, has both a good and bad character. In the upper atmosphere, ozone protects us from harmful solar radiation. However, when it is produced near ground level, it is recognized as a potentially serious health hazard by the EPA.
Ozone is a respiratory tract and lung irritant. Symptoms range from nose and throat irritation to coughing, breathing difficulty, and chest pain. Other toxic effects include changes in blood chemistry, liver function, nervous system response, visual acuity, and susceptibility to infection. EPA-recognized studies show that high levels of ground-level ozone are associated with 10-20 percent of summertime respiratory-related hospital admissions.
Further, EPA has concluded that ozone can aggravate pre-existing respiratory conditions such as asthma, and long-term exposures to ozone can cause repeated inflammation of the lungs, impairment of lung defense mechanisms, and irreversible changes in lung structure, which could lead to premature aging of the lungs and/or chronic respiratory illnesses such as emphysema and bronchitis. Children and the elderly are most at risk. See: http://www.epa.gov/ttn/oarpg/naaqsfin/o3fact.html.
The VDEQ is the state agency responsible for ensuring that the public is adequately protected from ozone pollution by monitoring the emission of primary pollutants, restricting emissions to levels that will maintain a healthy environment, and for enforcing appropriate EPA regulations. Ozone concentrations are measured in parts per million (PPM). Two federal criteria establish maximum air quality ozone threshold conditions above which air is considered unhealthy. These are: 0.12 PPM of ozone for a one (1) hour period and 0.08 PPM of ozone for an eight (8) hour period.
According to the VDEQ, in 2002 to date (Note: before the arrival of any Super Hornets), one or both of these threshold criteria were exceeded a total of 41 times resulting in unhealthy ozone levels in this area in violation to federal and state regulation. http://www.marama.org/ozone/2002/browsePA.idc?area=Hampton+Roads. In 2001 there were 9 such violations.
The Hampton Roads Region was an EPA-designated non-attainment air quality region until 1997 when it was re-designated as an “attainment area subject to a Maintenance Plan” after demonstrating that measures taken to improve air quality had been effective. The VDEQ prepared the Maintenance Plan that established air emission budgets for NAS Oceana, effective through 2008. To accommodate the anticipated arrival of 156 Hornet aircraft from NAS Cecil Field, the VDEQ authorized an increase to the NAS Oceana air emissions budget for VOCs.
Specifically, NAS Oceana was permitted to increase VOC emissions by 200 tons from 319 tons per year to 519 tons per year. The 519 ton per year allocation was to remain constant through 2008.
After the arrival of Hornet aircraft in late 1998, however, Clean Air Act violations have become increasingly frequent.
In October 2001, the EPA advised the VDEQ that the Region failed to meet EPA air quality standards and directed the VDEQ to prepare a Contingency Plan by October 2002 that would implement measures to bring the Region into compliance with the Maintenance Plan.
And, as can be seen by the data for 2002, the situation is getting much worse.
Thus, it is clear that instead of ensuring that public health was adequately protected, the VDEQ short-sightedly authorized increases in pollutant budgets at NAS Oceana that virtually ensured that the quality of the Region s air would become increasingly unhealthy.
Even more alarming, the Navy acknowledges that siting all the Super Hornet aircraft at NAS Oceana, even with an Outlying Landing Field, will increase VOC emissions by more than 136 additional tons (total 951 tons/year) annually relative to a new 2000 Baseline of 815 tons per year. This new Baseline itself, however, exceeds the VDEQ authorized emissions budget for VOCs by an astonishing 296 tons per year.
This enormous increase is explained in the DEIS as a result of differing computational methods employed by the Navy and the VDEQ. The establishment of a new baseline, however, may indicate that the Navy has routinely exceeded its VOC emission allocation for several years and therefore been a significant factor in the inability of the Region to meet the clean air objectives of the VDEQ Maintenance Plan.
Further, it appears that despite the fact that the VDEQ limited the Navy in 1997 to a VOC emission budget of 519 tons per year level thru 2008, the Navy apparently is prepared to ask the VDEQ to increase its budget, not by 136 tons per year, but by 432 (136 + 296) tons per year..
The DEIS indicates that the Navy would exceed the de minimis level for VOCs by 36 tons per year (36%) under the “Bring em All” scenario(Alternative 1) and using the 2000 Baseline emissions budget. [Note: The de minimis level for VOCs for Oceana is 100 additional tons per year.] In actuality, however, the alternative that would site all the East Coast Super Hornets at Oceana appears to exceed the VOC de minimis level by 332 tons per year or by 332%.
These facts beg several questions:
Why has this information been concealed from the public and why has the VDEQ, the agency responsible for protecting us, not contributed to this discussion?
How can the navy and elected officials responsibly consider bringing all the Super Hornets to NAS Oceana under the current conditions of the Region s unhealthy air quality?
How can responsible elected officials and Chamber of Commerce officials promote single-siting knowing full well that North Carolina will successfully obstruct the building of an OLF if that state gets none of the aircraft?
How can the VDEQ reverse itself and grant the Navy an increase in its budget of ozone-producing air emissions when the Navy has apparently exceeded its VOC budget for the past three years?
Why doesn’t the VDEQ require the Navy to demonstrate clearly that it is not comparing “apples with oranges” when it uses a new air emissions baseline.
Who is looking after the interests of local residents? Apparently, not the VDEQ.
