After being unable to reach agreement through extensive, in-depth consultations, the Navy has decided to terminate consultation under Section 106 of the National Historic Preservation Act (NHPA) regarding a planned increased EA-18G Growler operations at Naval Air Station (NAS) Whidbey Island.
Department of the Navy Federal Preservation Officer Karnig Ohannessian wrote in a letter to John Fowler, executive director of the Advisory Council on Historic Preservation:
"Despite our best efforts to reach agreement among the parties, there remains a disagreement on the type and amount of mitigation appropriate to resolve adverse effects to historic properties that would result from the undertaking. At this time, operational requirements dictate that the Navy make a decision on the undertaking. For these reasons, I have determined that further consultation is no longer productive."
Diificulties due to an unwillingness to separate concerns about historic properties from concerns about other economic and community apprehensions surrounding increased Growler flights at the OLF were cited as the reasons behind the decision.
Termination of consultation is an option provided to the Federal agency under the Section 106 process, when the agency and consulting parties are unable to reach agreement on how to resolve adverse effects.
Since October 2014, the Navy has consulted with the Advisory Council on Historic Preservation (ACHP), Washington State Historic Preservation Officer (SHPO), and local consulting parties to evaluate potential effects to historic properties resulting from the proposed increase in EA-18G Growler airfield operations at the NAS Whidbey Island Complex. The Navy distributed its determination of adverse effect on June 25, 2018 and received concurrence from the SHPO on June 27, 2018.
The Navy’s determination is that indirect adverse effects to the Central Whidbey Island Historic District would result from more frequent aircraft operations. Specifically, the preferred alternative would affect the historic integrity of five landscape viewpoints within the historic district. Subsequently, the Navy initiated a series of meetings and calls with all consulting parties with the intention to reach agreement on appropriate measures to resolve the effects.
In making this decision to terminate the Section 106 consultation, the Navy has considered all measures put forth by the consulting parties and carefully evaluated the nature, scale, and scope of adverse effects on the landscape viewpoints in historic district.
Since August 2018, the Navy conducted a series of meetings with the consulting parties in this resolution phase of the Section 106 process to address ways to resolve the adverse effect on five landscape viewpoints in the historic district. Considerable time has been spent in discussions with the SHPO, consulting parties, and ACHP staff working to explain the undertaking, the Section 106 process, and to evaluate and take into consideration resolution options put forth by the Washington SHPO and all consulting parties and the public.
After careful consideration, the Navy has determined that further consultation under Section 106 will not be productive within the time available to avoid unacceptable impacts to the Navy’s defense mission. This impasse results from an unwillingness to separate concerns about historic properties from concerns about other economic and community apprehensions surrounding increased Growler flights at the OLF. The 106 process is about historic preservation and does not address other possible impacts to the community.
The Navy remains committed to resolving the undertaking’s adverse effects to historic properties. The Navy will continue discussions with community leaders regarding other potential mitigations that should be addressed outside of the NHPA Section 106 process. The Navy has a long collaborative relationship with the local community on mutual concerns, and looks forward to continuing that relationship.
Extensive amplifying documentation is available for review on the Growler Environmental Impact Statement website: http://www.whidbeyeis.com/