Editor’s note: This op-ed is by Richard Joseph of Winooski and James Marc Leas, a patent lawyer in South Burlington.
While, to its credit, the Air Force revised draft Environmental Impact Statement (EIS) recognizes cognitive impairment of children, heart disease and hearing loss among the problems caused by military aircraft noise, the number of people in Vermont who will be affected by F-35 basing and the magnitude of the effects are shortchanged.
Also to its credit, the Air Force report clearly says that “the contribution of civilian aircraft to noise at Burlington International Airport would be negligible compared to the military aircraft contribution” (page BR4-33).
Also to its credit, the Air Force report says that property within the 65 db DNL (day-night average sound level) contour is “generally not considered suitable for residential use” (page C-14).
It further says that the 65 db DNL “is a level most commonly used for noise planning purposes and represents a compromise between community impact and the need for activities like aviation which do cause noise” (page C-14). It also suggests that the 65 db DNL line does not include an adequate margin of safety for the public. Instead, the revised draft EIS recommends 55 db DNL to provide an adequate margin of safety. The revised draft EIS specifically says that 55 db DNL is “a level ‘… requisite to protect the public health and welfare with an adequate margin of safety,’ (USEPA 1974) which is essentially a level below which adverse impact is not expected” (page C-14).
However, the revised draft EIS fails to provide the 55 db DNL contour line for either the F-16 or the F-35. The Air Force report should be revised to add the 55 db DNL contour so the public, Vermont political and military leaders, and the decision-makers in Washington will know where the contour is outside of which there is an adequate margin of safety. And how large is the area is for which there is no adequate margin of safety? And how many people and homes will be within the area for which there is no adequate margin of safety?
Adverse health effects
The Air Force report states: “… DNL of 75 dB… is the lowest level at which adverse health effects could be credible (USEPA 1974).” (page C-12).
The report says that 770 people will be in noise contours above 75 db DNL if the F-35 is based in South Burlington (page BR4-33). But the Air Force fails to state its recognition that it will be in violation of its own health standard for these 770 people if it decides to base the F-35 in South Burlington.
That serious adverse effects of aircraft noise occur at lower noise levels than the 75 db DNL reported in the revised draft EIS, particularly in children, has emerged as a scientific consensus during the last 10 years. Just as the original Air Force report was revised to include the latest census data, the latest version should be further revised to bring it up to date with current research results.
Not just that. The 39-year-old EPA study on which the 75 db DNL threshold is based is out of date and must be corrected based on more recent studies. These recent studies show adverse health effects at much lower noise levels than 75 db DNL, as described in a 2011 report by the World Health Organization (WHO), “Burden of Disease from Environmental Noise.” Although the revised draft EIS mentions a WHO and NATO study published in 2000, strangely, it omits mention of the 2011 WHO report or any of the other studies published during the past decade.
The Air Force report also omits mention of findings regarding adverse effects of noise on children provided in a training presentation for health care providers that was published by the World Health Organization, “Children and Noise,” updated in 2009. This presentation urges consideration that children are vulnerable to “lifelong impairment of learning and education” (page 15) and says that “over 20 studies have reported that noise adversely affects children’s academic performance” (page 33). It reports the conclusion that aircraft noise adversely affects hearing and cognitive performance of children. With regard to cognitive performance, it reports impairment in reading, memory, auditory discrimination, speech perception, academic performance and attention (page 35). It reports that the strength of evidence for all these scientific findings is at the highest level.
Nor does the revised draft EIS consider the point made in the “Children and Noise” presentation that: “Certain subgroups of children … [are] particularly at risk for harm from excess noise exposure. These include the fetus, babies and very young infants born preterm, with low birth weight or small for gestational age. Also, children who have learning disabilities or attention difficulties may be more likely to develop early problems with mild hearing loss compared to children without these challenges …” (page 13).
The “Children and Noise” presentation provides micrographs showing the damaging effects of repeated exposure to high noise levels on the hair cells in the ear that are responsible for sensing sounds and transforming them into nerve impulses. Such trauma to the hair cells results in hearing loss.
The Air Force report also does not mention a U.S. Environmental Protection Agency letter commenting on the draft EIS for the F-35 beddown at Eglin Air Force Base in Florida (November 2010): “EPA is particularly concerned over noise impacts to children per Executive Order 13045: Protection of Children from Environmental Health Risks and Safety Risks. E.O. 13045 recognizes children may suffer disproportionally from environmental health risks and safety risks. Because their smaller ear canals magnify the sounds entering the ear canals, children’s hearing may be particularly sensitive. For example, a 20-decibel difference can exist between adult and infant ears.”
That serious adverse effects of aircraft noise occur at lower noise levels than the 75 db DNL reported in the revised draft EIS, particularly in children, has emerged as a scientific consensus during the last 10 years. Just as the original Air Force report was revised to include the latest census data, the latest version should be further revised to bring it up to date with current research results.
What you can do
Readers are encouraged to email comments saying that the F-35 should not be based at the airport in South Burlington, and indicating your concerns about the plane and/or deficiencies in the revised draft EIS to Air Force Civilian Project Manager Nickolas Germanos before the July 15 public comment period deadline: nicholas.germanos@langley.af.mil
