March 23, 2007

Commander, Naval Facilities Engineering Command Atlantic
Attn: OLF SEIS Project Manager, Code EV21
6506 Hampton Blvd., Norfolk, Virginia 23508-1278

Dear Sir,

Please accept this letter as a commentary from the Delta Waterfowl Foundation, a non profit waterfowl conservation organization on the subject of the Outlying Landing Field (OLF) at Site C in northeastern North Carolina.

Delta Waterfowl continues to be concerned about the location of Site C as it is in extremely close proximity to the Pocosin Lakes National Wildlife Refuge, which provides critical staging and wintering habitat for waterfowl of the Atlantic Flyway. The refuge and surrounding agricultural fields and associated wetland habitats, host some of the highest densities of migrating and wintering waterfowl present in the Atlantic Flyway. The proposed range of operations and the footprint of the base itself, threaten not only the birds through continual disturbance, but also reducing the available habitat necessary to meet the foraging and roosting needs of the refuges’ flocks.

In addition, the recently released Supplemental Environmental Impact Statement (SEIS), cites several strategies to mitigate the presence of abundant waterfowl to reduce bird strikes. Proposed elements of these strategies include, altering agricultural practices which would reduce the foraging habitat in the areas around the field and have gone as far a suggesting poison as a means to deal directly with the waterfowl “problem.” The reduction of available forage cited above may cause unforeseen negative consequences for the areas waterfowl population. Today, few sites in the Atlantic Flyway provide the mix of habitats necessary to support current population size. The gross reduction of this habitat through manipulation of crops may have long-term implications for the species that have relied on the area as their preferred migrating and wintering habitats.

The issue of poison is much more direct, and its mention is frankly stunning. Waterfowl hunters and other enthusiasts have contributed tremendous sums to maintain waterfowl abundance through habitat conservation efforts, research and scientific management. Attempts to reverse these actions which have fostered abundance through lethal control by means of a poison, which could have significant impacts throughout the ecosystem, are irresponsible in our view.

Finally, we are concerned that the location of Site C, will lead to unnecessary exposure to unsafe conditions to the pilots who will be training in an area that Navy sources have been quoted as being a location of “severe risk” for bird strikes. The servicemen and women of this Country deserve a safer location for their training exercises, a site where bird plane collisions will not be a constant concern.

In conclusion, we urge the Navy to work with the citizens of North Carolina to find a more suitable site for its Outlying Landing Field, a site where the impacts on our waterfowl resource will be lessened and the safety of our servicemen and women will be secured. Thank you for your consideration of our perspective.

Sincerely,

John L. Devney
Senior Vice President