Case 2:19-cv-01059-RAJ-JRC Document 43 Filed 02/13/20 Page 1 of 3

1
The Honorable Richard A. Jones
2
3
4

6 IN THE UNITED STATES DISTRICT COURT

FOR THE WESTERN DISTRICT OF WASHING TON
7 AT SEATTLE
8
STATE OF WASHINGTON, CITIZENS
9 OF THE EBEY'S RESERVE FOR A
HEALTHY, SAFE AND PEACEFUL NO. 2:19-cv-01062-RAJ-JRC
10 ENVIRONMENT; and
PAULA SPINA,
11 DECLARATION OF
12 Plaintiffs, JAMIE STEPHENS, SAN JUAN
COUNTY COUNCIL MEMBER
13 v.

14 UNITED STATES DEPARTMENT OF

THE NAVY, et al.,
15

16 Defendants.

17
Pursuant to 28 U.S.C. § 1746 and under penalty of perjury, I, JAMIE STEPHENS, declare
18

19 that the following is true and correct:

20 1. I am over the age of 18 and competent to testify in this matter. The information in

21 this declaration is based on my personal knowledge.

22 2. I am a member of the San Juan County Board of County Council. The County
23
Council voted on February 11, 2020 for me to make this statement on behalf of the entire Council.
24
3. San Juan County borders Island County and Whidbey Island. Our islands are as
25
close to Ault field as OLF and Anacortes, Washington.
26

Bricklin & Newman, LLP

Attorneys at Law
1424 Fourth A,·enuc, Suite 500
Deel. of County Commissioner Stephens, Case No. 2:19-cv-01062-RAJ-JRC - 1 Seattle \\IA 98101
Tel. (206) 264-8600
Fax. (206) 264-9300
 Case 2:19-cv-01059-RAJ-JRC Document 43 Filed 02/13/20 Page 2 of 3

1 4. There are approximately 16,000 residents in the County. We receive over a million

2 visitors a year who come for the solitude and rural character. It is home to the San Juan Islands
3
National Monument.
4
5. The Growlers that fly out of Naval Air Station Whidbey affect our islands,
5
especially on Lopez and the south end of San Juan. The planes produce deafening noise that affects
6

7 schools and the conducting of business. The noise impacts visitors and residents alike.

8 6. The increased noise from the "Growlers" has affected real estate sales to the point

9 of putting disclaimers on listings. There has been no actual noise monitoring only computer
10
modeling. We have expressed these concerns to the Navy in commenting on the Draft
11
Environmental Impact Statement. See Exhibit A. These concerns were also voiced in a four county
12
comment letter on the DEIS. Nevertheless, the Navy has been unresponsive to our concerns.
13
Instead, the Navy adopted a Record of Decision that increases the number of Growler's operating
14

15 out of Whidbey NAS-and over our County.

16 7. The Navy's implementation of the Record of Decision has resulted in a considerable

17 increase in noisy Growler's affecting our County's residents and visitors. Noise complaints to San
18
Juan County's website are up 59% over prior years since the record of decision. See Exhibit B.
19
8. I understand that the plaintiffs in this lawsuit are seeking a preliminary injunction
20
to reduce the Growler flights to their pre-ROD levels during the pendency of the litigation. The
21
injunction would benefit Whidbey Island as well as the surrounding communities and residents of
22
23 San Juan County. The peace, tranquility, and rural character that our visitors expect will improve

24 greatly from a reduction in "Growler" operations.

25 I declare under penalty of perjury that the foregoing is true and correct.
26
Dated this/2/1{ day of February, 2020, in § /.
I ~ /
/«--J- .~-, Washington.
Bricklin & Newman, LLP
Attorneys at Law
1424 Fo urth Avenue, Sui te 500
Deel. of County Commissioner Stephens, Case No. 2: 19-cv-01062-RAJ-JRC - 2 Seattle WA 9810 1
Tel. (206) 264-8600
Fax. (206) 264-9300
 Case 2:19-cv-01059-RAJ-JRC Document 43 Filed 02/13/20 Page 3 of 3

~~
2
3 By/ ',;i'_;?uf·
JAMIE STEPHEN,S/
4 SAN JUAN COUNTY COUNCIL MEMBER
5

10

11

12

13

14

15

16

17

18

19

20
21

22
23

24

25

26

Bricklin & N ewman, LLP

Attorneys at Law
1424 Fourth Avenu e, Suite 500
Deel. of County Commissioner Stephens, Case No. 2:19-cv-01062-RAJ-JRC - 3 Seattle WA 9810 1
T cl. (206) 264-8600
Fa.,. (206) 264-9300