2015-05-29 declaration of joseph j. czech (with appendice)

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CZECH DECLARATION - 1 - U.S. Department of Justice 7600 Sand Point Way NE No. 2:13-cv-1232-TSZ Seattle, WA 981115 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 District Judge Thomas S. Zilly IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF WASHINGTON AT SEATTLE CITIZENS OF THE EBEY’S RESERVE FOR A HEALTHY, SAFE & PEACEFUL ENVIRONMENT, Plaintiff, v. U.S. DEPARTMENT OF THE NAVY; ADMIRAL PHIL DAVIDSON, in his official capacity as the Commander, Fleet Forces Command; and CAPTAIN MIKE NORTIER, in his official capacity as Commanding Officer Naval Air Station Whidbey Island, Defendants, No. 2:13-cv-1232-TSZ DECLARATION OF JOSEPH J. CZECH I, Joseph J. Czech, Senior Lead Engineer at Wyle Laboratories, Incorporated, do hereby declare as follows: 1. I have extensive experience modeling and studying military aircraft noise. I have reviewed the JGL study provided by Plaintiff in this case, and have found it to be flawed. It also does not present any new information that is significantly different than that already presented in the two 2004 Wyle Reports, the 2005 Environmental Assessment, or 2005AICUZ study. 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Case 2:13-cv-01232-TSZ Document 45 Filed 05/29/15 Page 1 of 7

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  • CZECH DECLARATION - 1 - U.S. Department of Justice 7600 Sand Point Way NE No. 2:13-cv-1232-TSZ Seattle, WA 981115

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    District Judge Thomas S. Zilly

    IN THE UNITED STATES DISTRICT COURT

    FOR THE WESTERN DISTRICT OF WASHINGTON

    AT SEATTLE

    CITIZENS OF THE EBEYS RESERVE FOR A HEALTHY, SAFE & PEACEFUL ENVIRONMENT, Plaintiff, v. U.S. DEPARTMENT OF THE NAVY; ADMIRAL PHIL DAVIDSON, in his official capacity as the Commander, Fleet Forces Command; and CAPTAIN MIKE NORTIER, in his official capacity as Commanding Officer Naval Air Station Whidbey Island, Defendants,

    No. 2:13-cv-1232-TSZ DECLARATION OF JOSEPH J. CZECH

    I, Joseph J. Czech, Senior Lead Engineer at Wyle Laboratories, Incorporated, do hereby declare as follows: 1. I have extensive experience modeling and studying military aircraft noise. I have reviewed the JGL study provided by Plaintiff in this case, and have found it to be flawed. It also does not present any new information that is significantly different than that already presented in the two 2004 Wyle Reports, the 2005 Environmental Assessment, or 2005AICUZ study.

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    Case 2:13-cv-01232-TSZ Document 45 Filed 05/29/15 Page 1 of 7

  • CZECH DECLARATION - 2 - U.S. Department of Justice 7600 Sand Point Way NE No. 2:13-cv-1232-TSZ Seattle, WA 981115

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    BACKGROUND 2. I am a senior lead engineer with Wyle Laboratories, Inc. (Wyle) with a Bachelors Degree in Aerospace Engineering from California State Polytechnic University, Pomona. I am a licensed Professional Engineer in the State of California in the discipline of Mechanical Engineering. I am a member of the Acoustical Society of America. 3. I have been doing research and consulting in the field of acoustics and aircraft noise, including noise modeling, for 27 years, mostly with my current employer Wyle Laboratories Inc. I began conducting aircraft noise studies for Wyle for the Navy in 1993 and was Wyles principal engineer for dozens of Navy aircraft noise studies in the 1990s. In 1994, in support of the Base Realignment and Closure Act of 1993, I authored an aircraft noise study analyzing A-6/EA-6 and P-3 aircraft operations at NAS Whidbey Island (NASWI) and Outlying Landing Field Coupeville (OLF Coupeville). I helped develop the Navys Air Installation Compatible Use Zone (AICUZ) Seminar and its Student Guide. I co-instructed the Seminar on two occasions. I was one of the measurement personnel for the acoustic tests of the FA-18E/F Super Hornet in the late 1990s. These acoustic tests furnished the reference acoustic data for the FA-18E/F, upon which modeling of the EA-18G Growler is based.1 I assisted with early modeling of the FA-18E/F for studies related to its introduction to facilities on the East Coast of the United States. More recently, I was Wyles project manager and principal investigator for aircraft noise for a Supplemental EIS for the Introduction of the P-8A Poseidon at NASWI and NAS Jacksonville. I co-authored the noise study supporting the 2012 EA for the proposed transitions of expeditionary EA-6B Prowler squadrons to EA-18G Growler aircraft. 4. I am Wyles Project Manager for the noise study associated with the ongoing EA-18G Growler EIS. Although I was not working with Wyle in 2004 when the Noise Study was published, I have since become familiar with the study by reviewing the report, and underlying data, and the AICUZ study2 that was based on the 2004 Wyle study as part of my responsibilities for the ongoing EA-18G EIS noise study.3 5. I have been involved with noise studies for the introduction of new aircraft. In addition to several studies of the MV-22B Osprey, I have been the Project Manager and investigator for the noise studies for the introduction of all three variants of the F-35 Lightning II (also known as the Joint Strike Fighter) for the United States Air Force, Marine Corps and Navy. I have provided

    1 EA-18G Growler modeling with DODs NOISEMAP suite of programs utilizes the NOISEFILE database and the FA-18E/F reference acoustic data therein. 2 Pursuant to DOD Instruction 4165.57, the AICUZ program requires that air installations engage State and local governments and communities to foster compatible land use. 3 The study supporting the AICUZ was Wyle Report 04-26 Aircraft Noise Study for Naval Air Station Whidbey Island and Outlying Landing Field Coupeville, Washington. Wyle Report 04-26 and Wyle Report 04-08, Operational Noise Comparisons between EA-6B and EA-18G at NAS Whidbey Island and OLF Coupeville; (Wyle Reports) support the Environmental Assessment for Replacement of EA-6B Aircraft with EA-18G Aircraft at Naval Air Station Whidbey Island, Washington, (2005 EA) dated January 2005. In this declaration, any reference to data found in the AICUZ is thus also a reference to Wyle Report 04-26 and the 2005 EA, which incorporates Wyle Report 04-08.

    Case 2:13-cv-01232-TSZ Document 45 Filed 05/29/15 Page 2 of 7

  • CZECH DECLARATION - 3 - U.S. Department of Justice 7600 Sand Point Way NE No. 2:13-cv-1232-TSZ Seattle, WA 981115

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    engineering support for the detailed acoustic measurements of the F-35A, F-35B, FA-18C/D Hornet, FA-18E/F and MV-22B Osprey. 6. I have authored the latest version, Version 7.3, of the core program (NMAP) of the Department of Defenses (DOD) NOISEMAP suite of computer modeling programs, which is used to develop contours of Day-Night Average Sound Level (DNL) around air stations and OLFs. I co-authored Version 7.0 of NMAP in 1998 which incorporated the modeling and effects of ground elevation and impedance4 into the computations, and I have taught DOD-sponsored training courses for NOISEMAP on several occasions. 7. Aircraft noise modeling primarily entails the gathering and entry of information for input to DODs NMAP program, which is part of the NOISEMAP suite of programs. NMAP requires the following categories of information: general airfield information (runway coordinates, weather data, etc), flight tracks, flight events and flight profiles,5 static run-up locations, static events and static profiles.6 The flight tracks, events and flight profiles are specific to aircraft type and type of operation (departure, arrival, closed pattern). For the EA-18G at the OLF this data is also specific to time/period of day. For the computation of the Day-Night Average Sound Level (DNL) metric, all of this information, except for the general airfield information, needs to be applicable to a 24-hour day. All of this information is typically gathered via interviews with station and squadron personnel and approved by them via data validation packages prior to execution of the program. 8. The NOISEMAP suite of programs includes the NOISEFILE database, which is a database of measured sound levels for most type/model/series of fixed-wing aircraft in the DOD inventory.7 9. The NMAP program computes DNL at hundreds or thousands points on the ground from the information gathered from station and squadron personnel and from the information in the NOISEFILE database. Another program in the suite called NMPlot produces the DNL contours. 10. A variety of metrics can be used to measure sound. Two of them specifically for individual aircraft events include Maximum Sound Level (Lmax) and Sound Exposure Level (SEL). As an aircraft flies over or near you, the sound increases in intensity, reaches its maximum sound level, and then decreases in intensity until below the ambient sound level. The maximum sound level during the event is the Lmax. SEL is the most common measure of cumulative noise exposure for a single aircraft flyover. If one takes all of the sound energy occurring throughout the event and

    4 Ground impedance is a measure of the ability of the ground cover (e.g., grass, plowed earth, water surface) to absorb or reduce sound. 5 A flight profile consists of points of altitude, power setting and speed along a flight track. 6 A static event is a maintenance run-up where the aircraft or engine is stationary and is operated at power for a duration of time. A static location is where the run-up physically occurs. A static profile consists of power setting, duration, number of engines and heading associated with a static event. 7 Type refers to the mission of the airplane, model refers to the model number, and series refers to the generation of the aircraft. For example, for the EA-18G, EA refers to type (Electronic Attack), 18 refers to the model, and G refers to series.

    Case 2:13-cv-01232-TSZ Document 45 Filed 05/29/15 Page 3 of 7

  • CZECH DECLARATION - 4 - U.S. Department of Justice 7600 Sand Point Way NE No. 2:13-cv-1232-TSZ Seattle, WA 981115

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    compresses it into one second, the SEL is the result, which represents the total sound energy of an event. The duration of aircraft events depends heavily on the aircrafts speed and its distance from the receiver; most events are 10-20 seconds in duration. Because the SEL is normalized to one second, it will almost always be larger in magnitude than the Lmax for the event. 11. Equivalent Sound Level (Leq) is a cumulative metric in that it represents the decibel average of all sounds in the time period for which it is intended. If Leq covers a 24-hour day, it is denoted Leq(24). 12. DNL is the same as Leq but penalizes sounds occurring during the DNL nighttime period (i.e., 10 p.m. to 7 a.m., also known as DNL night or acoustic night), by 10 dB. For example, if an aircraft event generates an SEL of 100 dB and that event occurs during the DNL nighttime period, 10 dB is added to the SEL, making the SEL effectively 110 dB. This 10 dB penalty is applied to account for greater sensitivity to nighttime noise. Also, events at night are often perceived to be more intrusive because nighttime ambient noise is less than daytime ambient noise. Another way to look at DNLs 10 dB penalty (and the way NOISEMAP computes DNL) is that each nighttime event is equivalent to 10 daytime events. Thus, DNL is calculated by the equation: DNL = + 10log10(Nd + 10Nn) 49.4, where is the decibel average SEL by the aircraft of interest, Nd is the number of daytime (7 a.m. 10 p.m.) events by that aircraft, Nn is the number of nighttime (10 p.m. 7 a.m.) events by that aircraft and 49.4 is 10log10 of the number of seconds in a day. 13. Energy averaging, or decibel summation, is logarithmic;8 it is not a statistical mean. This logarithmic nature means that higher sound levels tend to dominate the Leq and DNL. As a simple example, consider a case in which only one aircraft overflight occurs during the daytime over a 24-hour period, creating a sound level of 100 dB for 30 seconds. During the remaining 23 hours, 59 minutes, and 30 seconds of the day, the ambient sound level is 50 dB. The DNL for this 24-hour period is 65.9 dB. Assume, as a second example that 10 such 30-second overflights occur during daytime hours during the next 24-hour period, with the same ambient sound level of 50 dB during the remaining 23 hours and 55 minutes of the day. The DNL for this 24-hour period is 75.5 dB. Clearly, the averaging of noise over a 24-hour period does not ignore the louder single events and tends to emphasize both the sound levels and number of those events. Even Mr. Lillys extreme hypothetical example, Lilly Decl. 14, proves this point. If one days DNL was nearly 104 dB and the other 364 days were 0 dB DNL, the resultant annual average DNL would be 78 dB. Thus, the resultant DNL is clearly dominated by the 1-days value. The statistical mean of these 365 daily DNLs would be less than 1 dB. 14. DNL is the metric required by DOD for assessing aircraft noise impacts. DOD and Navy land use compatibility guidelines generally call for the 24-hour period used to compute DNL to be an annual average day (AAD), i.e., annual average daily aircraft operations, tracks, profiles, etc., consistent with FAA guidelines for civilian airports.9 Although aircraft operations at military airfields are not constant (as they may be at civilian airports), the AAD requirement

    8 Logarithmic means that the value increases on orders of magnitude (i.e., a tenfold increase) rather than a standard linear scale. 9 14 CFR Part 150

    Case 2:13-cv-01232-TSZ Document 45 Filed 05/29/15 Page 4 of 7

  • CZECH DECLARATION - 5 - U.S. Department of Justice 7600 Sand Point Way NE No. 2:13-cv-1232-TSZ Seattle, WA 981115

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    allows for standardization across all DOD airfields and equal treatment of aircraft noise assessments in all services. 15. The JGL study (the study), cited by Plaintiff, did not specify the following important parameters typical of aircraft noise studies:

    a) Which runway of the OLF was active; b) Whether windows were open or closed at Position 5; c) The weather conditions (temperature, relative humidity, wind speed and direction); and d) Photographs of each noise measurement location (the study only shows photographs of

    positions 1 and 4); e) Whether the sound level meters were American National Standards Institute Type 1 or

    2.10 16. The study had insufficient sampling (a 1-hour snapshot at 4 and 5 sites) to challenge the AICUZs DNL results. The DOD NOISECHECK guidelines require measurements at many (tens) of points on the ground.11 The length of the measurement program prescribed by the NOISECHECK guidelines varies based on the elevation angle (angle between the Point of Interest (POI) or receiver and the aircraft) and slant distance (distance between the POI/receiver and the aircraft), but could result in days or months of measurements. With FCLP activity occurring at the OLF approximately 40 days per year on average, a sample size of at least 10 flying days throughout the year would be reasonable. It would also be better to measure simultaneously at multiple sites rather than this studys strategy of a snapshot at one site and another snapshot of a different (not necessarily overlapping) time at another site. Simultaneous measurements allow for correlation between sites. Correlation between sites helps determine non-aircraft noise events. 17. The maximum A-weighted12 levels cited in the studys Table 1 for Positions 1 through 3 are not substantiated by the studys Figures 3 through 5. For Position 1, Figure 3 does not annotate the fast Lmax (Lmax,fast).13 For Position 2, Figure 4 shows 112.8 dBA Lmax,fast, not 113.4 dBA. For Position 3, Figure 5 shows 115.1 dBA Lmax,fast, not 115.7 dBA.

    10 The type of sound level meter dictates the accuracy. Type 1 is up to 1 dB more accurate than Type 2. Type 1 is standard practice for community/aircraft noise while Type 2 is acceptable for general purpose noise surveys/OSHA. 11 Bishop et al 1980. Bishop, Dwight E.; Harris, Andrew; Mahoney, Joan; and Rentz, Peter E., 1980. NOISECHECK Procedures for Measuring Noise Exposure from Aircraft Operations. Bolt, Beranek, and Newman Inc., November 1980. 12 Sounds with different spectra are perceived differently even if the sound levels are the same. Weighting curves have been developed to correspond to the sensitivity and perception of different types of sound. A-weighting is one of two of the most common weightings. The A-weighting mimics the sensitivity of the human ear to non-impulsive sounds such as aircraft noise, de-emphasizing the content of the sound below 1,000 Hertz (Hz) and higher than 4,000 Hz while emphasizing the content of the sound between 1,000 and 4,000 Hz. An impulsive type of sound would be a bang or an explosion. Such emphasis is made because the human ear is less sensitive to low frequency sound than mid-high frequency sounds from non-impulsive sources. 13 Most sound level meters (SLM) have two settings slow and fast. On the slow setting, the SLM averages sound every second and outputs the resultant level. On the fast setting, the SLM averages

    Case 2:13-cv-01232-TSZ Document 45 Filed 05/29/15 Page 5 of 7

  • CZECH DECLARATION - 6 - U.S. Department of Justice 7600 Sand Point Way NE No. 2:13-cv-1232-TSZ Seattle, WA 981115

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    18. The maximum A-weighted levels cited in the studys Table 1 are misleading because they used the fast setting on the sound level meter. Noise measurements of aircraft in the vicinity of airfields typically use the slow setting on sound level meters. Although the study states it measured one-second Leq values on page 1, it inconsistently reports Lmax,fast in Table 1. 19. The studys Table 1 overstates the maximum sound levels during the events. The maximum one-second Leq values for Positions 1 through 5 were 116.6 dBA, 110.9 dBA, 112.1 dBA, 114 dBA and 81.1 dBA, respectively. These maximum one-second Leq values are up to 3.6 dB less than the mostly Lmax,fast values in Table 1. 20. The study does not substantiate its claim on page 2 that some hearing damage criteria are based on the un-weighted peak sound pressure level. 21. The study states that the chosen measurement locations represent populated areas where -people could be exposed to the aircraft noise without necessary hearing protection and that one of the purposes of the study was to determine whether there is a need to examine possible impacts on the health and well-being of those exposed. The best choice of the type of location to fulfill these purposes would be locations representing residential land use. However, both Positions 2 and 4 represent locations with only transient, not long-term population. Position 2 is a bird watching platform at beach near ferry dock. The land use at Position 4 (Rhododendron Park Baseball Field) is recreational and its population is seasonal and temporary at best. Positions 2 and 4 are not representative of residential land use in the vicinity of the OLF. 22. The studys Table 2 presents durations above various sound thresholds but does not tie them to OSHA or DOD hearing loss criteria. Note that Table 2 is only for 1 session of FCLPs. Although an outdoor DNL of 80 dB is the DODs screening criteria for the potential for hearing loss (mostly at Position 1), DOD generally recognizes that it would require decades of continuous outdoor exposure to such or similar levels, on the order of 40 years, to affect a minimally noticeable hearing loss of 5 dB.14 23. The studys Table 3 is based on extrapolating part of a particular days measurements whereas the AICUZ study was based on annual average daily operations (24-hours). The study is making a false comparison between the JGL collected data and the data found in the AICUZ. To make an accurate comparison, either the AICUZs DNLs would have to be adjusted to reflect the days measurements, i.e., to the counts of aircraft events during the sessions, or DNL would have to be computed from the measured SELs and numbers of events. Also, Table 3 compares the 2005 AICUZs results to various combinations of DNL daytime and nighttime FCLP sessions without justification or explanation of the combinations. For example, it shows 2 daytime sessions and 2 night sessions in bold implying that is what was being flown by the Navy. Checking the calculations in Table 3, Mr. Lilly incorrectly assumes a Navy night

    sound every one-eighth of a second and outputs the resultant level. It is customary to report data from the slow setting for aircraft noise measurements like the kind Lilly did. 14 Department of Defense Noise Working Group, Technical Bulletin, Noise-Induced Hearing Impairment, July 2012.

    Case 2:13-cv-01232-TSZ Document 45 Filed 05/29/15 Page 6 of 7

  • Case 2:13-cv-01232-TSZ Document 45 Filed 05/29/15 Page 7 of 7

  • Exhibit 1

    Case 2:13-cv-01232-TSZ Document 45-1 Filed 05/29/15 Page 1 of 4

  • WR1022(October2012) Page|37

    7.2 LowFrequencyNoiseThe sound levels in this report are in A-weighted decibels. Sound frequency is the number of times per second the air vibrates or oscillates per second and has units of Hertz (Hz). The normal human ear can detect sounds that range in frequency from about 20 Hz to about 15,000 Hz. All sounds in this wide range of frequencies, however, are not heard equally by the human ear, which is most sensitive to frequencies in the 1,000 to 4,000 Hz range. Weighting curves have been developed to correspond to the sensitivity and perception of different types of sound. A- and C-weightings are the two most common weightings and are shown in Figure 7-3. A-weighting accounts for frequency dependence by adjusting the very high and very low frequencies (below approximately 500 Hz and above approximately 10,000 Hz) to approximate the human ears lower sensitivities to those frequencies. C-weighting is nearly flat throughout the range of audible frequencies, hardly de-emphasizing the low frequency sound while approximating the human ears sensitivity to higher intensity sounds.

    Source: ANSI S1.4A -1985 Specification of Sound Level Meters

    Figure73FrequencyResponseCharacteristicsofAandCWeightingNetworks

    These two weightings are adequate to quantify most types of environmental noises. Aircraft noise is assessed for land use compatibility in terms of A-weighted decibels (of Day-Night Average Sound Level). To assess the potential for structural vibration, rattle or damage, C-weighting is utilized.

    Normally, the most sensitive components of a structure to airborne noise are the windows and, infrequently, the plastered walls and ceilings. An evaluation of the peak sound pressures impinging on the structure is normally used to determine the possibility of damage. In general, with peak sound levels above 130 dBC, there is the possibility of the excitation of structural component resonances. While certain frequencies (such as 30 Hz for window breakage) may be of more concern than other frequencies, conservatively, only sounds lasting more than one second above a sound level of 130 dBC are potentially damaging to structural components (Committee on Hearing, Bioacoustics, and Biomechanics 1977).

    31.5 63 125 250 500 1000 2000 4000 8000 16000

    Frequency (Hertz)

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    -10

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    Rel

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    deci

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    A-weightedC-weighted

    No. 2:13-cv-1232-TSZ

    Exhibit 1 to Czech Declaration

    Case 2:13-cv-01232-TSZ Document 45-1 Filed 05/29/15 Page 2 of 4

  • WR1022(October2012)Page|38

    Noise-induced structural vibration may also cause annoyance to dwelling occupants because of induced secondary vibrations, or rattling of objects within the dwelling such as hanging pictures, dishes, plaques, and bric-a-brac. Window panes may also vibrate noticeably when exposed to high levels of airborne noise. In general, such noise-induced vibrations occur at peak sound levels of 110 dBC or greater. Assessments of noise exposure levels for compatible land use should address the potential for noise-induced secondary vibrations.

    NASWI has received complaints of building rattle/vibration due to Growler events. Figure 7-4 shows the unweighted one-third octave band spectra from the acoustic reference database (Noisefile). It is important to note that the databases condition is for the aircraft at an altitude of 1000 ft AGL and the receiver located on the ground directly below the aircraft. The Growlers unweighted spectral levels are, on average, 11 dB greater than the Prowler during a Mil power takeoff passing through 1000 ft AGL for frequencies less than 50 Hz. For approaches and cruise power at 1000 ft AGL the frequency spectra of the two aircraft are similar for frequencies less than 50 Hz with average differences of 3 to 5 dB. With its increased low-frequency content, the Growler takeoff events have higher potential to cause noise-induced vibration.

    Using the acoustic reference data, the overall C-weighted sound levels for both aircraft for these three conditions are contained in Table 7-4. Due to the EA-6Bs spectra sound levels, especially in frequencies minimally affected by the C-weighting, C-weighted sound levels for the EA-6B and EA-18G only differ by 1-2 dBC for the takeoff and approach conditions. In cruise flight, the C-weighted sound levels for the EA-6B are approximately 8 dBC greater than EA-18G. None of these conditions cause C-weighted sound levels to exceed 130 dBC and structural damage would not be expected, however, the takeoff condition has C-weighted sound levels greater than 110 dBC for both aircraft, creating an environment conducive to noise-induced vibration. Additional analysis is recommended to more accurately determine the potential for building rattle/vibration.

    Table74CweightedSoundLevels,1000ftAGL

    Condition EA-6B EA-18G

    EA-18G Relative to EA-6B

    Takeoff 116 115 -1Approach

    (gear down)

    111 109 -2

    Cruise 109 101 -8

    No. 2:13-cv-1232-TSZ

    Exhibit 1 to Czech Declaration

    Case 2:13-cv-01232-TSZ Document 45-1 Filed 05/29/15 Page 3 of 4

  • WR1022(October2012) Page|39

    a) Takeoff

    b) Cruise

    c) Approach

    Figure74ComparisonofSoundSpectraforEA6BandEA18G(1000ftAGL,59F,70%RH)

    10 100 1000 10000Frequency (Hz)

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    60

    80

    100

    EA-6B = 95% RPMEA-18G = 96% NC

    C-weighted Sound LevelsEA-6B = 116 dBCEA-18G = 115 dBC

    10 100 1000 10000Frequency (Hz)

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    60

    80

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    EA-6B = 85% RPMEA-18G = 85% NC

    10 100 1000 10000Frequency (Hz)

    40

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    EA-6B = 85% RPMEA-18G = 84% NC

    C-weighted Sound LevelsEA-6B = 111 dBCEA-18G = 109 dBC

    No. 2:13-cv-1232-TSZ

    Exhibit 1 to Czech Declaration

    Case 2:13-cv-01232-TSZ Document 45-1 Filed 05/29/15 Page 4 of 4

    45 CZECH DeclarationIN THE UNITED STATES DISTRICT COURTFOR THE WESTERN DISTRICT OF WASHINGTONAT SEATTLE

    45 CZECH EXHIBIT 1