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Case 1:01-cv-00201-VJW

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EXHIBIT G

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2

JOHN C. SHICK - 7/25105
1 IN THE UNITED STATES COURT OF FEI)ERAL CLAIMS 1 2 CAROL AND ROBERT TES~UIDE, et al., ) Plaintiffs, 5 v. 6 ) 3 4 5 6 7 8 9 9 10 10 11 11 2 3 14 14 15 Virginia Beach, Virginia 15 July 25, 2005 16 17 :17 DEPOSITION UPON ORAL EXAMINATION OF JOHN C. SHICK TAKEN ON BEHALF OF THE DEFENDANT 12 13 Appearances (C ont'd.) U. S. DEPARTMENT OF JUSTICE By: STEVEN g. BRYANT, ESQUIRE KELLE S. ACOCK, ESQUIRE And DEPARTMENT OF THE NAVY COMMANDER NAVY REGION ATLANTIC By: DOMINICK G. YACONO, ESQUIRE Counsel for the Defendant

) )

)

) NO. 01-201L ) Judge Victor J. W~:)lski THE UNITED STATES OF AMERICA, )

)
Defendant. 8 )

16 18
19 2O 21 22 HOFHEIMER/FERREBEE, P.C. By: KRISTEN D. HOFHEIMER, ESQUIRE And QUINN, GORDON & WOLF By: KIERON QUINN, ESQUIRE Counsel for the Plaintiffs

18 Appearances: 19 20 21 22 23 24 25 f ~j

23
24 25

1 2 3 4 5 6 7 8 9 :10 NO. DESCRIPTION 11 (NONE) 12 13 14 15 16 17 18 19 2O 21 22 23 24 25 DEPONENT JOHN C. SHICK

INDEX

PAGE By Mr. Bryant 4

EXHIBITS

PAGE

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

Deposition upon oral examination of JOHN C. SHICK, taken on behalf of the Defendant, before Frances P. Zahn, RPR.RMR, a Notary Public for the Commonwealth of Virginia at large, taken pursuant to notice, commencing at 1:15 p.m. on July 25, at the offices of Hofheimer/Ferrebee, P.C., 1060 Laskin Road, Virginia Beach, Virginia; and this in accordance with the Federal Rules of Civil Procedure. JOHN C. SHICK was sworn and deposed on behalf of the Defendant, as follows: EXAMINATION BY MR. BRYANT: Q. Good afternoon, Mr. Schick. My name is Steve Bryant. Thanks for coming here today. First, before we get started, Mrs. Zahn is taking down everything that you and I say so it's important that you wait until I finish my questions to respond to them and I wait until you finish answering before i ask more questions. And also please don't nod your head because she can't take those down. Everything has to be verbalized in terms of answers. And if you at some point are describing something with your hands, whatever, we need to describe that for the record as well. Everything has to be transcribed so it's reflected on the record. Also, at any time during this if you need a break

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Document 180-4 Filed 06/09/2006 Page 3 of 24 JOHN C. SHICK - 7/25/05 45 46 was a distinct increase in noise and annoyance. 1 operations were, why would you accept those? Q What about the sort of number of operations that 2 A. Why would ! not? I guess, the question is, it 3 was .- it was more reasonable to take an official study and you experienced at your house. You obviously had some overflights directly over your house, you said, and then 4 try to make our case that we needed = reasonable solution some, a couple hundred yards on each side. Is that a fair 5 than to generate our own numbers and say, I want you to description? 6 believe us. Let's believe the Navy. A. Yes. I mean it could go miles. It could go a 7 Q. Well, did your 30 years of experience in the Navy long way either side. 8 contribute to your conclusion that, hey, the Navy is putting Q. Has that been roughly the same since you have 9 out what it believes the correct operational numbers? Or 10 would that -been there, since '97? I mean, irrespective of the type of A. I would have no reason .-in my career I had no aircraft, has the level of operations been the same roughly? 11 A. I can only speculate. I don't know. 12 reason to believe that the Navy was fudging figures for the Q. But there at no point did you sit down and say, 13 public. Q. Aside from Navy documents saying how many oh, my gosh, the operations over my house have doubled or 14 tripled, or whatever, have increased significantly? You 15 operations we had this year or that year, whatever, did you have never sort of had that kind of thought? 16 experience anything that was different in terms of level of A. I have never made that particular analysis. What 17 operations, not the actual noise of an F-18 versus an F-14, analysis I do is I go baok to the Navy's information. We 18 at your house? 19 A. Repeat. I'm sorry. I started thinking on stuck very closely to Navy information in anything we did. If the Navy says they were doing 320,000 overflights in this 20 something else, and I lost my train of thought. Q. Putting aside for a second the .- you said the community, I believe that Navy figure. If that was bigger 21 than -- if that figure was bigger than it was prior, then I 22 F.t4 you measured with the high 90s, versus the F-t8 C/D I would have to say there were more overflights. 23 think you said was 117, or thereabouts. I may be getting Q. And why would you believe what the Navy would put 24 that wrong. A. F-18, because I really couldn't .- as I told you, out in terms of the numbers and say, 300,000, whatever the 25 47 I couldn't tell the distinction between an A and B and C and D. Q. Well, putting that difference aside in terms of one being louder than the other, and putting aside the documents that you reviewed that the Navy generated in terms of we have 100,000 operations, or however many operations in a given year time frame, was there anything that you personally experienced in living in the house that it changed suddenly. It was suddenly much higher than it was, more touch and gos, more FCLPs, anything of that nature? A. As far as frequency .- you're talking frequency? Q. Yes. A. Or you're talking consequences? I'm talking .. let's talk frequency right now. A. Okay. In frequency, as I said, I never made --I never looked at the frequency. They were .-I shouldn't say I never looked at it, but I never rnade a study of it. I never recorded any data to support there are more. The overflights, as you probably are already aware, are sporadic. You can go a couple of days without hav ng any, and you can go several days and it just seems to be constant. Those days of constant overflights I suspect were consistent with the number of aircraft that were here, the number of aircraft that were being prepared for a 48 1 deployment. If they have -- if the -- consistent with the 2 flights of the FRS, how many student flights they have to 3 have in a particular cycle, that they were consistent. As 4 for my experience with it, I was just noting that they were 5 flying over. They were in trail or, you know, one after the 6 other, and that sometimes it would go on for several hours 7 with repeating. Whether -- I can't give you a distinctive 8 answer on whether three years ago they were longer than they 9 are today, because I have never made that assessment. Q. I mean based on all that, you have never at any 10 time said, wow!, there's a lot more flights going on now 11 12 than there were. I mean a personal feeling of that and 13 living in your house, than there were when you first got t4 back here in '97? 15 A. I can make this as a definite, There are a lot 16 more overflights over my house that are annoying. Okay? 17 There are a lot more that annoy me now than there were in t8 the past. Whether that means there are a lot more flights 19 at this time than there were in the past, I don't know. 20 Q. And you attribute the higher noise and annoyance 21 to the higher noise level of the F.18. is that correct? 22 A. Yes. 23 Q. So again, like the preface to the question, 24 trying to put that aside, there is nothing about the number 25 of flights, though .. aside from the F.18 being louder,

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I

IN THE UNITED STATES COURT OF FEDERAL CLAIMS

1 2 3

Deposition upon oral examination of JEFFREY McCREARY, taken on behalf of the Defendant, before Kerry E. Zahn, Registered Merit Reporter, Certified Realtime Reporter, a Notary Public for the Commonwealth of Virginia at large, taken pursuant to notice, commencing at 11:30 a.m. on January 13, 2006, at the offices of Hofheimer/Ferrebee, PC, 1060 Laskin Road, Virginia Beach, Virginia.

CAROL AND ROBERT TESTWUIDE, et al., Plaintiffs, ) v.

) ) )

4 5 6

7 ) No. 01-201L )Judge Victor J. Wolski 8 THE UNITED STATES OF AMERICA, ) 9 ) i0 Defendant. ) ii 12 13 DEPOSITION UPON ORAL EXAMINATION OF JEFFREY McCREARY TAKEN ON BEHALF OF THE DEFENDANT VIRGINIA BEACH, VIRGINIA JANUARY 13, 2006 Appearances: HOFHEIMER/FERREBEE, PC By: JACK E. FERREBEE, ESQUIRE Counsel for Plaintiffs U.S. DEPARTMENT OF JUSTICE By: STEVEN D. BRYANT, ESQUIRE Counsel for Defendant 14 15 16 17 18 19 20 21 22 23 24 25

JEFFREY McCREARY was sworn and deposed on behalf of the Defendant as follows:

EXAMINATION BY MR. BRYANT: Q. Good morning, Mr. McCreary. My name is

Steve Bryant from the Department of Justice, and I'm representing the Navy in this litigation. My first question is, have you ever been deposed before? A. Q. No. This will be my first time. Just for some ground rules, I will be /

asking you questions and you'll answer. Ms. Zahn is going to take down everything we're saying, as she is right now. So please wait until I finish my question before responding, and I'll do my best to wait until

<

4
INDEX 1 2 DEPONENT PAGE 3 4 JEFFREY McCREARY 5 6 Examination by Mr. Bryant 7 8 9 EXHIBITS NO. DESCRIPTION PAGE i0 ii 12 13 (None) 14 15 16 17 18 19 20 21 22 23 24 25 and I'm an information specialist of the public library system at the oceanfront branch. Q. Okay. Amd how long have you lived at you're done responding before I ask another question. Please also articulate your answers because nods of the head are not going to be reflected when she's typing. Also, if you need a break at any time, please let me know. And if you don't understand a question that I ask, please ask me to rephrase it and I'll be happy to do so. Okay? A. Q. Okay. All right. Please first state your

name, address, and occupation. A. My name is Jeffrey Earl McCreary. I

reside at 804 Lord Leighton Court in Virginia Beach,

Lord Leighton Court? A. Q. A. Since November of '96. And where did you live before that? In Cardinal Estates, 2901 Finch Avenue.

I moved there in August of 1976. Q. Okay. How long have you lived in

Virginia Beach, since '76? A. Q. October/November '76. What is the address that you lived in in

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65 Go ahead. You can answer it again. MR. BRYANT: Q.

67 1 2 experiencing as a continual problem; is that Correct? A. Q. Yes. Okay. Do you expect that that problem,

What I'm finding difficult to understand 3

.s if you've experienced it for the last six and a 4

~if years, how did you not expect it to be for -- for that continual problem, is not going to be a problem 5 iet noise to be in the vicinity of your home tomorrow 6 the day after that or the day after that? A. 7 tomorrow? A. Sometime in the future, I hope something

Technology should be progressive. Used 8 9

is done about it. But I don't know who, I don't know how, and I don't know when. Q. Okay. Exactly. So at some indeterminate time in the future you expect it to no longer be a problem; is that right. A. Q. A. Q. If something is done about it. Okay. Or I die. So if nothing is done about it, then you

be at Cardinal Estates the noise of the test

~ines were a real bother. For hours on ends they I0 run these engines. You couldn't hear yourself. II built a hush house. So it became less of Technology fixed that problem. Q. A. When did they build the hush house? I couldn't say exactly when, but at 12 13 14 15 16

Estates you no longer hear the sounds of

engines being tested for seemingly hours on end. 17 that's technology progressing. 18

would expect-A. Q. A. Q. To be a continual irritation. -- for the irritation to continue? Yes. Okay. Have you kept a log of these

I would expect technology to progress 19 to extent that they are not going to get louder. Q. 20

So then you expect for this technology, 21 technology, to take place 22 23 24 and muffle the sound? 25

flights at all? A. Q. No, I didn't. Any sort of records at all?

66 No. I have only been here since '76 and 1 great advances. But when they keep 2 and farther away from what had been a 3 pattern, what had not been a problem 4 'hood before, is now a continual problem 5 should we accept it? No. 6 I'm no~ asking you to accept it. You 7 a continual problem. Do you expect that 8 through next month? MR. FERREBEE: Again, I'm gDing to 9

68
A.

No. Your wife, has she done that? No. Have you taken any photos or videotapes

Q. A, Q. or anything? A. Q.

No. Have you filed any noise complaints with

the air station? A. Q. No. Have you discussed jet noise with any --

i0 on the eighth time you asked him if he II answered he did not expect it. I don't 12 going no get out of him. We can be13 six weeks and you'll get the same 14 15 ahead. 16

any personnel from the Navy? A. Q. No. Have you communicated your irritation

with the jet noise to any public officials? A. Q° A. No. Are you a member of the group CCAJN? I get their newsletter. I've never

move-if they have moved all the 17 would not expect them to move them 18 they did move them to Fentress, I ]9 hear jet noise next week. 20 21 noises did come back, it's a jet, 22 do I expect it? No, I don't 23 24 So you describe what you're 25

attended any of their meetings. Q. Okay. Have you ever attended any public

meetings or hearings related to jet noise? A. QNo. Have you considered selling your house

because of the jet noise? A. Q. No. Is the reason for that because you

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EXHIBIT I

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HAROLD LEVENSON - 6/8/05
IN THE UNITED STATES COURT OF FEDERAL CLAIMS Appearances (C ont'd.) U. S. DEPARTMENT OF JUSTICE By: STEVEN D. BRYANT, ESQUIRE KELLE S. ACOCK, ESQUIRE And DEPARTMENT OF THE NAVY COMMANDER NAVY REGION ATLANTIC By: DOMINICK G, YACONO, ESQUIRE And DEPARTMENT OF THE NAW NAVY LITIGATION OFFICE By: J. PAGE TUNNEY, ESQUIRE Counsel for the Defendant

CAROL AND ROBERT TESTWUIDE, ) at al., ) ) Pl&intiffs, ) ) v. ) NO. 01-201L ) Judge Victor J. Wolski THE UNITED STATES OF AMERICA, ) ) Defendant. )

3 4 5 6 7 8 9 10

3 1 2 3 14 4 Virginia Beach, Virginia i5 June 8, 2005 i6 !17 i7 18 [8 19 i9 Appearances: 20 SHUTTLEWORTH, RULOFF GIORDANO & SWAIN, P.C. By: STEPHEN C. SWAIN, ESQUIRE Counsel for the Plaintiffs :21 22 23 24 25 1l 6 15 DEPOSITION UPON ORAL EXAMINATION OF HAROLD LEVENSON TAKEN ON BEHALF OF THE DEFENDANT 11 12 13

INDEX 2 3 4 5 6 7 DEPONENT Harold Levenson By Mr. Bryant PAGE 4

a
9 tO NO. DESCRIPTION 1 32 2 13 14 15 35 6 36 7 37 8 38 ~9 Deed of Trust dated April 17, 1987 ................ 85 Settlement statement datedd April 17, 1987 ........ 84 Deed dated 7 August 1986 .......................... 93 Deed dated July 25, 2003 .......................... 02 33 34 Subpoena and Notice of Taking Deposition Duces Tecum ...................................... 14 Tax assessment for 2004 Brickell Court ............ Plaintiffs" Answers to Interrogatories Harold and Elaine Levenson ........................ 55 PAGE EXHIBITS

78

i23

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

Deposition upon oral examination of HAROLD LEVENSON, taken on behalf of the Defendant, before Frances P. Zahn, RPR~MR, a Notanj Public for the Commonwealth of Virginia at large, taken pursuant to notice, commencing at 9:10 a.m. on June 8, 2005, at the offices of Shuttlewo~h, Ruloff, Giordano & Swain, 4526 South Boulevard, Virginia Beach, Virginia; and this in accordance with the Federal Rules of Civil Procedure. HAROLD LEVENS0N was sworn and deposed on behalf of the Defendant, as follows: EXAMINATION BY MR. BRYANT: Q Mr. Levenson, my name is Steve Bn/ant from the Depaffment of Justice. How are you today? A. Fine. rm listening to you. Q. Whet we're going to have is a deposition which I will ask you questions and you will answer them. Mrs. Zahn is taking down evenjthing we're saying, so please allow me to finish my questions before responding so we're not talking over one another. MR. SWAIN: Each time he's asking you a question, wait until he completes that question in its entirety, and then give him a response. THE DEPONENT: Okay.

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HAROLD LEVENSON 33 consistent as the Navy would like them to be. And that's 1 the reason they are training, i mean that's the reason that 2 3 Oceana operates, because the pilots are learning how to make 4 an ideal or perfect landing on a carrier, and if they were 5 able to do that every single time out of the box then they 6 would land in the same flight trajectory. But they .- of 7 course, wind conditions occur and there's individual differences between pilots and that kind of thing, yes. 8 9 Q. But when talking about that, sometimes it's to 10 the left, sometimes it's to the riight? 11 A. Yes. The distance changes somewhat? 12 Q. 13 A, Yes, Q Is it roughly the same on this side as the same 14 15 on that side? Is it about - you are like right on the 16 flight path, in the middle? 17 A. I had the occasion -. I've been waiting for the moment to tell you this story. I had the occasion to have a 18 19 telephone conversation with Ray Furenzi and Bobby Rountree. You know who they are? 20 21 Q. Yes, I do. 22 A. This conversation must have taken place two years 23 ago, maybe. Ray was in his office. Bobby was in Ray's office. He put me on a speakerphone. We had about a 46, 60 24 25 minute conversation, The reason for the conversation was 1 2 3 4 5 6 7 8 9 10 tl 12 13 14 15 16 17 18 19 20 21 22 23 24 25

that I was wanting to get Ray to have a pilot - Bobby is a retired pilot working in a civilian capacity with Ray explain to me why when the overflights occur sometimes the noise is much louder than at other times. Why there was the variation of noise levels as the planes were flying over my house. So we had this conversation. Very pleasant conversation. Rountree is a fine guy. And Ray is a fine guy too. And Rountree looked at his maps in Ray's office, and we agreed that the overflights were going to be at about 400 to 600 feet over my house. Okay? And that if the pilots were flying the perfect trajectory to land on the short runway that they would come approximately over my house. And that was part of the conversation for 45 or 60 minutes. So that is howl know without having to measure in some other way that the altitude, when the planes are landing on a short runway over my house, is about 4 to 600 feet. Because I take Bobby Rountree's word for it. Q. And in terms of- not just the altitude that you mentioned, the location in relation to your house? A. Yes. Q In terms ofA. Yes. I knowwhatyou'reasking. Whatisthe percentage of the time they fly directly over my house as opposed to the percentage when they fly 50 feet, or t00 Station Ooeana was? A. Only very vaguely. I knewit was somewhere in Virginia Beach, somewhere near the house. That's all I knew. Q. AndA. ! now know where it is. Q. I figured as much. But before you moved in, you did know it was near the house? A. No. No. I don't really think I did. (knew that the sellers of the house were a Navy officer. I knew that, ! had started working at WAVY, and I knew we did stories from time to time about Oceana. I knewthat Oceana was somewhere in Virginia Beach. Somewhere. But l mean, the days when we looked at the house, were there any overflights at the house when we looked at it? Absolutely none. No. Q. Did you inquire with - well, the naval officer you boughtthe housefromA. Yes. Q. - was he an aviator? A; I don't think so, but I'm not sure. Did he tell me about overflights of the house? Absolutely not. Q. Did you ask him about that at all? A. No. Not that i recall, no. Q. Did you inquire at the air s~ion about

35 feet, or 150 feet. Is that what you want to know?. Q Yes. A. To be honest with you I really wouldn't want to guess. I mean have I kept statistics? No. Do I have a clear recollection? You know, have I modeled in my head, you know, what the percentages are of that? No. All I can tell you is a certain amount of time, a goodly amount of the time they fly directly over my house. And that shouldn't be a surprise to anybody, because, as I am sure you know by now, the purpose of the 1 training at Oceana is to ge~tthe pilots to make a perfect 2 landing on a carrier. If they make a perfect landing they 3 would .. it doesn't happen this way, but they would fly in a 4 certain trajectory, and that trajectory, as I have 5 experienced it myself, and as the gist of the discussion was 6 that day with Rountree and Ray - Ray was just listening; 7 Rountree was doing most of the talking - comes over my house, yes. 9 Q. Now going back to before you bought the house? 0 A. Yes. 1 Q, You mentioned that you were aware of NAS Oceana? 2 A, I was aware only in my ¢mpacity as the news 3 director of WAVY that periodically in our newscast there 4 were stories about NAS Ocoana. That's all I knew. Q. And did you know where the location of Naval Air

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1 2 3 4 5 6 7 8 9 10 11 12 13 14 Virginia Beach, Virginia 15 April 27, 2005 16 17 18 19 20 21 22 23 24 25 ZAHN COURT REPORllNG (757)627-6554 Appearances: v. CAROL AND ROBERT TES~UIDE, ) et el., ) Plaintiffs,

Document 180-4
SEAN M. RYAN
1

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS

1 2 3 4 5 6 7 8 9 10 NO. DESCRIPTION 11 DEPONENT SEAN M. RYAN

INDEX

PAGE 8yM~Bwant

) ) }

)

} NO. 01-2OIL ) Judge Victor J. Woleki THE UNITED STATES OF AMERICA, } Defendant. )

EXHIBITS PAGE

DEPOSITION UPON ORAL EXAMINATION OF SEAN M. RYAN TAKEN ON BEHALF OF THEE DEFENDANT

3 12 13 14 15 16 17 18 19 4 5 6

Signed page of real estate contract, Bates OCE223263 ................................. 44 Appraisal of't856 Pathfinder Drive ............... Partial complaint ............................. 77 Plaintiffs" Answers to Interrogatories, Plelntiff~ SPan and Graclela Ryan ................ 86 67

7 leveice from Home Front ContracUng, Inc. to Mr. & Mrs. ~an Ryan ....................... 93 8 Deed of Bargain and Sale, from Richard M. Kemp to Sean M. Ryar~ and Grsciale F. Ryan ............ 94 9 Deed of Trust .................................. 95 .111

SHUTTLEWORTH, RULOFF GIORDANO & SWAIN, P.C. By: STEPHEN C. SWAIN, ESQUIRE Counsel for the PlaletiK~ U. S. DEPARTMENT OF JUSTICE By: STEVEN O. BRYANT, ESQUIRE DOMINICK G. YACONO, ESQUIRE Counsel for the Defendant

20 10 AICUZ map (retained by Mr, Bryant) .............. 21 22 23 24 25 ZAHN COURT REPORllNG (757) 627-6554

3 1 2 3 4 5 6 8 9 10 2 3 4 15 16 t7 18 19 20 21 22 23 24 25 Deposition upon oral examination of SEAN M. RYAN, taken on behalf of the Defendant, before Frances P. Zahn, RPR.RMR, a Notary Public for the Commonwealth of Virginia at large, taken pursuant to notice, commencing at 12:25 p.m. on April 27, 2005, at the offices of Shuttleworth, Ruloff, Giordano & Swain, P.C., Virginia Beach, Virginia; and this in accordance with the Federal Rules of Civil Procedure. SEAN M. RYAN was sworn and deposed on behalf of the Defendant, as follows: EXAMINATION BY MR. BRYANT: Q How are you, Mr. Ryan? A, Good. Q I'm Stephen Bryant from the Department of Justice, along with Commander Yacono on behalf of the Navy. We're here on behalf of the United States. First I'd like to know if you have ever been deposed before so I'll go over the ground rules. Have you ever been in a deposition? A. No. Q. It's a question and answer sort of thing, and I'll ask questions throughout. Yo, need to answer them. She's going to be taking everything down verbatim so we can't talk over one another, and please verbalize your answers. Don't nod or say uh huh because that can get ZAHN COURT REPORTING (757)627-6554 1 2 3 4 5 6 7 B 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 mistranslated. A. Yes. Q. Thank you. And if you need a break at any point during this, just feel free to say so at any time and we'll stop. For a bathroom break, whatever you need, that's fine. And if you don't understand the question I ask, please let me know and I'll rephrase it. A. Fine. Q. First, I'd like to ask, have you ever been a plaintiff or a defendant in another case before? A. Yes, I have. Q. Okay. Can you tell me about that, How many times, first? A. Just once. Q. Just one case? A. It was an accident that occurred to me on board ship. Q. And when was that? A. This was back in -. I'm not really sure about the date, but it was like '90 -- early '90s. Q. And you say it was on a ship. What happened? A. A line was hooked around a fairlead and the horn of the fairlead parted and the line hit me and I 9ot hurt. Q. I don't know what any of that -- what a fairlead is? ZAHN COURT REPORTING ('/57)627-6554

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77 A. it was. Q. Okay. And when did it become unsuitable? A. Well, it started to get bad, real bad, you know, when the Hornets were coming, and they - they, you know, when they started getting more and more jets at the base, there were more jets, more flyovers. And that's what made it getting bad. Q. Okay. A. it steadily got louder and louder. MR. BRYANT: rd like to mark this partial complaint as DX 5, ! guess is the next number? (Partial complaint was marked Defendant's Exhibit No. DX005.) (Discussion off the record) BY MR. BRYANT: Q. ! think I may have shown you this before, Mr. Ryan. OCE222981 through OCE223005. It's Plaintiffs' Answers to Interrogatories from the Plaintiffs Sean and Graciela Ryan. I hand this back to you. MR. BRYANT: I think we have another copy if you'd like to see it, Mr. Swain. BY MR. BRYANT: Q. If you could go to page 24 of that document, please. It has your name and your wife's name but no ZAHNCOURT REPORTING (757)627-6554
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78 signature. A. No. I guess we forgot that one. Q. Well, what rm trying to get at is, I'd like you, with that said, I'd like you to review the document and see if you have ever seen it and if you agree to the answers that are in there on your behalf. MR. SWAIN: Would, after you finish the question about the interrogatories, be a good time to take a break? MR. BRYANT: Absolutely. BY MR. BRYANT: Q. Take your time reviewing that. Don't let me rush it. A. Well, l remember talking to Jack about this. I don't know why I didn't sign it. Q. Did you see this document? A. i do believe so. Q. All right, rd like you to turn - once you are done - let me know when you are done reviewing it. A. Okay. I have seen it before. Q. And you agree with the contents? A. Yes. Q, Okay. On page 6, if you would go to - it discusses in the middle of subparagraph C in the response about aircraft operating in a pattern with several aircraft circling every few minutes, do you experience that at your ZAHN COURT REPORTING (757)627-6554 8O ! really don't know how big those planes are. But - yes. They are - you can see them fairly, real clear. Q. Okay. A. I don't know how high they are. No, ! don't. Q, And were the aircraft, the jets, when they flew over, when you moved in in 'gG and '97 and '98, were they also flying in that same pattern above your house? A. Yes. We were having flyovers. But I don't know if it's the same - maybe close to it. But I don't know if it was the same, you know, path. Q. Well, was it A. They were the same proximity, yes. Q. Some were over your house? A. Yes. Q. And some weren't? A. Yes. Q. Were they the same altitude, roughly? A. Yes. But sometimes they are higher and sometimes they are lower. You know, they are not all exactlyQ. Sure. A. - at the same heighL Q. So what would you estimate the range of altitudes. You said sometimes.500, maybe 1,000. What did you say? A. Something like that. rm not sure on the ZAHN COURT REPORTING (757)627-6554

t 2 3 4 5 6 7 8 9 10 11 12 13 14 15 t6 17 t8 19 20 21 22 23 24 25

79 house in Upton Estates? A. One flyover every couple of minutes. Q. Several aircraft circling every few minutes directly over and around the plaintiffs' home. rm trying to figure out if this part of the answer applies to your house or not. That's what rm trying to get at. A, Yes. They fly over. Q. When you say they fly over, let's start with that. Directly over your house? A. Sometimes. I'm not going to say all the time. Q And when you say, literally looking up it's directly over your house? A. Yes. Q. How high in the air, altitude?' A. I don't know. You can see them pretty close. ! don't know. Q. Can you see the pilots' face.,;? A. I'm looking underneath it. ! can't see the pilot. Q. Are we talking 100 feet, 1,000 feet, 2,000 feet? What are we - you've been around airplanes for a long time. A. i guess - ! don't know. Four, 500 feet I guess. Q. 500 feet above your house? A. Yes. I guess. Maybe more. Maybe less. I don't know. To look up there and, you know, to tell you the truth ZAHN COURT REPORTING (757)627-6554

1 2 3 4 5 6 7 8 9 t0 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25

Case 1:01-cv-00201-VJW

Document 180-4 SEAN M. RYAN
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

Filed 06/09/2006

Page 13 of 24

4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 2t 22 23 24 25

81 heights. I really don't know. Q. Okay. What percentage of the flights are directly over your house? Starting in 1999 when you said it became unbearable. A. I would say like about 46, 48 percenL Not all of them. And not quite half of them. Q. So just under half --just under 50 percent of the flights were directly over your house? A. Right. The small half. Q. i understand. Just under. So the remaining 60 whatever percentage? They were Q. Or 55, whatever? A. They were not -- they were like over a little bit. Q. And when you say over a little bit, blocks? A. Sir, I don't know. Maybe a block over. Within a couple of blocks? A. Yes, sir. Street, you know. Q. So, in other words, all the flights that you experienced are either directly over your house or within a couple of blocks of your house? A. From my house being the center. Okay? You probably could go five blocks each way. Okay? Q. And that includes all the flights that you are ZAHN COURT REPORTING (757)627-6554 83 house and not the flight path of the jets. Q. And aircraft noise was not a concern? A. Not at the time. Q. We'll take that break in just a minute, rm almost finished with this. Now going back to my original question, you said earlier in an August 1999 party you had, you had basically -- correct me if I am wrong -- four individual flyovers. A. i would say four, yes. Q. Three to four, whatever it was? A. Right. Q. What rm trying to figure out is -A. But I said that there were three to four jets that weren't clustered that would go over at a time, one right after the other. Q. Three to four jets roughly together but not right next to each other? A. No. One behind the other. Q. So in sort of a pattern kind of thing? A. Right. Q. And that happened in '99? A. The party in '99. Q. And it happened -- did it happen before in '96 through '98? A. It might have done that. ZAHN COURT REPORTING (757)627-6554

82 being exposed to? A. Well, the low ones. The lower ones are in that area. The higher ones are maybe a little off from that. Q. And when you say a little off from that, what do you mean? A. Add a couple more blocks to each side. Q. So within maybe even a five block radius, that's all the flights in terms of noise that you are experiencing? A. Yes. My house being the center. Q. And so are half on one side of your house and the other half on the other side? A. I don't knowthe percentage. Q. All right. And it was roughly the same sort of five block radius when you moved in in '96? A. I would say, yes. Q. Yes. So when you were doing that search for -you were looking for a house, how many houses did you say you looked at in the neighborhood? A. Afew. I don't know the exact number. Maybe15. Q. Yes. I think you said 10 to 15. Did you consider picking another one of the houses that might not have been directly under the center of that flight path that you were observing? A. Well, no. That didn't come into play, to tell you the truth, no. We were looking for the criteria of the ZAHN COURT REPORTING (757)627-6554 84 Q. Did it happen when you were looking at the houses? A. They were -- I remember that there were some jets that flew over, yes. I don't remember what flight path they were in, or whatever.. Q. rm saying were there groupings? That's what I'm getting at. Did you have three at a time, that kind of thing? Were they still spread out a little bit? A. I think they were spread out. They weren't wing to wing. Q. ! mean one behind the other. That's what I'm talking about? A. Well, sure. Yes. Q. So you had that in '96, and even before you bought the house? A. Right. Q. Before '99, when you were outside having a party, or barbecue, or whatever else, and the planes flew over, could you talk and hear each other? A. No. Q. Did you have to turn up the TV? A. Certainly. Yes. Q. And I'm talking about before '99. That's what I'm talking about now, not after? A. Yes. ZAHN COURT REPORTING (757)627-6554

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

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

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

Document 180-4 Filed 06/09/2006 Page 14 of 24 SEAN MRYAN - 4~7~5 85 86 Q. And phone conversations, the same sorts of 1 A. I supervise the maintenance of the ship. problems? 2 Q. And where does that take place? A. Yes. 3 A. Well, different places all over the world, Q~ So you had the same sorts otF problems before and 4 whatever ship rm going on. after '997 5 Q. So you deploy with the ships? A. Right. 6 A. I work for a union and the shipping companies Q. in terms of the enjoyment of the house? have ships. Right now, rm employed by Maersk Line Limited. 7 A. Right. 8 Q. Can you - sort of explain this to me because I Q. All righL Let's mark this exhibit as DX006, 9 don't really understand it. In terms of supervising the please, l'm sorry. The Plaintiffs' Answers to 10 maintenance of the ships? Interrogatories, Plaintiffs Sean and Graciela Ryan. 11 A. Right. (Plaintiffs' Answers to 12 Q. How and when do you do that? is it nine to five? Interrogatories, Sean and Graciela Ryan, 13 A. Eight to five. I'm usually a day worker. I'm was marked Defendant's Exl~ibit No. DX 006.) 14 not a watch-stander. And when guys come out for overtime, 1 MR. BRYANT: We can take a break now. 15 tell them what needs to be done to the ship, and they do it. (Recess) 16 Chipping and painting. BY MR. BRYANT: Q. And does this occur in Virginia Beach, or does it 17 Q. I want to turn back to -- what is your current 18 occur elsewhere in the world? occupation? 19 A. Elsewhere in the world. A. Merchant mariner. 2O Q. What types of locations? Q. And is it ABS? 21 A. Well, May 9 rm flying to Dubai to catch a ship. A. No. ! sail boatswain now. 22 Q. How often are you away from this area? Q. Say that again, rm sorry? 23 A. I usually work four and four. A. I sail boatswain. Q. Four months here, four months away? 24 Q. Can you -- what do you do in that position? A. All right. But that's not every time. This time 25 ZAHN COURT REPORTING ZAHN COURT REPORTING (757)627-6554 (757)627-6554 87 it's going to be eight and five. Eight here, five at work. Or four. Q. And when you are here, if it'.,; four and four, the four months that you are here, what are you doing during that time period? A. Messing around my house. Q, So you have A. I have a barn. Q. If we can go sod of over time, in 1999 do you recall, were you working in the same position in 1999? When did you start with this? A. Yes. I was sailing boatswain in '99. I think I staffed sailing boatswain sometime around '99. Q. What were you doing just before that? A. I was an AB. Q. AB. Okay. And were you deployed as an AB also? A. Yes. Q. ! said deployed in the colloquial sense. And that's with the same company? A. No. Different companies. Q. I'm getting them mixed up now. I'm sorry. When you were an AB, what was the time period you were anAB? A. From --I guess I started sailing AB in '88. Q. Through? ZAHN COURT REPORTING (757)627-6554 88 A. I guess '99. Something like that. Q. Okay. A. rd have to check my records. I don't know. Q. And with that position, how often were you away from this area? A. Four months. Q. The same four and four kind of thing? A. Well, no, I worked. Usually, I was what they call tramping. I was worked for anyone. I didn't have a permanent job. So I would work four months, and probably stay home six. Q. And then sometime in '99, do you recall what month you became a maintenance supervisor? A. I don't know. rd have to check my records. Q. And when you first joined this company, this is a unionized thing? A. It's for a union, yes. Q. What was your first assignment? A. With the union? Q. Yes. With this new position that you took in '99? A. What was my - where did we go? Q. Yes. I'm trying to figure out what your first A. Oh, we carried tractors to the Ukraine. Q. To Ukraine? ZAHN COURT REPORTING (757)627-6554

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1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 t7 18 19 20 21 22 23

6 7 8 9 10 11 12 13 14 15 16 17 18 19 2O 2t 22 23 24 25

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EXHIBIT K

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1 IN THE UNITED STATES couRT OF FEDERAL CLAIMS

1 2 DEPONENT 3

INDEX

PAGE

!et al.,

CAROL AND ROBERT TESTWUIDE, ) ) Plaintiffs, ) )

4 5 6 7

EILEEN MAY

Examination by Mr. Yacono

4

) No. 01-201L )Judge Victor J. Wolski 8 THE UNITED STATES OF AMERICA, ) ) Defendant. ) 9 I0 ii 12 13 14 DEPOSITION UPON ORAL EXAMINATION OF EILEEN MAY TAKEN ON BEHALF OF THE DEFENDANT VIRGINIA BEACH, VIRGINIA MARCH 9, 2006 15

EXHIBITS NO. DESCRIPTION PAGE

147 Notice of Appraisal

32 46

148 March 2005 Appraisal

16 17 18 19 20 21 22 23 24 25

2 Appearances: HOFHEIMER/FERREBEE, PC By: JACK E. FERREBEE, ESQUIRE Counsel for Plaintiffs 1 2 3 4 5 U.S. DEPARTMENT OF* JUSTICE 6 By: KELLE S. ACOCK, ESQUIRE 7 and 8 DEPARTMENT OF THE NAVY COMMANDER NAVY REGION ATLANTIC 9 By: DOMINICK G. ~CONO, ESQUIRE I0 and Ii DEPARTMENT OF THE NAVY NAVY LITIGATION OFFICE 12 By: MARY RAIVEL, ESQUIRE 13 Counsel for Defendant 14 15 16 17 18 19 20 21 22 23 24 25 Deposition upon oral examination of

4 EILEEN MAY, taken on behalf of the Defendant, before Kerry E. Zahn, Registered Merit Reporter, Certified Realtime Reporter, a Notary Public for the Commonwealth of Virginia at large, taken pursuant to notice, commencing at I:i0 pm on March 9, 2006, at the offices of Hofheimer/Ferrebee, PC, 1060 Laskin Road, Virginia Beach, Virginia.

EILEEN MAY was sworn and deposed on behalf of the Defendant as follows:

EXAMINATION BY COMMANDER YACONO: Q. A. Q. Good afternoon, Ms. May. Good afternoon. I'm Commander Dominick Yacono. I am the

Regional Environmental Counsel at the -- for Commander Navy Region Mid Atlantic in Norfolk Virginia, and this is Miss Kelle Acock from the U.S. Department of Justice in Washington D.C. A. Q. Okay. I'm going to be asking you a series of

questions today. If you don't understand a question that I ask you, please don't hesitate to ask me to

1 (Pages i to 4) ZAHN COURT REPORTING (757) 627-6554 www.zahncourtreporting.com

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21
O. A. Could you see the jets? I don't recall. Okay. While you are living at the on Bedford Lane, did you have -- did you a noise complaint with the folks at 1 2 3 4 5 6 A. No. YOU mentioned you lived at that on Bedford Lane for nine years. Why did you that residence? My husband passed away in the house. in the house, but almost in the house. When 7 8 9 i0 ii 12 13 14 15 16 17 So when my husband died, it was very 18 19 20 21 22 23 24 25 associated with at that time? A. swear to it. Q. Okay. With the residence at 620 Little I think she was ReMax, but I couldn't

23

Q.
residence ever file Oceana?

Neck Road, did you find it or did your friend the realtor find it for you? A. Well, we lived very close to that house,

Q.
residence ~move from A. Well, not

so -- it was for sale. My husband and I looked at it~ At -- the funny thing was, it would go on the market, then come off the market. And we assumed it was sold. It would come on the market and go off the market. So we didn't know what was going on with the house. To make a long story short, he passed away, and I wanted to move, and the house was on the market. Q. A. Okay. So we -- I looked at it, and I tried to

he died -- and I wanted to buy the house. I had ~anted to buy the house. We had wanted to buy the house. The landlord kept promising maybe one day he ~would sell it. His wife didn't want to move back ~e re.

!

keep my children in the same school district. They had enough to deal with with their dad dying. So that was very -- in the same everything. Q. So for that 620 Little Neck Road, the

:sudden, and there was a house down the road that we :]had been looking at, and I just went ahead with that purchased that house. Q. And that's the house you're currently

school districts were exactly the same? A. Except for elementary would have been

:]living at, 620 Little Neck Road? A. i" Q. Yes. That's correct. I just want to make sure. When you

Kingston, but they were already through there. They were into junior high and high school at that point.

22
inoved

24
1 2 3 4 5 6 7 8 9 i0 ii 12 Q. A. Q. pretty -area? A. Q. on 620 Little flying around before you A. Q. at 620 Little Yes, I sure did. Before you decided to purchase the home Neck Road, did you notice military jets that home or hear the noise at that home And this is 19937 -- three. He died November 12, 1993. So in terms of your house-hunting, you you limited yourself to this Kingston

out

-- your motivation for moving out of

~edford Lane was the passing away of your husband, or ~was it for other reasons? A. Well, actually, it was pretty much the

passing away of my husband. I didn't want to be there '~anymore for that reason. I was uncomfortable there. Q. A. ~, Q. Okay. That' s -With regard to the -- your current

~resldence at 620 Little Neck Road, hew long of a :house-hunting were you doing when you found that ~esidence ? A. Q. Three, four months. Were you using a ~ealtor -.>

purchased the home? No. Okay. When you moved into the residence Neck Road, how soon after you moved in

13 14 15 16 17 18 19 20 21 22 23 24 25

did you hear military jet noise? A. I lived there for a while before r

~.
Q~hat realtor A.

Yes
-- or were you on your -- do you recall you were using? She's actually a friend of mine. I

really noticed jet noise. Q. When was -- just estimate what year you

think you first heard jet noise. A. It was years. It was a couple years.

don't know who she was with at the tJhne. Her name is Janice Meyers Hollowell. Can you spell the last name for the bourt reporter? A. Which? Oh. Janice Meyers, M-E-Y-E-R-S,

Probably in 1997/'98. Q. Okay. Why does '97/'98 stand out to

you? Do you recall anything specific? A. I put a pool in, inground pool in my

~nd H-O-L-L-O-W-E-L-L. QDo you remember what firm she was

yard. I remember for years nothing bothered me. I'm just guessing a couple years. It didn't bother me. I

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25
~uld be on the phone, in my deck, on the pool, [oating, no problem. Then it just seemed to get ~uder. Q. This is pretty much you noticed it I 2 3 4 Q. 620 Little Neck Read -A. Q. Yes.

27
-- when you moved into your home in '94,

-- when did you first observe, when you

rimarily from your experience while being outdoors5 at actually physically sighted a military jet? he pool? i A. 6 7 Well, that's the worst. You can't even A. Q. A. You want the year? Just the year. Well, I would have to say 1997 if I had

~ay there when they are going overhead when you're8in ~e pool, or especially if you're on the phone you 9 I0 to -- I have a terrible habit of taking my phone

to pin a year down then. Q. A. Q. A. Q. time? A. As I said, I remember them becoming a So from '94 to '97 -No. -- you didn't see a military jet? No. Did you hear them at least during that

~ve

!4o the pool and laying on my chair talking. Q. A. Q. A. Q. A. Q. Okay. Portable phone. Okay. Or cell phone. But this was '97/'987 Something like that. Okay. After that you mentioned --

II 12 13 14 15 16 17 18

very big nuisance roughly three to four years after I moved in, but not at the beginning. Q. Okay. Now, from -- in '97/'98 when you

~

19 viously you mentioned it while outdoors; what about

~ the indoors? Same thing in terms of radio and 20 ~levision in terms -A. 21

said you were able to see -- at least you were able to see a military jet, could you estimate at what altitude the jet was at? A. Well, you saw how I did on that map.

Yes, turn that up. But I don't watch 22 a

)t of television, so, I mean, especially during the 23 24 ly, which is -- I seem to recall them mostly being ly or late in the afternoon, like dinnertime area, 25

I'm not real good -- I mean, I couldn't see anybody in the plane or anything like that. I could just see

26
there, and my TV is not usually on during the1 2 Q. A. What about phone conversations? Phone conversations, yes. Did you ever have to pause? Pause, stop, or call back, yes. 3 4 5 6 like the gray, the metal. Q.

28
Okay. Could you see any markings on the

plane, numbers, letters? A. Q. Not that I recall, no. Okay. And from '97/'98 to the present

day, has that changed? Can you see any markings on the jets? A. Q. A. Q. No. Okay. Can you see the pilot? No. Okay. From the time you moved into your

Okay. Now, from what you just described 7 , from '97/'98 -- '97/'98 to the present day, has 8 ~ything changed in terms of frequency or periodicity 9 ~ terms of military jet noise? A. I haven't noticed it as much lately, i0 ii

~ti~ the last -- but I don't know. I'm in the 12 0use more, so I don't know_ I mean, my pool is 13 iosed. Q. When you're outdoors at your current 14 15

current residence up to the present day, have you ever filed a noise complaint with any of the folks at the Naval Air Station Oceana? A. I never filed a complaint that I can

can you see ~esidence, the military jets flying in and 16

~

recall. I went on a website and filled out stuff, but I don't know if that was actually -- it might have been a complaint. Q. A. All right. That's how I got involved in this. I

ut? A.

17

Not necessarily the jets, but I can see 18 ~he trails, whatever they call them, white smoke that 19 ~ooks like line -- my mother used to -- yes, sir. 20 QYou can see the trails? 21 A. Yes_ Currently. I have seen -- I have 22 ~ooked up and seen, you know. Q. A. That's what I'm asking. From '97 -Oh.

don't know if it was a complaint, per se. Q. Okay. See, well, I didn't know you could,

23 24 25

A.

being a military town. I thought that was part of day-to-day life, just dealt with it. I'm not too big

7 (Pages 25 to 28 ZAHN COURT REPORTING (757) 627-6554 www.zahncourtreporting.com

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EXHIBIT L

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HARRIS, MILLER, MILLER & HANSEN, INC - NOV 1984; PREPARED UNDER CONTRACT # N00025-82C-0002, AICUZ OFFICE, NAS OCEANA

0CE090230

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HARRIS MILLER MILLER & HANSON INC. I. Annual Operations and Average

Report No. 2,3010~

Pa~e 6

Noise Contours are normally based on "average busy day" operations; this is the number of operations that occurs during a 2~-hour period when the s~ation is in full operation. The tower maintains daily and annual summaries of these operations. An examination of tower counts inOicates that at NAS Oceana the busiest months are March and August. The average weekday operational level during those months is approximately ~25 percent of the annual average day. (The annual average day is annual operations divided by 365 days). Therefore the noise contours are based on 125 percent of the annual average daily operations. Table 2 gives the total annual operations for 19B0 through 1952.

C 2. Operations b_zaircraft Type To compute the number of daily operations flown by each aircraft type, each squadron provided for its aircraft estimates of annual numbers of departures, arrivals and patterns flown. These numbers were added for all aircraft types, then used to determine percent of total operatlons by each type. The grand total of the operations data provided by the squadrons was approximately rive percent higher than the total from fir Traffic Control (ATC) counts. To be consistent with the ATC counts, we adjusted the squadron totals downward proportionately. We then developed operations numbers for an average busy day. The resultin~ numbers of operations are given in Table 3. Use of individual flight tracks by aircraft type is determined by combining runway utilizations provided by the Tower, and shown in Table 4, with flight track utilization provided by the squadrons. These percentages are multiplied by the numbers of operations of Table 3. Table 4 gives the flight track labelling conventions followed to distinguish the various types of flight tracks. Table 5 is a summary of operations by aircralrt type and by type of activity. Tables 6 and 7 list the numbers of operations by runway, flight track and type of activity for Oceana and Fentress, respectively. Figures 3 through 6 depict the corresponding flight tracks. Two notes concerning these operations are necessary, First, as indicated in Table 5, operations of certain aircraft are omitted since they contribute so little to total noise contours and thus would add only to the complexity of the noise computation process, not to its accuracy. The F-SE, T-2C and TC-~C were omitted at NAS Oceana and the E-2 and C-I were omitted at ALF Fentress. Second, general aviation activity is also omitted because it would have no noticeable effect on contours.

0CE090239

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HARRIS HILLER NILL~I & HANSOW,,INC.

Report No, 230104

Page 7,

TABLE 2 NA5 OCEANA AND ALF FENTRE35 ANNUAL OPERATION5 I l

ANNUAL OPERATION5 TOTAL ANNUAL OPS : LESS ENROUTE OP5 1 TOTAL STATION OPS ~
!

:

ANNUAL OPERATIONS NA NA 96062 90928

:

| I

Z 1982

177486 -15977 161509 231753

S : 1981 : 19g0

TOTAL AHNUEL OP$ JAN - OCT ONLY

;

mSource: Air Traffic Activity Report Note: Patterns are counted as two (2) operations

0CE090240

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HARRIS HILLER MILLEZ & HANSON INC.

Report No. 23010q

Pa~e 8

TABLE 3 WAS OCEANA AND ALF FENTRESS RUNWAY UTILIZATIONS NAS OCEANA RUNWAY 14 23 32 ] | ~ ~ UTILIZATION(S)

3 30 23

: I

ALF FENTRESS BUNWAY ; 05 23 ; ; ; UTILIZATION (S) 60 40 I :

TABLE 4 NAS OCEANA AND ALl; FENTRES5 FLIGHT TRACK DESCRIPTIONS

Flight Track Suffix

FliBht Track Description

Departures Interfacility Departures Patterns S~raiEht-In Arrivals Overhead Arrivals

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i ......

i ........

~'-

'_]=I

I ........

,- ~ ~?.

~--~

..

0CE090242