DEIS comments -

Suggested comment outline

The following topics are ones you may wish to address in your comments on the USAF DEIS.

Purpose and Need

Tell the Air Force that expanding military combat training over rural communities and tribal and public lands is not acceptable. The Air Force should restrict its lower elevation and supersonic flights, and other combat training, such as dropping chaff and flares, to the Barry M. Goldwater Range where it’s already happening. The Air Force must not shift the burden of risk to rural and tribal communities in southern AZ and NM.
The DEIS fails to offer a compelling reason why expanding low altitude combat training and lowering supersonic flight levels is warranted, given that it states the Barry M. Goldwater Range (BMGR) could meet its training needs with the addition of weekend scheduling. This is a much safer alternative than submitting dozens of communities and millions of acres of protected lands to increased safety risk. This has not been adequately analyzed as an alternative.
The A-10’s are being retired and will be replaced by aircraft that do not require the extreme low elevation training parameters, including lowering the supersonic floor from 30,000 feet to 5,000 feet. This has not been adequately analyzed in the DEIS, and the alternative of the BMGR in light of this has not been adequately considered.

Cumulative Effects

The DEIS repeatedly says that negative consequences “would not occur with any sort of regularity or be a repetitive situation in any location.” As we have seen in the Tombstone MOA, that is not the case. Even before this expansion, activities have been concentrated in areas, such as canyons in the Chiricahuas, which are populated and environmentally critical areas. We are supplying copies of nuisance flight reports to show this.

Lack of Accountability

Public and Agency Involvement in this process has been inadequate. No hearings were scheduled in Cochise County or on tribal lands. Relying on virtual hearings ignores the realities of broadband in rural and tribal areas. This is inequitable. Because of this lack of opportunity for public involvement, required by NEPA, the comment period should be extended by 60 days.
Public comments during scoping were largely dismissed without adequate analysis and without considering their substance.
Neither the letter nor the spirit of NEPA has been held to in this process.

The Air Force is currently violating FAA regulations that call for avoiding overflights of persons, vehicles, or structures in uncongested areas by 500 feet (14 CFR 91.119). They have been unresponsive to existing noise and disturbance complaints from communities below their airspace. We are supplying copies of nuisance flight reports to show this.

The Air Force has not responded to requests for information on the need for the optimization.
- This includes failure to respond to a Freedom of Information Act request to release public records, which has resulted in a lawsuit.
- The Air Force has failed to share public comments made during scoping. This includes comments made by the public, as well as those made by government agencies, municipalities, tribes, etc., other than in a summary format that left much unknown.

Specific Areas of the DEIS

The DEIS analysis of Noise is analytically inadequate.
- The DEIS relies on a measure of decibels DNL or Day-Night Average Sound Level. DNL is calculated by summing the sound exposure during daytime hours with weighted measure for nighttime hours and averaging this sum over a 24-hour day. It is an average not the ACTUAL SOUND that a person hears. DNL is not a measure sensitive to very loud, isolated events, such as an F-16 overflight, which may not even influence this measure.
- The DEIS reports some Lmax or SEL noise levels that are quite high and in a dangerous level. The CDC says “any sound that’s 85 decibels or higher can cause hearing loss.” Lmax for an F-16 can be as high as 131 dB according to the Air Force.
- The DEIS uses outdated research and does not consider additional and more recent studies.
- The DEIS acknowledges that lowering the flight floor of supersonic jet flight to 5,000 feet AGL will increase the sonic boom pressure five-fold. But the flawed analysis concludes there will be no increase in negative impacts, despite the increasing evidence of broken car windshields, cracked foundations and recorded evidence of damaged houses. The Air Force should restrict low level supersonic flight to existing training grounds more suited to that level of risk.

The DEIS analysis of Safety issues is analytically inadequate and does not provide adequate mitigations.
- The DEIS minimizes the cumulative risk of fire from the substantial increase in the number of flares drops permitted. References and data regarding these risks is outdated and dismisses known cases of fire caused by military training and ignores the rising threat of climate enhanced fires here. No realistic plans for fighting a flare or crash fire are included in the plan.
- With the significant increase in flights in the Tombstone MOA, there will be an increasing likelihood of “mishaps” or crashes. This is exacerbated by pilots “hot dogging” in the canyons and breaking regulations.

The DEIS analysis of Natural Resources is analytically inadequate and does not provide adequate mitigations.
- The DEIS dismisses possible impacts on the dozens of endangered and threatened species, particularly those with critical habitat below the airspace. The analysis does not adequately project the impacts of the increasing frequency of low-level jet flight on animal behavior and fails to consider the incremental and cumulative effects on these species.
- Research shows that a very high impact from aircraft noise may cause direct mortality, destruction of nests, and/or reduced use or abandonment of an area or nests.
- The DEIS should consider Avoidance Zones over all wilderness areas, wildlife refuges, designated critical habitats, national park units, traditional cultural properties, and tribal lands. These alternatives and mitigations were not adequately considered.