Several have asked what you might include in your 2-minute comments at the public hearings (virtual or face-to-face). The DEIS is full of outrageous statements, and it is hard to wade through it all and pick out the most salient points to make, but below are a few ideas. Of course, please focus on what is most important to you and make this your own. More detailed comments can and should also be made in writing online by Oct. 9, and we’ll be posting more thoughts on that as well before then.
If you’d like to share your comments, email them to us. (Note that inclusion here does not mean we endorse these comments.)
Sample
Moving flights from the unpopulated Barry M Goldwater Range to this area where families live, ranchers work, and wildlife thrives in biodiverse wildlands is a horrible and unnecessary plan.
In the DEIS, the USAF makes several statements that we believe are factually inaccurate.
First, the DEIS says there is “no new or unique flight safety issues or additional risk in any of the MOAs.” The DEIS claims that the risk of fire from flares is nonexistent. Clearly, this is not the case.
Second, the DEIS says “Noise exposure would be …[compatible] with all land uses to include recreational uses” and would not “disturb outdoor recreational users.” In addition, it says “noise exposure would not be at a level expected to impact property levels.” This is untrue even now, and will be worse under the new proposal. Doubling the flights equals doubling of noise. And sonic booms will add to that.
[Other optional issues to include: unique biodiversity and wildlands, sonic booms, chaff, etc.]
We will submit more detail on this in written comments.
In addition to this, I’m very concerned that the US Air Force and Air National Guard are not adhering even to the current regulations. Military flights are flying outside of the MOA and over residential properties. Flights are often below minimum limits. Noise is excessive.
If the current regulations are not being adhered to, how much worse will it be when they are expanded?
Finally, we are not receiving response to reports of nuisance flights that request response, and public records requests under FOIA have been declined. Why are we being denied the right to examine relevant data?
Please consider the many people living in this MOA and take no action on this proposal. Thank you for receiving my comments.
Sample
I am here to request that the Air Force extend the public comment period for an additional 60 days beyond October 9 to allow for the fact that there is no effort being made to inform or allow residents in Cochise County to legitimately comment on the community impacts of the Preferred Alternative. Additional time should be added to the public comment period to enable the people of Douglas, Bisbee, Portal, and many other populated places in Cochise County a chance to learn of the serious impacts on their lives posed in the daft EIS. Cochise County is the most heavily impacted of any county included in the DEIS proposal, yet no hearings have been scheduled in that county at all. This lack of intent to conduct hearings in places that matter raises major questions about USAF concerns for transparency.
And offering Virtual Hearings is no replacement for in-person hearings because many people living in rural Cochise County have very poor access to broadband services, or would have to travel for hours to reach hearing locations in places well outside Cochise County—in essence preventing them from exercising their right to comment. The fact that there have been no public hearings scheduled for the places in populated areas in the Tombstone MOA where impacts will be the greatest, makes one wonder—is the Air Force promoting something that is so highly detrimental to community welfare that wide-spread discussion of its plan might keep it from happening? Someone please explain this strange lack of transparency.
Thanks for your time.
Sample
The key premise of any kind of marketing plan is to understand the audience before starting the campaign. And the big failure of any marketing plan is to start a campaign without knowing the audience. But even worse is knowing what the audience wants, but starting the campaign anyway, without addressing those needs.
And that pretty much describes the marketing failure of the USAF as it attempts to convince an audience that clearly opposes its plans with one that includes everything that its audience (the public) opposes. The DEIS flies in the face of the 6,600 public comments received during the scoping process asking for changes. There is no excuse for this level of blatant audience-blindness in any marketing campaign—let alone one that imposes severe negative impacts on its audience. This DEIS insufficiency needs to be carefully addressed.
Another standard planning practice when developing a new version of an old product is to research what might have changed
demographically and geographically from the time the original project was developed until the current time. And once again, the USAF has apparently violated a basic planning practice with its proposal to double the intensity of Combat Training Missions over the Tombstone MOA. If the research had been done, it would have been clear that back in 1976, when rule-making and boundary design for the original Tombstone MOA was designed, there were 70% fewer people living in this region. And since then major increases in protected lands and more stringent protections for those lands and the species that live on them have taken place. Therefore, one would logically assume that any new proposal would take into account those substantial changes and adjust planning to reduce public risk and negative economic impact. But instead, the Air Force now proposes to DOUBLE the Combat Training Missions in the Tombstone MOA. Apparently, to the Air Force, a doubling of population and more protected areas simply means you should double the activities that pose the greatest risk to the public and our lands. Can someone please explain to me the basis for this backwards thinking?
Thanks very much.
Sample points
- The DEIS ignores the social and cultural impacts to tribal communities who will disproportionally experience the negative impacts from this proposal. Tribal communities were overlooked during the scoping period and the DEIS comment period and are absent from any of the Public Hearing locations. Three tribes, the Tohono O’odham Nation, White Mountain Apache Tribe, and San Carlos Apache Tribe, bear a disproportionate burden from the proposal since 5 of the MOAs are directly above millions of miles of Tribal lands and the impacts are so significant.
- The DEIS fails to offer a compelling reason why expanding low altitude combat training and lowering supersonic flight levels is warranted, given it states the Barry M Goldwater Range (BMGR) could provide all of 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 significant increases in combat training sorties. The DEIS eliminates this alternative, shifts risks of low altitude combat training from the safer option – the BMGR – to rural and tribal communities who are unprepared for accidents and emergencies. The Air Force should reconsider the use of BMGR in the EIS.
- 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 across the Desert Southwest. Communities and land agencies, ill-equipped to deal with large scale fire emergencies, are assigned to primary responsibility for crash response. No realistic plans for fighting a flare or crash fire are included in the plan.
- 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 thereby fails to consider the incremental and cumulative effects on these species – as is required by EIS regulations. The DEIS neglected to include NM Game and Fish as a consulting agency.
- The DEIS acknowledges that lowering the flight floor of supersonic jet flight to 5,000 ft (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 nationwide of broken car windshields, cracked foundations and dozens of recorded evidence of damaged houses. The Air Force should restrict low level supersonic flight to existing training grounds more suited for that level of risk.
- The DEIS analysis of noise is based on outdated research and needs to consider additional and more recent studies.
- The DEIS minimizes the effect on regional airspace needs within the developing civil aviation community.
- The Air Force has not responded to requests for information on the need for the optimization and has been unresponsive to existing noise and disturbance complaints from communities below their airspace.
The Code of Federal Regulations Section 91.119 defines FAA minimum safe altitudes for all flights. In part it says:
“[N]o person may operate an aircraft below the following altitudes:
….
(b) Over congested areas. Over any congested area of a city, town, or settlement, or over any open air assembly of persons, an altitude of 1,000 feet above the highest obstacle within a horizontal radius of 2,000 feet of the aircraft.
(c) Over other than congested areas. An altitude of 500 feet above the surface, except over open water or sparsely populated areas. In those cases, the aircraft may not be operated closer than 500 feet to any person, vessel, vehicle, or structure.”
The FAA administers this, and the US Air Force acknowledges and references these regulations throughout the DEIS.
In fact, this is part of the rationale the Air Force uses for its claims that there are no significant impacts of noise, dangerous aircraft crashes, and other safety risks as a result of this proposal.
However, those of us who live in these MOAs know that these rules are being broken routinely.
Citizens in the Tombstone MOA have documented this through hundreds of nuisance military flight reports, many of which occurred directly over people or structures including houses. Some occurred outside of designated MOA areas. These reports were sent to the US Air Force’s Davis-Monthan Base and the Arizona Air National Guard, usually requesting a response, which has seldom been given.
Data on actual military flights has been requested from the Air Force under FOIA to corroborate these violations. However, those requests were denied, and there is a pending lawsuit about that now. What does the AF have to hide?
If military combat training flights are already violating the rules, causing safety risks, noise, and economic harm to our area, one can only imagine how much worse things will be if the rules are expanded.
From Suzie G:
“Depending on the situation or recreational activity, the visual or noise intrusion may be annoying or disruptive,
particularly, in quiet settings such as parks, forests, or wilderness areas”.
This is precisely the situation AND the problem. This is an understatement!
Sonic booms, no matter how infrequent with any possible affects on fragile structures, and the environment with changes therefore, in historical properties and wildlife, also
including traditional cultural properties, ceremonies and gatherings, over time and these requested ongoing
intrusions is NOT acceptable.
You say you’d want not to have to publish times MOA’s would take place and not tell of any changes, causing an administrative burden. That could only mean that the burden would fall on the people and places, unannounced. This too is NOT acceptable. I would like to see a severe decrease in the use of chaff and flares that by some independent research, IS an
environmental hazard… with concerns of the aluminum, and other water and other environmental and wildlife safety.
I will also suggest that there be a better scheduling program at the Barry M. Goldwater range to better utilize that for your practices.
Perhaps the best way to increase your aircrew survival rates along with the peace and protection of Southern Arizona, and New Mexico, is to begin working on ways to De Escalate our war effort and work toward Peace instead.
And lastly, if we must then I ‘d say stay with the current plan of MOA’s (#1)
Noise is one of the greatest concerns our community has with the Air Force’s proposal to expand military combat training flights here, and the DEIS’s analysis of noise is flawed, misleading, incomplete, and inaccurate.
First, the DEIS relies on noise modeling instead of ACTUAL noise measurements. It says that “real time measurement of new aircraft noise in an area is not possible” since it hasn’t yet happened. However, measurement of even current noise show alarming levels.
In addition, the noise research that the DEIS cites is outdated and cherry picked.
Perhaps most importantly, 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.
Based on this measure, the AIr Force is able to claim repeatedly that noise is not an issue — or as they say, the noise from their planes is “generally compatible with all land uses.”
Clearly from the number of nuisance reports that have been filed by the community, THAT IS NOT THE CASE.
The DEIS does report some possible Lmax or SEL noise levels, which are single event metrics, and they 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.
Finally, the DEIS claims that bothersome levels of noise would be relatively rare. They say they rarely fly at low level and that they avoid “overflight of persons, vehicles, or structures.”
Again, we know that this is not true even now, and we will detail all of this in our written comments.
Over and over again, in the DEIS, the US Air Force concedes that while safety, noise, air quality, socioeconomic damage, and other concerns MAY exist, the concentration and frequency of flights in any one place makes this a non-issue.
In the DEIS’s language, “This experience would not occur with any sort of regularity or be a repetitive situation in any location.” It then concludes “The proposed training would not result in a significant adverse impact” for the many categories of harm to our area, including noise, recreation and tourism, effect on wildlife and wilderness areas, and property values.
These sentences or something similar appear throughout the document.
Living with this here every day, we can tell you this is not the case.
Over the last two years, we have seen flights concentrated in certain areas of the Tombstone MOA, including Cave Creek Canyon, Horseshoe Canyon, and other canyons and mountainous regions of the Chiricahuas.
We can document this through hundreds of nuisance flight reports and radar maps of planes flying here, sometimes circling over and over for hours. We will supply this data in our written comments.
Actual flight data has been requested from the Air Force to corroborate this; however, that FOIA request was not granted, and there is a pending lawsuit.
Reading the DEIS, it appears that the unique canyon terrain in the Tombstone MOA is particularly valuable for training purposes. Sadly, this is also an area of unique biodiversity. And while we understand that, it is not accurate to say that there is not regularity or repetitiveness is where these military combat training flights are done.
Because so much of the DEIS relies on this assumption and averaging out things like noise levels, fire risk, and safety risk to the point of being non-existent, this negates the DEIS.
We request that an analysis be done based on actual flight data and that this data be released to the public.
From Deborah Gordon:
I’m an ecologist and a professor at Stanford. I have been doing ecological research in the Chiricahuas for 40 years. The Chiricahuas are a precious ecological resource, providing a refuge for many local species as well as those on a migration path back and forth from the tropics. As an ecologist I am surprised by the many statements in the DEIS that are not true. Contrary to the report, it is clear that the noise, vibration, sonic booms and the overall disturbance from frequent low-flying airplanes will definitely have a harmful effect on wildlife and their capacity to reproduce. The report does not consider the cumulative effects of what is called ‘temporary behavioral disturbances’ when they occur over and over. The metrics used in the model, based on average yearly noise thresholds, do not take into account the immediate impact on animals of each disturbing event.
Of course flares will greatly increase the danger of destructive wildfires.
The National Science Foundation has supported my research with taxpayer money, as the scientific community recognized the value of studying the ecology of the Chiricahuas. It seems especially ironic that taxpayers are paying one branch of government to learn about this unique place, and another to maintain as a national forest, while they are paying a third part of the government to consider destroying it.
The proposed plan is of course dangerous and disturbing for people who live there and come to use the national forest for recreation, as well as for the plants and animals that live there.
In 1973, the US government created regulations banning sonic booms above land in the United States. This extreme response to unchecked technological advancement was done for several compelling reasons which are still relevant today:
• Public Safety and Well-being: Sonic booms cause sudden, startling noise that may lead to accidents or health issues, particularly in populated areas.
• Property Damage: One of the primary reasons for this ban was the damage caused by sonic booms to property. Windows were shattered, and buildings sustained structural damage. This concern still applies, especially in residential areas where homes may not be built to withstand such forces.
• Environmental Impact: The noise pollution created by sonic booms not only disrupts daily life for residents but also has a significant impact on local wildlife. Studies have shown that animals can be highly sensitive to sudden loud noises, leading to disruptions in their behavior, feeding patterns, and habitat use.
To be clear, a sonic boom is NOT a noise. It’s a shock wave that creates a loud noise. The shock wave is the danger.
When the US banned sonic booms, flights creating them were typically at 30,000 to 60,000 feet. The AF has proposed sonic booms as low as 5000 ft, or four times as intense as the sonic booms the government banned in 1973.
That the DEIS says there is no environmental impact from these flights makes the entire report suspect. No reasonable person could look at these facts and draw that conclusion.
From Gordon Miller:
Thank You, My name is Gordon Miller. I am a retired noise and vibration engineer from the
automotive sector with 38 years of experience conducting noise and vibration studies. I’ve read
over section 3.4 on noise and appendix J. As I read these sections the reality of the severity of
the impact to my community became clearer and clearer from the data that was presented, so I
was quite astonished to read in the conclusion that “The resulting DNL and CDNL does not
exceed significance thresholds, thus there are no land use restrictions or mitigations required
for noise exposure.” How could this be? So I reread the documents and documents from the
FAA and GAO. What became very clear is that the USAF has intentionally misused their analysis
tools in order to arrive at their conclusion.
The FAA uses the DNL metric to produce contour maps of cumulative noise exposure for areas
surrounding all of the airports in the U.S. This is done by calculating the the sound level at each
point on an evenly spaced grid. The calculation takes into account the number of flights, types of
aircraft, their expected flight paths and speed and acceleration scenarios. They also take into
account the effect of the topography near the airport. That is, the hills, valleys, mountains and
canyons in the area.
The Air Force calculates DNL over a grid of points with a spacing of 2000 ft. so for Tombstone
MOA around 28,000 data points. They only calculate at one speed, cruising at 518 mph. They
don’t use the topography, the mountains and canyons. They assume all flights are over a flat
plane. They don’t use a variety of flight scenarios, speeds, altitudes and accelerations. They
don’t use their already known flight paths in the calculations. Finally they average all of the
noise levels together, around 28,000 points, and out pops one number, the Air Force DNL
number. It’s not a contour map with 28,000 numbers, it’s one number that is derived from equal
time at each point on the grid, at one speed and over a perfectly flat region. In other words,
they calculate for a flight scenario that is physically impossible to achieve and produces the
lowest possible DNL. The analysis uses a stacked deck of inputs and processes. The result is that
the significance of the noise levels of individual flights and the concentration of those flights in
areas like canyons is obscured in the results.
The process used in this study violates the ethical standards and practices of the engineering
community, the most important of which is to protect the public’s health and safety
In conclusion, I stand before you, the Air Force, to plead, to beg of you to not implement the
alternatives 2, 3 or 4 until a noise study is completed and reported that is of the same quality
that the FAA produces, uses the known flights paths, uses known velocity, acceleration and
altitude scenarios, uses the topography and produces contour maps that show the true impact
on our environment.
There are many concerns I have with the Air Force proposal, but tonight I’d like to talk about the failures of the process and the lack of accountability.
Neither the letter nor the spirit of NEPA has been held to in this process.
This started with the scoping when thousands of substantive public comments were largely dismissed without adequate analysis. In fact, the Air Force declined to even share actual scoping comments with the public.
In addition, public and agency involvement in this process has been inadequate. No hearings were scheduled in Cochise County or on tribal lands. Instead, hearings were held in small rural areas often outside of the MOAs. With the exception of Silver City, if you looked at the list of towns where hearings have been held, it would be obvious that the goal was to discourage participation.
Like many others, I have read the entire DEIS. It is analytically inadequate and does not provide adequate alternatives or mitigations. More simply put, it is sloppy, misleading, and arrogant.
Beginning with the purpose and need, the Air Force does not make a case for why it cannot restrict this extreme combat training to the Barry M Goldwater Range where it’s already happening. This burden and risk should not be shifted to rural and tribal communities. In addition, the DEIS includes A10s which are currently being retired and replaced by aircraft that do not require the same extreme low elevation training requirements. There are also several other significant changes in Davis-Monthan’s activities which are being covered in separate EISs rather than combined with this one as they should be.
In the discussion of topics like noise, safety, and natural resources, the document relies on outdated and often inaccurate research. It tiptoes around the risks involved, always concluding by saying there are no negative impacts or that the proposal “is generally compatible with all land uses.” This phrase occurs countless times in the proposal.
Finally, the Air Force has not been transparent about In its dealings with the public. They have not responded to many requests for information including failing to respond to a Freedom of Information Act request, which has now resulted in a lawsuit. They have also failed to respond to hundreds of nuisance flight reports and requests for response about why existing FAA regulations are being violated.
Our government should be better than this. If the Air Force insists on going forward with exploring this proposal, I ask that it start over with an EIS that adheres to NEPA and respects the rights and concerns of our citizens.
Uncontrolled wildfires are one of the biggest risks we face here in New Mexico and Arizona. We have lived through horrible fires like the Telegraph and Horseshoe 2 fires that have burned hundreds of thousands of acres, threatened and destroyed homes and buildings, and cost tens of millions of dollars. This region has been in a long term drought for 30 years, and in the current environment of climate change, there is always a high risk of fire here.
The risk of wildfires caused by military flares dropped at both lower elevations and with more frequency is a great concern.
It is believed by experts that fires including Telegraph, many on native lands, and others in Oregon, New Jersey, and other places have been caused by military flares.
Statements from the DEIS like” the increased number of flares proposed does not directly correlate to an increased fire risk” defy both common sense and research. While the DEIS tiptoes around the possibility of flare-caused fires and the dangers of dud flares, it ultimately states “The possibility of a wildfire from flare usage would be remote.” Like so many other areas of the DEIS, the Air Force discounts facts and says that this won’t be a problem. What arrogance.
The DEIS does not provide information on why live flares need to be dropped at such low altitudes in areas so prone to fire or why this training can’t be restricted to areas like the Barry M Goldwater Range.
Please withdraw this proposal to drop flares lower and more frequently. We are not willing to let the Air Force burn down our forest or our homes.
I am concerned that neither the letter nor the spirit of NEPA has been held to in this process.
Public and agency involvement has been inadequate. Community sentiment, as well as factual and substantive data, have been ignored by the Air Force.
During the scoping period, 6,667 comments were made by members of the public, governmental agencies, and others. Those were not shared publicly as is generally done, but were summarized along with the Air Force responses in Appendix D of the DEIS.
Reading those responses was shocking. They were dismissive, incomplete, and inaccurate.
The Air Force apparently didn’t seriously regard the research, experiences, and comments of our community members who have spent a lot of time thinking about and researching this and who experience these military combat training flights regularly.
Further, the Air Force has chosen to schedule hearings like this in locations that are thinly populated and difficult to get to, despite our requests for more accessible locations. There is not one public hearing in Cochise County or on tribal lands, the area most heavily impacted by this proposal.
We have raised this issue several times and were told it was not possible to add other locations and referred to the Virtual Hearings The realities of internet access in underserved communities like ours is that this is not an equitable solution.
We have sent in hundreds of nuisance flight reports that document violation of current FAA regulations. We have received no response. Well, until this week now that public comments are open and the heat is on. How embarrassing.
We invite you again to take our concerns more seriously. If the Air Force insists on going forward with exploring this proposal, I ask that it start over with an EIS that adheres to NEPA and respects the rights and concerns of our citizens.