The EIS proposes 3 alternatives of increasing numbers of F-35s for TIA – increments of 24,48, and 72 planes. There is a “baseline” of no F-35s against which the 3 alternatives are compared. The EIS is deceptive in that it carefully avoids providing the obvious alternative of no F-35s at TIA for public review and comment. Thus, the apparent only choice is the F-35, in various numbers.

According to the EIS, there will be significantly higher noise levels than existing air traffic. It notes that the F-35 in traffic pattern flight will be twice (8 dB) as loud as the F-16. Approaching TIA, the F-35 will be approximately 4 times louder (22 dB) than the F-16. This would be 4 times louder than the A-10 while in traffic pattern flight and some 5 – 6 times louder approaching the airport. Some 7% of the F-35 training takeoffs would make use of afterburners.

Even the smallest increment of the 3 proposed alternatives for TIA will require an expansion of the noise contours around TIA beyond the existing commercial noise contour of today. The commercial noise contour had been shrinking in recent years as newer commercial aircraft with less noisy engines replace older equipment.

Safety risk analysis in the EIS is not based on facts. The F-35 is a brand new aircraft, incorporating new technologies, with no historical safety data records. It should be noted that this aircraft is currently undergoing operational readiness testing and evaluation. Major issues have been found in its engines, software systems, landing gear, etc., which have caused an unexpected three year delay in operational readiness and production. The EIS simply anticipates that operational readiness will be achieved and makes the statement that history shows that mishap rates of all types will decrease the longer the aircraft is operational as flight crews and maintenance personnel learn more about the aircraft’s capabilities and limitations. It then somehow concludes: “there would be no anticipated increase in safety risks associated with aircraft mishaps.”

The EIS notes that live and heavy inert ordnance is not stored at TIA. Therefore, the F-35 must transit to D-M AFB for weapons loading and takeoff. There is no discussion of the number of sorties or flight paths to and from D-M over the City of Tucson.

In addition, the F-35 scoping literature specify that facilities at DM may be required to meet training objectives and would be utilized as necessary. There is no discussion of flight paths over Tucson in the EIS other than a general statement that the F-35 will use the same flight paths as current F-16s.

There is no discussion of the F-35 inclusion in future Snowbird Programs, although it is noted that the F-35 will replace the F-16s, F-18s and Harriers from the existing Snowbird Program that fly into DM today. The EIS does note that the F-35B, slated for the Marine Corps Air Station at Yuma, proposes to use air space in the vicinity of Tucson AGS without specifying where and how often.

It is clear that neighborhoods surrounding TIA under approach/departure and other flight paths will suffer significant noise impacts. The EIS does point out that some 1,511 to 8,127 residents not now affected will fall under the new 65 dB noise contours generated by the 3 alternatives of F-35s proposed. Although the EIS does not so state, both DOD and FAA guidance identify areas within the 65 dB or higher contour as incompatible with residential use.

Unfortunately, the noise analysis itself is replete with technical jargon and fails to note general DOD and FAA guidelines, making it impossible for an ordinary citizen to decipher the overall effect on his neighborhood and quality of life. (A non-technical summary of noise effects is badly needed.)

It is also clear that these neighborhoods will suffer degradation over time. While aircraft degradation in neighborhoods is difficult to quantify since it is a long-term process (which sellers are reluctant to discuss), it is clear in hindsight when one drives through neighborhoods immediate to DM under its approach paths or Phoenix neighborhoods under the approaches of Sky Harbor.

The F-35 will shape Tucson’s future. The key Hospitality Industry brings in $2.4 billion annually to Tucson and provides 25,000 direct jobs and some 40,000 indirect jobs. Visitors are drawn by the area’s unique natural beauty, with 5 mountain chains, the desert and the outdoor climate combined with a rich heritage and culture. Building on this, Tucson has engaged in a major effort to expand its tourism appeal with a major rehabilitation of its City Center. Will winter visitors sitting poolside at higher-end hotels be willing to pay top dollar to listen to overhead air traffic? Would you?

Tucson is developing a second major economic driver – the promotion of high tech, bioscience, optic, medical treatment, and solar businesses linked to UofA research and development. The Bio5 Institute, Critical Path Institute, the Tech Park and new BioPark are all elements in that effort. These are the high-skilled, higher-wage jobs of the future. Will companies and their technical and professional employees be attracted by the amenities of the Tucson area, including the air traffic and degraded urban neighborhoods?

The fundamental question for Tucson residents is: does it make common sense to base the Air Force’s most powerful, loudest, and yet unproven fighter plane at a commercial airport in the center of a relatively large metropolitan area to train foreign pilots?

It is key that the F-35 pilots in training will be using live ordnance which must be loaded at Davis-Monthan.

Hard to find, but on page 40 of the Executive Summary of the DRAFT F-35 EIS, it states “Luke AFB with 72 F-35A training aircraft is the Air Force’s Preferred Alternative.” Holloman, Boise, and TIA are alternative basing locations which gives the Air Force maximum flexibility. If Tucson is selected as an alternative basing location, the question will be how many F-35s will be assigned?

Scroll down for dates, times, and locations of the Tucson public hearings on the F-35.

Air Force holding public meetings regarding F-35A training

Jan 20, 2012 8:15 AM Channel 4 News Tucson
Updated: Jan 20, 2012 8:15 AM

TUCSON – The U.S. Air Force is inviting the public’s input on a Draft Environmental Impact Statement for the proposed Pilot Training Center of F-35A aircraft.
The Air Force has not chosen a base yet. Potential locations include the Boise Air Terminal Airport Air Guard Station, also known as Gowen Field, Idaho; Holloman Air Force Base, N.M.; Luke Air Force Base, Ariz.; and Tucson International Airport Air Guard Station, Ariz.

The purpose of the proposal is to train pilots and personnel to operate F-35A aircraft. Training would include the use of existing training airspace and ranges, which permit flare countermeasures, supersonic flight and the use of munitions.

To download a copy of the Draft EIS, visit www.F-35ATrainingEIS.com. A paper copy of the document is also available at the following public libraries:

Copper Queen Library
6 Main St.
Bisbee, AZ 85603

Safford City-Graham
County Library
808 S. 7th Ave.
Safford, AZ 85546

San Carlos Public Library
89 San Carlos Ave.
San Carlos, AZ 85550

Sierra Vista Public Library
2600 E. Tacoma St.
Sierra Vista, AZ 85635

Valencia Branch Library
202 W. Valencia Road
Tucson, AZ 85706

All comments on the Draft EIS must be postmarked or received by March 14, 2012, for consideration in the Final EIS. Written comments on the Draft EIS may be submitted to:

David Martin, Air Force Contractor, and Kim Fornof
HQ AETC/A7CPP
266 F Street West, Bldg. 901
Randolph AFB, TX 78150-4319
Fax: 210-652-5649
Email: aetc.a7cp.inbox@us.af.mil
Written and oral comments may also be submitted in person at the public hearings.

Public Hearings: Three public hearings near Tucson International Airport Air Guard Station will be held to inform the public and receive public comments on the Draft EIS. All hearings include an open house information session from 5 p.m. to 6 p.m., followed by a presentation and formal public comment session from 6 p.m. to 8 p.m. Representatives from the Air Force will be available during the open house session to provide information and to answer questions related to the Draft EIS.
Public hearings will be held:

Open House Information Session: 5 p.m. to 6 p.m.
Presentation/Formal Comment Session: 6 p.m. to 8 p.m.

Date: Feb. 21, 2012
Location: Windemere Hotel & Conference Center
Grand Ballroom
2047 S. Highway 92
Sierra Vista, AZ 85635

Date: Feb. 22, 2012
Location: Holiday Inn Hotel & Suites Tucson Airport North Ballroom
4550 S. Palo Verde Road
Tucson, AZ 85714

Date: Feb. 23, 2012
Location: Tucson Jewish Community Center Auditorium
3800 E. River Road
Tucson, AZ 85718

The public hearings for the DRAFT EIS will be held between 2/6-2/29/2012. The deadline for comments will be 3/14/2012. Comments may be submitted at the public hearing or faxed to 210-652-5649 or E-mailed to aetc.inbox@us.af.mil. Comments can be mailed to:

HQ AETC/A7CPP
Attn: David Martin, Air Force Contractor and Kim Fornof
266 F Street West, Building 901
Randolph AFB 78150-4319

You can call (210)652-1961 for more information.

Tucson Forward has not had a chance to analyze the document yet, but we will be back with our comments.

By Walter Pincus, The Washington Post, December 26, 2011

There are 56 F-35 Lightning II Joint Strike Fighters being assembled at Lockheed Martin’s facility in Fort Worth. But because only 20 percent of the testing for the most advanced fighter-bomber in U.S. history is completed, each will probably have to get million-dollar-or-more fixes later.

The F-35 is already the most costly U.S. weapons program underway at about $385 billion. But that figure may go higher with overrun of the per-plane contract price for the 56 craft being assembled — along with the future multimillion-dollar fixes likely to be required for them — and the 15 F-35s completed but not yet delivered to the military services.

The plane is being built with the most sophisticated stealth technology, but initial flight tests have turned up hot spots and cracks associated with metal and composites used on most new aircraft. The development of the software controlling the F-35’s major warfighting functions, the most complex ever planned for an airplane, has been delayed so that the last block will not be introduced to the aircraft until at least June 2015.

Earlier this month, Vice Adm. David J. Venlet, executive officer for the F-35 program, said in an interview with the online service AOL that he recommended slowing down current production lines to reduce the replacement costs that will be necessary in aircraft produced before testing is completed.

Production had already been slowed twice. Then-Defense Secretary Robert M. Gates pushed back the building of 122 aircraft in February 2010 as problems became apparent, and again in January as he lowered near-term production for another 124 planes, boosting future production needs.

Sen. John McCain (R-Ariz.) took the Senate floor on Dec. 15 and described the F-35 fighter program as “a mess.”

What upset the senator was not just that the cost of each plane had risen nearly 100 percent from its original estimate of $69 million to $133 million today, or the fact that testing was only 20 percent complete while more than 90 planes had already been bought, or the fact that software — key to 80 percent of the stealth plane’s warfighting capability — wouldn’t be ready for another four years.

It was, he said, that the Pentagon had “sold this program as a fifth-generation strike fighter that would — more so than any other major defense procurement program — be cost-effectively developed, procured, operated and supported.”

McCain faulted the Pentagon for using what he called “a concurrent development strategy to procure a high-risk weapon system.” Production of the first airplanes began as testing was in its infancy.

McCain said the Pentagon was attempting “generational leaps in capability” but at the same time moving before the underlying design was stable. Developing needed technologies and being able to integrate them remain risky and manufacturing processes are still “immature,” he said.

A Government Accountability Office report from April said the forecast was for “about 10,000 more [engineering design] changes through January 2016.” The GAO added, “We expect this number to go up given new forecasts for additional testing and extension of system development until 2018.”

(Tom Harvey/ASSOCIATED PRESS) – Lockheed Martin says the F-35 flight was a success, even though what was to have been an hour-long flight only lasted 35 minutes. Although it did not pose a danger, the procedure called for ending the flight at that time, preventing completion of the remaining few tests, including raising the landing gear.

http://pogoblog.typepad.com/pogo/2011/12/leaked-pentagon-report-reveals-slew-of-joint-strike-fighter-problems.html

Leaked report on the F-35

OSB EA Comment Submittal
355th Fighter Wing Public Affairs Office
3180 S. First Street
Davis-Monthan AFB, AZ 85707

Dear Sirs:

In accord with a letter written to the Tucson community by the Air Force in 1978, to limit over-flights of quieter and safer military aircraft, Tucson Forward, Inc. (TF) serves to protect and enhance Tucson’s livability, property values, and economy. Our organization educates Tucson residents and government agencies about problems associated with the noise and safety of the military aircraft flying over our community. We also work with other organizations, individuals, and government agencies to re-establish safety and tranquility for all Tucson residents and neighborhoods.

Many supporters of TF are currently submitting written comments to the scoping phase of the Operation Snowbird Environmental Assessment. We agree with the comments of our supporters.

To ensure that the final decision regarding Operation Snowbird (OSB) will withstand potential legal challenges, the issues raised by supporters of TF must be carefully and comprehensively analyzed. This will require an Environmental Impact Statement.

Issues raised by supporters of Tucson Forward, Inc. include (but are not limited to):

* The analysis must use 1978 Operation Snowbird activity as its baseline.

The Air Force has advocated a 2002 baseline because they assert that the 2002 CSAR EA (Combat Search and Rescue Environmental Assessment) has analyzed OSB operations. Actually, the 2002 CSAR EA does not even mention OSB. The baseline chosen, however, does include the types of aircraft and the annual number of sorties that are flown by OSB.
Inclusion of OSB’s types of aircraft and number of sorties in the baseline of the CSAR EA does not constitute an environmental analysis of OSB. In fact, operations included in the baseline of any EA are excluded from analysis. The CSAR EA provided an environmental analysis only of the HH-60 and HC-130, both of which are CSAR aircraft, but current OSB analysis cannot use as its baseline any aircraft or operations that have not previously been analyzed in accordance with NEPA (National Environmental Policy Act). As the Air Force’s Wyle Study recognizes, OSB was last analyzed in 1978, and 1978 is the only defensible baseline.

* An updated AICUZ must precede completion of the Environmental Analysis.

Without the information provided by a current AICUZ (Air Installation Compatible Use Zone), the impacts of OSB aircraft over Tucson cannot be accurately analyzed.
Page 55 of the Wyle Study states: “The prevailing AICUZ, dated 1992, does not reflect the current level of operations.” The Study recommends that the Air Force prepare a new AICUZ to “re-evaluate aircraft noise and accident potential.”

* The analysis must carefully consider the effects of peak sound exposure levels.

DNL (day-night average sound level) measurements are often used to evaluate the noise impacts of aircraft. However, recent studies have shown that humans are most disturbed by peak levels.

When aircraft fly over urban areas at relatively low altitudes the noise they produce is loud but brief. Though they may be significantly higher than ambient levels, the loud brief noises do not substantially affect DNL calculations. DNL figures do not reflect the disruptive nature of peak levels.
Recognizing this, the Department of Defense’s Operational Noise Manual states, “To assess the impact of this transitory noise [of an aircraft], the Sound Exposure Level, or SEL, is the best measure of the annoyance response.” The Manual notes that “a Leq of less than 65 dBA during the day is considered acceptable for a residential area.” Additionally, in interior rooms of military facilities, Leq (equivalent continuous sound pressure level in decibels) should not exceed 45 dBA (decibel) for sleeping.
A thorough analysis of the effects of peak levels is critical to an understanding of the impacts of noise upon the residents of Tucson. An analysis of recent studies on peak sound exposure levels is also critical.

* Analysis of the noise impact must be based upon sound measurements of actual flights of military aircraft over Tucson.

Computer modeling of aircraft noise cannot adequately predict the effects of wind, humidity, and nearby mountain ranges that are unique to Tucson. The Air Force has acknowledged the shortcomings of computer modeling; its disclaimers include statements such as: “Acoustic levels experienced by the public depend on a number of conditions,” and “Acoustical impact is highly dependent on local environmental conditions.”

When sound measurements of actual flights over Tucson are made, the flights must be conducted at the power settings, altitudes, directions, and paths which the aircraft normally use when approaching and departing D-M.

* The analysis must consider alternative sites for OSB.

NEPA requires every analysis to include “reasonable alternatives to the proposed actions.” The Wyle Study was commissioned by the Air Force, and is the antecedent to this EA. On page 15, the Study proposed two appropriate alternatives for this EA:

Alternative A: Relocate Snowbird operations to another USAF facility
Alternative B: Relocate Snowbird operations to Tucson International Airport where the ANG (Air National Guard) has existing facilities.

Both alternatives should be included in the EA. Wyle’s Alternative A is imperative, because it eliminates many of the negative impacts that follow from all four of the Air Force’s proposed alternatives.

Relocating OSB to another facility would provide much greater flexibility for pilot training. At Davis-Monthan AFB, aircraft are severely restricted in their approaches and departures, and in their hours of operation. At another facility that does not require arrivals and departures over densely populated residential neighborhoods, pilots can train at all times of the day and night, at all throttle settings, and with a variety of approach and departure routes.

* The analysis must use results-oriented specifications in all recommendations for sound mitigation.

Merely specifying certain methods of mitigation is not sufficient, because the methods may later prove to be ineffective or unworkable. For example, because Tucson International Airport and Davis-Monthan are very close together, flight paths and altitudes cannot be easily altered. Mitigation by altering flight paths is difficult or impossible.

The analysis must use results-oriented mitigation. It must specify the maximum decibel level that will be permissible after mitigation has been implemented.
The analysis must consider the impacts that mitigation may have upon the training of pilots. For example, if mitigation requires that landings and take-offs be performed with reduced power, pilots will have no opportunity to learn how to control their aircraft while using military power at approach and departure.

The analysis must also consider the impacts that mitigation may have upon safety. For example, if mitigation requires aircraft to make a sharp turn at take-off in order to avoid populated areas, the analysis must evaluate the risks associated with that maneuver.

* The analysis must carefully consider the effects of sound exposure levels upon the livability of the affected neighborhoods.

Operation Snowbird flights constitute only five percent of approaches and departures at Davis-Monthan, but most Snowbird aircraft are much louder than the A-10s that are stationed at D-M. Snowbirds contribute disproportionately to the noise levels of aircraft over Tucson’s residential neighborhoods.

The analysis will consider the consequences of homeowners and tenants migrating from the neighborhoods as they seek quieter surroundings. It will consider the consequences of owner-occupied homes being converted into rental units. It will consider the consequences of lower rents in neighborhoods that have become noisier. It will consider the consequences of properties that will be allowed to physically deteriorate as pride-of-ownership erodes.

In establishing the requirement for an analysis, the National Environmental Policy Act states that, “it is the continuing responsibility of the Federal Government to […] assure for all Americans safe, healthful, productive, and aesthetically and culturally pleasing surroundings.” The analysis must take this mandate seriously.

* The analysis must carefully consider the effects of sound exposure levels upon the property values of the affected neighborhoods.

In addition to impacts on property values, this analysis will include impacts on the tax base of the affected neighborhoods, as well as impacts on property-tax revenues collected from those neighborhoods.

Many studies show the relationship between aircraft noise and the loss of property value. For example, in 1994 the Federal Aviation Administration and consultant Booz- Allen & Hamilton developed a methodology for evaluating the impact of aircraft noise on housing values. They demonstrated that in moderately priced neighborhoods in the vicinity of Los Angeles International Airport, noise diminished property values by 18.6%, or by 1.33% per decibel. A separate analysis, prepared for the Orange County Board of Supervisors, showed the diminution of property value averaged 27.4% in the vicinity of the three California airports that were studied.
Executive Order No. 13352, which was signed by President George W. Bush and which is appended to the National Environmental Policy Act, states that the Secretary of Defense shall “carry out the programs, projects, and activities of the agency [...] in a manner that [...] takes appropriate account of and respects the interests of persons with ownership or other legally recognized interests in land and other natural resources.” To comply with this Executive Order, the analysis must consider the loss of value that property owners suffer.

* The analysis must carefully consider the health effects of aircraft noise.

The National Environmental Policy Act states, “each person should enjoy a healthful environment [...].”
In a publication called Community Noise (edited by Birgitta Berglund and Thomas Lindvall, 1995), the World Health Organization compiled the results of more than nine hundred separate studies of the effects of noise upon humans. The studies demonstrated that increased levels of noise cause—among other things—elevated blood pressure, vasoconstriction, headaches, irritability, instability, argumentativeness, anxiety, nervousness, insomnia, and loss of appetite. The effects were most pronounced among children.

* The analysis must carefully consider the effects of aircraft noise upon the learning abilities of students—including students at the University of Arizona.

In Community Noise, the World Health Organization compiled the results of more than nine hundred separate studies of the effects of noise upon humans. The studies found that students affected by aircraft noise have a greater difficulty learning to read and processing information. The Department of Defense’s Operational Noise Manual lists additional problems that students suffer from when exposed to noise in the classroom, and it lists the types of students who are most susceptible to the impacts of noise.

Twenty-four-hour DNL averaging is not appropriate for determining the noise impacts on schools and other facilities that are occupied only for part of each day. Recognizing this, the Operational Noise Manual states that “contour maps of DNL, by themselves, cannot be used to determine whether a particular classroom is suitable for learning.” The Manual uses Leq, rather than DNL, to measure noise in classrooms.
The Manual notes that “For school children, the American National Standards Institute (ANSI) has recommended a [...] limit of 35 dBA.”

* The analysis must carefully consider the effects of aircraft noise and safety upon the assets of local school districts.

Several years ago, at the request of Davis-Monthan officials, Tucson Unified School District closed Keen Elementary School, which was located beneath a flight path (refer to TUSD Board Agenda Item of August 12, 2003). In addition, the Vail Academy and High School was moved from beneath a flight path in 2010, at a cost of $7 million.

The analysis must consider the impacts upon children, staff, and school budgets when schools are closed or moved. The analysis must identify the assets of local school districts that may be affected by aircraft noise and safety.

* The analysis must carefully consider the economic effects of aircraft noise upon local businesses.

According to the U.S. Department of Commerce, Tucson’s leisure and hospitality industry in 2008, contributed $1.5 billion in direct economic impacts on the area’s $33.1 billion gross domestic product. The leisure and hospitality industry provided 4.5% of Tucson’s total income. In contrast, Operation Snowbird provided less than 0.01%.

Though OSB aircraft perform only 5% of all sorties at Davis-Monthan, they create much greater disturbance because most OSB aircraft are louder than the DMAFB’s A-10s. Tucson’s leisure and hospitality industry suffers when visitors must endure the noise of OSB aircraft over the resorts, RV parks, golf courses, and surrounding attractions such as Saguaro National Monument, Tucson Mountain Park, or Old Tucson.

If the disturbances due to OSB aircraft cause a decline in the leisure and hospitality industry by only a fraction of a percent, the loss to Tucson’s economy will be much greater than the total contribution of OSB.

* The analysis must carefully consider the effects of flight paths on the development of Tucson.

A substantial amount of undeveloped property lies to the southeast of Davis-Monthan. Because of D-M’s flight paths, property owners are constrained from developing their investments. This deprives Tucson of income derived from the development of the properties, and it limits expansion of the area’s residential, commercial, and industrial facilities.

In just one example, in 2008, the University of Arizona Science and Technology Park contributed $2.1 billion in direct economic impacts on Tucson’s economy. Its contribution in future years would be significantly greater, except that Davis-Monthan flight paths have forced the Science and Tech Park to scrap its plans for substantial additional onsite development.
Properties inside the 65 dBA DNL contour are designated as “not compatible with residential use.” Currently, this designation affects several thousand properties in the vicinity of Davis-Monthan: Elementary and secondary schools, day-care facilities, and multi-family residences are prohibited; significant modification of existing single-family homes is also prohibited. Inside the 70 dBA DNL contour, colleges, churches, hospitals, libraries, and museums are prohibited; even cemeteries are prohibited.

* The analysis must carefully consider the impacts that urban encroachment will have upon the mission of OSB.

The Department of Defense’s Operational Noise Manual states that urban encroachment “can place severe limitations upon the ability of a military installation to support training and maintain an adequate level of readiness for assigned units.”
Because of urban encroachment, substantial restrictions have already been placed upon the activities of Operation Snowbird (and all other units at DMAFB). This compromises training opportunities for OSB pilots as well.

As encroachment increases in the years ahead, additional limitations will likely be placed upon operations at DMAFB. This will further compromise the training of OSB pilots. The pilots will be increasingly restricted in their hours of operation, in the flight paths, in the power settings at takeoff and landing, in the number of sorties permitted per year. Their training will suffer from continued urban encroachment.

* The analysis must carefully consider the handling, storing, and loading of live ordnance for the aircraft of Operation Snowbird.

The analysis must also consider the risks associated with aircraft that are loaded with live ordnance as they fly over densely populated urban areas. Further, the analysis must consider the methods used to ensure that stored ordnance is secured against potential terrorists and other criminals.

* The analysis must carefully consider the safety aspects of Operation Snowbird aircraft as they fly among the mix of other air traffic.

Davis-Monthan generates substantial air traffic, in addition to that of Operation Snowbird. Further, both commercial and military aircraft approach and depart the nearby Tucson International Airport. All aircraft fly in relatively close proximity using a variety of flight paths that are controlled by different air traffic controllers located at D-M, TIA, and TRACON (Terminal Radar Approach Control Facilities).

OSB pilots are not familiar with the flight paths over Tucson, and they are not familiar with the regulations that are unique to those flight paths. Further, the pilots of foreign services may not be proficient in English and may have difficulty communicating with the various ATCs (Air Traffic Control).
The analysis must consider the effects of potential crashes as Operation Snowbird aircraft fly over densely populated urban areas, which include schools, the University of Arizona, and the University Medical Center.

* The analysis must carefully consider the effects of air pollution from the aircraft of Operation Snowbird.

Exhausts from the aircraft affect Tucson’s air quality. Furthermore, hydrocarbons are released into the atmosphere during storage and transfer of aviation fuel and other petroleum products.

* The analysis must carefully consider the effects of aircraft noise upon the tranquility of parks and preserves that lie between TIA and the Barry M. Goldwater Range.

The Department of Defense’s Operational Noise Manual states that DOD “must be concerned with the potential effect that overflights in our national parks and wilderness areas may have on the wildlife and visitors.”
Areas potentially affected by OSB overflights include: Saguaro National Park, Organ Pipe National Monument, Ironwood Forest National Monument, Tucson Mountain Park, Picacho Peak State Park, and Cabeza Prieta National Wildlife Refuge.

* The analysis must carefully consider the effects of aircraft noise upon wildlife that inhabit the undeveloped areas between TIA and the Barry M. Goldwater Range.

As OSB aircraft fly between Tucson and the Goldwater Range they pass over the habitats of several endangered species. These include bighorn sheep, Sonoran pronghorn, ferruginous pygmy owls, and lesser long-nose bats.
“Recommendations for Improved Assessment of Noise Impacts on Wildlife,” which was published in Vol. 73, No. 5, of the Journal of Wildlife Management, lists several serious noise impacts upon animals. The article warns that because different species have different audiograms, “[w]eighting systems [such as dBA] developed for humans are not appropriate for animal species that have substantially different audiograms.” An analysis must use weighting systems that are specific to each species of wildlife.

The article notes that for “transient noise events, a simple measurement of SPL or LEQ is not adequate […] . For aircraft and helicopter flyby noise events, 2 metrics are sometimes measured and reported, both the SEL and the maximum equivalent average […] because both are good candidates to be related meaningfully with an animal’s response.”

Sincerely,

, Director
Tucson Forward, Inc.

On the first page of the Resolution there was mention of the MCRC.

WHEREAS, the Tucson and southern Arizona communities provide dedicated and superior support to the Air Force, its installations and its airmen and airwomen. Community support organizations such as the D-M-50 and the Military/Community Relations Committee, the Arizona congressional delegation, local elected officials and the community as a whole support the Base, its personnel and its continued growth in Tucson; and

TF Note: There was objection by several MCRC and TF members to characterizing the MCRC as a community support group for Davis-Monthan. Also, the MCRC has not voted to support bringing this unit to Tucson. Mention of the MCRC has been removed for the Resolution.

On the second page of the Resolution there is mention of the 2004 Pima County Bond issue.

WHEREAS, in 2004, Pima County allocated $10 million in voter approved General Obligation bonds to support the viability of Davis-Monthan Air Force Base and will continue to purchase and protect the departure corridor; and

TF Note: Here is the summary of the March 16, 2005 PIMA COUNTY DAVIS-MONTHAN OPEN SPACE ADVISORY COMMITTEE

After speaking to Regina Nassen from the Pima County Attorney’s office, he reported that the committee could bring an expert or consultant to report on a specific topic such as noise and not have it open for public discussion. Regina will work with the committee in preparing/tailoring the agenda when these types of issues come up.

One wonders why the public would be excluded.

Also, on page two of the resolution is mention of possible sound attenuation for residences to northwest of Davis-Monthan (the approach corridor). Julia Keen might be one neighborhood that would be considered. The City of Tucson had promised to diligently seek funds for sound attenuation back in September of 2004 just before the City Council voted to adopt the extension of the Airport Environs Zone (AEZ) overlay. The City made a half-hearted attempt to seek funds from the State for a study of such a program, but the Governor’s Military Affairs Committee (GMAC) turned them down. They no longer have funds.

WHEREAS, Pima County will consider allocating General Obligation bond funding to reduce or mitigate the noise impact on residential properties within the approach zone.

TF Note: One wonders why there is mention of a noise mitigation program when there are supposedly no aircraft connected to the “Drone-Driver” squadron. Pima County (Chairman Ramon Valadez’ District) has not consulted with the residents of the impacted neighborhoods to see if they want their homes to be noise mitigated. (Some are fearful that this would allow louder aircraft, i.e. the F-35.) Also, there is no mention that this program would have to be approved by voters who are not inclined these days to vote for added debt. This looks like a trail balloon. Something to perhaps impress Washington.

Re: OSB EA Comment Submittal
Environmental Justice

Dear Mr. Ingram:

Thank you for the opportunity to comment on the Operation Snowbird (OSB) Environmental Assessment. This letter is submitted on behalf of Tucson Forward Inc., an Arizona non-profit organization of approximately 600 persons. Tucson Forward works to protect and enhance Tucson’s economy and the livability and property values of Tucson by promoting limited over-flights of quieter, safer military aircraft.

We noted in the Scoping Meeting of September 27, 2011 the lack of any consideration for the impact of OSB on minority and low income neighborhoods under the flight paths; nor were there any publicity, materials, or presenters in the Spanish language available. Further, we noted that the Environmental Justice Section (4.12.1 .1) of the 2002 CSAR EA for Davis-Monthan concludes: no impact affecting minority and low-income communities. Yet, two years later, a minority neighborhood was forced to close its school. Additionally, that EA never examined the impact of the OSB changeover that occurred in about 2000 on minority and low income neighborhoods. As you know, this is not acceptable within the intent of Executive Order 12898 or Air Force Instruction 32-7061.

The EA needs to examine the neighborhoods under the DM OSB flight paths and the so-called “Race Track” landing pattern and identify if they fall under the low income and minority categories. This would include, but not be limited to Julia Keen, Alvernon Heights, Barrio Centro, Myers, Naylor, Roberts, etc.

The EA should look at the history of OSB found in the Wyle Study. DM has a clear urban encroachment problem to the northwest compounded by air restrictions from TlA, and mountain ranges to the east. There was a major changeover of the OSB
with significant impact on the above neighborhoods about the year 2000, but there was no environmental assessment done as required under NEPA. The 2002 CSAR EA did not address the issue of environmental justice in terms of OSB. In order to meet its NEPA requirements the AF is now carrying out an EA of a future OSB Program. However, that EA is being structured to minimize the impact on the environment and residents under the flight path by selection of the EA baseline. That selection circumvents the intent of NEPA law. Tucson Forward, Inc., and other residents are protesting the use of the year 2002 as a baseline, because of the major expansion of OSB prior to this baseline year which was done without any EA. This history needs to be documented in the proposed EA.

The EA should examine the impact of the changed OSB from the winter-time proficiency Program (prior to 2000) to the proposed year-round combat training alternatives and ascertain whether these neighborhoods currently, and in the future, suffer a significant impact in terms of livability, health, safety risk, noise and decline in property values. A professional judgment would be useful as to whether the neighborhoods knew what was happening during the change-over that occurred in about 2000, and whether they had the ability and/or means to organize themselves (as did more fortunate neighborhoods further along the flight path) in order that they could learn and begin complaining to the AF in Washington about the negative impacts of the changed OSB.

The EA should specifically examine the closing of the Julia Keen Elementary School in 2004 and how it was handled (several years after the OSB changeover) and the 2002 CSAR EA conclusion noted above. Attached is a TUSD Board Memorandum that indicates the Board was pressured by DM-50 business supporters to close the school. The neighborhood’s desire was to keep their school open. The EA should also examine where those specific business supporters resided and whether they had financial interests in promoting the increased air traffic over neighborhoods in which they did not reside.

The EA can then assess the results the school closing had on the Julia Keen neighborhood and how it subsequently affected property values surrounding the
school, including its current maintenance and use for trailer storage.

There is a strong belief among some of the neighborhood residents that the City and County officials have an unannounced policy of encouraging residents to leave and thereby lowering the cost of any future buy-outs. The EA needs to review with senior city and county planners their plans for these neighborhoods, as well as, any formal and/or unstated policies that impact these neighborhoods. It is noted that a 20-year development plan called “Plan Tucson” as required by the State is currently being formulated. Are there clear city and county policies in regards to the future of these neighborhoods and expansion of DM air operations?

The EA should also examine the history of mitigation promises made to these neighborhoods. In 2003, a major federally funded Joint Land Use Study (JLUS) was
conducted with substantial community participation. The neighborhoods to the NW of the Base were specifically not invited. In 2004, the Mayor and Council promised a home noise attenuation program for affected neighborhoods, prior to passage of an extension of the DM Airport Environs Zone, as recommended by Tucson city staff. Once the law passed the mitigation proposal was quietly dropped.

The EA should make a final judgment as to whether the consequences of the OSB changeover and its continuation under the proposed EA falls disproportionately on unsuspecting and unknowing minority and low-income neighborhoods.

Given the shallow treatment of environmental justice and the erroneous conclusion reached under the 2002 CSAR EA, an EIS is necessary to treat this issue fully and should also include the affected Tucson neighborhoods.

Sincerely yours,

Jessica Rafka
Director
Tucson Forward, Inc.

Cc: Mr. Richard Fimbres, Council Member, Ward 5

From: “Cherrey, John A Col USAF ACC 355 FW/CC” John.Cherrey@dm.af.mil

Date: October 20, 2011 12:23:01 PM MST

Subject: MQ-1/9 RSO Congressional “Candidate Brief”

Dear MCRC,
The Air Force has released a public statement and briefed Congress on candidate locations for the bed down of an Air Force
MQ-1/9 “Remote Split Operations” squadron. We believe this announcement will include Davis-Monthan AFB as one of the possible
locations under consideration. Much like the very deliberate process you are currently observing in the NEPA Environmental Assessment for
Operation Snowbird, the Air Force uses a strategic process when making basing decisions. Each decision takes an “enterprise-wide look” as it evaluates potential basing locations. HQ ACC will soon begin conducting detailed, on the ground, evaluations of the candidate locations covering a range of operational and facility issues; results of the site surveys will be briefed to the Secretary and Chief of Staff of the Air Force who will then select the preferred location. The basing process links missions and Combatant Commander requirements to installation attributes, cost considerations, and professional military judgment to identify locations best suited to support any given mission. A single remote-split operations squadron consists of approximately 280 personnel performing critical ground-station operations. It is also important to note that no remotely piloted vehicles, (RPV) will be assigned to or actually fly out of DM. The base will only serve as a ground control station for the RPVs. While there is limited information we can share during the evaluation process, my staff and I are standing are available to assist you with any questions you may have.

Sincerely,
JOHN A. CHERREY, Colonel, USAF
Commander, 355th Fighter Wing

How did the Air Force decide to use the 2002 CSAR EA as the baseline for the OSB EA when Operation Snowbird isn’t even mentioned in the CSAR EA? (There is a link to the CSAR EA on the Operation Snowbird page.)

When was the last time the Air Force analyzed the impact of the Operation Snowbird aircraft on the Tucson community?

Is the Gulf South noise consultant going to take actual measurements in Tucson or is he going to just use averaged data?

Will the Gulf South noise consultant come up with the same conclusion as he did in the Wyle Study that even though Operation Snowbird had doubled, you wouldn’t notice the difference?

Here is where you can send your comments. Make sure to keep a copy of your comment/question to see that it is included in the DRAFT EA for Operation Snowbird.

ATTN: OSB EA COMMENT SUBMITTAL
355th Fighter Wing Public Affairs
3180 S. First Street
Davis-Monthan AFB, Az 85707

Comments emailed should be sent to the 355WGPA@dm.af.mil. Subject line should state “OSB EA Comment Submittal.”

The public comment card can be accessed at the link below or requested via email to 355WGPA@dm.af.mil.

Some have been having trouble with this E-mail address. Please let 2nd Lt. Godfrey know if you have a problem Sarah.Godfrey@dm.af.mil

The proposed Plan 60-1 and the easels are now on the D-M website. (Be sure to bookmark this site.) You can also download a comment form.

Send your comments by mail:

ATTN: OSB EA COMMENT SUBMITTAL
355th Fighter Wing Public Affairs
3180 S. First Street
Davis-Monthan AFB, Az 85707

Comments emailed should be sent to the 355WGPA@dm.af.mil. Subject line should state “OSB EA Comment Submittal.”

The public comment card can be accessed at the link below or requested via email to 355WGPA@dm.af.mil.

Some have been having trouble with this E-mail address. Please let 2nd Lt. Godfrey know if you have a problem Sarah.Godfrey@dm.af.mil

Here are sample letters, but write what concerns you most.

Sample Letter-Education

Sample Letter-2002 CSAR EA Baseline

Sample Letter-Social Justice