Mr. Christopher J. Ingram
Gulf South Research Corporation
355th Fighter Wing Public Affairs
3180 S. First Street
Davis-Monthan AFB AZ 85707
October 20, 2011

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
Tucson Forward, Inc.

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