November 14, 2011

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.”


, Director
Tucson Forward, Inc.