How did the Air National Guard respond to the over 6,000 comments made by the public during the comment period for the Draft EIS? I’m not impressed.
Here’s an article on how we rated in Madison vs. the other 4 communities.
In a bureaucratic way that indicates they followed the rules, did the minimum they had to and in a way that inartfully blows off the concerns of the commenters. Here’s an example:
Within the census block groups that overlap with the 65 dB or higher noise contours, the percentage of those Spanish speakers who speak English “not at all” (approximately 1%) and of Hmong speakers who understand English “less than very well” (approximately 1%), does not justify the time and cost to translate the entire document. Further, during the scoping process, there was no indication that there was a need to translate the document or the public involvement materials into another language.
Appendix A6 is where you will find the comments. The Air Nation Guard (ANG) uses the following criteria to respond to comments:
There were over 6,000 comment letters received during the Draft EIS comment period. Not all comments received were considered to be substantive, though all were fully considered and made part of the administrative record. Substantive comments were considered individually and collectively and responded to in the following pages. Some comments were used to make corrections or modifications in the body of the EIS.
As discussed in the EIS (Section 1.6.2), substantive comments are those comments that generally challenge the analysis, methodologies, or information in the EIS as being factually inaccurate or analytically inadequate; that identify impacts not analyzed or developed and evaluate reasonable alternatives or feasible mitigations not considered by the National Guard Bureau (NGB) or USAF; or that offer specific information that may have a bearing on the decision, such as differences in interpretations of significance, scientific, or technical conclusions, or cause changes or revisions in the proposal. Non-substantive comments, which do not require a specific NGB response, are generally considered to be those comments that are non-specific; express a conclusion, an opinion, agree, or disagree with the proposals; vote for or against the proposal itself, or some aspect of it; state a position for or against a particular alternative; or otherwise state a personal preference or opinion. Due to the voluminous number of comment letters received on the Draft EIS and the sensitivity of Personally Identifiable Information, the USAF has summarized the comments. The following table of contents identifies where the reader can find relative comments and responses. However, public comment letters are a part of the official record.
Generally it seems they just blew off most of the concerns.
I organized the comments I picked out by the following categories – but some questions crossed catedgories so its not as nice and neat as I had hoped.
- NOISE
- PFAS
- HOUSING
- IMPACT ON LOW-INCOME MINORITY NEIGHBORHOODS AND CHILDREN
- ECONOMIC IMPACTS/JOBS
- SAFETY
- PUBLIC INPUT/PROCESS
NOISE
Comment #4a) Commenters raised general comments about noise (e.g., complaints about noise, claims that the analysis was inadequate, etc.).
page A6-5 & 6
Response: The EIS was written consistent with USAF policy for evaluating noise impacts. In the EIS, the Air National Guard (ANG) conducted a detailed noise analysis for each of the affected locations and determined that impacts from aircraft noise near the airfield would be considered significant in some locations. The noise analysis is located in Chapter 4, Section 3.1 in the installation-specific sections of the EIS. Other documents related to the noise analysis were located on the project website http://www.angf35eis.com/DocumentsRef.aspx, and included noise studies for each of the five alternative locations, as well as a noise appendix to the Pacific Operational Beddown EIS, which contained extensive background information on noise analyses (including impacts to structures from vibration, nonauditory human health impacts, wildlife impacts, etc.): http://www.angf35eis.com/Resources/Documents/F- 35A_Operational_Beddown-Pacific_Final_EIS_Feb_Appendix_E.pdf. Specifically, noise-induced vibration effects on structures and humans could be found in the Appendix Section E.2.10. This entire Pacific Ops Appendix E (which was previously incorporated by reference in the Draft EIS) has been brought into Appendix B of this EIS for easy access by the reader.
Comment #4e) Commenters mentioned that they do not understand why the analysis leans heavily on the DNL metric as opposed to Maximum Sound Level (Lmax).
Response: The EIS was written consistent with USAF policy for evaluating noise impacts. As discussed in the EIS (Section 3.2.2), DNL was included per Department of Defense (DoD) guidelines. It is also a well-accepted predictor of annoyance used by the FAA and U.S. Environmental Protection Agency (USEPA), along with various other agencies, for impact analysis. DNL is time averaged over a 24-hour period and includes all noise events, so it is a very good metric for comparing the impacts at multiple sites. DNL is the only metric that specifically recognizes the importance of noise that occurs at night and heavily penalizes it. The 24-hour timeframe (based on Annual Average Day operations) makes DNL the best metric for judging chronic exposure such as neighbors in host communities experience. For all these reasons, DNL is considered the most useful, appropriate, and fair general metric.
Lmax is the greatest sound level measured during a single noise event (typically lasting 1/10 of a second only). It can be very loud, but like a gunshot or a backfiring lawnmower, the sound is typically gone before the observer identifies the source. Lmax’s usefulness as an impact metric or a predictor of annoyance is therefore limited. Sound Exposure Level (SEL), presented in the EIS, is a better descriptor than Lmax in this type of analysis. SEL is integrated over a single noise event. It includes the building and then receding of the sound (duration) as well as the peak (Lmax). This is more appropriate to describe the sound that a vehicle in motion makes. For example, a firecracker’s bang for a tenth second at an Lmax of 100 dB is likely not as impactful as a dump truck accelerating up a hill from a stop sign lasting many minutes at an Lmax of 90 dB. In addition, the sound from aircraft overflights typically lasts more than 1 second, so the SEL is usually greater than the Lmax. As described in Sections 3.2.3.2 and 3.2.3.3, SEL events have been provided in addition to DNL at noise-sensitive locations. Lmax has been included for those locations to determine the potential for Residential and Classroom Speech Interference.
Comment #4h) Commenters mentioned that they believe that increased noise would have detrimental impacts to human health.
page A6-7 & 8
Response: Research continually refines our understanding of the effects of any pollutant or stressor on the human body. The studies to date continue to support the conclusion that permanent, physical harm for most people comes from chronic exposure to extreme noise. As discussed in the EIS (Section 3.2.3.7), the DoD uses National Institute for Occupational Safety and Health (NIOSH) criteria screening for partial hearing loss risk by determining if any residences would be exposed to 80 dB DNL or greater (working lifetime of 40 years with exposure lasting 8 hours per day for 5 days per week). The intermittency of aircraft noise, even during closed pattern training exercises, makes the risk much lower than that expected to harm nearly all people.
Studies have been performed to see whether noise can cause health effects other than hearing loss. The current state of scientific knowledge cannot yet support inference of a causal or consistent relationship between aircraft noise exposure and non-auditory health consequences for exposed residents. It is not yet possible to establish a quantitative cause and effect based on the currently available scientific evidence. Also see: Draft EIS Appendix E, Noise Modeling, Methodology, and Effects, of the USAF F-35A Operational Beddown Pacific Final Environmental Impact Statement, which was incorporated by reference (available on the project website http://www.angf35eis.com/) and has since been incorporated into the Final EIS Appendix B for easy access by the reader).
Comment #4i) Commenters asked what protections/mitigation are provided for people who may spend part of the day outdoors or with windows open, and thereby be affected by the increased noise levels. Similarly, what protections are there for people who may be waiting for gate-checked baggage on the tarmac when an F-35A takes off, and/or workers at the airfield?
page A6-8
Response: Permanent, physical harm from noise only occurs with extreme, chronic exposure. As discussed in the EIS (Chapter 3, Section 3.2.3), populations exposed to noise greater than 80 dB DNL are at the greatest risk of permanent hearing loss. Passengers and visitors to the airport will have no ill effects from casual, transient exposure.
There are some concerns for workers. The USEPA’s Guidelines for Noise Impact Analysis quantifies hearing loss risk in terms of Noise-Induced Permanent Threshold Shift (NIPTS). NIPTS defines the permanent change in the threshold level below which a sound cannot be heard. NIPTS is stated in terms of the average threshold shift at several frequencies that can be expected from daily exposure to noise over a normal working lifetime of 40 years, with exposure lasting 8 hours per day for 5 days per week. In response, workers in high-noise areas are required to wear hearing protection.
Comment #8) Commenters expressed a general concern for domestic animals and/or pets (e.g., my dog cowers when a fighter jet flies over; my goats will not reproduce due to aircraft noise).
page A6-11
Response: Potential impacts to domestic animals and/or pets were discussed in the EIS (Chapter 3, Section 3.2.1.3, and Appendix E).
Comment #16) Commenters questioned whether 5 percent afterburner use is reasonable – because F-35A aircraft at other locations are using a far higher percentage; there were requests to model afterburner at 5, 10, 15, 20, etc., percent.
page A6-13
Response: As addressed in the EIS (Section 2.2.1.2), use of afterburner by the F-35A aircraft at all five of these alternative locations has been modeled for 5 percent of take-offs. Due to the immense thrust provided by the F-35A engine, there would be little to no expected requirement for its use. Even though there is no anticipated requirement for afterburner use, it has been included at 5 percent in the noise model to provide a conservative estimate of potential noise impacts. The USAF will not be modeling additional levels of afterburner use for this EIS.
The RAP for the F-35A does not require afterburner use for take-off. As addressed in the EIS (Section 2.2.1.2), use of afterburner, in the take-off phase of flight, is dictated by the F-35A Joint Technical Data (JTD) and Air Force Manual (AFMAN) 11-2F-35A Vol 3. Based on airfield temperature, pressure altitude, winds, aircraft weight/configuration (drag), and runway length, the JTD will give pilots all the parameters for take-off based on the selected power setting, military or afterburner. This is called aircraft Take-off and Landing Data (TOLD). The parameters include take-off distance, abort speed, rotation speed, take-off speed, acceleration check speed, etc. Based on this, the F-35A JTD and associated AFMANs do not require afterburner take-off under normal training loads and atmospheric conditions at the currently proposed Ops 5 and 6 F-35A bases.
Comment #23) Commenters requested that the USAF bring the F-35A to their location so they can hear what it will sound like.
page A6-15 and 16
Response: Transient F-35A aircraft have flown into each of the five alternative locations on multiple occasions already. Further, most installation’s airshows have had F-35A aircraft participate over recent years. It was not possible to schedule these aircraft into a local area specifically for civilian interest outside of the airshows due to their ongoing training and mission requirements.
As mentioned by Acting SECAF Matthew P. Donovan in his response to Representative Pocan, “In contrast to the DNL, this would only present a momentary experience of that aircraft’s noise, which would serve no evaluative purpose. Scientifically, it would not represent the actual cumulative experience over an extended period of time, nor would it be repeatable at other bases being evaluated. The primary reason for this is that noise generated from a single event is influenced by many factors, such as wind speed and direction, air temperature, relative humidity, and take-off weight. Therefore, a single event would not reflect the requisite science, attend to the complexity and sensitivity of human hearing, and would inject subjectivity that would undermine the deliberative environmental analysis.”
Comment #44a) Commenters noted that “in a review of the list of preparers of this EIS (Chapter 6), the scoping letter distribution list, and the Draft EIS distribution list shows there were no medical professionals or medical organizations consulted or asked for comments during this EIS process. This appears to be a major omission given the well documented extremely high A-weighted decibel (dBA) noise levels of the F-35A and the F-16 with the PW-229 engine upgrade. The F-35A noise levels at military power at 500 feet above ground level (AGL) will clearly violate the Air Force Instruction (AFI) 48-127 115 dBA limit for unprotected hearing exposure. At 500 feet AGL, afterburner take-off for the F-35A and the F-16 PW-229 will create potential hearing loss after 3 to 14 seconds exposure in a 24-hour period. At 1,500 feet AGL in afterburner, the F-35A will still be in violation of AFI 48-127. Given a sortie of two aircraft taking off in close proximity, 3 to 14 seconds exposure in 24 hours seems more than likely. Why isn’t this analysis shown in the EIS as well as Lmax data by aircraft, by altitude, by power settings as has been shown in numerous other Environmental Assessments (EAs) and EISs? Without this data, there is no way to assess the potential hearing damage from the individual take-offs, overflights, landing approaches, closed pattern operations, or low altitude combat jet training with multiple passes over the same location.”
A6-21 and 22
Response: While medical professionals or medical organizations were not consulted directly in the preparation of the EIS, the technical guidance and professional references used in the analysis were written or reviewed by medical professional and organizations. See response to Comment #4e with regard to Lmax analysis.
AFI 48-127, Occupational Noise and Hearing Conservation Program, covers military and civilian personnel and is designed to reduce or eliminate hazardous noise exposure to workers subjected to high noise levels for long periods of time. The AFI includes recommendations to ensure an individual’s daily dose of noise levels above 85 dBA does not exceed 8 hours. While noise levels of the F-16 (115 FW and 187 FW both operate the F-100-GE-100 engines) can exceed these levels in areas outside of the installation, the noise level would not be sustained for any substantial amount of time.
Noise associated with aircraft overflights is not continuous, it peaks when the aircraft is closest to the observer and fades with distance. Aircraft taking off in afterburner (modeled for up to 5 percent of the time) cause Lmax on the ground at the airport boundary of approximately 100 dB or less, which decreases with distance from the airfield. When afterburner is engaged, it is used to get aircraft up to speed, then power is reduced to military power shortly after liftoff while aircraft are still above the runway at roughly 100 to 200 feet above the ground. When multiple aircraft events are summed, the AFI requires use of the 8-hour Equivalent Noise Level (Leq(8)) metric and testing for it to see where it is above 85 dB. At 187 FW, the Leq(8) 85 dB contour is on the airport for all but two small areas, neither of which overlays any residential areas.
The Defense Noise Working Group advises that military airfield impact studies should use the 80 dB DNL noise contour as a screening tool to identify populations at the most risk of PHL and if any are found, then additional analysis should be performed. The EIS found that existing conditions at 187 FW currently expose an estimated 2 acres of land outside of the airport to 80 dB DNL or greater, none of which contain residential structures. The Proposed Action would not cause any appreciable change in acreage nor expose any residential populations to 80 dB DNL or greater.
Comment #44b) Comments identified that “DNL and SEL are time-based energy averages that do not directly represent the sound level at any given time. This gives rise to gross misrepresentations by the military at public meetings and by the media portraying jet overflight noise levels as “comparable to a Hoover” vacuum when it is in fact the same as having a vacuum cleaner, running, with you 24 hours per day, 7 days per week. This comparison, or a similar one, should be mandatory in any document for public review and comment. Otherwise, a non-technical person has no basis to come to an informed decision. DNL and SEL are not appropriate measurements when there is potential for hearing and health effects from modern jet fighter noise levels. Lmax (unweighted and weighted) should be included in the analysis and compared to modern medical standards for noise levels, vibration effects, exposure times, and overall human health in the EAs and EISs.”
page A6-22
Response: DNL was included because it is a well-accepted predictor of annoyance and used by the FAA and USEPA, along with various other agencies, for impact analysis. See response to Comment #4e.
Comment #44c) Comments on the “use of DNL to assess Speech Interference Level (SIL) is inappropriate in addressing everyday life and safety issues (parking lots, job sites, child supervision) in low altitude jet operations areas.”
page A6-22
Response: As discussed in the EIS, (Appendix E, Noise Modeling, Methodology, and Effects, of the USAF F-35A Operational Beddown Pacific Final Environmental Impact Statement, which is incorporated by reference [available on the project website http://www.angf35eis.com/] and has also been incorporated into the Final EIS), the Defense Noise Working Group specifies indoor Lmax of 50 dB as a screening threshold for speech interfering events, which roughly translates to a SIL of 45 dB for aircraft noise. An Lmax of 50 dB has been shown to provide 90 percent speech intelligibility for students situated throughout a classroom and forms the basis for classroom speech interference and residential speech interference in the EIS.
Comment #44g) Commenters raised the concerns that the EIS address, in detail, the human health and safety impacts of the high dBA level/high onset rate of overflights, including extreme startle response, PTSD episodes, cardiovascular and hypertension issues, learning disruption in schools and hearing damage in children outdoors who are exposed to high dBA levels?
page A6-22
Response: See response to Comments #4e and #30.
Comment #48) Commenters requested files (i.e., noise modeling files) associated with development of the EIS.
page A6-24
Response: Relevant information can be obtained on the project website.
PFAS/HAZARDOUS POLLUTANTS
Comment #5b) Commenters suggested that the EIS is deficient because it did not address Wisconsin Natural Resources (NR) 445 “Control of Hazardous Pollutants.”
page A6-9
Response: Wisconsin NR 445, “Control of Hazardous Pollutants” only applies to stationary sources. The Proposed Action involves air emissions primarily from mobile sources. The EIS (Section 3.4.1.2) indicated that “Hazardous Air Pollutants (HAPs) would not create significant or adverse health risks to humans living adjacent to airfields or underneath airspace in which aircraft operate, and are not further evaluated in the analysis.” Therefore, the EIS does not address Wisconsin NR 445.
Comment #24a) Commenters expressed a general concern about hazardous materials and wastes.
page A6-16
Response: As discussed in the EIS (Chapter 4 Section 3.13 of the installation-specific sections), the ANG conducted a detailed analysis of the impacts of the Proposed Action associated with hazardous materials and wastes, and determined that there would be no new waste streams (including perfluorooctane sulfonate [PFOS]/perfluorooctanoic acid [PFOA]) associated with the F-35A aircraft). Additionally, existing contamination from previous activities is actively being investigated and in some cases remediation is ongoing. Impacts associated with hazardous materials/wastes from the Proposed Action would not be significant. See Comment #24b for more detailed information related specifically to PFOS/PFOA.
Comment #24b) Commenters suggested that the ANG cannot safely and legally perform the planned construction activities without a complete investigation that defines the extent and nature of PFOS/PFOA contamination in soil and groundwater and subsequent remediation.
page A6-16 and 17
Response: As described in the EIS (Section 3.13 of the installation-specific sections), each base implements an active environmental restoration program that addresses contamination at the bases. Additional details regarding PFOS/PFOA have been added to the EIS (Section 3.13 of the installation- specific sections). Existing PFOS/PFOA contamination is related to the former use of aqueous film forming foam (AFFF), a fire suppressing agent. The USAF is transitioning to an alternative firefighting foam and taking steps to reduce the opportunity for this alternative formulation to enter the environment. Transition to use of this alternative foam in the hangar systems is expected to be complete by the end of 2019, and retrofitting of the fire vehicles is 97 percent complete.
To address the potential presence of PFOS/PFOA in the environment, the USAF carefully follows the established, step-wise process set forth in the governing federal cleanup law, the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA), to protect human health and the environment. The U.S. Environmental Protection Agency (USEPA), which is endowed by Congress with the expertise and authority to regulate environmental contaminants, has not issued regulatory limits on PFOS/PFOA. However, USEPA has issued a 70 parts per trillion Lifetime Health Advisory level for PFOS/PFOA in drinking water. If PFOS/PFOA attributable to USAF actions is found in drinking water at levels that exceed USEPA’s Lifetime Health Advisory, the USAF takes immediate action to stop human exposure by providing alternate drinking water sources.
Consistent with the CERCLA cleanup process, each of the five bases has completed a Site Investigation Report on PFOS/PFOA. If necessary, the next step in the CERCLA process would be the Remedial Investigation, which would determine the nature and extent of contamination and assess the potential risk to human health and the environment. If CERCLA’s risk assessment process ultimately determines there is a need for cleanup action, federal and state cleanup standards will be evaluated under the CERCLA process to see if they are Applicable or Relevant and Appropriate Requirements at the specific site. If so, they are incorporated into the cleanup levels that must be attained at the site.
The only known potential for existing PFOS/PFOA contamination to be encountered as a result of the proposed F-35A beddown is through construction activities. As described in Section 3.13.1.2 of each of the installation- specific sections, the USAF will comply with Air Force Guidance Memorandum
(AFGM2019-32-01) AFFF-Related Waste Management Guidance to manage waste streams containing PFOS/PFOA (USAF 2019). The AFGM will be updated as needed to address changes in regulatory requirements, DoD determinations of risk, or development of new technologies.
Comment #33) Commenters raised concerns about water quality, in particular as it relates to PFOS/PFOA contamination.
page A6-19
Response: As addressed in Chapter 4, Section 3.10 in the installation-specific sections of the EIS, the ANG conducted a detailed analysis of water resources. The Proposed Action would be managed in accordance with all applicable federal, state, and local regulations. Please also see comment response #24b.
Comment #39) Commenters asked if the F-35A would jettison fuel.
page A6-20
Response: The F-35A does have the capability to jettison fuel for emergency situations. The FAA set requirements for when and how fuel dumping may occur. This FAA instruction stipulates that fuel can only be dumped above a minimum altitude of 2,000 feet to improve its evaporation, and that a dumping aircraft must be separated from other air traffic by at least 5 miles. Air traffic controllers are also instructed to direct planes dumping fuel away from populated areas and over large bodies of water as much as possible. The same guidelines apply to military aircraft; air bases only permit fuel dumping in a specified area. In 2001, the USEPA National Vehicle and Fuel Emissions Laboratory concluded, “Since fuel dumping is a rare event, and the fuel would likely be dispersed over a very large area, we believe its impact to the environment would not be serious.” This information has been added to the EIS in Chapter 4 within the installation-specific Sections 3.4.2 (safety within the airspace).
Comment #42) Commenters had concerns about infrastructure (e.g., ANG needs to develop a stormwater management plan; ANG must adhere to local stormwater management regulations).
page A6-20
Response: As discussed in the EIS, (Chapter 4, Section 3.8 of the installation-specific sections), the ANG conducted a detailed analysis of infrastructure, including potable water, wastewater, stormwater, electrical and natural gas systems, solid waste management, and transportation. The Proposed Action would be managed in accordance with all applicable federal, state, and local regulations.
HOUSING/PROPERTY VALUES
Comment #4b) Commenters were concerned that “incompatible” meant “uninhabitable,” and were concerned that they would have to move out of their homes.
page A6-6
Response: The land use compatibility table (Table 3.6-1) used by the Federal Aviation Administration (FAA) and USAF is not meant to determine the acceptability or unacceptability of a land use. Nor is it used to determine if a structure is habitable or uninhabitable. Combined with the land use table, Day-Night Average Sound Level (DNL) provides one factor for local communities to use in predicting the success and cost of new development. Noise from outside noise sources, such as aircraft overflights and other transportation noise, can interfere with day-to-day activities. The activities of some land uses are more noise-tolerant than others, and this is the basis of the compatibility guidance. However, all the factors affecting land use decisions must be assessed based on their cost and technological feasibility and the needs and desires of each particular community. As indicated in the notes for Table 3.6-1, residential areas, except mobile home parks, located in areas below 75 decibels (dB) DNL are conditionally-compatible when an outdoor to indoor noise level reduction of 25-30 dB is provided by the structure. (Mobile homes are excepted because the walls and roof cannot accommodate that much sound insulation.) As summarized in Table 2.4-1, no residential structures are located in areas where the DNL exceeds 75 dB at any of the installations. While not considered compatible, existing mobile home parks at some of the installations are located in areas where the DNL is currently above 65 dB. People continue to reside there; while the noise levels in these areas could increase, the noise would not be expected to make the homes uninhabitable. The noise may impact some activities. For example, momentary speech interference could be expected. This is similar to other environmental conditions. Extreme cold suggests that housing is incompatible above the Arctic Circle, but people live there by adapting their homes to the environment. Text has been added to the EIS (Chapter 3 and land use analysis for all five installations) clarifying this issue.
Comment #4j) Commenter indicated that Truax Park and Webb/Rethke Townhomes were located on the border of the 65 dB noise contour and suggested that these residences should be included in the analysis.
page A6-8
Response: These locations are outside the anticipated 65 dB contour and therefore would not have been included in those calculations.
Comment #11) Commenters were concerned about manufactured home communities located within the 65 dB and greater noise contours. With the current shortage of affordable housing in their areas, they are concerned that this would affect the lives of many disadvantaged people.
page A6-12
Response: The 65 dB DNL metric is used by federal agencies, including the USAF and FAA, to determine compatibility of military aircraft operations with local land use. Residential land use, including mobile home parks, is considered compatible with noise levels of <65 dB DNL, and therefore nobody would be displaced from these mobile home communities. One commenter in particular from Boise was concerned about her mobile home community within the South Eisenman Neighborhood being located in the noise contours. Though this community is located near the airport and underneath aircraft flight tracks, it is located outside the 65 dB DNL noise contours both currently and under the Proposed Action.
Comment # 17) Commenters raised concerns about potential decreases in property values near the airfield; and potential for businesses to leave the area and a resulting decreased tax base.
page A6-13 and 14
Response: Property values are a function of many different variables, including noise levels. The issue of the negative effect of airport noise on property values has been widely researched. The property value to noise effects relationship is presented in the form of the Noise Depreciation Index (NDI), which reflects the estimated percent loss of property value per dB DNL. A review of several relevant studies concluded that noise may affect property values and related taxes in a NDI range of 0.2 to 2.0 percent per dB of noise increase, which correlates to an average loss of 0.5 percent of the property value per dB. The value of the property is determined based on many individual variables, which when taken together, form the total price and requires detailed information on local housing markets and actual sales prices. Furthermore, price property value studies model relationships between city level income and population data, and the overall willingness to pay for noise abatement, which enables an estimate of noise impacts in locations where detailed housing data is not available. The cost of noise mitigation is less of a factor in regions that experience extreme temperatures. Many structural elements designed to improve energy conservation also improve the acoustic performance of homes. The way properties are used in hot or cold environs (such as not opening windows for ventilation) can add as much as 15 dB of noise attenuation.
Information regarding potential impacts to property values and taxes has been added to Chapter 4, Section 3.6.1.1 in each installation-specific section of the EIS as well as Appendix B in the Final EIS.
Comment #18) Commenters expressed a concern that some of these communities have affordable housing shortages and there is nowhere for people to go if they move from the noise impacted areas. There were additional concerns that the communities cannot support the new ANG families due to the housing shortages.
page A6-14
Response: Some people may perceive that any increase in noise is unacceptable. That is a personal decision, which may prompt them to relocate their residence. Overall, noise would not impact the availability of housing in the market as noise levels would not be expected to make any houses uninhabitable (see response to Comment 4b). In addition, there would less than or equal to 85 new personnel as a result of the Proposed Action, which would be a negligible impact on the housing market in any of these communities.
Comment #22c) Commenters noted that there is housing near the proposed 65 dB noise contour line and they will not be eligible for sound mitigation funding through the noise compatibility program. They also noted that these residences would experience virtually the same noise impacts as those located within the 65 dB noise contour.
page A6-15
Response: The USAF does not have authority to expend appropriated funds on facilities that are not under the direct control of the USAF. However, the FAA has a program that addresses noise and compatible land use near airports. Title 14, Code of Federal Regulations (CFR), Part 150 – Airport Noise Compatibility Planning, the implementing regulations of the Aviation Safety and Noise Abatement Act of 1979, as amended, provides a voluntary process an airport sponsor can use to mitigate significant noise impacts from airport users. It is important to note that the Part 150 program is not a guarantee that sound mitigation or abatement will take place. Airport Improvement Program requires that the impacted property is located within a DNL 65 dB or higher noise contour and meet various other criteria in FAA guide documents used for sound mitigation.
IMPACT ON LOW-INCOME NEIGHBORHOODS AND CHILDREN
Comment #4c) Commenters asked if any schools would be closed as a result of the F-35A beddown.
page A6-6
Response: The USAF does not anticipate it would be necessary to close any schools as a result of its basing decision. Interference with classroom speech is expected to remain the same or increase by no more than one event per hour at any school under any of the alternatives (EIS Chapter 4, Section 3.1 of the installation- specific sections). It is important to note also that structures, including school buildings, could be insulated from distracting, exterior noise. Such mitigation may be available from the FAA’s noise mitigation programs and other sources (EIS Section 2.6). The EIS (Chapter 4, each installation-specific Section 3.7.1.2) has been modified to explain that the USAF does not plan to close any schools or purchase any homes or businesses as a result of the basing decisions.
Comment #6a) Commenters raised several general questions about the Environmental Justice analysis (e.g., concerns about minority, low income, and/or children).
page A6-9
Response: The USAF identified and addressed, to extent practicable, disproportionately high and adverse human health or environmental effects of its activities on minority populations and low-income populations based on the Council on Environmental Quality (CEQ) “Environmental Justice Guidance Under NEPA,” December 10, 1997. In the EIS (Chapter 4 Sections 3.1 and 3.7 of the installation-specific chapters), the ANG conducted a detailed analysis of the noise impacts from the Proposed Action to low-income and minority populations, and determined that impacts from aircraft noise near the airfield would be considered significant in some locations. The methodology used for the analysis of Environmental Justice and the Protection of Children is located in Chapter 3.8.
Comment #6b) Commenters mentioned the use of thresholds of 20 percent poverty and 50 percent minority being inappropriate. They also mentioned that the City of Madison conducted their own analysis, which demonstrated significant disproportionate impacts.
page A6-9 and 10
Response: In the EIS (Chapter 3, Section 3.8.2), the 20 percent and 50 percent methodology used is from the CEQ guidance (Environmental Justice Guidance Under NEPA, December 10, 1997). Furthermore, the analysis in the EIS is consistent with the City of Madison’s determination that there are disproportionate impacts. Groupings of sensitive receptors or areas of high concentration of minority population would not change the significance findings of the EIS, which adequately inform the USAF decision maker of potential impacts.
Comment #6c) Commenters also mentioned that poverty and persons of color occur just outside of the 65 dB DNL contour line at CDA Truax housing, CDA Webb-Rethke townhomes, and other housing near Worthington Park, and near the intersection of Packers Avenue and Northport Drive that might be ineligible for sound attenuation assistance.
page A6-10
Response: Eligibility for sound attenuation is determined by FAA guidance. Such determinations are outside of the scope of the proposed USAF action and outside of the USAF’s control (see response to comment #22c).
Comment #6d) Were consultations with the U.S. Department of Housing and Urban Development (HUD) performed?
page A6-10
Response: HUD has no jurisdiction by law over the Proposed Action. However, data from HUD on the location of Public Housing Developments and Public Housing Buildings was used to analyze whether any of these locations were within the proposed 65 dB DNL noise contour. According to this data from HUD, none of these public housing locations are located under the proposed 65 dB DNL or greater noise contour for any of the five installations.
Comment #7d) Commenters suggested that the EIS should explain how Environmental Justice and children’s health impacts were considered when identifying the preferred alternatives.
page A6-11
Response: As discussed in Sections 2.3.1 and 2.3.2 of the EIS, application of the screening criteria resulted in an enterprise of 18 alternative installations, which yielded a clear break in scoring with the five alternative installations carried forward for detailed analysis in the EIS. The screening criteria involved considerations of mission, capacity, cost, and environmental factors. The two alternatives that have been initially identified as the preferred alternatives for Operational Beddowns 5 and 6 were identified by the SECAF in December 2017, as best meeting the needs of the USAF based primarily on operational and cost factors. The analysis conducted in the EIS had not yet been accomplished; Environmental Justice and children’s health were not and are not required to be considered in the identification of the preferred alternatives.
Comment #30) Commenters expressed concern for special needs children/adults – autism, Post-traumatic Stress Disorder (PTSD), etc. There is a school for special needs children (Richardson School) that would be affected at Madison.
page A6-18
Response: PTSD is a serious, life-altering condition that can be successfully treated. The National Institute of Mental Health (NIMH) offers guidance to understand the symptoms and reactions as well as information to find treatment. NIMH has specific links on their website at https://www.nimh.nih.gov/health/topics/post- traumatic-stress-disorder-ptsd/index.shtml. PTSD affects 6-8 percent of the population. Initiating events are highly varied – from military combat and natural disasters to car accidents and assault. Given the diverse causation and success rate of individual treatment, it is unlikely that basing the F-35A at any of the alternative locations would have a significant effect on persons suffering PTSD.
Vulnerable groups (such as those who suffer autism) regarding environmental noise have been understudied, are generally underrepresented in study populations and evidence of differential effects is still highly anecdotal. As a consequence, clear effects are few and this is partly due to the lack of targeted and well-designed studies making clear comparisons between the general population and the potentially susceptible groups and quantifying these differences in terms of noise levels. Setting specific limit values to protect susceptible groups is not yet possible based on the available evidence, although some suggestions have been made in the literature. To further this field, it is necessary in future studies to present and compare subgroup-specific exposure effect relations. Generic use of the term “vulnerable groups” should be avoided as the mechanisms are quite different and maybe more important: they vary in time, place, and across contexts. Groups at risk or susceptible groups, periods or places would, in most cases, be more appropriate terms to use and are less stigmatizing than the term vulnerability. (van Kamp I, Davies H. Noise and health in vulnerable groups: A review. Noise Health [serial online] 2013 [cited 2019 Nov 14];15:153-9. Available from: http://www.noiseandhealth.org/text.asp?2013/15/64/153/112361). Information regarding impacts to special needs children/adults has been added to Appendix B in the Final EIS.
Comment #41) Commenters suggested that the document be translated into Spanish and Hmong for Madison. Why was outreach in other languages not accomplished?
page A6-20
Response: Within the census block groups that overlap with the 65 dB or higher noise contours, the percentage of those Spanish speakers who speak English “not at all” (approximately 1%) and of Hmong speakers who understand English “less than very well” (approximately 1%), does not justify the time and cost to translate the entire document. Further, during the scoping process, there was no indication that there was a need to translate the document or the public involvement materials into another language.
ECONOMIC IMPACTS/JOBS
Comment #3d) Commenters inquired as to what would happen to the Fighter Wing if the F-35A does not come.
page A6-5
Response: As stated in the EIS (Section 2.3.5), under the No Action Alternative, no F-35A operational aircraft would be based, no F-35A personnel changes or construction would be performed, an increase in Active Duty Associate Unit would not occur due to this action, and no training activities by F-35A operational aircraft would be conducted in the airspace. Under the No Action Alternative, the NGB would continue to conduct their current mission using existing, legacy aircraft with multiple configurations. If a future mission conversion were to occur, that conversion would be the subject of subsequent National Environmental Policy Act (NEPA) analysis.
page A6-11 and 12
Response: The ANG conducted a detailed analysis of socioeconomics, including population, housing, employment, and income in Chapter 4, Section 3.6 in the installation-specific sections of the EIS, which provides specific analysis on potential economic input from temporary construction jobs and salaries from additional personnel.
SAFETY
Comment #9a) Commenters expressed a general concern for safety issues related to the F-35A and/or military flights at commercial airfields (e.g., concerns about the safety record of the F-35A; what happens if this jet crashes in my neighborhood?).
page A6-11
Response: As discussed in the EIS (Section 3.3.4 of the installation-specific sections), the ANG conducted a detailed analysis of safety, including fire/crash response, accident potential zones/runway protections zones, explosive safety, and anti-terrorism/force protection.
Comment #9c) Commenters were concerned about the stealth coating on the F-35A. Some were concerned about the material in the event of a crash, and some were concerned with basic maintenance of the material on the planes.
page A6-11
Response: The EIS discussed (Chapter 4, Section 3.4.2.2 of the airspace portion of the installation-specific sections) the stealth coating and concerns regarding its characteristics in a crash event. This discussion has been brought into the installation section of Safety as well. The installations would keep local firefighting departments informed about any new information or firefighting techniques associated with composite materials should an accident occur. The only maintenance of the stealth coating (e.g., low observable material) that would be accomplished at the base would be done using a brush or roller to apply coatings, bonding materials, or applying tape. Depot-level maintenance of the low observable material (including spray capability) would be conducted off-site, and therefore the composite material for major repairs to the low observable material would not be stored on base. This has been added to the EIS.
Comment #12) Commenters expressed concern that the F-35A is nuclear-capable and the community would not want nuclear weapons at their airfield.
page A6-12
Response: The F-35A Block 3F aircraft is not “nuclear-capable”; therefore, the F-35A aircraft that would be based at any of these five alternative locations would not have the hardware necessary for a nuclear mission. Currently, there are no plans to add the hardware necessary to make these F-35A aircraft nuclear- capable. Only units with a nuclear mission are provided the hardware necessary to carry nuclear weapons; therefore, because none of these five alternatives have a nuclear mission, should any of the aircraft associated with this F-35A beddown ever be fitted with Block 4 upgrades, they still would not be nuclear- capable. This has been added to the EIS Chapter 2.
Comment #46) Commenters suggested that having the F-35A at their locations would make their city more vulnerable to attack by adversaries and/or terrorists.
page A6-23
Response: Each of these five alternative locations have previously had state-of-the-art aircraft; therefore, it is highly unlikely that having the F-35A aircraft based at these locations would increase the risk of such an attack.
PUBLIC INPUT/PROCESS
Comment #19) Commenters at Madison and Boise were concerned that the public meeting venue was not located near the impacted area; therefore, some impacted communities were unable to attend the meeting.
page A6-15
Response: The USAF made every attempt to find the best possible venue as close to the impacted area as possible. Because it was apparent that there would be a large turnout at both the Madison and Boise meetings, the USAF had to seek fairly large venues that could comfortably accommodate the anticipated crowds. There were no venues closer to the airports that had availability at any time during the public comment period. Venues for both of these meetings were within a 4 to 8 mile drive of the airfield (Boise and Madison, respectively). This information has been added into the public involvement section of the Final EIS.
Comment #27) Commenters asked why they were not notified about the public meeting or had other concerns about public outreach and involvement.
page A6-17
Response: The NGB notified the public of the release of the Draft EIS and the public meetings through a variety of means. The Notice of Availability (NOA) for the Draft EIS was published in the Federal Register on August 9, 2019. Newspaper ads were placed 2 weeks prior to each public meeting and the week of the meeting in the local newspapers. Press releases were distributed to local media organizations prior to the public meetings. Flyers were posted at local businesses near each airfield. Fact Sheets were mailed to everyone that signed up to be on the mailing list as well as all properties located within the projected 65 dB noise contours. Updates were also posted on the project website. Appendix A of the EIS provides a list of individuals on the mailing list as well as federal, state, and local agencies that were provided scoping letters and copies of the Draft EIS. This information has been added to Section 1.6.2 of the Final EIS.
Comment #37) Commenters asked if the USAF/ANG would hold another public meeting to discuss the proposal.
page A6-19 and 20
Response: There is no plan to have additional public meetings on the Draft EIS or the Final EIS.
Comment #40) Commenters requested that the comment period be extended.
page A6-20
Response: The Draft EIS public comment period must be a minimum of 45 days; however, due to the timing of public meetings and the requirement for the comment period to extend at least 15 days after the last public meeting, this comment period was originally 51 days beginning on the NOA publication date on August 9, 2019 through September 27, 2019. The Draft EIS comment period was extended until November 1, 2019.
Comment #45) Commenters suggested that the USAF respond to their elected representatives in a respectful and expedient manner.
page A6-23
Response: Note that Congressional inquiries require extensive coordination. Several Congressional inquiries were responded to as promptly as possible, which can be found in Appendix A.
