The Air Force has just released the draft environmental assessment of its plan to expand the National Air Guard training program that brings U.S. and foreign jets to Tucson. It is asking for public comments by Sept. 14. Unfortunately, the Air Force has refused to hold public meetings.
The expansion of Operation Snowbird, based at Davis-Monthan Air Force Base, would increase the number of flights from 1,190 to 2,256 a year. Night training flights would be allowed. Strangely, the assessment (which can be found in PDF form at www.dm.af.mil/shared/media/document/AFD-120730-035.pdf) concludes that the expansion will have no significant impact on the surrounding community.
The fundamental deficiency of the assessment is its failure to explain how the total number of Operation Snowbird flights can be almost doubled and yet have no significant effect on the surrounding human environment. Residents who live under the current Snowbird flight paths, as well as simple common sense, tell us this can't be true.
The answer lies in the selectivity and presentation of data in the assessment. For example, it notes that under the current program, a disproportionate number of minority/low-income populations adjacent to the base on the northwest are already seriously affected by noise. This involves some 826 homes and 134 multifamily complexes. The Federal Aviation Administration and the Air Force both consider such areas as "incompatible with residential use." The assessment then says that an expanded Operation Snowbird will add only 20 more homes to the impacted area. It, therefore, concludes that the noise effect from the expansion will be slight. There is no discussion of the effects of doubling the number of flights on this already impacted group of residents. Also, the expansion appears to run counter to economic-justice legislation, yet that is not discussed in the draft environmental assessment.
The assessment seriously understates the number of residents impacted by noise. There is no discussion of Operation Snowbird flight patterns over the city, which involve two half-circles, several miles apart, over residential neighborhoods northwest of D-M. For example, a noise chart prepared by D-M for the Military Community Relations Committee shows that an F-18 or a Harrier approaching D-M over the Broadmoor-Broadway Village neighborhood (left out of the assessment) will be four times louder than an A-10. To claim, as the assessment does, that this aircraft noise will be "insignificant" is simply not credible.
The assessment's noise analysis leaves out the noisiest Snowbird aircraft: the F-18s, Harriers and F-22s. It is based on a 2007 noise study which the public has never seen.
The safety analysis is based on a table developed by D-M listing the risk factors for Operation Snowbird aircraft. Neither the methodology nor the calculations are provided for public review. It is not evident that the risk factor captures the full picture of the aircraft-safety record. The table also leaves out data on the F-18. One crashed three years ago in a San Diego neighborhood, killing four; another crashed recently into an apartment complex in Virginia Beach, Va. Both the Osprey and F-22 are also left out. An Osprey crashed in Marana in 2000, killing 19 Marines, and F-22 pilots have refused to fly for safety reasons. The only foreign aircraft included is the Tornado, leaving out data on the Mirage, Typhoon, Kfir and Rafale.
The economic analysis is given short shrift. Tucson's premier economic engine is tourism. The assessment notes that there was concern expressed at public meetings about the effect on tourism of an expanded Operation Snowbird. However, the assessment states the costs would be difficult to quantify, so it simply ignores the issue. It then draws the completely unsupported conclusion that the expanded Snowbird program would have negligible adverse impacts.
Contrary to the assessment, expanding air operations over densely populated urban Tucson will impact large numbers of residents in terms of safety, noise and social justice. It will also impede future development, as well as the quality of life needed to attract high-tech, bioscience businesses to the city.
Please write the Air Force before Sept. 14 and request a full, objective environmental impact statement. The address is: Attn: OSB EA Comment Submittal, 355th Fighter Wing Public Affairs, 3180 S. First St., Davis-Monthan AFB, AZ 85707.
Robin Gomez is a member of Tucson Forward Inc.