Franklin Countys First News

Governor requesting supplement to draft EIS for low-flight proposal

AUGUSTA - In the latest response in a series of letters between state agencies and Air National Guard, the governor has asked the ANG to prepare an additional Supplemental Draft Environmental Impact Statement.

The document requested by Gov. John Baldacci would require the ANG to delve further into addressing issues ranging from noise analyses to impact studies on civilian aircraft safety to spelling out the necessities of low-flight training over western Maine.

"Considering the significance and extensiveness of concerns for the potential impacts that would be imposed on the State of Maine," Baldacci wrote to Lt. Gen. Harry Wyatt III, director of ANG, on Dec. 29, 2009, "the citizens of the State of Maine and I respectfully request that a Supplemental Draft Environmental Impact Statement (SDEIS) be completed and published with significant lead time notification of the required public hearings."

The ANG is asking the Federal Aviation Administration to modify Condor 1 and Condor 2, military operation areas that have encompassed most of Franklin County for 30 years. Currently, ANG pilots must stay above 7,000 feet throughout the MOA, unless they're training in military training routes, or MTRs, where pilots can fly as low as 500 feet off the ground.

Supplemental EIS are usually prepared after a final version of EIS has been issued. New information, previously-unstated impacts and alternatives can be contained within a Supplemental EIS, which has its own public comment period and public hearing, much like the EIS process.

In addition to requesting more data about the impacts of the low-flight proposal and more information about the necessity of LOWAT training, Baldacci asked the ANG to readdress two alternative proposals: expanding the Adirondack Airspace Complex, near Fort Drum in New York, or expanding the Yankee MOA, located over New Hampshire.

"The DEIS does not adequately demonstrate that expanding the existing [MOAs] are economically infeasible alternatives," the letter reads, "or would impose greater environmental impacts than the proposed expansion of use at the Maine CONDOR...."

The ANG had previously stated that the Adirondack option was too small, at 15 nautical miles by 35 to 45 nautical miles (depending on season). The Yankee MOA, the ANG has said, is configured for the training of the pilots of A-10 Thunderbolt IIs, better known as "Warthogs;" low-flying aircraft designed to attack targets on the ground.

The governor's letter also includes another look at several points of contention that some state agencies and residents have been debating with the ANG.

Two major issues raised by the Maine Department of Transportation's review of the draft EIS have related to safety and noise levels. These two issues have been central talking points for those opposed to the airspace modification. In regards to safety, the MDOT has requested a more in depth look at local airports (there are six within the MOA) and civilian air traffic numbers (the MDOT claims that more than 43,000 flight operations take place within the MOA annually).

In a response directed toward Baldacci's earlier letters, Wyatt wrote in a letter, dated Dec. 1, 2009, that the draft EIS already includes a "required safety assessment to consider how the proposed action would affect the potential for accidents within the affected airspace."

The safety assessment can be found between pages 4-6 and 4-10 of the draft EIS, located here, off the MDOT website.

However, in the Dec. 1 response, Wyatt also wrote that "Without an analysis of the 43,340 operations, a clear understanding of flying operations is difficult to assess.... Consequently, further investigation will be required to validate current operations to assess safety considerations."

Baldacci's letter called the safety assessment referred to by Wyatt, "a basic impact analysis," and asks that the requested supplemental draft EIS contain the results of "further investigation."

"The additional investigation and analysis suggested by the DEIS to validate safety considerations should be included in the requested SDEIS," Baldacci wrote, "to provide the decision-makers a complete safety analysis prior to committing to a particular Condor flight location and/or height."

In regards to concerns over the noise of the F-15 and F-16 jets, the governor's response reiterates a request by the MDOT that the ANG hire an "independent noise consultant." The findings of this consultant, Baldacci suggests, could appear in the requested supplemental draft EIS.

This may be a sticking point for the ANG, however. In previous communications, Wyatt noted that "all contractor noise work is reviewed by [United States Air Force] specialists."

The governor raised other, specific concerns with the draft EIS. These include "conflicting statements" about the presence (or lack thereof) of a migratory route for waterfowl within the Androscoggin River Watershed, that the draft EIS is "deficient in analysis of noise impacts to eagles," that the number and timing of sorties be capped, that a previous attempt to modify the MOA in the 1980s be referenced, and that more socioeconomic impact studies be conducted. Finally, the governor included a list of 20 specific issues with the draft EIS, ranging from mislabeled figures to repeated references to "environmental assessment" rather than EIS to misspelling "Carrabassett" as "Garrabassett."

In a Dec. 31, 2009, letter to Lt. Gen. Wyatt, Maine's Attorney General Janet Mills is also requesting additional study be conducted on the proposed change to lower flight training to 500 feet off the ground over western Maine. Mills testified at the Nov. 14, 2009, public hearing conducted by the ANG and held in Farmington, in which she spoke out against the proposal, noting that the EIS draft provided only incomplete, inaccurate or no new information.


Noting that the EIS draft provided only incomplete, inaccurate or no new information, Maine's Attorney General Janet Mills said she agreed with the governor in her opposition of the low flight proposal at the Nov. 14, 2009 public hearing held in Farmington. At left are members of the Air National Guard and consultants on the draft proposal.

"After reviewing the Draft Environmental Impact Statement and the recent comments from our Governor and members of the Legislature and after listening to the testimony of dozens of western Maine businesspeople, environmental experts, military veterans and other citizens, I strongly concur with the request of our Governor that a Supplemental Draft Environmental Impact Statement be completed and published in order for the ANG to respond to the substantial scientific and socioeconomic concerns raised concerning the current DEIS.

"Such an in depth supplemental analysis is called for to reassure the officials and citizens of Maine that the proposed action is based on science and actual need, and not on mere convenience and opportunity," Mills wrote.  

The response and request of a supplemental draft EIS by the governor also met approval with local state Rep. Thomas Saviello (R - Wilton), who has been a critic of the ANG's draft EIS as being incomplete from a technical standpoint.

"The Governor and I often differ in our approaches to what should be done at the state level, but in this case we are on the same page," Saviello said. "I thank him for staying engaged."


The Condor MOA consists of Condor 1 and Condor 2, shown in this map taken from the environmental impact study. The three colors represent the western mountains, foothills and central mountains.

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11 Responses »

  1. The Daily Bulldog definitely holds the lead in coverage of this critically important issue. It's one of the top two or three as far as potential for economic impact on the region and it deserves close scrutiny by our citizens and elected officials -all the way to the top. The deeper one peers into the MA ANG conduct of the process, the more reasons for concern at all levels are revealed.

    Following the issue for nearly three years now, one is left with a choice between two very unsatisfactory conclusions. Either: 1.) the ANG is woefully incompetent to conduct the process according to standard procedures, or 2.) the ANG is being deliberately evasive and deceitful. In either case, they are failing to provide accurate and complete information we and our officials must rely on to make informed judgement. Both of these alternatives have grave implications for our collective security and economic well-being.

    The fact is that these issues have been active since the early 90's and that the unsatisfactory conduct of MA ANG has raised the hackles of DOT, FAA, Two Maine Governors, our Maine Congressional Delegation our State Attorney General and various active and retired military officers. Consequently, this sorry mess justifies a comprehensive investigation and a full report published to the citizens of Maine.

  2. I think the Mass ANG has seriously underestimated the people of Western Maine Mtn area. They perhaps thought that we were a bunch of Country Folk not engaged in what goes on up here. They are finding out differently in the process of getting their training boundaries loosened up. At the hearing in Farmington, I was very impressed with Tom's (Saviello) understanding of EIS stuff and his ability to dissect the problems in the one presented. I am a proud USAF Commissioned Officer (Retired) and want the best for our men in the Air Guard. But I am also located on Ground Zero of the proposed CONDOR zone. I have experienced a couple of rogue crews buzzing the area at about 3-500 feet...cutting in afterburners, etc...and it is no joke...as the Italian skiers near Aviano found out some years back...A very black mark on a proud USAF record there and elsewhere. I hope the Mass ANG can find some space in Mass to do their flying or over the ocean and Cape, perhaps. Dick Brooks Phillips

  3. ANG's approach has been thoroughly insensitive to the people of western Maine. They have never even attempted to answer why this issue was revisited when it was soundly and solidly rejected almost two decades ago. Real national security is when all agencies of government are performing at a level of Best Practices on behalf of its citizenry. Whether incompetent or deceitful, we are forced to question MA ANG's judgment, in this regard, and that can only make someone feel less secure when the function of ANG is to make us feel more secure.

    This process needs field hearings to legitimately answer the critical questions it raises. If we're not going to pay attention to the conclusions reached in the 1990's, then we need to revisit how those conclusions were reached and that means field hearings.

  4. I find it laughable that the governor is so concerned about the impact of these flights on the pristine beauty of western Maine while he'd like to see every ridge top here covered in wind turbines.

  5. Lets see....after years and years of chainsaws, log trucks, skidders and lots of vehicle traffic from tourists, along with oilburners to keep us warm, everyone is now concerned about the air above us. How come no one cared before about air? I am getting anxious to know the people who are anti ANG, that profit from the tourist trade and why are these people still driving vehicles and wasting good electricity if the air is so sacred? I say a true anti ANG should walk, not drive to all locations and burn wood that they cut with a handsaw. Till then they really can't complain.

  6. As a "Vet" may I suggest that you take due care to look at the reasons for the concern about ANG conduct before venting? If you cared to look, you'd find that most of us care deeply about our natural resources and quality of life and devote significant time to ensure that they endure. Recall that until news and internet coverage came to us, discussions like this were rare and confined to sidewalks, bars and those increasingly rare times when folks cared enough to rip themselves away from American Survivor and Limbaugh to attend Town Board and Town Meetings. Folks numbering in the hundreds have been interested enough in this ANG issue to endure real time/travel/weather hardship to hear and to contribute to the discussion.

    Priding yourself as a Vet, you might take this opportunity to join us citizens and veterans as a concerned American who cares enough about our democracy to get smart on important issues and to enter discussions as a well-informed citizen. Until you and others with similar inclinations do, you contribute nothing but smoke, poorly informed noise and more tragically, you degrade our American democratic process.

  7. Will someone please tell me WHAT will actually happen to the forests, etc., if a low jet flies over? And why aren't the antis WALKING instead of driving? With answers to my questions, I will be better able to get the picture. I say if you burn fuel and complain of the fuel used by the jets, you have no right to complain.
    If you follow the lead of the oldtimers, ie: no gas or electric engines, you are ok in my opinion. The rule is Practice what you Preach. It has nothing to do with being patriotic, what bothers me is that your driving and other fuel uses are polluting my airspace.

  8. Vet, let me paraphrase your logic here and see if you still support the same view:

    "Starving Ethiopian children have no right to complain until they stop eating altogether."

    As far as the fuel argument goes, do you honestly believe that a car that gets 30-40 MPG has an impact equivalent to an F-16 that can use tens of thousands of pounds of fuel in a single 1-hour training run?

  9. Ben,

    Agreed about the car, but you are still polluting my airspace by driving and wasting fuel used for electricity.

    I would prefer the jets that could save military lives over your car that does nothing to help anyone.

  10. Mr. "A Vet", you're going to have to back up a bit and take another look at the *whole* issue. The jet fuel aspect, while important, is a secondary issue. Wasting expensive jet fuel and increased pollution are just two of the many symptoms resulting from one ROOT CAUSE problem that has citizens alarmed. The Root Cause of the problem is that required documents produced by and for the MA ANG are so deeply flawed, confused and contradictory that even very well informed folks find them unsatisfactory in virtually every regard, including failure to justify the mission in the first place. Those well informed folks include active and retired military officers, commercial and private pilots, engineers and high-level people in our government.

    These problems have persisted for many years, and have now grown to have huge potential to impact a very fragile economy and the quality of life that supports it. The ANG just don't get it or they think they can crank out any kind of crap and we'll take it. We are saying: "Enough - go back and do it right this time or don't come back at all". If you are really interested in understanding the issue, you will find all the ANG documentation and citizen correspondence you could want on the web site westernmainematters.org.
    You will also find a bunch of good folks, trying to be good citizens too.

  11. NO Fed Gov report will be any good I agree with that, but my eyes are bleeding, trying read WHAT the impact would be! WHAT is the impact? WHAT?????????????

    Someone please tell me what an impact is!!!!!

    You are not getting my train of thought...WHAT IMPACT? All Fed Gov reports are vague and full of lawyered up words.

    All I have read is about "the impact on the economy" WHAT IMPACT? No one can tell me what the impact is, because there is no impact!

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