Franklin Countys First News

Letter to the Editor: Air National Guard’s proposed flight training over western Maine

In the last couple of weeks you have read editorials that have been general in nature about the Massachusetts Air National Guard (ANG) petition to change the flying situations allowed over western Maine airspace (Condor I & II). Many have asked me to publish my testimony from the November hearing. I thought instead I would provide a copy of the letter I sent for the record to the ANG. It is as follows:

I would like to offer the following written comments in relation to the proposed Condor 1 and 2 changes as a reiteration of the statements I made on November 14, 2009 at the public hearing held in Farmington at the University of Maine Farmington. First I would like to restate my background. I have earned a BS in Forestry, MS in Agronomy and a PhD in Forest Resources. I am a Maine registered forester and soil scientist. I am the former manager of International Paper’s Northern Forest Research Center. I have been employed at a local paper mill as the environmental manager for nearly 19 years. I am an adjunct professor at the university of Maine at Farmington teaching environmental regulations and political science. As I said at the hearing and restate for the written record, this Environmental Impact Statement (EIS) is the worst document of its nature I have read in 30-plus years as an environmental professional. My reasons are as follows:

1. EIS ownership and Literature cited: The EIS author is not identified nor are their qualifications.
The literature cited is “stale” and out of date. The most recent citation in the EIS is 2006. In the two sound reference in the appendix the most recent citation is 1992 and 1996.

Request: The principal author(s) be identified and their qualification(s) be added to the EIS. That a profession stamp be applied to the EIS.

2. The sound information is based on an “averaging” of potential increased noise: What is the background level used for rural areas? It is not identified in as such in Table: 3-2. There is no statement saying the “averaging” approach is a standard technique. Maine’s Department of Transportation Commissioner sent a letter in 2007. His concerns about sound changes are still not addressed.

Request: 1. A third party consultant review be made available to the State to evaluate the noise/sound section of the EIS. The Governor of the State of Maine requested this in his August 2009 letter. 2. Please address the DOT Commissioner’s concerns identified in his 2007 letter.

3. The latest information on windmills is not included in the EIS.

Request: A state task force identified high priority mountain sites for expedited wind energy production permitting. This document must be added to the EIS and the mountain sites within the condor airspace be addressed accordingly.

4. The air quality will be seeing a significant increase in Nitrogen Oxide (> 40 tons).

Request: A mitigation plan needs to be included to reduce this increase below significant levels.

5. The state endanger species list has not been addressed.
a. Bald Eagles are no longer endangered. However, the same protections for nesting and habitat are still in place.
b. The Barrows Golden Eye Duck is not addressed.

Request: 1. The bald eagle nesting location map needs to be updated, documented and recorded to insure no flights will go over them. 2. The Barrows Golden Eye Duck needs to be addressed. This includes the inclusion of an approved “Taking Plan” as these birds are migratory and bird/plane contact is highly likely.

6. The socioeconomic study is incomplete.
a. The Brookings report is not addressed.
b. Quality of place is not addressed.

Request: This needs to be addressed in the EIS. Any response needs to be available for adequate review time.

7. Mitigation efforts must be modified to include the following if in fact this is already a “done deal”:
a. No more than 40 sorties per month allowed. This would be a permanent cap imposed on the airspace. The cap would apply to all that may use the airspace.
b. No flying on weekend, holidays, or nights.
c. No flying on any school vacation weeks.
d. No flying over towns.
e. No flying over eagle nests.
f. No flying over Indian land holding in the area.
g. Provide an 800 number for locals to get flight plans for the day. This will be updated hourly.
h. Provide an 800 number complaints can be followed. Provide a response plan to address these complaints
i. Provide an approved “taking” plan for the Barrows Golden Eye Duck.
j. Provide an annual report to the Governor of Maine on near misses and accidents that occur in the airspace.

The questions and concerns raised above must be answered before any airspace utilization changes can take place.

On closing, I would be remiss not to thank you for your service to the country.

Sincerely,

Thomas B. Saviello
State Representative
Wilton

You too can send a letter with your comments against or in support of these airspace changes. The deadline for written comment is Jan. 1, 2010.

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12 Responses »

  1. Rep Saviello has some great ideas to try to introduce a measure of fairness into this process. Additionally, the FAA should come to Maine to listen to people that live in the area below Condor MOA. So far, we have only spoken to the Air National Guard and their hired contractor and they don't want to listen. Now is the time to make the FAA accountable for the decision they will make.

  2. Tom you disappoint me. And thanks for not being the Farmington rep.

  3. A Vet,
    Most, if not all, at the hearings covering this issue have been nothing but respectful of our military and their need to train. It has been retired pilots from the service that have been the biggest opponents of this proposal to expand the low flight area of these jets. They have been respectful and mindful of the traing needs as well, and strongly feel that these training facilities are already available without forcing western Maine to give up yet another quailty of place and receiving nothing in return. They have used facts and figures to make their agruments agains expanding the air space in Maine such as the facts like the many base closures throughout the country meaning less need for additional air space. It was made clear that many others would be using this space besides just the Mass ANG including the Canadains.

    I want to be supportive of our men in uniform as well, but at the same time I'm wouldn't give up my nice farm field just so the kids next door can tear it up with their new four wheelers rather than them having to drive to the track where the facility is already set up, but not as close for them or as fun as "tearing" up new "ground." Especially after our home team (Loring & Brunswick) had been made to put up their toys and ship out to a different section of the country, and they didn't even "tear up" our back yard while they were here.

  4. I have to agree with "a vet" and say that Tom disappoints me.

    Tom, why are you still on the fence. Make a decision please.

    I'm not interested in spending any more taxpayer money to "study" this proposal and how Barrows Golden Eye Duck's are impacted.

    This proposal is fundamentally flawed. Our airspace here is FURTHER from the ANG base than the other two alternatives mentioned in the proposal. Our economy is based on tourism of folks that wander around in our woods. Shall we add a no fly zone limitation to wilderness areas to your list? If so, that would be complete.

    I sincerely wish that you could just take a stand please and be a real voice for your constituents rather than a mere political mouthpiece.

  5. k. no flying over state parks.(Like the current law that there be to no flashing lights on top of mountains in state parks.)
    l.
    m.
    n.
    o.
    p.
    q.
    r.
    s.
    etc.

  6. Dennis,

    I have to disagree. It sounds like Tom is looking for facts that would impact his decision on whether or not to support this expansion. If the answers were good (e.g., there turns out to be zero impact on wildlife and no adverse effects from noise pollution on local population or tourism), then it seems like a rational consideration of the proposal would lead to support (or at the least, indifference). Now, I don't think any of that is actually true -- I do believe the flyovers will have an impact on wildlife as well as residents, and I don't personally support this expansion. Either way, though -- doesn't it seem more responsible of him, as a representative, to ensure he has all of the facts before making his decision, rather than just leaping to the conclusion you'd prefer and defending it vociferously, as you suggest?

    I don't think it doesn't do any harm to make sure we're all as well-informed as possible while this discussion is happening. Even though I'd personally be happy to see the request turned down, I'm at least willing to entertain opposing viewpoints if they're presented along with sound evidence. I just haven't seen that from the Massachusetts ANG so far.

  7. Thanks Benjamin.

    The only conclusions I'm leaping to are the conclusions already made in 1992 when a similar expansion of flights was proposed and decided against.

    The only public hearing thus far was overwhelmingly opposed to the current expansion of flights.

    I am not naive enough to think that the military will provide an updated impact statement that doesn't support their proposal.

    Not surprisingly, Tom appears to need a report to tell him what to think about this issue. I suppose that's fine for him. Personally, I would rather see him choose to represent the majority of his constituents rather than waver.

    Perhaps I'm too cynical, but it is an election season once again and I think it's important to know how a candidate such as Tom stands on giving away the peace and quiet of our airspace with nothing in return. That's the bottom line.

  8. Thank you Dennis, Benjamin, and Bill.
    It seems clear to me that Rep. Saviello opposes the flights by the litany of questions he has posed to the ANG in response to the evidently empty EIS they provided. It would be cheaper for the ANG to find a different low level training area or method than to draft an EIS that provides sufficient answers. Rep. Saviello is just speaking bureaucratese; a language that the ANG can easily understand. Thank you Tom.

  9. To All, Before one makes a decision he or she should have all the facts. I do not have all the facts. Good politicans gather the data BEFORE acting. I have made that clear on this issue from day one.

    Additioally there are those and many I might add, like a vet, who support this air change. Their voice needs to be heard too.

    the letter suggested alternatives that NEEDED to be in the record. The should be responded to by the ANG. Not having them in the record could limit our response at a later date.

  10. I appreciate Tom's letter for the information that it provides regardless of his end position. He has read the EIS, he understands it, and he is letting us all know what it says and the implications of the incompetence of that report. Dennis, don't pretend your position is in any way more helpful. Asking people to "join the team" has gotten us NAFTA, the Iraq War, Afghanistan, Bank Bailouts, etc. etc. I like the civic action that takes place here and the more informative it gets the better.

  11. Mr Haszko, you are being cynical and a bit naive. Rep. Saveillo is looking for facts not emotion. That is what representatives of the people do. They gather facts, report to constituents, and make decisions based on the wishes of the people and the facts that are gathered. If you actually read Rep. Saviello's testimony, and read the Draft EIS, you would realize that he is not a big fan, for the same reasons you state, but he needs more information to make an informed decision.

    My response below (part of a three page document), as written in my public comment:

    1. As a retired Air Force Lt. Colonel, squadron commander, F-15E Instructor Pilot, and Wing Flight Safety Officer, I am appalled at the lack of integrity with which the DEIS was prepared and embarrassed by the lack of quality and content within the DEIS.

    2. The DEIS (Draft Environmental Impact Statement) put forth by the ANG is wholly inadequate and fails to prove “No Significant Impact” in numerous areas of concern. The Draft Environmental Impact Statement is merely that, a statement, not a study. Studies contain relevant, quantifiable, and current data. The DEIS does not. It is a pre-foregone conclusion supported by misleading statements and incomplete data. I will support this assertion by giving several examples, and only a sample of the plethora of incongruent facts and conclusions contained in the DEIS. The DEIS does not meet criteria to prove there would be no significant impact in the majority of the areas of concern.

  12. If the ANG has their way private aviation will not be safe in the CONDOR air space, period!! If the military training requirements cannot be satisfied anywhere else (not shown to be the case) then the simple solution is for the ANG to tell us the simple truth. They must state categorically that private aircraft flying above or below 7000′ MSL will have no adequate warning of high speed aircraft operating in that air space. There is no mechanism in place that will guarantee all private aviation full or even partial disclosure of military operations in the Condor air space. Flying low performance aircraft in the CONDOR airspace under these conditions is tantamount to committing suicide.

    Based on these realities, and just these realities alone, one can quickly come to a conclusion about how safe 4 season private aviation will be in our area. As a retired veteran of 30 years and 30 days service in the USAF, and a private pilot, I will not fly under such conditions.

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