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The literature cited is “stale” and out of date.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.
Thomas B. Saviello
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.