JPARC Modernization and Enhancement DEIS

ALCOM Public Affairs 6/14//12

9480 Pease Ave, Suite 120

JBER, AK 99506

Dear JPARC Planning Team.

The following comments are submitted by the Alaska Quiet Rights Coalition (AQRC) as testimony concerning the Joint Pacific Alaska Range Complex Modernization and Enhancement Draft EIS, published March 2012.

As stated in the AQRC scoping comment letter of 1/31/11,  AQRC is a statewide non-profit organization dedicated to protecting the important resource of natural quiet on our public lands for the benefit of all Alaskans, visitors, wildlife, and future generations. State surveys have shown that the majority of Alaskans cherish the beauty, peace and quiet of wild places, and consider that peace and quiet necessary and important to their lives. Natural Quiet is a natural resource that is an essential ingredient of wild areas.

AQRC reluctantly supports the no-action alternative, but has a strong preference for an alternative that would reduce the size of the existing MOAs, not leave them as they are or increase them. While AQRC is appreciative of the role of the military and the need for training to stay current, the proposal to, once again, expand the already enormous areas of MOAs and increase the training exercises with their accompanying noise, safety, and environmental degradation issues, sacrifices the quality of life that Alaskans cherish. It is also a major threat to wildlife resources.

Human effects:

Low altitudes to 500 feet are not compatible with acceptable civilian quality of life. Both Alternatives A and E include this level which was rejected in the past by both military and civilian reviewers and should be rejected now.

Noise created by military aircraft adversely affects rural and backcountry users. There are all kinds of recreationists along the Richardson and Denali Highways, cabin owners in the Lake Louise area, backpackers in the Talkeetna Mountains and near the Denali Highway, and hunters and fishers throughout the expanded areas being proposed. The mitigation suggestion of publishing times of training missions, as proposed, will not be sufficient to meet their many and varied interests and needs. Further, there are many homes and growing communities along the Glenn and Richardson Highways, and elsewhere in the Copper River Basin that would be negatively affected by either Alternative A or E.

The Draft EIS quotes various standard noise measurements such as the day-night average noise level and the FAA and EPA standards for noise safety.  The FAA mission is airplane safety. The EPA standards address noise as it effects physical health. None of this is relevant. As is admitted in Chapter 3, noise is not experienced as an average and noise increase in quiet areas has greater impact than in less quiet areas. The impact of machine or ordnance noise is to remove peace and quiet. The Draft EIS Alternative A indicates that sonic booms would become much more frequent in Fox 3 and “would be expected to be considered significant.”(3.1.2)  According to the Draft EIS, in Alternative A subsonic noise under the  Fox 3 expansion and new Paxson MOA would result in problems. “Overall, the relative (noise)change is high, and in quiet settings, these increases would be highly noticeable and cause potentially significant impacts on communities.” (3-79)

The Draft EIS describes the expanded Fox 3 and the new Paxson MOA as being over rural and sparsely populated areas, as if that made noise less of a concern. The opposite is true. The very value of those areas are that they are rural and sparsely populated and therefore a resource to be enjoyed and treasured. If the military judges the effect of its actions by the number of people adversely affected, then the judgement being made is that cities are to be saved and wild areas are appropriate sacrifice zones. Many Alaskan civilians see it the other way around. Cities and noise are expanding. Wild areas and natural quiet are shrinking and becoming progressively more valuable. Alaskans live here in this cold dark place because we value the wild and the peace and quiet above all.

Wildlife effects.

As AQRC has stated in the scoping letter, mammal mating, birthing, feeding, resting, and migrating have been shown to be sensitive to stress in different species at different times. Similarly bird mating, nesting, feeding their young, fledging, food storing for migration or winter, migrating or wintering have been shown to be sensitive to stress in different species at different times. Few, if any, windows of opportunity are available when air noise and/or ordnance will not have negative effects on wildlife.The Alaska Department of Fish and Game has written to you with concerns that both the low level flights and the large scale training could disturb all species. (March 1, 2011)

The Draft EIS Alternative maps show extensive overlay of Dall Sheep, Caribou calving, and Trumpeter Swan nesting areas. The EIS claims that effects would be short term based on a few studies in other areas. No reference adequately supports the claim that Alternative A with mitigation would have “moderate effects on wildlife and would not be measurable at the population level and not significant.”(3.1.8)  No MOA expansion or decrease in flight altitude should occur before specific studies on the effect of various kinds of military noise on moose browsing, Dall sheep lambing in both the Alaska Range and Talkeetna Mountains, caribou calving in the northern Talkeetna Mountains, migration, nesting and fledging of water fowl, including Trumpeter Swan, are done.

For the above reasons, AQRC supports:

No action alternative.

No reduction in flight altitude levels.

No increase in ordnance and training areas.

The perceived need to keep expanding air and training space to keep up with technology never ends. However, our land is finite. When will enough be enough? What volume of civilian outrage is sufficient to stem this inexorable take-over by the military asking itself if it should have more space and answering “More More More.”


Elizabeth Hatton

Alaska Quiet Rights Coalition

8601 Sultana Drive

Anchorage, AK 99516