ALCOM Public Affairs 1/31/11 9480 Pease Avenue, Suite 120 JBER. AK 99506
Dear JPAC 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 EIS, Scoping phase.
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 essential to their lives. We are appalled that the military is once again proposing to expand the already enormous areas appropriated as MOAs.
Human effects:
Noise created by military aircraft adversely affects backcountry users. There are climbers in the eastern Alaska Range, 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.
Although we have been assured in the past that military planes do not break the sound barrier and do not fly low in areas not designated for low flight, it is common to hear of such instances. From the first hand experience of some of our members living under the Susitna MOA, and others recreating in the Talkeetna Mountains, AQRC is well aware of the shattering impact of military exercises. One can only conclude that neither the speed nor the altitude requirements have been vigorously monitored and controlled.
Wildlife effects: 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. 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 need to be done.
Alternative approaches:
Given that service personnel can sit at a desk in the US. and direct drones to pinpoint bombing the border of Pakistan, that astronauts can get their training in on the ground simulators, that simulated pilot training has been shone to be superior to in the air
training at least in some circumstances, that multiple nation simulated military exercises have occurred successfully, it seems that simulated training is well advanced in the military. If, at the present time, there are circumstances that require actual rather than virtual experience, it would be less expensive and use less resources to further develop simulation rather than continue to expand MOAs and usurp more civilian territory. In view of the national deficit, it would seem prudent to put a stop now to this endless expansion and focus efforts on reduction. It is curious that one of the alternatives suggested so far does not include a decrease in the size of the MOAs. The reason stated for “needing†more territory is that it would save fuel by reducing the distance planes travel to do their training (p. 1). It would seem that simulation would save even more fuel and be an all around effective and cost saving approach.
AQRC requests the following to be added to the scope of the EIS: 1) Further study on other “documented noise sensitive areas†(see p. 14) needs to be
done. This map shows a ridiculously small scattering of such areas. Clearly there are a great many more. One could argue that most of the state is comprised of noise sensitive areas.
2) Include additional alternatives that consider the reduction of existing MOAs including any that cover noise sensitive areas currently identified or identified in future studies, any that cover national parks, preserves, and wildlife sanctuaries, any that cover bird nesting and/or migration routes.
3) Remove the 500 feet AGL proposal from any current and future alternatives. Low level flying is intolerable for both wildlife and humans.
4) Fund wildlife studies, perhaps through cooperation with the University of Alaska, on specific effects of air noise on wildlife including moose, Dall sheep, caribou, and migratory birds. This recommendation was made the last time the military decided to take over more civilian air space and was recognized by the military as important to any future expansion.
5) Remove any alternatives that are shown or suspected to add stress to wildlife mating, birthing, foraging, migration and winter survival. For example, the proposed Fox 5, 6, and Paxson MOA contain extensive caribou habitat.
6) Remove any alternatives that add stress to bird mating, nesting, migration routes, stopovers, and wintering sites. For example, the proposed Fox 5, 6, and Paxson MOA contain numerous waterfowl and other bird nesting sites.
7) Monitor altitude in a proactive plan to identify and prevent unauthorized AGL pilot behavior.
8) Monitor plane speed in a proactive plan to identify and prevent unauthorized speeds.
It is the right and the duty of citizens to ask at what point the line is crossed between protecting the country and destroying the country in order to save it. For those of us that love rural and wild Alaska, the intrusion of military noise crosses that line.. Therefore no increase in the MOAs is one solution. Another is a decrease in the size of the MOAs as simulation becomes even more sophisticated.
It is time to “just say no†and ask that our military value our ways of life, our wildlife, and what natural quiet still exists, even as we value our service personnel and the enormous contribution that they make.
Thank you for this opportunity to comment.
Elizabeth Hatton Board Member, AQRC