December 8, 2021
Ramon E. Ortiz
National Guard Bureau
SUBJ: PPFF Comments on Duke MOA Draft FONSI
Dear Mr. Ortiz:
Allow this opportunity for the Pennsylvania Parks and Forests Foundation (PPFF) to comment on the proposed changes to the Air National Guard’s Duke Military Operations Area (MOA) that would establish a lower threshold for the current MOA and the draft Finding of No Significant Impact (FONSI). PPFF is a statewide not-for-profit foundation advocating and educating for the benefit of the Commonwealth’s 121 state parks and 2.2 million acres of forestland. Our dedicated volunteers and supporters work tirelessly to sustain and enhance Pennsylvania’s natural assets and beauty.
Firstly, PPFF supports our men and women serving in the armed services and the National and Coast Guards. Your dedication and sacrifice are a great source of pride for our country, and we simply cannot thank you enough for your service. We understand the critical need to keep our troops highly trained and to maintain our equipment to the best of its capacity. That is without question. This letter provides comments and considerations pertaining to the draft FONSI.
It is understood that the changes, as proposed, would lower the existing Duke MOA from 8,000 feet above mean sea level (MSL) extending to 17,899 feet MSL to a new 100 feet above ground level (AGL) extending to 7,999 feet AGL. It is also understood that the MOA may be in operation 170 days per year, for up to four hours per day, and will not entail the usage of supersonic flights, live ordnance, chaff or flares.
While the area in question in the MOA is one of the lesser populated areas in Pennsylvania, it has changed since the existing MOA was first established. As a result of the Commonwealth’s efforts in this region, we now market the area as the Pennsylvania Wilds. These efforts have resulted in greater economic activity in the form of outdoor recreation and increased tourism throughout the region. As existing MOA actions at the minimum threshold of 8,000 feet MSL may not be as noticeable, lowering it to a potential 100 feet AGL will undoubtedly have an impact on recreational activity and wildlife.
Within the current MOA, there are 12 state parks and six state forests. These are a part of the $13 billion outdoor recreation and tourism industry in Pennsylvania. As we have noticed over the past 18 months, the coronavirus pandemic has forced an explosion in the exposure and usage of our state’s parks and forest system. Even now, as the world continues to recover and reopen from this pandemic, we have not seen a drop-off in the usage of these assets. Not only have these parks and forests provided safe shelter for families, but they have also provided a residual economic benefit. A benefit that is greatly needed and welcomed, particularly in the rural MOA counties of Cameron, Clinton, Elk, McKean, Potter and Tioga.
The PPFF works closely with the state Department of Conversation and Natural Resources (DCNR) in supporting and maintaining our state parks and forests system and has also made voluntary and financial investments in the area known as the Pennsylvania Wilds.
Additionally, the area proposed for the altered MOA is also a recreational area for private pilots. The PPFF has members that do fly over this area due to its scenic beauty. The proposed low-level flights may be hazardous to the unreported flight schedules of these private enterprises.
There are approximately 49 public and private airports in the counties of Warren, Forest, McKean, Elk, Potter, Cameron, Clinton, Tioga and Lycoming. Several of these 49 locations are small uncontrolled private airstrips which pose the highest risk to the flyovers where little or zero traffic data is available. The Bradford Regional Airport (BFD) in McKean County is one of these airports that could be severely impacted. Bradford Regional’s website (https://www.bradfordairport.net) markets its facility as a “Gateway to the PA Wilds.” Furthermore, this facility provides daily commercial commuter flights to Pittsburgh (PIT), in addition to service to Washington Dulles (IAD) and maintains approximately 3,600 operations annually which includes Air Carrier, Air Taxi, General Aviation Local, General Aviation Itinerant, and Military. Other public-use airports in the affected counties operate mainly General Aviation flights (over 30,000 flight operations annually).
It is our understanding that a military training area would have to be published as a “Restricted
Airspace” for the days and hours of the training flights. This information is normally depicted on the Sectional Aeronautical Chart for the affected area and would be listed in a Notice to Airmen (NOTAM) for the airports in the impacted military flyover area.
The PPFF is concerned for the pilots flying recreationally in the area as they likely would not be filing an FAA Flight plan or have checked NOTAMs for the airports in the area. They are in most cases flying via Visual Flight Rules (VFR). Ultralights and gliders pose a significant danger to the flyover area and are often flown out of an uncontrolled private airstrip. Severe medical emergencies have required Life flight helicopter to evacuate victims from the forest in the defined military flyover area to medical facilities. These life flight helicopters could be endangered by low-level high-speed military aircraft and need special coordination with for both the civil and military flight service authorities.
To conserve the assets that define this region, our first recommendation would be no action—can the training continue where it is currently occurring?
In the result that a no-action alternative is not feasible, are there alternative locations that provide the needed training with limiting impact to people and wildlife?
If no alternatives exist, we support the Pennsylvania Department of Conservation and Natural Resources’ (DCNR) scheduling recommendations to limit the activity during specific seasons as outlined in their letter of October 2019. DCNR’s recommendations are as follows:
- Consider a no-action alternative, in which the AFB maintains current flight protocols and operations as defined in the current MOA;
- Consider alternative locations that would not be as adversely impacted by the frequency and nature of this activity;
- Limit the activity significantly to lessen the impacts on the proposed region by:
- Eliminating any low-level flight activity directly above state parks and key recreational, historical, and tourist destinations (consulting with DCNR and other stakeholders as appropriate).
- Prohibiting this activity during the following months: April, May, September, and October (to avoid impacts to raptor migration and the elk rut);
- Prohibiting activity on weekends and federal holidays, which draw large numbers of visitors;
- Prohibiting activity to avoid interference with key recreational activities, including:
- Spring Turkey Hunting Saturdays in May = 4 days
- Big Game Hunting Seasons of Traditional Rifle Bear and Deer = 15 days
- Elk Tourism: Mid-Sept to Mid-Oct. = 30 days
- Calving Season (stress)- May-June of Deer & Elk= approximately 30 days
- Primitive Hunting Season: from Christmas Day onward = 14 days
In conclusion, the PPFF believes that the draft FONSI may be presumptuous given the established activities associated within the existing MOA. We request that further review beyond an Environmental Assessment be conducted to include a Draft Environmental Impact Statement. At the very least, public meetings should be held throughout the affected area to gather public input and for the Air National Guard to provide further elaboration on the impacts of the altered MOA on the community and businesses.
Thank you again for the opportunity to provide comments. We look forward to working with you to keep our men and women the best armed service in the world.
Brad Mallory Marci Mowery
PPFF Board of Directors
Department of Conservation and Natural Resources
Ta Enos, PA Wilds