The Pennsylvania Audubon Council shared concerns for this proposal when it first surfaced over a year ago. It is now back on the “radar” and there will be an opportunity for the Council and our chapters to voice concern. This is not just an issue for chapters in the affected counties like Lycoming, Tiadaughton, or Jamestown (Warren County & NY) Audubon Societies. We will all need to offer comment to seek modification of this proposal in support of the coalition of environmental groups and agencies leading on this issue.
In review, the Maryland Air National Guard (MD ANG) is seeking to expand its use of Pennsylvania’s airspace over six counties in northern Pennsylvania, known as the PA Wilds. The establishment of a new Low Military Operations Airspace (low MOA) over the area will permit various military units to fly A-10 Warthogs, F-16s and possibly other military aircraft as low as 100 feet Above Ground Level (AGL) and as often as every other day. According to the MD ANG's Duke Low MOA website FAQs, “communities under the Duke [Low] MOA can expect to have flight training exercises overhead for one to two hours a day, two to three times a week. Typically, no more than two to four aircraft will be in the airspace at any one time.”
Because the MD ANG completed an Environmental Assessment, instead of a more in-depth Environmental Impact Statement (EIS), they have focused on the PA Wilds as the only option, without fully evaluating alternative training locations, which would have been required as part of an EIS.
The MD ANG will be releasing the Draft Final Environmental Assessment and Draft Final Finding of No Significant Impact (FONSI) in the coming weeks. A 45-day comment period will allow concerned citizens to respond to the revised documents and submit additional feedback. The MD ANG will expect to hear from key stakeholders and the people of the Pennsylvania Wilds, including permanent and seasonal residents, business owners, elected officials, and visitors.
The MD ANG received a large number of substantive comments during the first round of public input when it had released the Draft Environmental Assessment (DEA) in late fall of 2021. The DEA was made available on the 175th Wing’s website and in local libraries. Although numerous requests for in-person meetings were made to the MD ANG by all levels of government, no public meetings were held in the PA Wilds.
In its Draft FONSI, the MD ANG stated that the:
"Proposed Action would not have a significant impact on the quality of the human or natural environment or generate significant controversy. Accordingly, the requirements of NEPA, CEQ, and 32 CFR 989, et seq. have been fulfilled, and an Environmental Impact Statement (EIS) is not necessary and will not be prepared."
It’s hard to imagine that military aircraft flying as low as 100 ft AGL as often as every other day will not impact the quality of the human or natural environment. The MD ANG will need to demonstrate due diligence in regards to studying the impacts. Also, simply stating that they are in compliance with the National Environmental Policy Act (NEPA) is not enough. The actions being taken should require completion of a full EIS, which would ensure all impacts are fully assessed, other viable options are properly vetted, and public meetings are held in the impacted counties.
