Alder Rebecca Kemble
210 Martin Luther King, Jr. Blvd
Madison, WI 53703
Phone: (608) 266-4071
Fax: (608) 267-8669
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Alder Kemble’s Blog
F-35 EIS Comment Period Extended and Request for Revised EIS
Earlier this week I joined Congressman Mark Pocan and State Rep. Chris Taylor in requesting an extension of the period for commenting on the Draft EIS relating to the siting of F-35s at Truax. Rep. Taylor and I requested 60 days. Yesterday the Air Force announced an extension for comments until November 1, 2019.
You can read the letter I sent to the Secretary of the Air Force here, or read excerpts from the letter below.
Sixty Day Extension Request
According to the Title 32 (National Defense) Code of Federal Regulations (CfR) §989.33 (Environmental justice): "During the preparation of environmental analyses...the EPF should ensure compliance with the provisions of E.O. 12898, Federal Actions to Address Environmental Justice in Minority Populations and Low-Income Populations, and Executive Memorandum of February 11, 1994, regarding E.O. 12898. Further, CfR PART 989--Environmental Impact Analysis Process (EIAP) states that during the Draft EIS process, "Where analyses indicate that a proposed action will potentially have disproportionately high and adverse human health or environmental effects on minority populations or low-income populations, the EPF should make special efforts to ensure that these potentially impacted populations are brought into the review process."
The Draft EIS states that impacts to environmental justice associated with the Proposed Action would be considered significant, and yet no special efforts were made to ensure that these potentially impacted populations were brought into the review process. The recent Draft EIS Open House was held 9 miles distant from the impacted area making it extremely difficult for most of the low-income, transit dependent people who live within the 65 dB noise contour to attend.
During the EIS scoping Open House held at the Crowne Plaza hotel on March 8, 2018 my Council colleagues and I specifically requested that efforts be made to reach out to those living in low-income housing in close proximity to the base. We were told that the Air Force would only host two meetings: the scoping Open House and the Draft EIS Open House and that no special efforts would be made to do any other form of outreach.
Furthermore, materials have all been presented in English. Schools located just outside the 65 dB noise contour that serve children who live within the contour have a student population of 37% English Language Learners. This means their non-English speaking families who will be most impacted have not had access to this vital information.
I'm therefore requesting a 60 day extension to the comment period so that local officials and community members can do the outreach and share the information in the Draft EIS with the most impacted populations - something the Air Force has thus far failed to do.
In that letter I also request that the EIS Project Manager prepare a revised EIS given that so much information is missing from the current Draft.
Revised EIS Request
Many of our elected officials at the municipal, state and federal level have communicated concerns and questions to you and the EIS Program Manager Mr. Ortiz. Among them are US Sen. Tammy Baldwin, US Rep Mark Pocan, State Reps Chris Taylor and Melissa Sargent, and Madison Mayor Satya Rhodes-Conway.
Just this week the Madison Metropolitan School District Board of Education sent a letter of concern regarding the potential noise impacts on school children, and the Madison Water Utility Board sent a statement about the ongoing PFAs contamination issues on site at Truax indicating that there are many unanswered question about the Air Force's willingness and ability to further study and remediate the already existing soil and water pollution.
In my formal comments to Mr. Ortiz I listed a number of areas of missing information that require further investigation. Among them are:
- The lack of a study on the impact on property values and property taxes within the 65 dB noise contour
- The lack of realistic modeling concerning afterburner use
- The lack of peak and Lmax dB data for both F-16C and F-35A aircraft in both military power and with afterburner use
- Given the large number of daycares in the area where young children nap, the lack of Probability of Awakening data for the hours between 7am and 10pm
- The lack of safety data for current F-16C operations
For these reasons I'm requesting that a revised EIS be prepared which would address all of these outstanding issues.
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