Alder Marsha A. Rummel
210 Martin Luther King, Jr. Blvd
Madison, WI 53703
Phone: (608) 266-4071
Fax: (608) 267-8669
WI Relay Service
Alder Rummel’s Updates
D6 Items of Interest Week of September 30, 2019
Highlights: I wrote most of my weekly update yesterday and instead being saved in drafts for final touch ups today, somehow 99% of it was deleted (aargh). So here is the condensed version! There are no city meetings on Monday and before sundown on Tuesday because of Rosh Hashanah. Happy New Year! Common Council meets Tuesday at 7p https://madison.legistar.com/View.ashx?M=A&ID=659018&GUID=F097D196-79B3-4C3C-AA56-89A8CE29BF3E and Mayor Rhodes-Conway will introduce the 2020 Executive Operating budget midafternoon at a press conference.
Wednesday is packed with meetings. Red Caboose/Movin' Out proposal for 2340 S. Winnebago is at Urban Design Commission for Final Approval. The Board of Parks Commissioners has several items of interest including agenda item 17. 57578 Statement of Policies and Guidelines for On-Leash Dog Access to the Madison Park System and the Superintendent's monthly report is a trove of info https://madison.legistar.com/View.ashx?M=A&ID=646055&GUID=6E0192B4-9580-41B2-9759-804978FDEDA6. One of the topics at the Task Force on Government Structure meeting Wednesday is whether to reorganize the city's boards, commission and committee structure around "lead committees" and require alders to serve only on lead committees with residents only serving on feeder committees.
Thursday is also packed with meetings: The Public Market Development Committee and Historic Preservation Plan Advisory Committee meet at the same time (I am on both committees...). CDBG will recommend three affordable housing projects to fund including Red Caboose. The resolution does not propose funding the transitional housing proposed by The Salvation Army. And the Madison Arts Commission discusses the Thurber Park artist in residence and the selection of the new poet laureate. Go to the City Clerk's weekly calendar listings for agendas https://www.cityofmadison.com/clerk/meeting-schedule
Draft F-35A EIS Public Comment Period Extended. Press release: To ensure ample opportunity for the community to provide comments, the Air Force is extending the public comment period for the Draft Environmental Impact Statement (EIS) for the F-35A operational beddown at Truax Field. The original EIS period was to end September 27, 2019; the comment period will now end on November 1, 2019.
The Air Force notified the 115th Fighter Wing September 26 that it wants to provide all interested parties with every opportunity to provide input to the proposed action to beddown F-35s at Truax through the environmental impact statement process. The Air Force has announced this extension to the community by publishing an advisory in the Federal Register.
The National Guard Bureau has prepared a Draft Environmental Impact Statement to evaluate the potential environmental consequences from the proposed bed down of 18 F-35A aircraft at two of five alternative locations:
• 115th Fighter Wing, Madison, Wisconsin
• 124th Fighter Wing, Boise, Idaho
• 125th Fighter Wing, Jacksonville, Florida
• 127th Wing, Harrison Township, Michigan
• 187th Fighter Wing, Montgomery, Alabama
Please forward your comments to F-35A EIS Project Manager, NGB/A4AM, Shepperd Hall, 3501 Fetchet Avenue, Joint Base Andrews MD 20762-5157.
You may also download a copy of the Environmental Impact Statement and submit comments via the project website at www.ANGF35EIS.com or via email at firstname.lastname@example.org. All substantive comments received by November 1, 2019 will be addressed in the Public Comment Section of the Final EIS.
POINTS OF CONTACT: Please call Mr. Ramon Ortiz, NGB/A4AM at 240-612-7042, or 115th Fighter Wing Public Affairs at 608-245-4395 with any questions. "
According to Safe Skies Clean Water documents https://www.safeskiescleanwaterwi.org/wp-content/uploads/2019/09/Safe-Skies-How-to-Respond-to-EIS.pdf?fbclid=IwAR3_Co6fokgs5hKPkJcrQfubE7-Wof0ev3KbBHJ_QMoTFGzq9jmYK5PKWMM Substantive Comments challenge the analysis, methodologies, or information in the EIS as being factually inaccurate or analytically inadequate; that identify impacts not analyzed or developed and evaluate reasonable alternatives or feasible mitigations not considered by the NGB; or that offer specific information that may have a bearing on the decision, such as differences in interpretations of significance, scientific, or technical conclusions, or cause changes or revisions in the proposal. Non-substantive Comments do not require a specific NGB response, are generally considered to be those comments that are non-specific; express a conclusion, an opinion, agree, or disagree with the proposals; vote for or against the proposal itself, or some aspect of it; that state a position for or against a particular alternative; or that otherwise state a personal preference or opinion. The group provide examples in their link.
Here is my partial list of substantive topics I sent to National Guard Bureau: I submitted a letter by mail and attached the recently passed Council resolution, the April 2018 EIS F-35 statement signed by several Council members and the resolution passed by the Council during the initial scoping period (see end of update for links). I have also submitted online comments as more questions are raised. You can do both.
1. While the draft EIS identifies the disproportionate impacts to people of color, low income neighborhoods, and children in the immediate area, the lack of meaningful outreach to impacted neighborhoods during the initial scoping and the draft EIS process by the National Guard Bureau per Executive Order 12898 "Federal Actions to Address Environmental Justice in Minority Populations and Low Income Populations" (1994) fails to fully achieve NEPA's environmental justice mission. According to the consultant and WANG staff, I was told during the scoping meeting that outreach consisted of flyers in gas stations/c-stores. Were residents and businesses inside the 65+ dB noise contour mailed information about the draft EIS?
2. The draft EIS underestimates health impacts on children and other vulnerable populations who attend schools and daycares just outside the 65 dB noise contour. The increase in peak noise events, up to 110 dB during twice a day sorties, which may occur up to four times a week, will exacerbate a degraded quality of life indoors and outdoors for nearby residents and students. Vulnerable populations include people who experience PTSD, second and third shift workers, and students who attend the Richardson School, a therapeutic day school that specializes in working with children, adolescents and young adults who have diagnoses of developmental/neurological disabilities and behavioral and emotional issues. The number of households but not the number of affected people is quantified in the draft EIS. Will you provide more demographic information in the final EIS
3. According to the City of Madison F-35 EIS Analysis: "It should also be noted that there are several concentrations of poverty and persons of color just outside the 65 dB contour, including the CDA Truax housing, CDA Webb-Rethke townhomes and other housing near Worthington Park, and near the intersection of Packers Avenue and Northport Drive. While these areas will experience virtually identical noise exposure as residents who live on the contour line, they will not be eligible for federal sound mitigation funding through the Noise Compatibility Program. If Truax is selected for future F35s, it's a reasonable conclusion that non-mitigated areas immediately adjacent to but outside the 65 dB contour may experience more significant impacts than mitigated (soundproofed) residences inside the impacted area." (page 2)
If nearly 800 subsidized low-income housing units are within 1,500 feet of the 65 dB contour, but not potentially not eligible for remediation, how is the environmental justice mission served? In addition, there will be over two years of uncertainty about access to remediation funds while residents experience an increase of annual flights and peak noise events while both the F-16 and F-35As that could potentially damage children and vulnerable populations. As stated in the draft EIS, remediation funds are not guaranteed by the FAA and also require a county and state match.
The noise contour maps are based on a 24 hour average of 65 dB versus peak noise events during takeoff/landing that exceeds 110 dB. Will the final EIS include peak noise events and will you measure the 50-65 dB noise contour to capture the impacts to nearby public housing and affordable housing?
4. After the draft F-35A EIS was released, City of Madison Council members whose aldermanic districts surround the airport mailed a postcard invitation to nearby residents to attend a community meeting on September 11, 2019. Over 300 residents attended. We heard testimony from residents within the 65 dB noise contour who were very concerned about the potential decline in property values of their homes and businesses when they were identified in the 65 dB zone. Council members received emails from real estate brokers that their professional ethics would require the noise contour impacts should be disclosed. But the draft states: "Negligible impact on the housing market in the city of Madison." (Table ES-2, page 11).
How did you arrive at this conclusion? Did you conduct a study on the impact on property values and property taxes within the 65 dB noise contour as a result of the proposed action? If not, I would request that the Air Force issue a revised EIS with that information.Depressing property values of those who can least afford it, is essentially is a taking
5. According to the City of Madison F-35 EIS Analysis: "One contaminant present on the Air National Guard base is per- and polyfluoroalkyl substances, or PFAs, a bioacumulative, toxic and persistent group of chemicals historically used in firefighting foams. The PFAs investigation on the base has yet to be completed and the WDNR has required additional investigation of soil, surface water, groundwater, and sediment both on and off the base. It is staff's understanding that DNR's request is not being acted upon, and the Department of Defense does not consider this a priority site for mitigation. Based on initial test results, PFAS-contaminated soil and groundwater contamination is widespread and its extent has not been fully defined. Under NR 700, a completed site investigation is required to define the nature and extent of PFAS contamination before remediation activities can be planned.... The Department of Defense and the Air National Guard cannot safely and legally perform the planned construction activities without a complete site investigation that defines the extent and nature of PFAs contamination in soil and groundwater. The WDNR will require a materials management plan for any areas of the base impacted by construction, describing how excavated soil and dewatering will be managed. The 115 FW does not have enough information presently to do this. This investigation should be completed with full coordination with WDNR, and remediation of the contamination should take place concurrently in the event of an F-35 transition. Other areas of concern include two former burn pits on the base. While the Air National Guard has taken responsibility for conducting the site investigation, no additional work has taken place yet. These should occur as soon as possible." (page 6)
Will the Air Force conduct a complete site investigation into existing PFAS contamination before commencing construction for the Proposed Action?
6. The May 18 2018 statement from Council members: "The EIS report should review the contaminants found in the Starkweather Creek downstream from the airport and determine which chemicals may be coming from Truax Field. The EIS should include an updated runoff, water filtration and monitoring plan to address contaminants. The UW Starkweather Creek Watershed report offers numerous details and strategies to improve filtration of water and contaminants at sites throughout the Watershed."
The draft EIS on page WI-96 states:"The west branch of Starkweather Creek drains the area around the Dane County Regional Airport and other urbanized portions of Madison. This area of Starkweather Creek received intensive point source discharges of many different toxic substances up to the 1960s and early 1970s. Some of these discharges remain in the sediment of the creek and continue to pose problems for fish and aquatic life (WDNR 2018)." Will the final EIS include an updated monitoring plan to address contaminants created by the base?
7. The May 18 2018 statement from Council members : "The F-35A's can carry up to 18,000 pounds internally and externally. The EIS should provide information about how much fuel and what type of fuels will be carried. The EIS should also detail what types of armaments will be carried (including nuclear munitions), what would be released from these munitions if the planes crash and/or burn, the environmental and public health effects of these potential releases, and what the types of emergency response will be employed in the event of a crash or accident."
Members of the 115 FW command staff assured the Common Council that F-35As would not carry nuclear weapons. While WANG staff were clear that initial the Block 3 F-35As were not currently capable of conveying nuclear weapons, they were not as clear about the possibility that Block 3 F-35As could be upgraded to Block 4, which is capable of conveying nuclear weapons. Will the Block 4 upgrade to the F-35As have nuclear capabilities? Is there a possibility that when Block 4 technology is available and deployed in Madison the 115 FW will get a nuclear mission? If so, is the Air Force required to inform the public about this change in mission? Will there be a new EIS process?
If F-35As carry nuclear weapons, crashes could release radioactive materials into the environment, exposing people and ecosystems and contaminating ecosystems irreversibly.What plans are in place for emergency responders if there is a nuclear spill?
8. The May 18 2018 statement from Council members : "Aircraft operations and maintenance involve a variety of chemicals, emissions and hazardous materials. Chemicals reviewed and discussed in the F-35 EIS for the Pacific Beddown included lead, carbon monoxide, Nitrogen Dioxide, Ozone, Particulate Pollution, Sulfur Dioxide and Benzene. However, the Pacific Beddown EIS does not provide a comprehensive list of chemicals and hazardous materials utilized or generated in the operations and maintenance of the F-35A aircraft."
In the final EIS, will you provide a complete accounting of the solvents, lubricants, and petroleum products including fuels that are currently in use at the ANG facility at Truax, as well as a list of chemicals that will be used to support operations and maintenance of the F-35A aircraft and the management of the F-35A armaments, fuels, and emergency response supplies?
9. The May 18 2018 statement from Council members : "The ANG should provide a full assessment of how the health and safety of Air Force and National Guard personnel will be protected in the case of F-35 crashes, explosions, or burning, and plans for responses to these incidents in the EIS." ..." According to the 2015 Air Force Research Laboratory's Composite Material Hazard Assessment at Crash Sites report, "Potential contaminants/hazards include the following: jet fuel, unexploded ordnance, isocyanates, blood-borne pathogens, radioactive material, plastics, polymers composed of organic material, and composite fibers. Aircraft structural alloys include, but are not limited to, beryllium, aluminum, zinc, hydrazine (F-16), magnesium, titanium, and copper released in the form of metallic oxides, which pose an inhalation hazard to unprotected responders." The F-35 is composed of 42% advanced composites will include carbon fibers in the micron and nanosized ranges. Numerous scientific studies have shown that carbon fibers in this size range, when inhaled, can have health effects similar to asbestos."
Have there ever been any F-35A mishaps at Hill AFB, Eglin AFB or Luke AFB?If so, how many? How frequently can we expect F-35As to crash in Madison given the track record so far?In the event of fire, what are the effects of burning military grade composite materials with which the F-35As are constructed? What toxins do they emit and what is the impact on human health? In the event of a mishap and subsequent fire, what are the effects of burning stealth coating with which the F-35As are constructed? What toxins do they emit? What is the impact on human health?
If there is an emergency, what are procedures for landing the plane? Would they land at Truax or go elsewhere?
What special occupational safety gear is required for workers applying stealth coating to F35As? Why is it required? What special occupational safety gear is required for workers cleaning the outside of the F-35As? Why is it required?
What are the impacts of stealth coating contaminating the water and soil after the F-35As are washed? Will local maintenance workers at the 115 FW do the cleaning? Or would the manufacturer or their assignees do this work?
10. A recent article appeared in our local media about a leaked memo from Christopher L. Brewster, USAF Chief, Environmental Compliance at Davis-Monthan Air Force Base, Tucson, Arizona that raises the question whether the EIS modeling that assumes 5% afterburner (AB) usage is flawed. ("It might get louder, F-35As could use afterburners more frequently than Air National Guard promises" Isthmus, Howard Hardee, September 19, 2019). If the modeling using 5% AB is inaccurate, the noise contour maps that show the 65 dB lines may be understated and the disproportionate impacts may actually extend to a larger area. How often do the F-35As currently in service take off with afterburners?
I request you redo the draft F-35A EIS to provide modeling of AB usage at 10%, 25%, 50%, etc. I would request information that identifies actual peak noise at the named points of interest identified in Table WI3.1-12 so people understand the maximum dB levels, not the DNL average, with and without afterburners. If the EIS is flawed, it cannot be a source of information to make an informed decision and the EIS is not legally valid.
April 16, 2018, comments to Ms. Christel Johnson (on my alder webpage, a very large document) https://www.cityofmadison.com/council/district/?district=6
RES-18-00312 - "A Resolution on the Air National Guard F-35 Operational Beddown Environmental Impact Statement" file:///C:/Users/Owner/AppData/Local/Packages/microsoft.windowscommunicationsapps_8wekyb3d8bbwe/LocalState/Files/S0/27514/Attachments/50973.pdf
RES-19-00588 - "A Resolution Responding to the Draft Environmental Impact Statement (EIS) for the Air National Guard F-35A Operational Beddown"
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