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Letter to Terry A. Yonkers, Assistant Secretary of the Air Force for Installations, Environment and Logistics

Letter

By:
Date:
Location: Unknown

Senators Mark Udall and Michael Bennet are urging the Air Force to address concerns raised by Southern and Western Coloradans following a draft Environmental Assessment (EA) of newly proposed low-altitude flights over Colorado.

In a letter to Terry A. Yonkers, Assistant Secretary of the Air Force for Installations, Environment and Logistics, Udall and Bennet requested a full and more comprehensive analysis before any plan moves forward. The draft EA, which underwent a public comment process earlier this year, states that the proposed plan would not result in significant impacts to local communities or the environment. If the draft EA is made final, a full Environmental Impact Statement would not be required.

"As you continue to analyze the comments received during the recent draft EA public comment period, we strongly encourage you to undertake a full and more comprehensive analysis that addresses these concerns and those submitted by all stakeholders in Colorado," the senators wrote in the letter. "Based on comments from a number of counties, private citizens, and other parties, we believe that substantive improvements to the EA must be made before a decision on this proposal is rendered."

Because some counties affected by this proposal did not learn of the Low-Altitude Tactical Navigation (LATN) plan until after the comment period closed, Udall and Bennet are urging that these comments and others receive full consideration by the USAF and that they are taken into account before any decisions are made about moving forward.

Last year, Udall and Bennet sent a letter to the Air Force's Special Operations Command expressing their concerns about the potential impact that proposed Low-Altitude Tactical Navigation flights could have on civilian and military aviation operations and other interests in Southern Colorado and urging additional coordination to ensure that the training missions don't interfere with other military, medical, or agricultural operations.

Full text of the letter is included below:

Dear Assistant Secretary Yonkers:

Thank you for your continued assistance regarding the 27th Special Operations Wing's proposed Low-Altitude Tactical Navigation (LATN) area in northern New Mexico and southern Colorado. We wish to express our concern with the current draft Environmental Assessment (EA) and to request that the USAF continue to work to address the concerns of officials and residents in southern and western Colorado.

As you will remember, last year we wrote to Lieutenant General Donald Wurster, Commander, Air Force Special Operations Command, expressing our concern over the proposed LATN training area for MC-130 and CV-22 aircraft and ongoing efforts to ensure that USAF planning takes into account civilian comments and military aviation operations in Colorado. We remain steadfastly committed to our Armed Forces and to ensuring the readiness of our nation's Soldiers, Sailors, Marines, and Airmen. Therefore, we also want to ensure that any proposed training area has been carefully coordinated with Army and Air Force commanders in Colorado to protect current and future aviation missions. To this point, leaders from the 27SOW have participated in coordination meetings with the 140th Fighter Wing at Buckley AFB, the 302nd Airlift Wing at Peterson AFB, and the 4th Infantry Division at Fort Carson, but the outcome of those meetings remains unclear. The letter also asked USAF to take into account wilderness areas, agriculture operations, ski areas, and the concerns of rural communities.

In August, USAF's draft EA proposed a Finding of No Significant Impact (FONSI), essentially stating that the proposed plan would not result in significant impacts to local communities or the environment. If the draft EA is made final, a full Environmental Impact Statement would not be required.

We understand USAF has held at least 16 information sessions in both New Mexico and Colorado to discuss the draft EA and the new proposed training area. Thank you for proactively engaging the local communities of southwestern Colorado and for organizing an additional session in Aspen. Unfortunately, some counties affected by this proposal did not hear about the LATN plan until after the comment period closed and have now contacted us with their concerns. In light of their and other southwest Colorado concerns about the draft EA, we believe USAF must take a number of issues into account before moving forward.

We understand that there are inherent environmental effects associated with any low altitude training area used by our nation's Special Operations forces. At the same time, we believe that several issues raised during discussions with officials and constituents have not been sufficiently addressed in the draft EA.

First, rural communities should have an understanding of what specific measures USAF will take to avoid populated areas. The draft EA merely states that populated areas will be avoided, but gives no definition for populated areas or procedures for how the USAF will do so. It would be helpful if the Air Force would release updated maps that show which populated areas will be avoided.

Second, we are concerned that the draft EA lacks clarity on whether all Special Use Land Management Areas (SULMAs), wilderness areas, and other protected areas will be sufficiently avoided. Table 3-11 in the draft EA does list several identified SULMAs; however, the EA does not specifically state that each will be avoided by at least 2,000 feet as required by the Department of Defense's Area Planning Guide for North America (AP-1).

Third, we strongly encourage USAF to work with the Colorado Division of Wildlife and the U.S. Fish and Wildlife Service to improve mapping analysis of several wildlife species important to Colorado, including at-risk species and game species so crucial to southwest Colorado. For example, the draft EA makes no mention of the Gunnison Basin sage-grouse, which is a Federal candidate species under the Endangered Species Act.

Finally, we have heard continued concerns from communities that feel general noise impacts, livestock impacts, and public safety concerns have not been adequately addressed. Attached please find additional correspondence on these important issues and others.

As you continue to analyze the comments received during the recent draft EA public comment period, we strongly encourage you to undertake a full and more comprehensive analysis that addresses these concerns and those submitted by all stakeholders in Colorado. Based on comments from a number of counties, private citizens, and other parties, we believe that substantive improvements to the EA must be made before a decision on this proposal is rendered.

We thank you for your continued engagement on this issue and for your efforts to train our Special Operations Forces with tough, realistic low altitude training for worldwide deployment. We look forward to continuing to work with you on this important issue.


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