February 2, 2010
F-35A Training Environmental Impact Statement (EIS)
ATTN: Mr. David Martin, AETC NEPA Program Manager
266 F Street West, Bldg 901
Randolph AFB, TX 78150-4319
FAX: (210) 652-4266
PHONE: (210) 652-1961
Re: Scoping Comments on Proposed F-35A Training EIS Scope for Holloman AFB (expansion)
DEAR MR. DAVID MARTIN:
I HAVE BEEN A RESIDENT OF W EED, NEW MEXICO FOR THE LAST 10 YEARS. THIS IS WHERE I HAVE BUILT MY HOME. I
USE SOLAR POWER FOR MY HOME (FOR 10 YEARS NOW ) AND AM PLEASED TO LEAVE A SMALL ENERGY FOOTPRINT ON
OUR PLANET. I'M ACTIVE IN THE COMMUNITY. I AM A VOLUNTEER FIRE FIGHTER AND AMBULANCE DRIVER IN OUR LOCAL
FIRE - EMS DEPARTMENT. I LIVE IN W EED, NM BECAUSE IT IS AFFORDABLE AND BECAUSE I LOVE THE QUIET, PRIVACY,
SPACE AND WILD CREATURES OF THIS PART OF THE MOUNTAINS. I WANT TO LIVE IN A HEALTHY ENVIRONMENT WITH
CLEAN AIR AND CLEAN WATER. I VALUE MY LIFE AND HOME IN W EED AND PLAN TO RETIRE HERE. KEY FOR ME IS THE
RELAXED, PEACEFUL MOUNTAINS WHERE I CAN WALK QUIETLY AND ENJOY NATURE. MY WIFE IS AN ARTIST (PAINTINGS)
AND SHE IS DAILY INSPIRED BY OUR SURROUNDINGS. WE DEPEND ON HER INSPIRATION FOR OUR LIVELIHOOD.
I AM VERY DISAPPOINTED THAT THE USAF HAS FAILED TO MEET IN W EED, NM (OR MAYHILL, NM OR PINON, NM) OR
EVEN POST NOTICES, WHILE MEETING WITH OTHER POTENTIALLY IMPACTED COMMUNITIES. I DO NOT KNOW WHY WE
HAVE BEEN IGNORED ESPECIALLY DURING THE SCOPING PROCESS. W EED HAS BEEN DENIED A SEAT AT THE TABLE AND
BECAUSE OF THIS, I RECOMMEND THAT THE SCOPING PERIOD BE EXTENDED FOR 90 DAYS DURING WHICH TIME THE
USAF CAN ARRANGE TO MEET WITH OUR COMMUNITY.
WHEN DEVELOPING THE DRAFT ENVIRONMENTAL IMPACT STATEMENT (EIS), THE USAF MUST RECOGNIZE THAT IN MY
VIEW , THE PROPOSED F-35 BASING AT HOLLOMAN AFB (HERE AFTER CALLED "EXPANSION") CANNOT BE MITIGATED IN
TERMS OF VISUAL RESOURCES, SAFETY, BIOLOGICAL RESOURCES, AIR POLLUTION, NOISE, OR IMPACT ON OUR WATER
AND OUR QUALITY OF LIFE.
SINCE I, AND MANY OF MY NEIGHBORS, ARE ON A LIMITED INCOME, I BELIEVE THAT THE COSTS OF MOVING WOULD BE
UNAFFORDABLE AND UNFAIR, AND I AM VERY CONCERNED ABOUT HOW THE F-35 EXPANSION WILL AFFECT MY PROPERTY
VALUES. I HAVE NOTICED THAT USAF OFTEN USES GENERALIZATIONS ABOUT NOISE NOT AFFECTING PROPERTY VALUES.
THE USAF MUST STUDY, SPECIFICALLY, PROPERTY IN QUIET, PEACEFUL MOUNTAINS THAT HAS BEEN TURNED INTO A
HIGH NOISE TRAINING AREA, THEN ANALYZE AND PUBLISH THE FINDINGS FOR THE CHANGES IN PROPERTY VALUES IN
CONSTANT DOLLARS. DISCUSSING CHANGES IN PROPERTY VALUES IN AN URBAN OR NON MOUNTAINOUS IS NOT A
CORRECT ANALYSIS. W EED, NM IS UNIQUE.
I HAVE MANY SERIOUS CONCERNS AND QUESTIONS REGARDING THE PROPOSED EXPANSION F-35 OPERATIONS OVER
1. AESTHETICS/VISUAL RESOURCES:
WEED IS UNIQUE IN ITS LONG VISTAS, CLEAR SKIES, DARK SKIES AT NIGHT, LIMITED LIGHT AND AIR
POLLUTION, AND BEAUTIFUL, UNDISTURBED LANDSCAPE. W HAT IMPACTS WILL THE PROPOSED EXPANSION
HAVE ON THE AESTHETIC AND VISUAL RESOURCES WITHIN THE VIEW SHED OF W EED ON EITHER TEMPORARY
OR PERMANENT BASIS?
2. TAKING OF PROPERTY:
ONE OF THE RESULTS OF THE PLANNED INCREASE OF USAF NOISE/POLLUTION FROM F-35 OPERATIONS IS A
LOSS OF MY QUALITY OF LIFE. I LIVE IN A PEACEFUL AREA, NOT CHICAGO OR HOUSTON BUT W EED, NM. I
MOVED HERE SPECIFICALLY TO AVOID CITY DISTRACTIONS SUCH AS NOISE. SINCE THE USAF PLANS TO
"TAKE" MY (AND OTHER RURAL CITIZENS) QUALITY OF LIFE AN ANALYSIS IS WARRANTED. W HAT WILL BE THE
QUALITY OF LIFE IMPACTS TO RURAL CITIZENS? AGAIN THE USAF HAS IN THE PAST USED GENERALITIES TO
GLOSS OVER THE IMPACT ON QUALITY OF LIFE. THE ANALYSIS SHOULD BE SPECIFIC TO THE AREA AFFECTED;
THE SACRAMENTO MOUNTAINS, NOT ANALYZED AGAINST AN URBAN SETTING.
3. AIRSPACE/AIR TRAFFIC: THE USAF HAS ALREADY ALLOWED TOO MANY OVERFLIGHTS IN W EED CAUSING A
DISRUPTION TO WILDLIFE AND PEACE AND QUIET. IN ADDITION, OVERFLIGHTS POSE THE DANGER OF A CRASH
ON THE CIVILIAN POPULATION AND POSSIBLE WILD FIRES. THE DRAFT EIS SHOULD FULLY DESCRIBE THE
TOTAL NUMBER OF OVER FLIGHTS, HOW THEY WILL BE DISTRIBUTED (OVER A WEEK AND OVER A 24 HOUR
PERIOD), TYPE OF AIRCRAFT, TIMES OF DAY AND NIGHT, FLIGHT PATTERNS, NOISE POLLUTION, AND IMPACTS
ON WILDLIFE AND HOW CRASHES WILL BE HANDLED AND WHO WILL PAY DAMAGES.
4. BIOLOGICAL RESOURCES: W EED, NM IS HOME TO A NUMBER OF THREATENED AND ENDANGERED SPECIES,
SPECIES OF SPECIAL CONCERNS AND SENSITIVE SPECIES PLUS NATIVE VEGETATION. W HAT IMPACT WILL THE
PROPOSED EXPANSION HAVE ON THE PLANTS AND ANIMALS AS WELL AS THE NATURAL SYSTEMS THAT
SUPPORT THEM? W HAT IMPACTS WILL THE ALTERNATIVES HAVE ON THE CHANGE IN WATER SYSTEMS, SOIL
STABILIZATION AND WILDLIFE CORRIDORS? INCLUDE NOISE, FUEL DUMPING, FLARES, CHAFF AND SONIC
BOOMS AND FOCUSED SONIC BOOMS IN THIS ANALYSIS.
5. Cultural Resources: There are significant cultural resources contained in all of the proposed areas
that must be inventoried and protected with consultation with educational institutions, researchers
and relevant American Indian tribes. Sonic booms, especially "focused" booms may damage
sensitive structures. An inventory of these structures must be taken and the likelihood damage
accessed. The draft EIS should also discuss all future potential activities that may disturb cultural
resources and what studies will be conducted to determine these impacts before operations are
6. Environmental Justice: Weed, NM is a rural, low-income community with limited services and a
significant number of retired and disabled persons who cannot afford to move. What would be the
potential adverse economic impacts on Weed residents and the community as a whole? What have
been the environmental and economic impacts on other communities like Weed which are subjected
to the pollution and noise but are many miles from the benefiting airbase? Once again the USAF has
in the past used generalities to gloss over the impact on the local economy. Rural Weed is not a city.
It is unique. It is far from Holloman with little benefit from Holloman's operations. The analysis should
be specific to the area affected; Weed, NM in the Sacramento Mountains. In addition, Chaff, flares
and lasers will be used over the Weed area. Where will the debris land? An analysis of the likely
impact from chaff (based on altitude and winds) must be made and maps constructed for citizens
impacted. Will some areas be saturated with debris due to local wind / topography? Same for flares.
Laser hazards must be addressed and made available to stakeholders.
7. Hazardous Materials/Hazardous Wastes: The draft EIS should include a comprehensive
study of the impacts of any hazardous materials or hazardous wastes on the public health and
environment in all of the alternatives. This should include a “ cradle to grave” analysis and an
epidemiological study of the current population to establish a base line for future studies. The
draft should explore all avenues of hazardous materials migration from points of origin. What
has been the USAF’ s track record regarding compliance with clean-up standards for hazardous
materials and waste since the beginning of operations at Holloman? Specific concerns include
but not limited to; chaff (including the new chemically enhanced version and the lead version),
flares, fuel, depleted uranium munitions, laser hazards and other materials consumed / dumped
over Weed by the USAF F-35 operations should be accounted for in detail. quality issues include
questions about the potential for chaff to break down into respirable particle sizes and the
possibility that hazardous air pollutants may be generated from pyrotechnic impulse cartridges
used with some chaff models. Can chaff break down over time into respirable particles? Will
chaff be concentrated? Again the USAF often simplifies / generalizes chaff dispersion by using
averages rather that a detailed analysis of local conditions. This chaff will be falling on private
property, including my house.
8. LAND USE: MANY RURAL RESIDENTS USE SOLAR (PHOTOVOLTAICS) PANELS FOR POWER. W HAT WILL
BE THE IMPACT OF F-35 OPERATIONS ON SOLAR POWER? CONTRAILS AND CHAFF ARE OBVIOUS
CONCERNS. IF JUST A FEW PERCENT OBSCURATION OF SUN LIGHT OCCURS FROM USAF OPERATIONS
IT WILL ADVERSELY AFFECT MANY RURAL W EED RESIDENTS. IT WILL ALSO AFFECT FUTURE SOLAR
POWER DEVELOPMENT IN THE W EED, NM AREA. CHAFF, FOR EXAMPLE, MAY HAVE SUCH AN ADVERSE
AFFECT AS IT IS DESIGNED TO STAY IN THE AIR FOR RELATIVITY LONG PERIODS WHILE REFLECTING
ENERGY. AN ANALYSIS OF POSSIBLE LOSSES FROM F-35 OPERATIONS IS NECESSARY. THE IMPACTS OF
ALL OF THE PROPOSED ALTERNATIVES MUST BE ANALYZED WITHIN A COMPREHENSIVE LOOK AT ALL
OTHER PROPOSED DEVELOPMENTS IN THE AREA INCLUDING ENERGY PROJECTS, OTHER RESOURCE
EXTRACTION AND GROUND AND SURFACE WATER USE.
9. NOISE: TO DATE, THE USAF HAS FAILED TO ADEQUATELY RESPOND TO THE COMMUNITY’ S COMPLAINTS
ABOUT OVER FLIGHTS OF MILITARY AIRCRAFT. THIS NOISE HAS A GREAT NEGATIVE IMPACT ON OUR PEACE,
QUIET AND QUALITY OF LIFE. THE DRAFT EIS MUST DISCUSS ALL POTENTIAL FOR NOISE ASSOCIATED WITH
THE PROPOSED ALTERNATIVES AND ITS ON PUBLIC HEALTH, QUALITY OF LIFE AND WILDLIFE AND "TAKING" OF
10. PUBLIC HEALTH AND SAFETY: BESIDES CONCERNS ABOUT PUBLIC SAFETY AS REGARDS TO HAZARDOUS
MATERIALS AND WASTES, THE DRAFT EIS MUST ANALYZE ALL POTENTIAL IMPACTS INCLUDING POTENTIAL
ACCIDENTS. W HAT IMPACT WILL THE ADDITION OF AIRCRAFT, PERSONNEL AND ARMAMENTS HAVE ON THE
PUBLIC SAFETY? (SEE MAY 15, 2007, 18,000 ACRE NEW JERSEY PINELANDS FIRE CAUSED BY USAF
OPERATIONS). W HAT USAF SAFE GUARDS WILL BE IN PLACE? W HAT USAF RESOURCES WILL BE AVAILABLE
FOR FIRE SUPPRESSION? HOW QUICKLY WILL USAF RESOURCES BE MADE AVAILABLE IN THE SACRAMENTO
MOUNTAINS? W HAT AVAILABILITY (TIME AND RESOURCES) SHOULD THERE BE? W HAT MITIGATION WILL THE
USAF OFFER? CHAFF CAN DEGRADE INTO SMALL PARTICLE THAT MAY CAUSE LUNG DAMAGE. THE USAF
MUST STUDY CHAFF DETERIORATION OVER TIME AND ADDRESS THE IMPACT ON ANIMAL AND HUMAN HEALTH.
TONS OF CHAFF MAY BE DUMPED OVER PRIVATE LAND IN THE W EED AREA. STUDIES TO DATE HAVE NOT
ADDRESSED CHAFF'S LONG TERM HEALTH ISSUES.
11. RECREATION: I AM VERY CONCERNED THAT NOISE, INCLUDING BUT NOT LIMITED TO SONIC BOOMS WILL
REDUCE ENJOYMENT OF THE MOUNTAINS AND REDUCE HUNTING AND TOURISM. W HAT WILL THE USAF DO
TO MONITOR AND INSURE THIS DOES NOT HAPPEN? THE DRAFT EIS SHOULD ALSO DISCUSS THE IMPACT TO
RECREATION AND WHAT IT WILL DO TO MITIGATE THE COMMUNITY LOSSES. AGAIN, THE USAF HAS IN THE
PAST USED GENERALITIES TO GLOSS OVER THE IMPACT ON THE LOCAL ECONOMY. AN ANALYSIS IS NEEDED
FOR W EED'S SPECIFIC LOCATION IN THE SACRAMENTO MOUNTAINS.
12. SOCIOECONOMICS: LOCAL REAL ESTATE AGENTS HAVE DISCUSSED A POTENTIAL FOR THE USAF
OPERATIONS EXPANSION OVER W EED TO HAVE AN ADVERSE IMPACT ON PROPERTY VALUES. HOW WILL
THE OVERFLIGHTS EXPANSION AFFECT MY PROPERTY VALUES AND THE REAL ESTATE MARKET IN
WEED? W HAT SOCIOECONOMIC IMPACTS HAVE OTHER BASE EXPANSIONS HAD ON OTHER
SURROUNDING COMMUNITIES? I AM VERY CONCERNED ABOUT HOW THE F-35 EXPANSION WILL AFFECT
MY PROPERTY VALUES. I HAVE NOTICED THAT USAF OFTEN USES GENERALIZATIONS ABOUT NOISE
NOT AFFECTING PROPERTY VALUES. THE USAF MUST STUDY, SPECIFICALLY, PROPERTY IN QUIET,
PEACEFUL MOUNTAINS THAT HAS BEEN TURNED INTO A HIGH NOISE TRAINING AREA (THE F-35A WILL
BE THREE TIMES NOISIER THAN AN F-16). THEN ANALYZE THE CHANGE IN PROPERTY VALUES IN
CONSTANT DOLLARS. DISCUSSING CHANGES IN PROPERTY VALUES IN AN URBAN OR NON
MOUNTAINOUS AREA IS NOT A CORRECT ANALYSIS AND DISINGENUOUS, W EED, NM IS UNIQUE.
BUSINESS MAY BE NEGATIVELY AFFECTED BY DUMPING OF CHAFF OVER W EED, NM. IS MADE OF
ALUMINUM-COATED THIN FIBERS AND IS RELEASED BY THE MILITARY TO CREATE WIDESPREAD RADIO
WAVE ECHOES AND, THUS, CONFUSE RECEIVERS. TO MAXIMIZE BACKSCATTERING CROSS SECTION,
CHAFF LENGTH IS CHOSEN TO EQUAL ONE-HALF RADAR WAVELENGTH. W HILE NOT DESIGNED TO
DESTROY OR INTERFERE WITH RURAL SATELLITE SERVICE IT HAS THE POTENTIAL TO REDUCE OR
INTERFERE WITH SATELLITE NETWORK SPEEDS, INTERFERE WITH SATELLITE TELEPHONE AND
TELEVISION USE FOR RURAL BUSINESS / CITIZENS. MANY RURAL RESIDENTS MUST USE SATELLITE
COMMUNICATIONS (ESPECIALLY NETWORK CONNECTIONS) AS THERE IS NO OTHER INFRASTRUCTURE.
INTERFERING WITH THESE COMMUNICATIONS WILL CAUSE RESIDENTS CONSIDERABLE LOSS. AN
ANALYSIS OF SIGNAL DEGRADATION FOR THE VARIOUS FREQUENCY SATELLITE UP LINKS / DOWN LINKS,
INCLUDING AN ESTIMATE OF SPEED REDUCTION / SIGNAL DEGRADATION MUST BE FURNISHED. THE
USAF MUST DISCUSS MITIGATION OF LOSS TO BUSINESSES AND PRIVATE RESIDENTS.
ANOTHER UNIQUE FEATURE OF RURAL OTERO COUNTY IS IT'S CLEAR SKIES. NUMEROUS
OBSERVATORIES MAKE THE W EED, NM AREA HOME. INDEED ASTRONOMY AND OBSERVATORIES ARE
ONE OF W EED'S GROWTH INDUSTRIES. BOTH CHAFF AND FLARE USE WILL HARM THIS INDUSTRY.
CHAFF IS DESIGNED TO REMAIN AIRBORNE FOR LONG PERIODS INTERFERING WITH THE CLEAR
UNOBSTRUCTED VIEW THAT IS BEST FOR OBSERVATIONS. FLARES BLOT OUT AN ENTIRE SPECTRUM
FOR OBSERVATION. OBSERVATORIES HERE ARE ACTIVE DAY AND NIGHT. IN ADDITION, TELESCOPES
ARE SENSITIVE TO VIBRATION. ANY ANALYSIS BY THE USAF MUST TAKE INTO ACCOUNT VIBRATION
CAUSED DEGRADATION OF OBSERVATORY OPERATIONS (FROM FLIGHT OPERATIONS AS WELL AS SONIC
AND FOCUSED SONIC ) INCLUDING PHYSICAL DAMAGE TO PRESENT OBSERVATORIES. ECONOMIC
ANALYSIS MUST INCLUDE THE LOSS TO THE COMMUNITY FROM FUTURE OBSERVATORY BASING IN
OTERO COUNTY FROM LOSS IN ENVIRONMENTAL QUALITY FROM USAF OPERATIONS.
13. Utilities and Infrastructure (including alternative energy production): How will the proposed
alternatives impact existing utilities and infrastructure, and what new utilities will be constructed?
What impact will the proposal have on air quality and water usage? Will this impact the view shed and
wildlife habitat and wildlife corridors (include bird migrations)?
14. WATER RESOURCES: I AM EXTREMELY CONCERNED ABOUT THE IMPACT OF THE PROPOSED ALTERNATIVES
ON OUR WATER QUALITY AND AVAILABILITY. EXACTLY WHERE WILL THE USAF OBTAIN THE WATER IT PLANS
TO USE FOR EXPANSION, HOW MUCH WATER WILL BE USED AND WHAT IMPACT WILL THAT USAGE HAVE ON
OUR AQUIFERS AND ACCESS TO WATER? W HAT IMPACT WILL FLARES AND CHAFF HAVE ON WATER
RESOURCES? W HAT DAMAGE WILL OCCUR TO ANIMALS? W HAT IMPACT TO THE FOREST? ALL ESTIMATES
MUST CONSIDER DROUGHT AND OTHER POTENTIAL WATER SHORTAGES.
15. SONIC BOOMS AND NOISE: PAST EIS HAVE USED MANY MISLEADING NUMBERS. "AVERAGE" NOISE
AND "AVERAGE" SONIC BOOM PRESSURES, "AVERAGE" NUMBER OF BOOMS PER MONTH, DO NOT
ACCURATELY REPRESENT THE IMPACT TO RESIDENTS UNDER THE TRAINING AREA. IT IS DISINGENUOUS
OF THE USAF TO USE THESE KIND OF NUMBERS AS A SOLE MEASURE OF NOISE ON CITIZENS (AS AN
EXAMPLE: I HAVE EXPERIENCE ELEVEN (11) SEVERE SONIC BOOMS IN A FORTY-SEVEN (47) MINUTE
PERIOD YET THE USAF F-22 EIS INDICATED AN AVERAGE OF FEWER THAN ONE A DAY). IT IS
DISINGENUOUS TO COMPARE NOISE LEVEL CHANGES IN THE CONTEXT OF AN URBAN ENVIRONMENT WHEN
WEED, NM IS RURAL WITH NO NOISE EXCEPT USAF OPERATIONS. ANALYSIS SHOULD INCLUDE THE
MAXIMUM NOISE LEVELS, ACCOUNT FOR FOCUSED SONIC BOOMS WHILE USING RURAL NOISE LEVELS
AS A BASIS. IT MUST INCLUDE HOW THE USAF WILL MITIGATE.
16. Damages: The USAF has (and continues) to claim responsiveness to damage claims. Weed, NM is
a rural, low-income community with limited services and a significant number of retired and disabled
persons who cannot afford to go to Federal Court for claims settlement. Has the USAF at Holloman
acted in good faith? What percent of claims submitted are "allowed" from Holloman AFB? How does
this compare to the other USAF bases? What assurances do the rural poor in our area have that the
USAF will not (and has not) acted knowing we have little recourse?
As this process moves forward, it is important that the USAF make itself accessible to Weed, NM residents,
distribute materials as required and come out to meet with the community so that we can develop a constructive
I expect to be notified at every step in the National Environmental Policy Act (NEPA) process and that my
comments will be fully addressed in the draft Environmental Impact Statement (EIS). I would like my
comments/communication incorporated into the administrative record. Please find my contact information below.
In conclusion, I recommend that the USAF extend the scoping period for 90 days; meet with all affected
communities including Weed, NM; and produce and distribute accurate maps of the proposed alternatives.
PO Box 425
Weed, NM 88354