Concerns raised regarding military airspace adjustments, public comment period extended

Some opponents of the proposed expansion of Camp Grayling’s training areas – the National Guard is asking the Michigan Department of Natural Resources for more than 160,000 acres of additional state land to lease – are also concerned about possible adjustments in area military airspace use.

In mid-November, military officials said they would be collecting public comment regarding the “Michigan Air National Guard’s proposal to reconfigure charted airspace available for military aircrews to meet current training requirements,” and the comment period would be open from November 15 through December 14.

“The proposal is a culmination of years-long coordination with the Federal Aviation Administration, the National Guard Bureau, and local communities to modify existing military operating areas at low and medium altitudes and create some new (Military Operation Areas) on a limited basis within the Alpena Special Use Airspace,” according to Michigan National Guard officials.

“The Alpena (Special Use Airspace) complex was originally charted during the Korean and Vietnam War eras. Though commonly referred to as the largest overland training airspace east of the Mississippi, it lacks the altitude and complexity U.S. aircrews need to maintain and develop proficiency with 21st century tactics. The Michigan Air National Guard opened one public comment period for the airspace in 2019, which solicited public feedback on the proposal from Michigan communities, local authorities, and private citizens,” according to the National Guard.

Part of the proposal involves Crawford County airspace.

“Changes from the 2019 proposal include: implementing a one-mile buffer around the ‘thumb’ region’s Lake Huron shoreline that will prohibit military aircraft from flying lower than 1,500 ft. during peak vacation and tourism seasons; excluding access by F-35 fighters to the Steelhead Low MOAs over Michigan’s ‘thumb’ region; raising the minimum altitude for the Steelhead Low South MOA to 4,000 ft. to accommodate civilian and commercial flight air patterns in the ‘thumb’ region; eliminating six miles of military training airspace from the north side of the Grayling West MOA; raising the minimum altitude from 7,000 ft. to 10,000 ft. in the Grayling East MOA to deconflict with north/south civilian flight traffic,” according to a press release from the Department of Military and Veterans Affairs.

During a press conference on Thursday, December 8, opponents of the Camp Grayling training area expansion – people representing conservation organizations, a private citizen group, and one area unit of government – discussed the proposed expansion and the airspace issue.

The Michigan Air National Guard’s airspace public comment information page describes the two issues as “separate.” 

“The (Michigan Air National Guard) Airspace reconfiguration is a process that has been ongoing for years. The MI Air National Guard has followed the federal approval process to request additional airspace capability and we are now in the culminating stages of that process. The Camp Grayling land access request is a completely separate initiative with an approval process through state agencies that is presently in its very early stages. The two are not linked except for the fact that they both come down to readiness and meeting modern and future military training requirements,” according to the Michigan Air National Guard.

“The (Michigan Air National Guard) airspace reconfiguration is a separate process from the Camp Grayling land access request ongoing with the Michigan Department of Natural Resources. The Federal Aviation Administration is the deciding agency for airspace,” according to the Department of Military and Veterans Affairs.

December 8 press conference participants said they were concerned about some of the changes and were not satisfied with the available comment period. The document contains more than 100 pages.

“We’ve now learned of a proposed expansion into the airspace. We were surprised about this proposed expansion. Apparently they’ve been working on this plan for the last three years and yet they announce it at the start of deer season, which in northern Michigan is a national holiday. They had a 30-day period for public comment – that’s it. They get three years, we get 30 days,” said Joe Hemming, President of the Anglers of the AuSable.

On Tuesday, December 13, the Department of Military and Veterans Affairs announced a one-month extension of the public comment period.

“A public comment period – originally opened November 15 for 30 days – for the Michigan Air National Guard’s proposal to reconfigure charted airspace available for military aircrew training, has been extended until January 14,” according to a December 13 press release from the Michigan Department of Military and Veterans Affairs.

“Extending the public comment period for this proposal will give us time for more listening and discussion with community groups, citizens, and stakeholders upon request,” said Brig. Gen. Bryan Teff, Assistant Adjutant General and Commander of the Michigan Air National Guard. “Public comment has always been an extremely important part of the process to formalize this proposal, and it will remain so.”

Hemming said the plan does not take into account use of affected areas by recreational users such as hikers, hunters, snowmobilers, and anglers.

“They indicate that with this plan it’s more flights, more noise,” Hemming said. “This proposed expansion of airspace in and of itself – let alone the (Camp Grayling) land expansion – is going to dramatically affect the outdoor tourism, the outdoor economy, the property values of that area.”

Anglers of the Au Sable officials have also raised concerns that flares/chaff from aircraft could offer more pollution (including PFAS) and the new plan may allow “flying within 500 feet of ground level (instead of the current 5,000 feet)” in the area.

“Minimum airspace requirements for the F-16 to conduct Defensive Counter Air missions are laterally 50 nautical miles by 100 nautical miles at altitudes from 500 feet above ground level to Flight Level 500. Fifth generation fighters that use the Alpena Complex have similar airspace volume requirements,” according to Page 7 of the “Draft Environmental Assessment for Modification and Addition of Airspace at the Alpena Special Use Airspace Complex.”

“The National Guard Bureau’s Environmental Analysis for the airspace proposal can be viewed in its entirety at the following link: https://www.alpenacrtc.ang.af.mil/. To offer public comment, please contact: National Guard Bureau; Attn: Ms. Kristi Kucharek; 3501 Fetchet Ave, Joint Base Andrews, MD 20762-5157, or emailed to NGB.A4.A4A.NEPA.COMMENTS.Org@us.af.mil with subject ATTN: ALPENA SUA EA. For more information or questions, please contact the Michigan National Guard public affairs office: ng.mi.miarng.list.pao@mail.mil,” according to the Michigan Department of Military and Veterans Affairs.