Public comment period ends for National Guard airspace adjustments

The public comment period recently ended for “Michigan Air National Guard airspace reconfiguration” and “the feedback received from community members, stakeholders, and agencies is now under review by the (National Guard Bureau),” according to the Michigan Department of Military and Veterans Affairs.

“The public comment period for the Draft Environmental Assessment for the Modification and Addition of Airspace at the Alpena Special Use Airspace Complex, prepared by the Michigan Air National Guard and the National Guard Bureau, has closed, effective January 14. The Draft (Environmental Assessment) was prepared to consider the potential impacts to the human and natural environment associated with the modification and utilization of the Alpena (Special Use Airspace) Complex,” according to a January 19 press release from the Michigan Department of Military and Veterans Affairs.

“Following analysis, a Final (Environmental Assessment) will be prepared that considers any additional information and answers substantive questions raised during the public comment period. The (Environmental Assessment) is prepared by a third-party contractor in coordination with the (National Guard Bureau). The estimated timeline for completion of the Final (Environmental Assessment) is late summer 2023. If approved by the Federal Aviation Administration, the airspace would be officially charted in late 2023,” according to the Michigan Department of Military and Veterans Affairs.

In mid-November of 2022, the Michigan Department of Military and Veterans Affairs announced that “a public comment period will re-open November 15 for the Michigan Air National Guard’s proposal to reconfigure charted airspace available for military aircrews to meet current training requirements. 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 operating areas) on a limited basis within the Alpena Special Use Airspace. 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 Michigan Department of Military and Veterans Affairs, Changes from the 2019 proposal include “eliminating six miles of military training airspace from the north side of the Grayling West (military operating area)” and “raising the minimum altitude from 7,000 ft. to 10,000 ft. in the Grayling East (military operating area) to deconflict with north/south civilian flight traffic.”

Initially, the public comment period was slated to end December 15. In December, the Michigan Department of Military and Veterans Affairs announced that the deadline had been extended 30 days.

“The public comment period for the Draft (Environmental Assessment) originally opened on November 14. In accordance with 40 CFR 1501.6(a) and 32 CFR 989.15(e)(2)(v), the public is offered an opportunity to review and provide input on a proposed action during the public comment period. These regulations state that public, state, tribal, and local governments, and relevant agencies should be involved in the preparation of an (Environmental Assessment) to the extent practicable with a standard public comment period of 30 days. The period was extended by the (Michigan Air National Guard) for an additional 30 days until January 14 to allow stakeholders more time to offer feedback,” according to the Michigan Department of Military and Veterans Affairs.

“We appreciate each and every comment received over the past 60 days,” said Brig. Gen. Bryan Teff, commander of the (Michigan Air National Guard). “Public commenting is an important part of this process, as mandated by the National Environmental Protection Act. Substantive input allows the (National Guard Bureau) to make better and more informed decisions and helps further the Final (Environmental Assessment) for this action.”

The Draft Environmental Assessment for Modification and Addition of Airspace at the Alpena Special Use Airspace Complex – a document with more than 100 pages – was available online for people to view during the public comment period.

Some citizens, local governments, and conservation groups publicly opposed parts of the airspace plan, citing possible increases in flights, noise, and pollution based on information provided in the Draft Environmental Assessment.

“The (Lovells Township) primary business district is located just 3.25 statute miles east south east of the eastern fence line of Camp Grayling’s existing Range 40 complex, Range 40 being the location where all air delivered ordnance is directed. The proposal would, if approved as presented, permit the operation of military aircraft at altitudes as low as 300 feet above ground level in the vicinity of the (Lovells Township) primary business district, a dramatic reduction in allowed minimum when compared to current restrictions, and given that the visitors to, residents of, and businesses located in the vicinity of (Lovells Township)’s primary business district currently do and historically have been forced to tolerate the noise and jet fuel fumes of low flying military aircraft under the current flight restrictions, and given the significant deficiencies of the proposal as presented the (Lovells Township) Board must adamantly and resolutely oppose the lessening of any altitude restrictions for military aircraft operating within the (Lovells Township) area,” according to Lovells Township Resolution #12-13-2022.

Beaver Creek Resolution No. 5 – 2022 says “the unnatural noise level of training is tolerated currently” but “any expansion of the ground and air usage will create a much larger distraction from the serenity of Pure Michigan driving away citizens and visitors that love our community and the peaceful enjoyment of nature,” and the Beaver Creek Board of Trustees opposes “any proposed expansion of Camp Grayling and any proposed expansion of military air space in Crawford County and the surrounding counties.”

According to Anglers of the Au Sable, “The proposal will result in a dramatic increase in noise. The tables contained in the proposal show up to a tenfold increase in flights. The (Environmental Assessment) justifies this increase in noise by use of a flawed statistical method of averaging the peak noise to achieve what appears to be a slight increase average noise. The proposal will result in an increase of various pollutants. This increase will be a rain of pollution on the headwaters of one of the most famous and most-loved trout streams in the United States, as well on the lands and waters of permanent residents, seasonal residents, and participants in outdoor activities for which the area is justly famous and desired. The (Environmental Assessment) contains no discussion of the magnitude or effect on land and water of this increased pollution. The (Environmental Assessment) relies on generic studies that do not relate to eastern northern Michigan. The deployment of chaff by military aircraft is one of several countermeasures used to evade radar detection. The (Environmental Assessment) indicates that a total of 6,103 chaff cartridges will be used for training purposes, which is approximately a 20 percent increase over previous expenditures. The flight floors stated for the proposed new Grayling West (500 feet) and VRs 1601/1602 (300 feet) are extremely low. It is inconceivable that aircraft flying at these levels would not interfere with quiet enjoyment and the pursuit of fishing and any other recreational activities on the state land and waters located beneath these areas.”

Brig. Gen. Teff said he does “not expect a significant increase in the number of flights.”

“We’d like to reiterate that this airspace proposal is designed to improve pilot safety and the overall capability of our existing airspace complex, not the actual number of flights,” said Brig. Gen. Teff. “The projected sound impacts were modeled in the Draft (Environmental Assessment) using worse-case scenario figures, in some cases several times greater than the existing number of flights. We do not expect a significant increase in the number of flights, regardless of whether the Proposed Action is approved.”

“The (Federal Aviation Administration) is the deciding agency for airspace,” according to the Michigan Department of Military and Veterans Affairs.