Contamination of Land, Air, and Water

Military fighter training over the Gila Region will generate significant amounts of pollutant emissions and contaminant releases to the environment, potentially causing air quality, visibility, land and water quality problems.

Military jets emit criteria air pollutants which are regulated by the US Environmental Protection Agency. The Gila Region is currently in attainment of all National Ambient Air Quality Standards. Holloman Air Force Base estimated the increase in criteria air pollutant emissions for bringing two squadrons of F-16s to Holloman from Hill Air Force Base. The total emissions estimated from this action are 39.28 metric tons of volatile organic compounds (VOC); 101.55 metric tons of nitrogen oxides (NOx) (VOC and NOx combine to form ozone); 87.46 metric tons of carbon monoxide (CO); 14.16 metric tons of particulate matter of 2.5 microns or less in diameter (PM2.5); 15.74 metric tons of particulate matter 10 microns or less in diameter (PM10); 7.59 metric tons of sulfur dioxide (SO2); and 21,123 metric tons of carbon dioxide (CO2), a greenhouse gas that causes climate change.

What is the proportion of these emissions estimated to be released over the Gila Region under Alternative #2? The associated impacts on ambient air quality concentrations and visibility impairment in Class I wilderness areas must be assessed. Included in this evaluation should be disclosure of the use of mid-air refueling, fuel dumping, and assessment of the air quality impacts of these practices.

According to initial Environmental Impact Statement documentation, Holloman estimates annual deployment of 15,360 chaff units over the Gila region under Alternative #2. These bundles of aluminum-coated fiberglass fibers would introduce metals and fiberglass into pristine wilderness areas and the Gila National Forest. Wildlife can ingest these materials by mistaking these small particles for food. The chaff material can also enter waterways and pose a water quality concern. It is possible that 77 trillion pieces of chaff per year (5 million pieces/chaff unit x 15,360 chaff units/year = 7.68 x 1010 pieces/year) would be released to the Gila region under Alternative #2. The EIS should estimate the concentration of chaff fibers in the Gila National Forest and Gila and Aldo Leopold Wilderness Areas and evaluate the environmental risk of deposition of this material to our environment and waterways.


More information


Technical Memorandum regarding potential air quality impacts from implementing the interim relocation of two F-16 FTUs to either Holloman AFB, NM or JBSA-Lackland (Kelly Field, TX), available at


“Environmental Effects of Radio Frequency (RF) Chaff Released during Military Training Exercises: A Review of the Literature” –