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What are Military Operation Areas (MOAs)?
MOAs are a type of “Special Use Airspace” (SUA) designated for military training and maneuvers. The designation provides for a “segregation of uses of airspace” to alert other aircraft that military activity may be occurring, although as with Military Training Routes below, MOAs are open to other aircraft when they are not being used for military training. MOAs are assigned to one military base for use and scheduling but may also be used by many units from different bases, when requested and available.
What are Military Training Routes (MTRs)?
A MTR is an aerial corridor in a region of the United States in which military aircraft can operate below 10,000 feet and faster than the Federal Aviation Administration (FAA) regulation of a maximum safe speed of 250 knots per hour. Military aircraft are supposed to be limited to 420 knots but may not exceed Mach 1 (the speed of sound). MTRs may be classified as instrument routes (IR), visual routes (VR), or slow routes (SR). These routes may also be flown by private and commercial aircraft. The routes are operated through a local military air base, which “owns” and schedules the route. However, any military base may request use of the route.
How do MOAs and MTRs affect the Gila National Forest?
The Gila National Forest is bisected by several military training routes, most notably, route VR-176 and slow route SR 211/210. Because a MTR allows for 5-15 miles on either side, the flight corridor may be 30 miles wide over the Gila and Aldo Leopold Wilderness Areas which lie below these routes. Several towns on the perimeter and within the forest are also within VR-176. In some sections of a low level VR, aircraft may be authorized to fly as low as 100 feet above ground level. Portions of the Gila National Forest and surrounding communities also border on, or are included within, the Smitty/Cato, Reserve, and Morenci MOAs. There is also one recently approved Army Local Flying Area (LFA) for Fort Bliss which extends into the Gila region.
What are the rules for Military Flights over Wilderness areas?
Within any MOA or MTR, the military does not have to adhere to FAA regulations; when a military aircraft is outside of these areas, it is required to follow FAA regulations. FAA regulations mention wilderness areas specifically, but only by requesting that pilots maintain an altitude of 2,000 feet. Some protected areas do have specific federal statutes that protect their airspace; the Gila and Aldo Leopold Wilderness Areas do not.
How would the Air Force’s proposal for Holloman AFB F-16 training affect the area?
One of the alternatives in the Air Force’s proposal for Holloman AFB involves expanding the existing Smitty/Cato MOA to the east and the creation of a new MOA called Lobos directly above the Gila Wilderness and notionally to the west of the Silver City area. (Note: in the proposal, Lobos is not clearly defined; so its location and extent is not yet known.) Read about the proposal here.
How do I know if a plane or overflight should be reported?
The public has limited information on the specific maneuvers, training exercises, and altitude allowances within MOAs or MTRs in the Gila region. That does not mean that the public should not comment or report concerns regarding military aircraft that cause disruptive noise or other types of disturbance. The majority of the Gila National Forest and surrounding area is NOT within any MOA; therefore, it’s important to report all apparent violations. Military aircraft that appear to be low flying over areas within or near the Gila National Forest or wilderness areas should be reported. Aircraft that buzz river corridors, camping areas, archaeological sites, farms, or ranches, should be cause for concern. Any unusual maneuvers or activity or the appearance of smoke of any kind should be reported. In addition, any aircraft that fly over your neighborhood or property that cause animals or wildlife to be unduly frightened by sound or vibration are aircraft that are causing a disturbance and should be reported.
There are at least five military bases that utilize Military Operation Areas (MOAs) and/or Military Training Routes (MTRs) in the Gila region. Each of the bases has multiple units with military aircraft assigned there. Below is a general description of the activity and aircraft originating from each base. While Holloman is the base for which the proposed Lobos MOA may be created, any regional base may potentially utilize the airspace. You can learn more about current military flight activity in the Gila Region below.
Holloman Air Force Base, Alamogordo, NM. (49th Wing)
The 54th Fighter Group out of Holloman AFB includes three fighter squadrons. This group operates the F-16 Fighting Falcon aircraft and conducts initial upgrade training in the F-16 for pilots who complete undergraduate pilot training prior to reporting to Holloman AFB. Training plans include conducting up to 10,000 annual F-16 sorties to train about 300 pilots per year.
Arizona Air National Guard, Tucson, AZ.
Tucson International Airport hosts the Tucson Air National Guard Base (ANGB) and the 162nd Fighter Wing, the largest ANG fighter unit in the US. The 162nd Fighter Wing hosts and performs training for ANG and F-16 foreign military sales nations. Eighty F-16 Fighting Falcons are assigned to Tucshon ANGB, including eight F-16s belonging to the Iraqi Air Force and F-16s from the Dutch Air Force. The 162nd also flies four F-16s out of Davis Monthan Air Force Base in Tucson for air defense of the southern border. Tucson ANGB F-16s regularly fly in MOAs that border the Gila National Forest.
Davis Monthan-Air Force Base, Tucson, AZ.
With both resident and tenant units assigned, Davis-Monthan may be the origin of several military aircraft that can be seen over the Gila. Both the EC-130H Compass Call and the HC-130J Combat King fly from Davis-Monthan AFB. In addition, Davis-Monthan is home to over eighty A-10C Thunderbolt II aircraft. Units assigned there also utilize the HH-60G Pave Hawk helicopter. Although Davis Monthan maintains MOAs west of Tucson, they may be using military airspace over the Gila National Forest, as confirmed by multiple A-10C aircraft sightings and photo documentation in the fall of 2017.
Luke Air-Force Base, Phoenix, AZ.
Located west of Phoenix, Luke Air Force Base is home to the 56th Fighter Wing, the Air Force’s F-35 Lightning II training wing. The wing trains pilots in F-35A, the Air Force’s newest multi-role fighter aircraft. Luke flies primarily within MOAs clustered around the Phoenix area and Sonoran Desert.
Kirtland Air Force Base, Albuquerque, NM.
The 377th Air Base Wing is the host organization at Kirtland Air Force Base and supports nuclear readiness, non-conventional weapons development, missile technology, and several special operations units. Much of the aircraft utilizing Kirtland are Huey and Pave Hawk helicopters and the tilt-rotor craft, the Osprey. These helicopters train in MOAs in the northern part of the state. However, there are also four different C-130s that fly from Kirtland and may use Military Training Routes that traverse the Gila region.
Cannon Air Force Base, Clovis, NM.
The 27th Special Operations Wing at Cannon has over a dozen squadrons utilizing multiple types of military aircraft. Their fleet includes surveillance craft, such as the MQ-1 Predators, MQ-Reaper, and U-128; the rescue craft CV-22 Osprey, and large aircraft such as C-130s and a C-146.
Fort Bliss Army Base, El Paso, TX.
Fort Bliss is the largest installation in United States Army Forces Command and second-largest in the Army overall (the largest being White Sands Missile Range). It has an area of about 1,700 square miles (1.12 million acres) and provides the largest contiguous tract of restricted airspace in the continental U.S. (1,500 square miles) used for missile and artillery training and testing. Fort Bliss was just granted access to a Live Training Area that includes the Silver City area.
Grant and Catron Counties were unaware of the Air Force’s proposal to expand its airspace over the Gila. Because the Air Force did not hold a public meeting in Silver City, the local communities that would be impacted by this proposal were left out of the formal NEPA scoping process.
Once citizens found out about the proposal, the response was swift and loud in opposition to the Air Force’s plans for Holloman AFB. Thanks to the public outcry and the efforts of local elected officials and conservation groups, the Air Force agreed to attend a public meeting hosted by the Grant County Commission on November 14, 2017.
More than 2,300 petition signatures and public comments in opposition to the Air Force’s proposal were submitted to the Air Force after the public meeting. In addition, more than 150 Grant County business owners signed letters opposing the Air Force’s proposal.
More than 20 conservation groups signed on to scoping comments that identify the range of issues the Air Force should address in its draft Environmental Impact Statement.
The Grant County Commission unanimously passed a resolution requesting the Air Force consider several important points and opposing the Air Force proposal, and the Town of Silver City sent a letter to the Air Force in strong opposition to Holloman’s proposal.
State elected officials also voiced their opposition to the proposal. Howie Morales, then a State Senator, published an op-ed opposing the F-16 military training. In August 2018, Senator Martin Heinrich also wrote an op-ed stating that the Gila Wilderness is an inappropriate place for F-16s.
“Making Noise Over New F-16 Flights” Guest Column by Senator Howie Morales, Albuquerque Journal 11/8/17
“Crowd packs meeting on proposed increase in F-16 flights” Albuquerque Journal 11/14/17
Frequent low-altitude flights can disrupt the feeding and breeding habits of wildlife and livestock. Many of the health impacts to humans, including stress, will be felt by animals, too. Some of the most significant impacts from noise on wildlife are caused by chronic exposure. The timing of proposed flight training over the course of a year could affect game species and, therefore, hunting and fishing in the Gila, which has some of the state’s best elk herds and most sought-after hunting permits.
Noise Effects on Wildlife – Literature Review – https://www.nonoise.org/library/fctsheet/wildlife.htm
Effects of Overflights on Wildlife – https://www.nonoise.org/library/npreport/chapter5.htm
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.
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 https://www.holloman.af.mil/Portals/101/Environmental%20documents/Technical%20Memorandum%20Air%20Quality%202017-2a.pdf?ver=2017-07-25-151214-440
“Environmental Effects of Radio Frequency (RF) Chaff Released during Military Training Exercises: A Review of the Literature” – https://www.mae.gov.nl.ca/env_assessment/projects/Y2004/1159/environmental_effects_of_radio_frequency_chaff.pdf
As part of defensive countermeasures system training, the F-16s may release 15,360 flares a year. There is an increased risk of wildfire from this practice. Three catastrophic wildfires have occurred over the past six years in the Gila National Forest and Gila and Aldo Leopold Wilderness Areas, burning nearly 500,000 acres, including the Whitewater-Baldy Complex Fire that still stands as the largest wildfire in New Mexico. The Gila Region cannot afford to risk another fire like those which have been experienced in recent years.
There have been documented instances of wildfire caused by flare use, including a wildfire in New Jersey that burned more than 12,000 acres. In Southeastern Oregon, fire officials believe that flares caused a series of six wildfires on federal public lands on July 11, 2017.
New York Times, “Thousands Flee New Jersey Wildfire Ignited by Flare from F-16”, May 16, 2007, available at https://www.nytimes.com/2007/05/16/nyregion/16fire.html
Oregon Public Broadcasting, July 11, 2017, “Feds Examine Military Flares In Mysterious Oregon Wildfires” https://www.opb.org/news/article/feds-examine-military-flares-in-mysterious-oregon-wildfires/
Chaff and flares are released by military aircraft to avoid detection by air defense systems and other aircraft. According to Holloman’s EIS information, up to 15,360 flares and 15,360 chaff bundles may be released in the MOA above 2,000 feet above ground level. Bundles of chaff contain up to five million aluminum-coated fibers that may remain suspended in the air up to ten hours, and eventually land on the ground. The impact of chaff to wildlife and human health, as well as water quality, is disputed. Flares burn for up to four seconds at temperatures above 2,000 degrees Fahrenheit. If released properly, they burn out before landing, but there are documented cases of flares starting fires on the ground, both in forests and towns.
Use of flares can cause wildfires and contribute to air emissions. Deployment of chaff releases contaminants to our air, land and water.
While we understand the economic significance of military base activity in some areas of New Mexico, the Air Force proposal for Holloman AFB would not bring economic gains to the Gila Region. On the contrary, this proposal could harm one of the area’s principal economic assets identified in Grant County’s current economic development plans: quality of life amenities, including the rural nature of small towns and villages in a beautiful landscape, far from the disturbance of big cities, with easy access to wilderness and solitude.
Three recent strategic economic documents specific to Grant County and Silver City highlight the importance of the quality of life and remote location near the Gila Wilderness. Quality of life is the top attraction cited by businesses for being located in Grant County, and the #1 response to the survey query, “What are the three primary reasons you have chosen to live in Grant County?” According to Silver City MainStreet’s Community Assessment, Silver City’s best strategy is to transform its main constraint (geographical remoteness) into its principal asset (proximity to the Gila Wilderness).
A clean, quiet environment is directly linked to the tourism and outdoor recreation economy in the Gila region. The tourism economy in New Mexico is growing and in some places, is breaking records.
Birding is an important component of the tourism economy in the region. More than 350 species of birds are found in the Gila Region. This premier birding region attracts birders from in-state and out-of-state. The Southwest New Mexico Birding Trail and Map guides birders to the best locations throughout the Gila Region, including six Important Bird Areas (IBAs) that could be affected by sorties under Holloman’s proposal.
A 2013 New Mexico Department of Game and Fish Study showed that hunting and angling are significant contributors to Grant County’s economy. That year alone, 10,000 people participated in angling in Grant County for 100,000 angler-days, spending $6.5M, supporting 74 jobs, generating $1.9M in labor income, and contributing $10M to federal, state and local taxes. That same year, nearly 7000 people participated in hunting for nearly 38,000 hunter-days, spending $8.9M, and supporting 112 jobs that generate $2.8 M in labor income and $1.4M in federal, state and local taxes.
Revenues from retirees moving into the area, from entrepreneurs establishing businesses, and from tourists represent significant portions of the local economy. Many of these people are drawn to the Gila Region by its natural beauty and tranquility as well as the outdoor recreational opportunities offered by the nearby mountains, rivers, and forests. Increasing military training in these areas is likely to be significantly harmful to local residents.
Effects of Noise and Airport Activity on Residential Property Values: A Survey Study (1988), University of Illinois
Noise is a result of military fighter jet training. The F-16 can fly as fast as 1,550 miles per hour. At 1,000 feet above the ground, at 500 mph, the plane generates 114 decibels of sound pressure, roughly equivalent to someone shouting in your ear. Minimum cruising speed generates 89 decibels, above the level at which OSHA requires hearing protection.
The sheer volume of studies on the impacts of noise to our physical and psychological wellbeing points to the magnitude of the problem. A May 2017 article in Science, titled “Noise Pollution is Invading Even the Most Protected Natural Areas,” states that, “[n]oise pollution from humans has doubled sound levels in more than half of all protected areas in the United States—from local nature reserves to national parks—and it has made some places ten times louder, according to a new study. And the cacophony isn’t just bad for animals using natural sounds to hunt and forage—it could also be detrimental to human health.”
The increased presence of aircraft and sudden, unexpected noise over the Gila National Forest poses risks to human safety. Loud, low-flying aircraft that appear to “come from out of nowhere” can easily spook horses and mules, who may throw their riders, causing injuries and even fatalities to equestrians, hunters, packers, and outfitters.
“Noise Pollution is Invading Even the Most Protected Natural Areas,” Science, May 2017
Aviation Noise Effects, Federal Aviation Administration, 1985