Major Joseph SundyNational Guard BureauAir National Guard Readiness Center NGB/A4AM3501 Fetchet AvenueJoint Base Andrews, Maryland 20762-5157
Re: Environmental Assessment for Proposed Construction, Renovation and Demolition of Facilities at 115th Fighter Wing, Truax Field, Madison, Dane County, Wisconsin
Dear Major Sundy:
As communities impacted by the project proposed in the April 2019 Draft Environmental Assessment (EA) regarding major demolition, construction and renovation at Truax Air National Guard (ANG), we submit the following comments:
The project includes 27 “infrastructure improvement projects” including demolition of seven facilities, construction of various buildings, indoor small arms ranges, renovations and additions, and repairing and renovation of roads and runways and installation of a fiber optic communication cable along Wright Street.
The proposed construction will result in approximately 25 acres of new construction footprint and up to 1.2 acres of new impervious surfaces. The total cost of demolition, construction and renovation is estimated at between $40 and $60 million dollars.
This is a major military project being proposed, at a time when another major military project, (basing of F-35A fighter jets at Truax), is being proposed and the public is still waiting for release of a full Environmental Impact Statement (EIS) on that project.
It is disturbing to note that the only public notice on this current project, as far as we are aware, was in the bottom corner of page 13 of the third section of the Wisconsin State Journal on April 7, 2019. The only printed copy of the Draft Environmental Assessment available for the public to review, as far as we are aware, was at the Lakeview Library in Madison. (Madison has eight branch libraries and a central library.) In the list of public officials and agencies that received this report, the only city or county official that appears to have received it was County Executive Joe Parisi.
We are fairly certain that the vast majority of Madison and Dane County citizens, including public officials, were not aware of this proposed project until less than two weeks before the public comment deadline. This was when the Midwest Environmental Justice Organization (MEJO), the organization most active on issues relating to the environmental impact of Truax Field, accidentally discovered the EA report.
Perhaps most disturbing of all is that the very first words in the document are: Draft Finding of No Significant Impact (FONSI). In other words, an Air Force official (Marc V. Hewett, Chief, Asset Management Division) had already made a decision that the proposed project would have no significant impact before the public comment period had closed. Federal environmental laws require public review of the EA before a FONSI determination is made but it appears that this notice at the beginning of the EA makes a travesty of the public review and input process.
A major question that must be asked is: Why is this project being proposed at all at this particular time? In Section Five of the Draft EA, the issue of cumulative impacts is discussed, defined as impacts “to environmental resources resulting from incremental effects of proposed actions when combined with other past, present and reasonably foreseeable future projects.” The report goes on to mention the potential siting of F-35A jets at Truax. It lists some proposed actions in the EA that may not occur in the event that the F-35s arrive, and other construction and modifications that might happen instead.
In a letter to you on March 18, Kenneth Westlake, Chief of the NEPA Implementation Section of the EPA, advised you that the EA “should describe cumulative impacts associated with the proposed F-35 beddown project that is being proposed at Truax Field.” It does not appear that the EA makes any attempt to do this.
It should be obvious that everything in this proposed project should be viewed and considered in light of the proposed future basing of F-35s at Truax. The decision to propose these 27 new construction, demolition and renovation activities before a final decision is made regarding the F-35s would seem to greatly bias that decision.
There are many more concerns that are not adequately addressed in the Draft EA. One very troubling project proposed is to “construct an earthen berm southeast of the munitions storage area … to provide protection from aircraft artillery.” It may help the Air National Guard to feel more secure to know they have an earthen berm to shield them from enemy aircraft (or is this their own?) But what about the men, women and children who live adjacent to the base in one of the most densely-populated areas in Madison? And does the Guard anticipate a would-be enemy to attack the base because the F-35s are likely to carry nuclear weapons, making Madison a nuclear target? Is it possible to imagine that anything could have more of a negative impact on the local environment than a nuclear attack?
And even in a best-case scenario, how will an earthen berm protect Madison residents from the steady onslaught of air, noise and water pollution that the ANG has subjected them to for decades?
Speaking of the Madison residents who are neighbors to the base, it is also troubling to read that the Air Force has concluded that “populations, including minority populations and low-income populations outside the boundaries of the installation and airport, will not be significantly impacted.” As MEJO has pointed out, the EA ignores clear statements by the EPA that several of the neighborhoods bordering Truax are indisputable environmental justice communities. The Air Force seems to be claiming that no one residing beyond the confines of the base will suffer any impacts. But this ignores the impacts of air, noise and water pollution caused by the base, which do not respect a fence border and have burdened these neighborhoods for decades.
The demolition and construction proposed in the EA will almost certainly increase the amount of PFAS and other toxins that migrate from the base into the groundwater and storm water system and then into Starkweather Creek and Lake Monona.
The over-arching concern that we have in regards to this EA document is that it is probably an unrealistic task to accurately measure the environmental harm that may be caused by this project given that there is so little known about the damage already done by the ANG, with the help of complacent local regulatory bodies. MEJO released an extensive report on April 22, (Earth Day), detailing all the ways that city, county and state government have been negligent in their responsibilities to regulate, gather data, monitor, engage citizens and generally exercise their authority in regards to stewardship of resources in the Starkweather Creek Watershed. The Wisconsin State Journal has likewise been documenting this shameful abdication of responsibility for at least four months.
The local leader of the Chamber of Commerce was quoted in the State Journal on February 24th of this year as saying that he did not anticipate the PFAS issue would “have any effect on Truax Field securing the F-35A jets.” He described the approach that local governments were using “to ensure our water was clean and safe” as “collaborative.” But Donald Trump’s favorite word, “collusion,” would be more appropriate. Local units of government, with encouragement from the Chamber, and perhaps pressure applied by the federal government, have put the promise of “jobs” before the health of the citizenry.
On June 22, 2018, Michael Schmoller of the Wisconsin DNR wrote to Captain Matthew Shaw of the Wisconsin ANG, in regards to PFAS detected on the base, saying “we believe you are responsible for investigating and restoring the environment at the above-described site under Section 292.11 Wisconsin Statutes, known as the hazardous substances spill law … Your legal responsibilities are defined both in statute and in administrative codes.” A little later: “The longer contamination is left in the environment, the farther it can spread and the more it may cost to clean up … Unless otherwise approved by DNR in writing, you must complete the work by the timeframe specified.”
But, as the State Journal reported, the ANG never responded, and then local levels of government “collaborated” once again, as they have seemingly done since the 1980s, if not well before. By the end of May, 2018, the State Journal noted that “all demands were wiped away by a DNR promise to “work cooperatively with Air National Guard staff to develop an agreeable project timeline.” But “nine months later there is still no timetable for Truax to take the first steps toward a cleanup by mapping each source of contamination and the spread of pollutants through groundwater that is the city’s source of drinking water.”
The April 22 MEJO report listed various studies done in 2005 and 2006 that tracked stormwater runoff from Truax to Starkweather Creek, then south through two low-income communities, and on to Lake Monona. Nearly all of the stormwater runoff from Truax Field goes directly to Starkweather Creek; 38 stormwater outfalls discharge to the creek on the airport and military base alone, said one report.
“From 1988-2012, numerous Installation Restoration Program (IRP) investigations at the Truax Air National Guard base documented extensive soil and groundwater contamination that would have entered Starkweather Creek via stormwater runoff, storm drains/ditches, and leaching of shallow groundwater into the creek,” the MEJO report noted. Among the chemicals were PCE, TCE, PCB, petroleum compounds and metals. “However, the DNR did not ask for Department of Defense investigations to assess these contaminants in creek water or sediments and approved “no further action” for the site.”
Among many other charges in the MEJO report:
* The City of Madison and Dane County are required under a DNR-issued WPDES stormwater permit to “exercise and enforce legal authority” to control the discharge of pollutants to and from their stormwater sewer systems. Neither entity is meeting this requirement.
* City, county and state agencies have authority to gather contaminant data from the creek (or ask permittees to do so) but rarely use these authorities. The resulting lack of contaminant data makes it difficult to prevent toxic pollution from sources, mitigate contamination to the creek, and assess the health of the creek, its fish and/or wildlife.
* The City of Madison and/or Dane County failed to meet (or only sporadically met) several of their DNR stormwater permit requirements from 2014-19, including: public engagement requirements; gathering/reporting Illicit Discharge Detection Elimination (IDDE) data; submitting required reports; and addressing impaired waterway report requirements.
* A March 2018 Truax ANG report on PFAS found that PFAS levels (PFOA and PFOS combined) in surface water samples were 569 times the EPA health advisory level. Soil PFAS levels were also extremely high in some locations near storm drains. DNR did not ask the ANG to test PFAS levels in Starkweather Creek.
*There is almost no toxic contaminant data relevant to understanding the impacts of stormwater discharge from known polluted sites along the creek and limited data relevant to assessing and addressing several of the contaminants that led to the creek being listed as an impaired waterway.
* The Air Force EA claims that Truax’s WPDES stormwater discharge permit and required Stormwater Pollution Prevention Plan (SWPPP) will prevent increases in surface runoff and “improve the quality of stormwater runoff and thereby improve the quality of receiving waters.” But, as MEJO noted, the Dane County Airport and Truax joint permit does not even mention PFAS or most of the toxic contaminants known to be in soil and groundwater at the airport and base.
“There is little or no evidence that the permit and SWPPP are preventing toxic chemicals from discharging from stormwater into the creek,” MEJO charged. “In fact, there is abundant recent evidence that the section of the creek just downstream from the airport and Truax base is very toxic.” The most recent airport SWPPP report is out of date, it added, and does not include all recent findings of contamination on the airport and Truax land, itself a permit violation.
Given all this, along with other information provided in the MEJO report and newspaper accounts this year, we feel this is not a good time for the Air Force and ANG to be preparing major expansions or bringing F-35 jets into a highly toxic and dysfunctional situation. It is time for the ANG to become good neighbors and truly cooperate with local government agencies to remediate all the environmental harm it has caused to our community.
We ask that you reject this Environmental Assessment and reject this project.