The Maryland Air National Guard wants its fighter jets to be able to fly 100 feet above ground level in portions of a large area in North-Central Pennsylvania.
Elected officials, stakeholders from the region and the state Department of Conservation and Natural Resources have concerns, including why the out-of-state military force will not hold a public meeting with residents.
They are urging the Maryland National Guard to conduct a more detailed study into the impact the flights would have on the region, which has become an outdoor recreation destination. The stakeholders are worried about noise pollution from the low level flights, including whether or not the sound is safe for both humans and wildlife.
"Once this airspace is established it really will forever exist and it will be controlled by the Maryland Air National Guard," said Nicole Faraguna, director of policy and planner for the Pennsylvania Department of Conservation and Natural Resources.
She spoke during a webinar on the proposal, hosted by the PA Wilds Center on April 24.
The airspace is named the Duke Military Operations Area, or Duke MOA. It covers 21,078 square nautical miles in parts of McKean, Potter, Tioga, Clinton, Cameron and Elk Counties and extends into a small portion of New York. The Maryland National Guard’s 175 Winged Guard (175th WG) primarily uses the area to run practice flights with A-10 fighter jets but other Air National Guards, including Pennsylvania’s, can also train in the airspace.
The 175th WG is proposing lowering 17,027 square-nautical miles of that airspace, calling it the Duke Low MOA. If approved, pilots, in some areas, would practice diving to 100 feet above ground level and climbing to accurately train to prepare for current and future conflicts, said Susan Beck, a retired Air Force colonel from New Mexico. She volunteered to help stakeholders understand the proposal during the webinar.
In the proposal, the Maryland Air National Guard said they need to train in a close air support environment where they're supporting troops on the ground and deploying weapons.
"So it's a very steep dive to deploy the weapons and then a climb back to altitude," said Beck.
The public has until Wednesday, May 17, to comment on the draft Environmental Assessment (EA), which is a process required under the National Environmental Policy Act. The Maryland National Guard extended the period that the public could comment and also released a second EA after receiving sustainable comment on the first proposal. The documents are available online.
“Military organizations do not normally release a final draft or additional public comment," said Beck. "So you're receiving something that's not normally done.”
Stakeholders in the PA Wilds have been working for two decades to revitalize the area, making it an outdoor destination, said Ta Enos, CEO of the Pennsylvania Wilds Center for Entrepreneurship.
“This is not about being anti-military or anything like that," she said. "We have put a lot of investment into this strategy and I feel it could be threatened by this."
The PA Wilds Center helped coordinate a letter urging the Maryland Air National Guard to hold public meetings, Enos said.
"Those public meetings have not happened," she said.
According to a statement sent to WVIA News from the Maryland National Guard: “public input was received, reviewed and considered during multiple opportunities for review and comment. Public meetings are not planned for the purposes of this EA, are not required by regulation, and are not typically conducted for EAs.”
Elected officials, including state Sen. Cris Dush, have reached out to the Maryland Air National Guard about the proposal.
Dush, whose district covers the area, is a veteran of the U.S. Air Force and the PA Air National Guard. He is calling on the commander of the 175th Wing to conduct a full Environmental Impact Study, which is a more detailed assessment into the impact the flights could have on the region.
“Although I am the first to support our military, this is a situation where I do not believe the 175th Wing has done its due diligence in looking at the impact of the proposal and possible alternatives for flying the low-level training that is proposed," he said in a press statement.
In December 2021, U.S. Representatives Dan Meuser, Glenn “GT” Thompson and Fred Keller sent a letter to the Maryland National Guard.
"The region has become an outdoor recreation and tourism destination, resulting in a nearly $2 billion economic impact for the region," the letter states. “The nature of the Maryland Air National Guard’s proposal could jeopardize this economic and environmental progress as well as the livelihoods of residents who rely on related industries.”
Meuser has again reached out to the Maryland National Guard about the proposal.
An Environmental Impact Study (EIS), which many of the stakeholders are calling for, is the most intensive level of analysis, said Beck.
"It fully discloses the environmental impacts and reasonable alternatives," she said.
Agencies must hold public meetings after the draft EIS is released.
“The reason to do an Environmental Impact Statement instead of an EA would be there's a potential for significant degradation of the environment, a potential for significant threat or hazard, or substantial environmental controversy," Beck said.
According to the plan, the 175th WG is expected to use the airspace twice a day, one hour at a time, around 179 days per year. No more than six A-10s — nicknamed Warthogs — would fly at a time. Weekend operations would be limited mostly to Saturdays. And nighttime operations, which are defined as sunset until 10 p.m., at low altitude would be limited to above 1,000 feet above ground level.
The Duke MOA is currently active from 10 a.m. to 3 p.m.
“We do have some concerns though about that nighttime activity because it could impact Pennsylvanian's premiere and internationally renowned dark sky preserve Cherry Springs," said Faraguna.
The PA Wilds has the greatest concentration of public lands in the state, said Enos.
In the EA, the Maryland Air National Guard says lowering the altitude that jets can fly will have no significant effects on airspace management, noise, land use, biological resources, cultural resources, safety, socioeconomics, and environmental justice.
Representatives from the area disagree.
"The bottom line is we just need more analysis," said Deborah Pontzer, president of Grow Rural PA. "We would also like to have public meetings ... because it shouldn't be incumbent on the people who live here to try and disseminate information."
Within the footprint of the proposed Duke Low MOA there are 10 state parks with five additional state parks just beyond the boundary; over 395,000 acres of state forests, around 36,000 acres of state game lands, the Hammersley Wild Area, which is one of the most remote natural areas in PA; an ever growing population of elk, the historical Austin Dam and the Pine Creek Gorge, said Faraguna.
The Maryland National Guard has included avoidance areas for low level flights in its Environmental Assessment, including over state parks and Hammersley Wild Area.
Farguna said her department recognizes the need for the Maryland Air National Guard to effectively train their pilots.
"We do have concerns that these proposed low level training activities are not compatible with the nature of this wilderness area, and really could adversely impact the natural resources and the wildlife that we protect," she said.
Faraguna said the 175th WG needs to do a better job at finding potential alternatives.
The 175th WG was training for low-level flights in a restricted area controlled by the U.S. Navy, according to project documents. That area is no longer available and they had to find an airspace within 200 nautical miles of Martin State Airport in Maryland, where they are based. Nine alternatives were considered but they did not meet requirements.
Pontzer and other community members who participated in the webinar also worry about the strain the low level flights could put on local emergency services, many who are volunteers, if there is an accident. They are also concerned over the lack of cell service in the region.
“There are some very, very big concerns about safety, not just for the pilots, but also for the people who live here," she said.
Ultimately, Beck said the stakeholders from the region must do all they can to educate the Air National Guard about the PA Wilds.
"You are the experts. What else do they need to know about this region of Pennsylvania to make an educated decision," she said.
For more details on the proposal or to leave a comment, visit 175wg.ang.af.mil/Duke-MOA-Low/
