Proposal for Expansion of Airspace for Air National Guard in Northern Michigan

by Joe Hemming, Anglers of the Au Sable

As anglers and hunters deal with the idea of the National Guard’s proposal to more than double the size of Camp Grayling, already the most extensive National Guard base in the country, there is another proposed expansion in play: the airspace above us in Northern Michigan. The Michigan Air National Guard is asking to increase its airspace, which is already the largest east of the Mississippi River.

The increased airspace being asked for? An additional 4,174 square miles below 17,999 feet MSL (mean sea level). This airspace would cover the eastern half of the Northern Lower Peninsula from roughly the Thumb north to around Rogers City and from Grayling east over the waters of Lake Huron.

Whereas any approval for the proposed land expansion rests for the moment with the Department of Natural Resources acting director, any decision to approve the proposed airspace expansion will be with the Federal Aviation Administration, which operates under the authority of the U.S. Department of Transportation, headed by Transportation Secretary Pete Buttigieg.

The Michigan Air National Guard has studied the proposed air expansion since 2019. The current Environmental Assessment was offered to the public for a 30-day comment period on November 15 of last year, coincidentally the same day as the start of firearm deer season in Michigan. The Air National Guard did agree to an additional 30 days for public comment through the Christmas holiday season but refused any further time beyond January 14 of this year.

Public comment for the proposed airspace expansion was based on the issuance of a 110-page draft EA regarding this proposal, which finds that more missions with louder aircraft would have no environmental impact. Yet, as indicated in the EA, the proposed airspace would see in some parts of the airspace (think Grayling and the Au Sable River) a tenfold increase in flights and a flight ceiling to as low as 300-500 feet from the current 5,000 feet.

The EA is terribly flawed for several reasons.

Noise Levels

One of the planes that will be used in this airspace is the EA-

18G Growler. It’s exceedingly loud. So loud that the harmful impact of noise from this aircraft is the subject of a lawsuit in the state of Washington (State of Washington v U.S. Navy et al, 19-cv-01059RAJ).

The FAA expressly instructs the military to utilize the NOISEMAP system to evaluate noise impact. Yet, there is no mention whatsoever of this system, its use, or its findings in the EA. What the EA does is utilize an “average” to achieve what appears to be a slight increase in average noise.

Here’s a better way to look at it. Let’s talk about a jackhammer that operates outside your bedroom window for an hour daily. Averaging that one hour of hell over 24 hours does not begin to accurately describe the effect of that one hour of jackhammering to which you are being subjected on a daily basis.

Similarly, increasing the number of flights tenfold in the Grayling area, as the EA indicates will happen, or allowing aircraft to fly as low as 300-500 feet, again as shown in the EA, WILL dramatically increase noise levels. But, the EA indicates only a negligible increase in noise.

Electromagnetic Warfare Training

The EA indicates that tasking events for this airspace for the A-10 and F-16 aircraft that fly in this airspace include “military activities that use electromagnetic energy to control the electromagnetic spectrum (‘the spectrum’) and attack an enemy.” Electromagnetic warfare training and its effects on the environment is an entire discussion by itself. Amazingly, there is no discussion of the possible side effects of such warfare on humans or any other life form in the EA or in the Findings of No Significant Impact, which accompanied the EA.

Flawed Modeling

The EA claims the affected area consists of a decreasing and aging population, not taking into consideration the tens of thousands of users, such as fishers, hunters, hikers, bikers, and other assorted groups of outdoor enthusiasts, who recreate in the area together with its seasonal residents. According to the DNR, fishing alone contributes more than $2 billion a year to the state’s economy. The EA didn’t look at the economic effect of this proposed increased use of airspace over the Au Sable River.

Pollution

Chaff, a countermeasure used by aircraft to evade radar detection, will be deployed by the aircraft in this proposed airspace. Anglers of the Au Sable estimates that every year a total of 33,306,000,000 micro-glass/aluminum-coated fibers will be released into the air based on the information provided in the EA. Additionally, based on the EA, this chaff will be released at lower altitudes noted elsewhere in the EA, thus resulting in a higher concentration of these fibers landing on the ground and water. The EA dismisses potential risks from this chaff.

Flares are also deployed from aircraft as a countermeasure to evade various types of missiles. Flares contain compounds that cause skin, eye, and respiratory irritation, as well as have toxic effects. Then there are the variety of combustion products from jet fuel (both burned and unburned), the results of which will be exacerbated by low-altitude training.

Risk of Fire

Flares burn at a high temperature. Despite the DNR previously having voiced concern over the risk of fire, the EA fails to accurately assess its potential risks given the lower attitudes at which the flares will be released.

Cumulative Effects

There is no analysis of the cumulative environmental effects that a combined expansion on land and in the air might cause to the environment. None. Even though the National Guard is trying to more than double the size of Camp Grayling, adding 250 square miles to the already 230 square miles it currently has. Also, it wants to add 2165 square miles to the airspace and treats these expansions separately when evaluating their effects on the environment.

I could go on. But you, hopefully, get the idea. The EA is flawed, terribly flawed. An environmental impact statement will be far more comprehensive in determining what effects this proposed airspace expansion will have on the environment. The Au Sable River watershed and the people of Northern Michigan deserve nothing less when looking at all the effects of this proposal.