The Maryland National Guard 175th Wing has issued a draft finding of no significant impact for public comment on a proposal to fly combat training missions with A-10 Warthog aircraft within 100 to 7,999 feet above the ground in six Pennsylvania counties and two New York counties in what is called the Duke Military Operating Area (MOA) training area.

The counties affected in Pennsylvania are Cameron, Clinton, Elk, McKean, Potter & Tioga-- the heart of the Pennsylvania Wilds region.

According to the draft FONSI, the proposed action would involve flights of six A-10 aircraft or less on combat training missions approximately 170 days per year.

The training flights over the affected areas would generally occur twice a day for one hour at a time between 10:00 a.m. and Noon and 2:00 and 4:00 p.m.

Weekend operations would be limited to mostly Saturdays.  Nighttime operations could occur from sunset until 10:00 p.m. and would be limited to flights above 1,000 feet.

A 1,000 foot floor would be established over the Hammersley Wild Area in Potter and Clinton counties, the Forrest H. Dutlinger Natural Area in Clinton County and Kettle Creek State Park.

A 500 foot floor would be implemented over "sensitive areas of concern,” such as State Parks, Sinnemahoning Creek and the historical Austin Dam ruins and over windmills and oil drilling rigs.

Potential Impacts

The draft FONSI says, "The Proposed Action would have less than significant adverse effects on airspace management, noise, land use, biological resources, cultural resources, safety, and socioeconomics."

At the same time, it concludes the action "would have the potential for long-term minor adverse effects on the noise environment."

"The Proposed Action would not increase noise levels by more than 1.5 A-weighted decibels (dBA) day-night Sound Average Level (DNL) in a noise sensitive area that is exposed to noise above 65 dBA DNL, or generate individual acoustic events loud enough to damage hearing or structures.

"The Proposed Action would increase overall sound levels (Ldnmr) between 0.1 and 1.3 dBA in areas beneath the proposed Duke Low MOA, this includes wilderness areas, state parks, and state forests."

Public Comments

Public comments on the draft FONSI are due December 15.

For background documents and other information, visit the Maryland National Guard 175th Wing Duke MOA Low webpage.

DCNR Concerns

In October of 2019, the Department of Conservation and Natural Resources wrote to the Maryland National Guard expressing its concerns about the proposed Duke MOA Low training area saying--

"DCNR has concerns regarding the proposal and its impact on wildlife, residents and visitors and the communities that rely on the outdoors for steady tourism revenue.

"The proposed activity would drastically change the character of this region and the numerous state parks and forests that shape its unique conservation landscape and wilderness."

"Twelve state parks would be impacted by this proposed activities, including Bucktail, Cherry Springs, Denton Hill, Elk, Kettle Creek, Lyman Run, Ole Bull, Patterson, Prouty Place, Sinnemahoning and Sizerville."

"[The proposed Low MOA training area] ... is the Commonwealth's greatest concentration of public lands, the state's largest acreage of wilderness and is home to two National Wild & Scenic Rivers, the largest elk herd in the northeast, and Cherry Springs State Park, a Gold Level Dark Sky Park designated by the International Dark Sky Association."

"If the proposed Low MOA is approved there will be an impact on outdoor recreation, especially for those that are seeking a wilderness experience.  This impact may constitute a conversion [of use for properties conserved in the area under the Federal Land and Water Conservation Fund] which will require the acquisition of replacement land."

"For the reasons indicated above, the agency believes that these low-level airspace activities are not conducive to the nature of this wilderness area and could adversely impact the natural resources and wildlife we protect; impede Pennsylvanian's constitutional right to recreate in our parks and forests; and harm the people and businesses that rely on these lands for their livelihood."

Among other recommendation, DCNR suggested--

-- Eliminating any low-level flight activity directly above state parks and key recreational, historical and tourist destinations;

-- Prohibiting the activity during April, May September and October to avoid impacts to raptor migration and the elk rut;

-- Prohibiting the activity on weekends and federal holidays;

-- Prohibiting the activity to avoid interference with key recreational activities, including: Spring Turkey Hunting Saturdays in May; Hunting Seasons for Bear and Deer; Elk Tourism; Calving Seasons for deer and elk and primitive hunting seasons.

The proposal issued by the Maryland National Guard did not change significantly from the one discussed in DCNR’s October 2019 letter.

Related Article:

-- DCNR Concerned About Proposed Maryland National Guard Plan To Fly Very Low-Level Training Flights Over Cameron, Clinton, Elk, McKean, Potter, Tioga Counties In PA Wilds

-- Environmental Assessment On The Proposed Maryland National Guard Very Low-Level Training Flights Over PA Wilds To Be Ready In January

-- The Future Of Pennsylvania’s Parks and Forests Is in Our Hands; New Online StoryMap Describes Critical State Park, Forest Funding Needs

[Posted: November 1, 2021]

11/8/2021