It comes as no surprise to followers of the F-35 “stealth” siting strategy for Burlington, that significant information about sound and safety impacts from the super jet has only seen the light of day after the “decision” was made to accept its location at the urban airport.

The long and short of it appears to be that the Airforce plans to “mitigate” those impacts with exactly the same measures as it has taken for the F-16’s which are currently based at the airport.

Quoted directly from the Plan (attached at the end of this diary, minus the tables):

F-35A aircraft operations at Burlington AGS will use existing airspace units and ranges in a manner consistent with current F-16 operations.

But the F-35 is no F-16.

The F-35 will be up to four-times louder than the F-16; and, when it comes to Burlington airport in 2020, the plane will still be at a significantly increased risk for crashing, due to its lack of air experience.  The F-16 had over a million flight-hours logged before it was sited in an urban center, which substantially reduced that risk for the Burlington community.

In his press release, siting opponent James Marc Leas suggests a number of mitigations that might address some of the increased impacts from the F-35, but do not appear in the plan:

Will thousands of houses be sound insulated? Will air conditioning systems be installed so windows need not be opened in summer? No such mitigation for thousands of families is mentioned in the plan.

Will children and elderly be warned in advance of flights and told not to go outside during those times? Nothing in the plan.

Will potential buyers be notified that property in the high noise zones is considered by the US Government to be “unsuitable for residential use.” Not in the plan.

Will thousands of homes have to be purchased and more communities destroyed–like the part of South Burlington near the airport?

The last remains an open question.

Changes in operational parameters developed by the AF in advance of basing the aircraft in Burlington will inform the 158 FW/F-35PIO as to potential local operational mitigation measures that may be evaluated. Performance and other characteristics may also change as the aircraft is adapted to flying conditions at Burlington AGS. Additional noise modeling will be conducted by NGB after local operations mature,and the resulting noise contours and related impacts will be compared to those in the FEIS.

Small comfort to the communities that have already been persuaded to acquiesce to the siting with promises of overarching benignity.

It appears that South Burlington may have bought itself a pig in a poke.

F-35A OPERATIONAL BASING MITIGATION AND MANAGEMENT PLAN

On 2 December, 2013, the United States Air Force (Air Force) issued a Record of Decision (ROD) for the F-35A Operational Basing Final Environmental Impact Statement, September 2013 (FEIS) (Federal Register, Vol.78, No.193, EIS No.20130295, pg. 61845, October 4, 2013). The ROD documents the Air Force’s decision to beddown 18 F-35A primary aircraft assigned (PAA) at the Burlington, Vermont Air Guard Station (AGS). The Air Force is mandated by Title 32 of the Code of Federal Regulations Part 989 (32 CFR 989) to prepare a Mitigation Plan (MP) for each ROD that contains mitigation measures. The 2 December 2013 ROD contains mitigation measures and management actions, which are also referenced in the FEIS. Since these mitigation measures and management actions have the effect of reducing potential environmental consequences, it is necessary and appropriate to ensure these actions are implemented as part of the basing of the F-35A at the Burlington AGS. This plan will be referred to herein as the Mitigation and Management Plan (MMP).

The objective of this MMP is to ensure that actions to avoid or mitigate potentially significant environmental impacts are implemented during construction and operation of the project. In accordance with the requirements of 32 CFR 989.22(d), this MMP was prepared to ensure that mitigation measures and management actions identified in the FEIS and the ROD for this action are implemented in an effective and timely manner and that identified impacts are avoided or mitigated. This MMP identifies organizations responsible for funding and implementing the mitigation measure/management action, and a completion date is identified for each.

The ROD acknowledges that, given the relative immaturity of the F-35 program, identification of new data and information relative to the F-35A may arise and it is possible that the impacts identified in the FEIS (Table 2-12) and the effectiveness of prescribed management and mitigation measures may be different from those expected. Consequently, new information may become available, or the effectiveness of mitigation measures may be different than expected. To accommodate for this, the ROD requires that this MMP incorporate an adaptive management program in accordance with the President’s Council on Environmental Quality (CEQ) mitigation and monitoring guidance, and other legal and generally accepted practices. Section IV of this MMP describes the adaptive management program to be implemented for this action.

I. RESPONSIBLE PARTIES

The Air Force, as the lead agency, has overall responsibility for ensuring that commitments outlined in the ROD and this MMP are carried out. In practice, the majority of management actions and mitigation measures will be developed and implemented at the base level, with support as required by the Air Force and the National Guard Bureau (NGB). The 158th Fighter Wing (158 FW) of the Vermont Air National Guard (VTANG) operates at the Burlington AGS, and the 134th Fighter Squadron (134 FS) is the only operational flying squadron on base. The 158 FW incorporates a mature and highly successful active duty association as part of the Air Force’s Total Force Enterprise (TFE).

F-35A Operational Basing Environmental Impact Statement Burlington AGS Mitigation Plan 18 April 2014 Page 1Responsible parties for each mitigation measure and management action are identified in Table 1 of this document. The 158 FW F-35 Program Integration Office (F-35PIO), Operations Group (OG), Civil Engineering Squadron (CES) and Environmental Management (EM) office are the key organizations responsible for implementation of specific actions. The 158 FW leadership will direct, assign accountability for and track the results of mitigation measures and management actions through the base Environment, Safety and Occupational Health Council-Installation Safety Council (ESOHC-ISC) and by incorporation of these activities into the Environmental Management System (EMS) maintained at the base.

II. MITIGATION REQUIREMENTS

The Air Force will beddown one PAA squadron of 18 F-35As under the 2 December 2013 ROD at Burlington AGS. The AGS is collocated with the Burlington International Airport (BIAP), a civilian airport that operates primarily under Federal Aviation Administration (FAA) rules and regulations. The most significant environmental impacts associated with basing F-35A aircraft at Burlington AGS are anticipated to be related to noise generated during operation of the aircraft. Current mitigation measures and management actions in place for F-16 operations will continue as F-35A operations begin, and additional mitigation measures will be assessed and implemented before and after arrival of the new aircraft. This will necessarily be an evolving process, as the local operating procedures for the F-35A and noise abatement procedures that may be implemented will not be fully developed until the aircraft begins to be flown at the Burlington AGS, which is anticipated to be in the year 2020. Table 1 of this MMP lists the specific mitigation measures and management actions related to noise abatement that are currently employed, and outlines procedures and time frames for evaluation of additional mitigation measures that will be assessed upon arrival of the aircraft at the Burlington AGS. Additional operational changes that may mitigate noise impacts will be evaluated for effectiveness and reviewed to assure they do not result in negative training or safety implications. Management actions for potential environmental impacts not related to noise are also listed in Table 1.

Construction associated with beddown of a total of 18 F-35A aircraft primarily consists of renovations and upgrades to existing facilities and installation of new utilities on previously developed land at the Burlington AGS. Construction is needed to upgrade existing utility infrastructure, aircraft hangars, maintenance shops, simulator facilities and associated work areas. Construction will occur primarily within the highly developed and previously disturbed flight line area and adjacent buildings. F-35A aircraft operations at Burlington AGS will use existing airspace units and ranges in a manner consistent with current F-16 operations.

Pages 5 through 7 of the ROD list management actions to avoid or reduce potential environmental impacts, and each is addressed in Table 1 of this MMP.

III. METHOD FOR ACCOMPLISHING MANAGEMENT ACTIONS

Noise related mitigation measures fall into two general categories at Burlington AGS: 1) operational measures directly implemented and maintained by the 158 FW (also referred to as “local noise abatement procedures”) and 2) noise mitigation measures that are developed and implemented under the Burlington IAP’s Noise Compatibility Program (NCP) required by 14 CFR Part 150, and administered by the Federal Aviation Administration (FAA).

Local noise abatement procedures are codified in Fighter Wing Instructions (FWIs) and other base level standard operating procedure documents such as the local In-Flight Guide. 158 FW aircraft operations are closely tracked, counted and analyzed and are continually assessed for compliance with established procedures. Local noise abatement procedures can be modified and adapted to some extent as new information is received, including input from the local community. Changes to preferred runway operations, modified ground track departure procedures, and adjusting of pattern operations and altitudes are examples of operational elements that can be reviewed and potentially modified by 158 OG personnel to mitigate noise impacts on surrounding communities. Flight, ground and weapons safety are always considered when assessing potential changes to mitigate noise, and safety cannot be compromised to mitigate noise.

The 158 FW participates in the Burlington IAP’s noise mapping, NCP updates and 14 CFR Part 150 compliance process. In some cases, as referenced in the ROD, voluntary mitigation measures undertaken by military organizations at Burlington AGS are referenced within the NCP update and FAA’s resulting Part 150 Record of Approval memorandum. The 158 FW will continue to participate in the Burlington IAP Part 150 process to the maximum extent required to effectively coordinate, implement and continually assess noise mitigation measures and management actions. It is noted that the 158 FW, NGB and Air Force cannot control the timing or final content of the NCP and Part 150 process, as FAA has jurisdiction over the process.

Non-noise related impacts are also addressed in Table 1, and can be effectively managed using existing 158 FW environmental management, safety and occupational health procedures, and continued compliance with applicable federal and State of Vermont regulations, Air Force Instructions, and Executive Orders.

An adaptive management program as described in the CEQ Memorandum titled, “Appropriate Use of Mitigation and Monitoring and Clarifying the Appropriate Use of Mitigated Findings of No Significant Impact” dated 14 January 2011, will be incorporated into this MMP, and is described in the next section.

IV. ADAPTIVE MANAGEMENT PROGRAM (AMP)

The ROD acknowledges that, given the relative immaturity of the F-35 program, identification of new data and information relative to the F-35A may arise and it is possible that the impacts identified in the FEIS (Table 2-12) and the effectiveness of prescribed management and mitigation measures may be different from those expected. Consequently, new information may become available, or the effectiveness of mitigation measures may be different than expected. Adaptive management techniquewill be utilized to identify additional management action refinement, and will be compared to information provided in the FEIS.

The 14 January 2011 CEQ memorandum referenced above provides guidance to assist agencies in assuring that mitigation commitments are being performed as described in the FEIS and ROD, and advises that an adaptive management program can provide a mechanism to adjust and refine mitigation measures if needed to achieve projected environmental outcomes. The CEQ memo states on page 11, “For mitigation commitments that warrant rigorous oversight, an Environmental Management System (EMS), or other data management system could serve as a useful way to integrate monitoring efforts effectively. Other possible monitoring methods include agency-specific environmental monitoring, compliance assessment, and auditing systems.”

The 158 FW maintains an active EMS that follows the International Organization for Standardization (ISO) 14001 EMS model to monitor and continually improve the Wing’s environmental performance. ISO 14001 is an industry standard management program that provides practical tools for organizations looking to identify and control their environmental impact and constantly improve their environmental performance. The 158 FW EMS targets specific significant environmental aspects of its operations, and annually runs through a cycle of an internal audit by the 158 FW EMS Cross Functional Team (CFT) and a subsequent Management Review by the 158 FW Environment, Safety and Occupational Health Council-Installation Safety Council (ESOHC-ISC). The base ESOHC-ISC consists of all base commanders and other key decision makers and supervisors, and action items that result from annual audits and management reviews are assigned to a responsible party and results tracked at semi-annual meetings. Incorporating this F-35 MMP into the 158 FW EMS will assure that the mitigation measures and management actions listed in Table 1 are implemented, tracked, assessed, and modified or expanded as necessary to meet the intent of minimizing the environmental impacts of the basing action.

As stated above, the 158 FW will continue to participate in the Burlington IAP’s noise mapping, NCP updates and 14 CFR Part 150 compliance process. This process is typically repeated on a 5 to 10 year cycle, and is itself an adaptive process. Noise modeling and mapping done during the Part 150 process will provide the data on which future noise mitigation and management actions will be proposed by Burlington IAP and ultimately approved by FAA as part of an updated NCP. There are well-defined public involvement requirements during the development and implementation of the NCP, and the 158 FW will participate in this public process to the extent requested by the Burlington IAP Manager.

The F-35A aircraft is currently flying under a restricted flight envelope at an early stage of overall life- cycle development. As the Air Force gains more experience flying the F-35A prior to basing the aircraft at Burlington AGS, operational parameters such as airspeed and power setting requirements will be refined. Changes in these parameters will be compared to those used in the FEIS, and the AF and NGB will evaluate how these changes would affect the noise contours calculated for Burlington AGS. Changes in operational parameters developed by the AF in advance of basing the aircraft in Burlington will inform the 158 FW/F-35PIO as to potential local operational mitigation measures that may be evaluated. Performance and other characteristics may also change as the aircraft is adapted to flying conditions at Burlington AGS. Additional noise modeling will be conducted by NGB after local operations mature, and the resulting noise contours and related impacts will be compared to those in the FEIS. Refer to Table 1, item numbers 5 and 6 for more specific mitigation and management actions.

Any changes in the construction schedule would have an effect on completion of the actions for those specific projects (Table 1).